I wish to support the extension of the SPCC implementation date. We have done
over 50 SPCC plans. To implement by October 2007 will force many companies to
implement temporary measures that do not fit into a long range plan. Eg, one
compamy plans to reduce the amount of storage and build a first class secondary
containment. However, if the 2007 date is adhered to, they will need to improve
their secondary containment with features that will soon be torn down and
disregarded. Some of our clients serve a rural facilities and do so as a service,
with little or no profit. These companies need to close several of their facilities, but
need to construct centralized facilities to maintain the service. This takes time to
plan and implement. Again, I support the extension.
Comment submitted by John Cashatt, Schwab-Eaton, PA
This is comment on Proposed Rule
Oil Pollution Prevention; Non-Transportation Related Onshore Facilities
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