Wait a minute you may say, I do not want to do that I know we are our of compliance with so many areas why would I want to tell anyone about it? I know we can't afford to update our shop/fuel storage/mix load pad etc. so why should I document our lack of compliance and open us up to more risk?
I understand this line of thought however I would argue that you are not opening yourself up to more risk, the risk is there and inherent regardless of your documentation. I can also say that the recognition of the risks by you and the communication to your facility decision makers is an important insurance policy for you personally and for the facility. Ignorance is not a reasonable excuse when it comes to fines or possible environmental accidents. However a clear documentation and assessment of your risks is a powerful tool when it comes to inspections and possible fines. I can tell you without any hesitation that the MDARD and DEQ look very favorably upon facilities that have made a clear and honest assessment of their environmental risk regardless of the facilities ability to properly mitigate that risk. The specific facility information in the MTESP is not available to anyone but myself, Dr. Kevin Frank and the Stewardship Specialists John Johnson and Kathy Antaya. The state departments are not interested in facility specific information, just the total number of facilities and if the facility is utilizing the program or not. So please go to the website and get your facility registered this winter. Thank you for your support of this very important program.