Guidance on Technical Clean Up of Existing Threshold Standards
Project summary: The TRPA 2017 Assessment of 173 existing threshold standards identified 46 standards as overlapping with other standards in the threshold system (TRPA, 2017). In addition to the 46 previously identified overlapping standards, further sources of overlap may exist that were not specifically noted by the Assessment as redundant. Redundancy in threshold standards has the potential to increase the cost of enforcement and monitoring, to confuse the process of implementing standards, and to add uncertainty around the intent of threshold standards and how they contribute to meeting the overall goals of the regulations. Through examination of the existing threshold standards, the Tahoe Science Advisory Council (TSAC) identified five types of overlap: (1) complete overlap, (2) wholly encompassing standards, (3) competing targets, (4), indirect overlap, and (5) policy and management statements that overlap existing standards. This document provides a description those identified types of overlap, and for each one discusses the sources of each, the relative harm caused by the various types, and potential strategies to avoid or resolve that type of overlap.
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