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6.7. SR 12-21-1998
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6.7. SR 12-21-1998
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12/21/1998
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.DEC.11.199@ S:~6PM MPCA WQD MA/WA SECT HO.B88 P.B/5 <br /> <br />P~e: 2 <br />applied in the past decade, these facilities on average have achieved about a 9g% compliance <br />rate. We have told the Stax Tribune that these facilities are constructed and operated to achieve a <br />compliance rate of 95% to account for uncontrollable events such as drastic changes in <br />temperature, water levels in the discharge river, equipment malfunctions and operator errors. <br /> <br />Inspe,etions and Enforcement Aetio.~ <br />The database seems to indicate a decline in the number of inspectior~ conducted at these <br />permitted facilities and the number of enforcement actions taken, Thc reporters also seemed to <br />think that the agency has moved too slowly in taking enforcement actions when they are <br />warranted. It is precisely because some enforcement actions do take so much stafftime that we <br />explore other solutions Sst. We have explained that to ensure that the facilities understand their <br />environmental commitments we have shied resources to training and outreach activities rather <br />than solely relying on enforcement activities to gain compliance, Therefore, many of these staff <br />contacts with facilities are not legally defined as "inspections" and so are not recorded in the <br />database, <br /> <br />As well as emphasizing compliance rather than enforcement, over thc past decade thc agency <br />began shifting resources from ad&casing point source threats to water quality to nonpoint source <br />threats, This focus on pollution from feedlots, stormwater runoff, failing septic systems and <br />others problems is consistent across the country and has been fully supported by the EPA and <br />most environmental groups. We plan to hold to the gains we've achieved in reducing pollution <br />from wastewater treatment facilities but Imow that there is unchartered ground to cover with <br />newly emerging threats to our lakes, rivers and streams. A look at thc total number of <br />enforcement actions taken among all of our water quality programs shows an increase in activity, <br />not & decline (see attached graph). <br /> <br />Lastly, we lmve shared with the Star Tribune that in recent years, the pohlt source program staff <br />has spent considerable time implementing process improvement practices recommended by the <br />1995 Report of the Blue Ribbon Task Force on Funding Minnesota's Water Quality Programs, <br />designing and entering compliance data in the agency's new computer database (DELTA), and <br />participating in redesign of the agency's organization (GOAL 21). These investments of time <br />may have affected productivity in the last few years but will have a positive effect on the <br />program's efficiency and effectiveness in the near future. <br /> <br />Involwment of Environmental_Orouvs in Pemait~ing Activities <br />Perhaps most alarming to us is the Star Tribune's apparent support of one environmental group's <br />insistence that they are doing the MPCA's job in demanding stricter limits or additional controls <br />be placed in water quality permits. <br /> <br />We at the MPCA axe proud of the efforts we mice to ensure that our permits and other activities <br />are conducted with active public part/cipation. Rather than be scorned for their willingness to <br />listen to all affected parties when draftSng pemaits, MPCA staff should be commended for their <br />open-mindedness. When there isn't scientific certainty to guide staffin setting standards or <br />permit limits, and when outside expertise is freely offered, this open approach is guaranteed to <br />provide a better environmental outcome than if staff worked in isolation. <br /> <br /> <br />
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