For those of us waiting for "The Number", it appears the waiting game must continue. On August 17, 2011, EPA stated that additional research regarding treatment performance from construction and development sites is still needed before a final number would be provided. No new timeline was offered.
Navigate to this link to read a nice write up from Bureau of National Affairs on the news release from EPA.
Is this good news or bad news? It depends on who you are asking, right? Regulators and MS4 managers could have looked to the numeric limit as the clear indication of whether a construction site was protecting water quality or not. The BMPs, for all intents and purposes, become secondary as long as the numeric limit was achieved. Not having The Number means the regulations continue to be a greater challenge to enforce. Now we are all required to continue enforcing and overseeing a "more flexible" standard that relies on the full cooperation and understanding between the Applicant, Municipality, Design Engineer, Construction Engineer, Project Manager, Contractor, Subcontractors, Third-Party Inspectors, and others. Those in the field know how challenging this task is.
For Applicants and those in the construction and development industry, it would appear to be good news. The lobby against this numeric limit has been very strong. Significant questions were raised about the number's legitimacy and implementability. These, for now, seem to have been enough to push back the decision. So what to do in the mean time while additional research is gathered? Wait? Do a better job of implementing the non-numeric conditions of the permit? Perhaps. The likelyhood of a number in the future is strong. A good suggestion would be to take samples of discharge from time to time and see how clean your BMPs are getting the stormwater running off your project. No one says they have to be samples that are reported and you may want to know if your efforts are good enough before The Number is put down on the permit.
What messages do you take from this extended delay? Is it good news or bad?
About Our Association
- Nebraska Floodplain and Stormwater Managers Association
- The Nebraska Floodplain and Stormwater Managers Association (NeFSMA) is an active organization of over 100 members representing over 50 organizations. NeFSMA pursues multiple purposes including: 1.)promote public awareness of floodplain and stormwater management; 2.) promote the professional status of floodplain and stormwater management and secure all benefits resulting there from; 3.) promote cooperation and information exchange between individuals and entities concerned with floodplain and stormwater management; 4.) keep individuals concerned with floodplain and stormwater management well informed through educational and professional seminars and to provide a method for dissemination of information, both general and technical; 5.) inform and educate concerned individuals of pending floodplain or stormwater legislation, funding and other related management matters. Please browse our website to learn more about NeFSMA at www.nefsma.net. If you are interested in joining, either contact one of the board members or complete the membership form.
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