Significant Noncompliance (SNC) and High Priority Violation (HPV) sit on the same Monday spreadsheet. They are not the same conversation. SNC is the Clean Water Act and RCRA word for a serious, unresolved compliance problem in EPA ECHO. HPV is the Clean Air Act word. If you use one opener for both, the air counsel deletes you and the wastewater PM thinks you do not know the statute.
This note is about outreach angles — who you call, what you lead with, and what you do not claim. It is not a legal memo, not EPA guidance, and not a Phase I. The SNC vs HPV tool is the vocabulary page. Record of Sale, LLC operates SNCAlert; questions go to publisher@noticenearby.com.
Same warehouse, two status languages
ECHO’s weekly Exporter publishes program flags next to status flags. Media (CAA / CWA / RCRA) answers which statute’s data showed up. SNC vs HPV answers how the warehouse labels seriousness inside that statute.
| Status | Typical media | Word you may say in the subject |
|---|---|---|
| SNC | CWA, RCRA | Significant Noncompliance |
| HPV | CAA | High Priority Violation |
Do not write “SNC/HPV” as if it were one product. Program-first triage still comes first: if you do not sell air, drop HPV rows. If you do not sell water or waste, drop SNC rows. This article assumes you already kept the statutes you staff.
A flip into the flag is still only a Saturday-to-Saturday diff. The Exporter is not ECHO Notify. Notify is EPA’s own alert product. Your list is a sales signal, not a live inspector feed and not a Phase I.
The SNC angle: water, waste, and “unresolved”
CWA and RCRA SNC reads, to a BD desk, like a problem that has already been classified as significant and is still open in the snapshot. The operator often has a permit writer, a lab, or a hazardous-waste vendor in the story — even if ECHO is late.
Who the first email is for
Lead with the operator on the Detailed Facility Report, not a scraped personal mobile. For CWA, think environmental manager plus whoever owns the discharge or pretreatment relationship. For RCRA, think the person who owns tanks, manifests, and “are we still a generator.” Counsel gets copied when a formal-action or penalty date is new in the same cycle.
What you sell in the first six lines
- Sampling, reporting, and corrective-action plans (water).
- Waste characterization, container/tank programs, closure support (waste).
- A second pair of eyes on whether the source system matches the warehouse. You are not certifying that it does.
What you do not say
Do not say “EPA listed you as a criminal.” SNC is a compliance-status label in ECHO, not a verdict. Do not say “your air permit is in SNC.” That is the wrong word. Open the DFR and name CWA or RCRA once.
When a formal action changes the SNC script
If the zip also shows a new CWA or RCRA formal-action date, lead with the docket week, not the flag. Finance recognizes a date. A quiet SNC that has been on for two years is nurture. A new SNC plus a new action date is Monday.
The HPV angle: air, Title V, and “priority”
CAA HPV reads like the air program put this source in a priority bucket. The buyer is often a different human: EHS plus the person who owns Title V, stack testing, or the last deviation report.
Who the first email is for
Still the DFR operator. The internal forward is more often air staff or outside air counsel than the wastewater lab. If you only have a general “environment” inbox, say you are writing about the Clean Air Act HPV flag, not “your SNC.”
What you sell in the first six lines
- Stack testing, NESHAP/NSPS, Title V deviations, and negotiation support.
- A check that the HPV flag on the DFR still matches this week’s Exporter story.
- Monitoring or reporting help after a clear — a different script than entry.
What you do not say
Do not congratulate them on “leaving SNC” when the row is HPV. Do not imply the water permit is clean because air flipped. Multi-permit sites can be HPV on air and SNC on water in the same snapshot. That is two angles, one owner, usually two sentences or two emails, not one “ECHO problem” blast.
When a formal action changes the HPV script
A new CAA formal-action or last-penalty date is the air-docket week. Use the published dollar field only if it is on the DFR. Blank means blank. The penalty exposure estimator is for framing a watchlist stack, not for inventing a fine in Outlook.
How to split Monday without drowning
- Split the weekly flip list into SNC (CWA/RCRA) and HPV (CAA) after you drop statutes you do not sell.
- Inside each stack, put new formal-action / penalty rows above quiet flag flips.
- Collapse sister registry IDs so one EHS lead does not get an SNC note and an HPV note that sound like two vendors discovered ECHO independently. A multi-state watch makes this worse if you skip clustering.
- Open DFRs. If the interactive report disagrees with the zip, park the call.
Cadence stays weekly. Saturday snapshot, Monday two stacks. Do not refresh county NOV PDFs and call it an HPV desk.
Two subject lines that do not lie
SNC: “CWA SNC flag in this week’s ECHO Exporter snapshot — [facility]. We do wastewater work. DFR attached. Not EPA advice.”
HPV: “CAA HPV flag in this week’s ECHO Exporter snapshot — [facility]. We do air compliance work. DFR attached. Not a legal conclusion.”
Name the status word that belongs to that statute. Link the DFR. Do not scrape a personal phone to fill a gap.
Where this sits next to the product
The explainer at /tools/snc-vs-hpv stays free. Hours versus Starter and Pro are on watch ROI. The rest of the tools are public. The weekly list — three states on Starter, nationwide on Pro — is pricing. Cancel in the Stripe Customer Portal.
ECHO lags and is incomplete. HPV is not SNC. A flag is not a court order. A published penalty is not total cost. The warehouse is not Phase I ESA and is not endorsed by EPA.
Record of Sale, LLC operates SNCAlert from Oregon. Contact publisher@noticenearby.com.