CWPMA wants to Thank the committee and the consultant community and OPS for the engagement on this important issue.
I think its important to recognize some underlying points.
- The E.R.S has not been adjusted for inflation since the program’s inception.
- Due to the severity of releases decreasing and the time it takes to clean things up many marketers are not receiving any benefit as some releases don’t meet the 10,000 deductible
- OPS has made significant strides in incentive based programs that have a quantifiable environmental benefit but have also led to a continual pressure on the Fund which otherwise would have been abated.
- Reimbursement timelines have been stretched where consultants and operators are having to cash flow money for qualified releases that are eligible for reimbursement.
- While we haven’t seen a noticeable decrease, fuel efficiency and E.V. will have a marginal impact on the E.R.S. being remitted to the state moving forward.
CWPMA takes the solvency of the fund and the benefit for the marketers as our top priority, to that end CWPMA staff will be proposing legislation next year that extends the spending authority and environmental surcharge assessment to 2030. We also are going to propose a 10% E.R.S increase across all the tiers in order to account for inflation. We also recognize that releases continue to be less severe. Further, we believe that supporting the environmental consultant community is important and that REP’s should be accorded the preference that the certification provides. We are concerned though of shifting market dynamics that might tilt the field towards non REP market participants, who may not have the health of the fund in mind.
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