ANR Member action needed NOW!
Dear VSEA Member,
This is an urgent message for all ANR VSEA members. To take action, please scroll down towards the bottom of the email for the ACTION ALERT! It’s critical that you take action.
If you have been reading our legislative updates over the previous months, you know that we have been watching “Challenges for Change” (C4C) closely to ensure that your interests are protected. It has been a difficult initiative to monitor as it has had no concrete information on how the state intends to create “efficiencies” until just last week when the administration reported to the House.
We are gravely concerned with the proposal to deregulate Act 250 permitting and other permitting processes! This will result in job cuts and will negatively impact your working conditions.
Below are the reasons why it is problematic:
· Eliminates staff education on regulatory requirements, which occurs as part of the permit application review process with applicants. As a result, the number o f violations of environmental standards will significantly increase and ANR will be playing catch-up and environmental cleanup. The environment and public health will suffer;
· General permitting and self certification substantially restricts or eliminates public participation on development permits. Under the present individual permit system, each individual development can be evaluated by affected public including municipalities and neighbors;
· ANR’s track record speaks for itself; if it is not issuing individual permits, but relying on general permits and self certification, it will not maintain the necessary staffing to perform inspections of regulated activities necessary to ensure compliance with environmental standards.
· Violations will generally not be addressed due to the sheer increase in number together with the decrease in ANR staffing to conduct field inspections and referrals for enforcement.
· Developers will end up the losers as well, having in some cases invested in the construction of developments which fail to meet regulatory standards. Once built, the question will then be, does ANR require the developer to tear down and tear out the violating infrastructure at great cost to the business or does ANR look the other way and allow the violation to exist in perpetuity?
· Creates huge inefficiencies in terms of utilization of staff resources by focusing not on prevention of violations through upfront education, but enforcement of violations at the backend, consuming huge amounts of resources with little benefit;
· Will result in irreversible environmental impacts which could have been avoided through the upfront permit application discussion. ANR will be unable to fully reverse the environmental damage incurred, but will be seeking to only mitigate impacts to a tolerable level.
· Will create an unleveling of the regulatory playing field, creating a competitive disadvantage for businesses who chose to follow standards and will need to compete with the bad actors who are able to save money by cutting corners knowing that they will get away with it.
· Will not save money nor create efficiencies if ANR intends at the same time to ensure or improved regulatory compliance. Will instead create new and greater inefficiencies.
ACTION ALERT! We need you to contact ALL of the legislators listed below who will vote on this portion of the bill shortly tell them to vote NO on any changes to ACT 250’s permitting process.
****Include some of the above bullet points in your email to help educate the legislators.
House Committee on Fish, Wildlife and Water Resources
Rep. David Deen (D), Chair
Rep. Steve Adams (R), Vice Chair
Rep. Jim McCullough (D)
Rep. Charles Bohi (D)
Rep. Peter Fagan (R)
Rep. Bob Krebs (D)
Rep. Robert Lewis (R)
Rep. Floyd Nease (D)
Rep. Kate Webb (D)
House Committee on Natural Resources and Energy
Rep. Tony Klein (D), Chair
Your VSEA Legislative Team