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<br />The new permit requires the establishment of legal mechanism(s) between the City and <br />owner/operators responsible for the long-term maintenance of structural stormwater BMPs not <br />owned by the City. We will recommend ordinance language that meets this permit requirement, <br />along with preparing a draft stormwater maintenance agreement for staff review. <br /> <br />Bolton & Menk will compare your current stormwater management ordinances and prepare a draft <br />ordinance with recommended modifications for staff consideration. We propose to forward these <br />draft ordinances to your staff for consideration prior to scheduling a meeting to discuss the <br />recommended revisions. Based on the outcome and consensus modifications, we anticipate <br />developing a final revised ordinance recommendations for staff and ultimately City Council <br />consideration. <br /> <br />II.Develop Enforcement Response Procedures (ERPs) <br /> <br />The new permit requires the development of ERPs associated with discovered violations to the <br />various new ordinances being reviewed and revised. To meet this need, Bolton & Menk will work <br />with staff to develop a table of violations vs. enforcement procedures as part an administrative task <br />for each ordinance. It is desired that the administrative table can be referenced in the proposed new <br />ordinances and that it can be revised as needed by Council resolution rather than revising the <br />ordinance on a regular basis. <br /> <br />The City will need to develop procedures and forms for Illicit Discharge Detection and Elimination <br />as well as develop a record keeping and documentation process that meets the current permit <br />requirements <br /> <br />III.Address Permit Changes for the Minimum Control Measures (MCMs) <br />Bolton & Menk has reviewed your SWPPP reauthorization application and noted the following <br />commitments that are above and beyond the items described in Tasks I and II above: <br /> <br />MCM 1 - The City has committed to the following public education and outreach categories: <br /> <br />-revise the program to include specifically selected stormwater issues, <br /> <br />-revise the program to include illicit discharge recognition and reporting, <br /> <br />-review the program priorities and make modifications as necessary. <br /> <br />-document the following program activities annually: <br /> <br />specifically selected stormwater related issues <br />o <br /> <br />implementation plans <br />o <br /> <br />annual review findings <br />o <br /> <br />activities held <br />o <br /> <br />materials distributed <br />o <br /> <br />-Bolton & Menk will provide two education articles that the City can use in their monthly <br />newsletters to meet the commitments of MCM 1. <br /> <br />MCM 3 - The City will need to develop procedures and forms for Illicit Discharge Detection and <br />Elimination and also develop a record keeping and documentation process that meets the <br />current permit requirements. <br /> <br /> <br /> <br />