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Sam Sankar [ssankar@ecos.org] 4/17/2018 1:47:24 AM Wagner, Kenneth [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=048236ab99bc4d5eal6cl39blb67719c-Wagner, Ken]; Darwin, Henry [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=7ae8e9d24eeb4132b25982e358efbd9d-Darwin, Hen] keogh@adeq.state.ar.us [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=8fde384118954a20belf9210c502dl4b-keogh@adeq.]; Jim Macy [jim.macy@nebraska.gov]; John Stine (MPCA) [john.stine@state.mn.us]; Todd Parfitt [todd.parfitt@wyo.gov] ECOS Follow-up from St. Paul Meeting
Henry and Ken,
On behalf of the ECOS leadership, I want say how pleased we were to meet with you in St. Paul and how much we look forward to our continued work together. I'd like to share our understanding of our next steps together:
1. States and EPA will discuss and agree on general principles of EPA deference in the context of delegated program implementation, and will communicate this to EPA and state staff.
2. States and EPA will discuss and agree to appropriate standards of review that EPA should apply in those situations where it does review individual state actions, then implement an appropriate standard in two selected program, areas (NPDES Municipal and NSR. permits).
3. States and EPA will establish an "elevation" approach for addressing oversight disagreements.
4. States and EPA will establish an "elevation" process for addressing program-specific oversight disagreements (NPDES Municipal and NSR permits).
5. EPA will reframe and rename its National Enforcement Initiatives program. The new program will be called National Compliance Initiatives, and EPA will seek out state engagement in developing its next areas of focus.
6. States and EPA will explore alternative models in compliance and enforcement, such as environmental self-audit initiatives for regulated entities, enhanced self-monitoring by regulated entities; and new ways to reliably measure the compliance rate in a particular program or sector.
My staff is working to find 15 minutes on your calendars tomorrow (Tuesday) to discuss this. Following our discussion and shared understanding of the immediate actions, the ECOS Officers are planning on updating the full ECOS membership on current progress and upcoming work. The calling card for our cooperative federalism work is more effective and efficient environmental protection, and we're pleased that our message of working smarter while maintaining environmental results resonated in St. Paul. Now it's time for action, which will require continued serious work on both our parts. We're looking forward to it.
--sam
Sambhav (Sam) Sankar Executive Director Environmental Council of the Slates 202-316-1002
Sierra Club v. EPA 18cv3472 NDCA
Tier 10
ED 002061 00174941-00001
Sierra Club v. EPA 18cv3472 NDCA
Tier 10
ED 002061 00174941-00002