| Under the "Challenges for Change" agenda, compliance would pretty much become a voluntary decision on the part of the applicant and inevitable permit holder. To my knowledge no spreadsheet analysis has so far even been offered to support Douglas' claim of savings. Whatever might be saved through these so-called "efficiencies" in the permit system would quickly be dwarfed by losses the state would experience through water quality and environmental impacts, declining property values and unanticipated brown-field situations.
The ANR's practice of issuing "general permits" has already tested applicants' reliability when it comes to self-certification. A 2008 Messenger article by Michele Monroe reports on a study conducted by the Conservation Law Foundation. In its analysis, among other evidence of ANR's failure to do the most fundamental job of water protection, the CFA found that:
the state issued 319 Notices of Alleged Violation (NOAVs) from 1997-2006 for discharging pollutants into waters of the state or failing to obtain a permit for discharges. Of those only 32 resulted in formal enforcement action... Ninety-nine of those NOAVs were for National Pollution Discharge Elimination System (NPDES) violations. Of those only nine were followed up with formal enforcement action.
The governor's CFC proposal would increase unregulated discharges up to 6,500 gallons.
If that isn't bad enough, the CFC would eliminate Regional Planning Commissions; double the lag time between required reviews of solid waste certifications and hazardous waste facilities from five years to ten; and significantly reduce monitoring requirements on those waste sites following closures.
It looks like the Governor's answer to ANR's failure to effectively do their job is to give them more responsibility and lower the bar so far that almost no level of pollution is prohibited.
If, as the Free Press article would seem to suggest, members of the House are inclined to go along with the Governor's recommendations, they ought to be ashamed of themselves for being so short-sighted; and I invite the Speaker to tell us why we should entrust full responsibility for permitting in Vermont to an Agency which, when repeatedly accused of ineffectiveness, has characterized itself as underfunded and understaffed.
Contact your legislative representatives. Tell them you're paying attention; tell them what you think of the "Challenges for Change" agenda in general; and remind them once again that their first obligation is to protect their constituents' right to full participation in an effective environmental protection and permit review system.
http://www.leg.state.vt.us/lms...
http://www.leg.state.vt.us/lms...
And the sergeant at arms number for phoning messages
into the statehouse: (802) 828-2228 |
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Among the smorgasboard of ritual guttings that are suggested in Douglas' "Challenge For Change" report, is a proposal that could effectively eliminate the permit process altogether. Talk about throwing the baby out with the bathwater!! Barely mentioned in the 
