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FLOOD08316
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Last modified
1/25/2010 7:14:14 PM
Creation date
10/5/2006 3:31:59 AM
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Template:
Floodplain Documents
County
Statewide
Basin
Statewide
Title
Flood Hazard News The 1997 Floods in the District
Date
2/11/1998
Prepared For
State of Colorado
Prepared By
UDFCD
Floodplain - Doc Type
Educational/Technical/Reference Information
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<br />I <br />f' <br />I <br />~ <br /> <br />Notice of Intent. You will be required <br />to evaluate program compliance, <br />appropriateness of your six minimum <br />measures, and progress toward <br />achievement of your measurable goals. <br />Monitoring may be required by your <br />NPDES permitting authority, but it is <br />not required as part of the proposed <br />EP A regulations. However, reference is <br />made to the potential of monitoring. <br />You must keep records for at least three <br />years. You must submit the records <br />only when specifically asked and you <br />must make records available to the <br />public. It is nnt clear in the proposed <br />permit what will constitute adequate <br />record keeping. <br />You must submit an annual report <br />to the NPDES permitting authority for <br />the first permit term. For subsequent <br />terms, you must submit reports in years <br />two and four uuless the NPDES <br />authority wants them more often. Your <br />report must include: 1) status of <br />comp1iance with permit conditions, <br />asses~ment of appropriateness of your <br />identified BMPs, and progress toward <br />achieving the measurable goal for each <br />of the six minimum control measures; <br />2) results of information collected and <br />analyzed including monitoring daU" if <br />any; and, 3) summary ofwhat <br />stormwater activities you plan to <br />undertake during the next reporting <br />cycle and changes in any identified <br />measurable goals that apply to your <br />program elements. <br />NPDES permits are federally <br />enforceable. Violators are subject to <br />enforcement actions and penalties of the <br />Clean Water Act. Comp1iance with the <br />NPDES permits issued under the <br />anthority of this rule will be deemed to <br />be in compliance with the Clean Water <br />Act. For the time being, do what you <br />say you will do and you will be okay. <br />Concerns and Unresolved Problems <br />This is just the beginning. While <br />EP A is recommending in the proposed <br />rule that no additional requirements <br />beyond the six minimnm control <br />measures be imposed on small <br />regulated municipalities, until they <br />review and evaluate the program, there <br />is a caveat. When adequate information <br />exists in an approved TMDL study to <br />develop more specific conditions or <br />limitations to meet water quality <br /> <br />standards, additional requirements can <br />be imposed. There is current1y a lot of <br />pressure to conduct TMDL studies. <br />The NPDES permitting system will be <br />used as an enforcement mechanism to <br />implement TMDL recommendations. <br />There is a concern that the NPDES <br />permitting system will eventually be <br />used to regulate the flow rate and <br />volume of stormwater which in turn <br />translates to land use control. In nther <br />words, the NPDES permit may become <br />a vehicle for federal land use control. <br />Local governments should, on their <br />own, attempt to regulate the flow rate <br />and volumes of stormwater, but it <br />should not be a subject ofNPDES <br />permitting control. <br />Your public works program will <br />forever be linked to the federal <br />government and/or state through a <br />regulatoty program. They will have the <br />power and authority to force local <br />governments to do what they think is <br />required to meet water quality <br />standards. <br />The NPDES permitting program is <br />fundamentally a point source program. <br />It is designed for the control and <br />permitting of point sources such as <br />waste treatment plant effluent <br />Stormwater is a diffuse source of <br />discharges and does not lend itself to <br />point source control. The Clean Water <br />Act needs to be revised to reflect the <br />realities of stormwater. <br />It is hard to develop partnerships in <br />a command and control environment <br />such as with the NPDES permit system. <br />It is like being a partner with an 800 lb. <br />gorilla. One partner has a defiuite <br />advantage. Local government is not the <br />gorilla in this case. <br />There is concern that eventuaI1y <br />cities and counties will be forced to <br />meet numerical effluent limitations at <br />the end of their storm sewers. This <br />would be an impossible requirement <br />and would cost local governments a lot <br />of money trying. <br />In summary, I urge all of you to get <br />a copy of the proposed regulations and <br />comment on them. If you have <br />concerns or suggestions to improve the <br />proposed regulations, let EP A know in <br />writing. What we can all agree on is <br />the goal of reducing pollutants in <br />stormwater. The mechanism congress <br /> <br />21 <br /> <br />has chosen, command and control <br />through the NPDES permitting <br />program, may eventoa11y cause <br />problems for local governments. <br />Review the proposed regulations <br />carefully, think in terms of how your <br />local government can respond to the <br />requirements and comment accordingly. <br /> <br />Student Intern Program <br />Since the late 1970's, the District <br />has hired students on a part-time basis <br />to assist staff with various activities. <br />The students have come most1y from <br />the Uuiversity of Colorado at Denver <br />Civil Engineering Program, and the <br />Metro State University Civil <br />Engineering Technology Program. We <br />started with one student in the late <br />1970's. At the present time, we have <br />six interns. Three students wolk in the <br />Maintenance Program, one student is <br />splitting duties between the <br />ConstnJction Program and Floodplain <br />Management Program, and two <br />students are assisting with research, and <br />data collection and evaluation activities. <br />Some 30+ student interns have worked <br />for the District since the program <br />began. <br />Stodents typically join the District <br />in their junior year and remain with us <br />for one to two years. The students work <br />about twenty hours a week during the <br />nine months of the school year and up <br />to 40 hours a week during the summer <br />months. As soon as the student <br />graduates, they are no longer eligible <br />for employment at the District under <br />our imern program. <br />It has been satisfYing indeed to see a <br />number of young people join the <br />District as student interns, walk <br />productively for the District, graduate, <br />and then enter the wolk force. Many of <br />the former student interns are now <br />pursuing successful careers and <br />working with local consultants or <br />municipalities throughout the Denver <br />metropolitan area and elsewbere. <br />This program has been a plus for <br />both the students and the District. The <br />students gain from the experience and <br />contacts they make while they are at the <br />District, and the District gains by <br />employing competent people at <br />reasonable rates. <br />
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