Looking ahead to the meeting Wednesday (February 8, 2012) on eliminating/modifying/improving the MCP Permits, Tier Classification and Numerical Ranking System sections, here are a few leading questions for you to ponder…
- In your experience, are Tier 1 sites treated the same or differently as Tier 2 sites? (By MassDEP? LSPs, PRPs, the Public?)
- Should MassDEP maintain Tier 1 Classifications (Tier 1A, Tier 1B,and Tier 1C)? Why or why not?
- What has been your experience with MCP permit approvals? Are they mostly/all presumptive or do you receive additional permit conditions? Are those additional conditions relevant, useful, and thoughtful, etc…?
- Should MassDEP maintain a Tier I Permit?
- What aspects/requirements/safeguards from Permits are useful and should be maintained (if any) in some form?
- What are your views on streamlining or eliminating the Numerical Ranking System? What aspects of the NRS are useful and should be maintained (if any)?
- What information would be beneficial to include/exclude from the existing transmittal forms (including NRS scoresheet)?
- Does the NRS provide benefits to the public, LSPs or PRPs, such as useful information on the complexity/range of sites? If so, how is that information useful?
- There are different extension periods for Tier I versus Tier II. Should they be consistent? 1 to 2 years? How would a permit-less system work for extensions?
- MassDEP has the statutory authority/obligation/need to implement fees to cover operating costs. How can/should fees should be restructured for sites beyond year 1 if the current permits & tiers are modified/eliminated?
- Please provide any thoughts on specific regulatory changes, modification of transmittal forms and/or updates to data tracking/management to improve efficiency, improve the information submitted to DEP, improve the quality of the work, etc. THINK BIG
- And what about Special Projects?
Filed under: TC/NRS/Permits |