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Questions to Ponder for Permits/TC/NRS

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…

  1. In your experience, are Tier 1 sites treated the same or differently as Tier 2 sites? (By MassDEP? LSPs, PRPs, the Public?)
  2.  Should MassDEP maintain Tier 1 Classifications (Tier 1A, Tier 1B,and Tier 1C)? Why or why not?
  3. 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…?
  4. Should MassDEP maintain a Tier I Permit?
  5. What aspects/requirements/safeguards from Permits are useful and should be maintained (if any) in some form?
  6. 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)?
  7. What information would be beneficial to include/exclude from the existing transmittal forms (including NRS scoresheet)?
  8. 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?
  9. 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?
  10. 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?
  11. 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
  12. And what about Special Projects?
Questions for us? Please comment here on the MCP Reg Reform Blog!



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