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LSPA Members Identify Their Priority Issues

On February 1, 2021, the LSPA sent an email blast to all members asking them to rank nine practice issues, involving various regulations, policies, and programs, in order of importance to them.  Our intent was to help focus our resource and advocacy efforts on the issues most important to our members.  

We received responses from about 20% of our members (lower than usual for LSPA surveys) and you told us that your top three issues were:
  1. Finalize outstanding guidance/policies: AULs, Engineered Barriers, Historic Fill, etc. (MassDEP)
  2. Soil Management: Assist with needed capacity, beneficial uses, PFAS disposal (MassDEP and others)
  3. PFAS: Address background conditions and MCP release exemptions (MassDEP)
Each of these three issues were in the top three choices for over 50% of the respondents. 

Here are the percentages of respondents who listed the other issues as a top three choice:
  1. Asbestos in Soil: Streamline and clarify regulations (MassDEP) – 29%
  2. PFAS Private Well Sampling Program: Address MCP responsibility and liability issues (MassDEP) – 26%
  3. LSP Board of Registration: Update regulations, improve operations (EOEEA) – 23%
  4. 21J Fund: Reconcile LSP decision making and allowed reimbursements (MA Department of Revenue) – 18%
  5. Brownfields Tax Credits: Reconcile LSP decision making and allowed reimbursements (MA Department of Revenue) – 17%
  6. Public Involvement: Update guidance documents (MassDEP) – 8%%
Many thanks to the 60+ members who volunteered to be involved in LSPA efforts to advance these issues; in fact, many respondents volunteered to work on several issues. At this time, LSPA leadership is discussing how best to proceed and we expect that in the coming weeks, an LSPA Board member or Committee Chair will reach out to volunteers to invite them to participate in a committee or focus group, or even help form a new subcommittee. So stay tuned!

We look forward to working together to make some progress on these issues. Please don’t hesitate to contact [email protected] with suggestions and questions.
Michele Paul, LSP
LSPA President

 

MassDEP AUL Compliance Assistance Letters to be Mailed Soon

MassDEP has asked the LSPA to share the following information.
In December 2020, MassDEP is planning to mail an Activity and Use Limitation (AUL) compliance assistance letter to individuals listed in MassDEP records as owning a property at which a Notice of Activity and Use Limitation has been implemented.  This compliance assistance letter has been sent periodically (previously in 2010 and 2015) to provide property owners with a description of the nature and purpose of an AUL and remind them of their obligation to adhere to the terms of the AUL. 
 
The letter is strictly informational and generic (i.e., it does not reference site-specific AUL conditions) and does not require any response from the property owner to MassDEP.  MassDEP email and telephone contact information will be provided in the letter should the recipient have any additional questions or concerns.  A link to the generic letter is available here.   
 
Note, to avoid confusion, this generic compliance assistance letter will not be sent to those property owners with AULs related to Active Exposure Pathway Mitigation Measures (AEPMMS) that support a Permanent Solution pursuant to 310 CMR 40.1025(7).   Property owners in such cases are required to respond to an annual letter sent by MassDEP to certify the ongoing operation and maintenance of AEPMMs.  MassDEP will be sending the AEPMM annual certification letters in a subsequent mailing.