NJDEP’s move to the LSRP program has had a significant effect on the management of environmental cases in the Garden State. Many are obvious and are a direct function of the program in and of itself, such as the LSRP’s direct ownership of case closures, the relative expedience to get cases closed, and the NJDEP’s newly defined roll in case management in the Site Remediation Program. But some other impacts are less obvious, particularly the new administrative burdens that have been placed on projects. These additional tasks can be related to completing the multitude of forms that are required and the revisiting of RAOs that have been submitted. The current rush to submit extension requests for the May 2014 Remedial Investigation Deadline is indicative of the scrambling and overhead that comes with the mandatory timeframes introduced with the SRRA requirements.
While it is appropriate to introduce deadlines and timeframes to ensure that responsible parties are doing their share to address their issues and cases, it is interesting to witness the dynamic that has been introduced when trying to adhere to the mandatory deadlines. First there was the March 2012 deadline for Initial Receptor Evaluations, next came the May 2012 deadline for retaining an LSRP, and then there was the Remediation Priority Scoring exercise. I can’t speak for other firms, but these deadlines became a primary focus for JMS to ensure it was protecting its clients. The looming RIR deadline is the latest deadline that has consultants scrambling to ensure their clients stay compliant. The May 2014 date even inspired the March 2014 deadline to submit an extension request for the RIR deadline. These deadlines shift focus from remediating cases to preparing paperwork and forms to satisfy NJDEP requirements. It is difficult to quantify the value these activities add to the overall remediation of the project, but they are necessary and prudent consultants do the work necessary to navigate the requirements, however burdensome they may be.
As noted above, JMS appreciates the need for these deadlines and understands that they are not always due next week, but it also acknowledges the overhead and administrative costs that result in compliance. At the moment, the RIR deadline and extension seems to be the last in a long line of mandatory deadlines; however, JMS remains diligent in monitoring the NJDEP rule changes and supporting its client base in addressing the ever-changing requirements.
James Vander Vliet, PE, LSRP