On Monday, March 11th, the Industrial Minerals Association – North America (IMA-NA) submitted comments to the Environmental Protection Agency (EPA) on the proposed National Compliance Initiatives for FY20-23 (NCI).
In August 2018, the EPA signaled a shift in the agency’s approach to protecting our nation’s air, land and water by changing the “National Enforcement Initiatives” to the “National Compliance Initiatives.” The change to compliance from enforcement is meant to improve environmental outcomes by utilizing all the various tools and resources available to attain compliance, rather than relying on punitive enforcement measures to act as deterrents to non-compliance. This shift will make several important changes to how environmental regulations are enacted, in the Agency’s own words:
“In the transition from NEIs to NCIs, EPA has made these important adjustments: (1) modifying our selection criteria for the FY2020–2023 NCI cycle to better align with Agency Strategic Plan measures and priorities; (2) engaging more fully with states and tribes in the selection and development of the initiatives; (3) enhancing EPA’s use of the full range of compliance assurance tools in an NCI; and (4) extending the priorities cycle from three to four years (FY2020–2023) to better to align with the Agency’s National Program Guide cycle,” IMA-NA said.
In addition to expressing support for the shift in focus from enforcement to compliance as a way for all stakeholders to work collaboratively towards better outcomes, IMA-NA focused its comments on the request for feedback on Transitioning “Keeping Industrial Pollutants Out of the Nation’s Waters” NCI to “National Pollutant Discharge Elimination System (NPDES) Significant Non-Compliance (SNC) Reduction.”
The Association said it supports the initiative to reduce non-compliance with the National Pollutant Discharge Elimination System (NPDES) permits. It is the Association’s belief that using NPDES permits as the base rather than the term “Industrial Pollutants” allows the EPA to address discharges from all activities that could impact our nation’s waters.
Reducing rates of non-compliance will greatly improve environmental stewardship across the board. IMA-NA looks forward to collaborating with EPA towards our shared goal of decreasing negative environmental outcomes across all industries.