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?