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10-Year Compliance Report. Issue identified by all user groups: Treated like new permit application Extensive, duplicative documentation required New rules applied Allocation cut-backs provided a disincentive for conservation. Extensive, duplicative documentation required.
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10-Year Compliance Report Issue identified by all user groups: • Treated like new permit application • Extensive, duplicative documentation required • New rules applied • Allocation cut-backs provided a disincentive for conservation. Extensive, duplicative documentation required. Ensure WMD rules reflect DEP Guidance Memo on Compliance Reports issued March 23, 2012
10-Year Compliance Report Objective of rulemaking: • Ensure WMD rules reflect DEP Guidance Memo on Compliance Reports issued March 23, 2012
10-Year Compliance Rule Development Concepts • Maintain consistency with rules in place when permit initially issued. • *No allocation reductions for decreased use resulting from: • water conservation • Changes in growth/economic conditions, unless no possibility of need for water during permit term • Growing different crop * Applies to all permits, not just those requiring 10 year compliance reports.
10-Year Compliance Report Rule Development Benefits • Greater assurances for permittees during term of permit • Removes disincentive for water conservation • Recognizes fluctuations in economic and market conditions
Issues for Feedback • Handout of rule language. • What factors should be considered to determine when a 10-year compliance report is warranted? • What components should a 10-year compliance report include?