Comments on: The Next Generation of Enforcement and Compliance http://blog.epa.gov/blog/2013/08/nextgen/ The EPA Blog Mon, 14 Dec 2015 16:24:21 +0000 hourly 1 http://wordpress.org/?v=4.2.1 By: Brenda Morris http://blog.epa.gov/blog/2013/08/nextgen/#comment-28184 Wed, 08 Jan 2014 22:03:24 +0000 http://blog.epa.gov/epaconnect/?p=277#comment-28184 Next Gen-Construction stormwater permits and SWPPs-Would it be possible to have the State’s MS4 stormwater permits require every developer that applies for a permit to have a website or a publically available electronic permit and SWPP on their website or available electronically at the local library as part of the application process? What this would do: allows regulators to do electronic inspections of the permit/SWPP;allows the industry to have the SWPP on a phone app that can be used in the field to detail changes to the site based upon construction completions and modifications to the SWPP map-minimizing industry errors in not updating the SWPPs or not having the permit available to ensure they are complying and saving time since changes are made simultaneously as construction needs change;allows the permit to be accessed using mobile technology in the field; allow for oversight of implementation of BMPs (perhaps pictures uploaded to confirm BMPs/changes) etc; allows the public access to the permit/SWPP; achieves transparency; places construction stormwater issues in the hands of the locals where the impact of noncompliance is seen and felt most readily by the locals impacted by the construction stormwater issues; and frees up and prioritizes resources. Additionally, it makes sense for the 21st century.

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By: Tawny Fawn http://blog.epa.gov/blog/2013/08/nextgen/#comment-28183 Thu, 05 Sep 2013 14:45:13 +0000 http://blog.epa.gov/epaconnect/?p=277#comment-28183 teh USA is using water wastefully, Fracking is not the cause. Use rain barrels, low flow toilets, dry your clothes out on the line, put in a desert front yard like they do in Arizona, which are very attractive. Texas as o [arts of California are originally desert and we shouldnt be using the amount of water we consume e.g. household usages. Here is a Forbes report on water in Texas:
http://www.forbes.com/sites/davidblackmon/2013/08/21/shale-fracking-are-not-the-main-cause-of-texas-water-shortages/

Each of us need to conserve on our own usage, personal responsibility.

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By: Keith Belton http://blog.epa.gov/blog/2013/08/nextgen/#comment-28182 Fri, 23 Aug 2013 18:18:11 +0000 http://blog.epa.gov/epaconnect/?p=277#comment-28182 In theory, by using advanced monitoring technologies, the Agency’s regulatory offices will have a greater incentive to favor performance standards (i.e., output-based standards) instead of more prescriptive standards (i.e., input-based standards). Economic theory suggests greater use of performance standards can reduce the cost of regulation. Will be interesting to see whether an increased emphasis on advanced monitoring systems will lead to the elimination of outdated prescriptive regulatory requirements.

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By: Ken Mangelsdorf http://blog.epa.gov/blog/2013/08/nextgen/#comment-28181 Fri, 23 Aug 2013 18:16:40 +0000 http://blog.epa.gov/epaconnect/?p=277#comment-28181 A couple of comments:

1) “rules with compliance built in” In California, many of our air pollution laws, by many of the 34 local air districts, already include compliance in them; and have for several decades! So nothing new here.

2) “advanced monitoring technologies” A couple of things here. one, many of these ‘real time’ monitors are only roughly indicators, neither quantitative nor qualitative. If hand held, very little opportunity to have direct data reporting.

3) “electronic data reporting” All well and good for CEMS and other similar types of equipment. But what about missing all the manual visual inspections, maintenance procedures performed, and many other day to day manual operations, and most importantly… what about reviewing and certifying the data? Agreed it is nice to have data collected, but reporting directly to EPA with no other review or verification, will lead to many, many miscommunications and misunderstandings between the regulated community, the regulating agencies and the public! Electronic data reporting is ‘OK’ but not definitive and certainly will not provide anywhere near a complete enough picture of compliance.

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By: Bob Kelsey http://blog.epa.gov/blog/2013/08/nextgen/#comment-28180 Fri, 23 Aug 2013 14:31:47 +0000 http://blog.epa.gov/epaconnect/?p=277#comment-28180 I work for a lead manufacturing facility that has four (4) environmental permits; POTW pretreatment, TVOP, RCRA Part B for permitted container storage area, and NPDES Storm water permit. All four permits have 5 yr. terms but the rules and agencies need to allow the issuance of 10 yr terms for permittee’s with good or excellent compliance records plus they will save agency and permittee resources and money.

Our facility has had ISO 9001/14001/18001 as well as Lean Mfg./JTE systems in-place for years which show its dedication to doing things right.

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By: Karen Skinner http://blog.epa.gov/blog/2013/08/nextgen/#comment-28179 Thu, 22 Aug 2013 15:30:37 +0000 http://blog.epa.gov/epaconnect/?p=277#comment-28179 Please stop fracking. There are too many spills already. It hurts our land, air and is using up our precious clean drinking water in the process. Texas is in a drought. 50% of their communities water supply has been used up for fracking. More oil but less clean water we need to survive. This cannot go on any longer. Thank you for your time & service. Good luck stopping the polluters.

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