Comment submitted by Brett D. Smith, Engineer / Geologist / Geophysicist, ECA Geophysics, Environmental Compliance Associates, LLC

Dear Mr. Howard, > > I noticed that the SPCC deadline has been moved back 18 months to May > 2013. > > At the risk of sounding like a self-serving consultant, I can honestly > state that this action is EXTREMELY counterproductive! > > Case in point – I’ve given SPCC info talks to farmers and will again > do > so (WA-ID-OR Grain Growers) next month. I was prepared to make the > STRONG point that “hey guys, the deadline has come and gone, so you > better get yourselves into compliance with 40CFR112.” Now my talk > will > carry NO impact, as the need to become compliant just went away (for > the > 8th time)! > > From a business standpoint, this probably helps my company, as I was > (until now) preparing to refer farmers to other PEs, as I’m currently > slammed with Plan writing. > > As a serious environmentalist (I support NRDC, Earthjustice and am a > Sierra Club wilderness guardian), I feel that the EPA has just removed > all urgency for a reluctant demographic (farmers) to do the right > thing. I strongly suspect that HENCEFORTH they’ll simply forget about > spill compliance altogether. > > Please do NOT extend (for the 8th time, no less) the SPCC deadline for > farms. > > Sincerely, > > > > > Brett D. Smith PE, PG > Engineer / Geologist / Geophysicist > ECA Geophysics > Environmental Compliance Associates, LLC