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<br />. <br /> <br />. <br /> <br />. <br /> <br />Enforcement <br /> <br />Joan Mulhern-There is no "worse than before" in the standard. Does that mean it is <br />possible for a Good Sam to walk away from a project and it is actually worse? <br /> <br />Shaun McGrath-There are 2 scenarios: 1) if there are unforeseen circumstances and the <br />Good Sam wants an early termination of the permit, then they have to leave the site in a <br />no worse than before condition; 2) if the Good Sam does every thing called for in the <br />permit and the permit is then terminated, there is no worse than before requirement. <br /> <br />Brent Fewell~the risk of things getting worse is on the permitting authority. Therefore, <br />it's important that everyone agree before a permit is issued that the proposed project has a <br />high likelihood of success. <br /> <br />Joan Mulhern-That needs to be clarified in the bill. If clarified, it would help a lot. Joan <br />will send other language. <br /> <br />Michael Gianotto--raised question about emergency powers. <br /> <br />Brent Fewell-said he thinks emergency powers in strawman would give EPA power to <br />require actions even if the Good Sam was in compliance. He said EP A very rarely uses <br />these emergency powers, but they need to be able to order these actions. EP A would be <br />very reluctant to waive that authority. <br /> <br />Next Steps <br /> <br />Lori Faeth asked everyone to send comments and proposed revIsIons to Shaun <br />(smcgrath@westgov.org) by March 23. Shaun will revise the bill accordingly, i.e., <br />integrate those suggestions that seemed to draw consensus. Suggestions and issues for <br />which there was not consensus will be bracketed. <br /> <br />WGA hopes the new draft will serve as a good starting point for members considering <br />introducing legislation in this Congress. <br /> <br />7 <br />