Dear Ms. Pickett:
The Florida Association of Professional Geologist (FAPG) would like to provide comments regarding implementation of the new Low Scored Site Initiative (LSSI) guidance proposed by the Florida Department of Environmental Protection (FDEP). FAPG has been a consistent proponent of the LSSI Program as a means to reduce petroleum site backlog, and to remove low scored sites from the cleanup program, if they do not pose a threat to human health and the environment. This goal was the industry and legislative purpose of the law. However, we are concerned that as initially proposed by FDEP, the guidance for implementation of the LSSI may significantly reduce participation by site owners and/or Responsible Parties (RP). We feel it is important that FDEP and industry work together to develop LSSI guidance that is an incentive for site owners and/or RPs to take advantage of the program and begin to remove low scored, low impact sites from the cleanup program.
Attached with this e-mail are comments and recommendations that were previously provided to FDEP by Mr. Stephen Hilfiker, containing proposed changes and items for FDEP consideration for implementing the LSSI program. FAPG has thoroughly reviewed the attached comments by Mr. Hilfiker, and we are in agreement with his proposed modifications to the LSSI guidance.
We urge FDEP to consider modifying the current LSSI guidance and incorporate the attached suggested changes. We believe doing this will provide the legislature, citizens of our state, and site owners and RPs a clear message that positive changes continue to be made within the cleanup program – changes that are fiscally beneficial to the state and to the FDEP cleanup program, and that will also continue to protect the water resources of the State of Florida.
Thank you for the opportunity to provide our comments on the draft LSSI Procedural and Technical Guidance. Please do not hesitate to contact us if you have any comments and/or questions regarding our position on this issue.
Sincerely,
Joseph M. Fuhr, P.G.
President
Florida Association of Professional Geologists
