Comments on: Comments on National Ordinance Review

By: StormBlog9

StormBlog9 — Mon, 14 Dec 2009 22:12:12 +0000

I thought the National Ordinance Review was very well done and provided some useful insight into what others have done in creating successful and innovative programs. I believe everyone is in favor of protecting properties from flood damages and storm water pollution. However, we don’t all agree on to what extent and at what cost.

I’ve looked at the EPA cost projections and found them woefully underestimated. Our community has performed a needs assessment, recent cost analysis of existing storm water management practices and have a storm water management program in place. Our actual costs are much greater than their estimates and when the additional needs are included our costs are even greater. There is also a large cost being borne by the development community.

There is a cost to being innovative and cutting edge. With the financial uncertainties facing all of us we must identify what all these costs are before we make a decision. Some regulations may actually save us money or are simply worth the costs, but I think we owe it to the Storm Water Committee, DuPage County and our municipal Boards to identify those costs as best as we can before they enact any new regulations.

By: admin

admin — Wed, 25 Nov 2009 20:21:20 +0000

We’ve attempted to address these comments in part. The National Ordinance Review Document, currently under final revisions, will have a section referring to Seattles Maintenance Requirements and how this program inspects and enforces maintenance of stormwater facilities by private owners.

As for costs, four informational documents will be posted on the “Nat’l Ord Review Supplemental Info” page of this website, accessible at the upper left margin of this page. Two of these are case studies for conventional versus LID stormwater management approaches at numerous sites, in one case for 17 locations across the US, in another specifically for a number of sites in IL. In addition, there are two documents by the EPA discussing costs estimated to be incurred by Municipalities, Constructors, and others in order to be compliant with the NPDES Phase II program. They are slightly dated, but should provide some baseline information.

Please allow 3 – 4 working days to actually see these documents posted to this webpage.

By: StormBlog24

StormBlog24 — Mon, 16 Nov 2009 15:23:06 +0000

I agree that the reveiw was well done. I was hoping for more of a discussion on what these entities do for long term maintenance. What are the long-term requirements for the infilatration bmps and how are they enforced? What happens if it is found that a bmp simply does not perform after construction? What type of monitoring is required at the point bmps vs. downstream?
The section that discusses infiltration references studies from the east coast. Are there similar studies locally?
What sets the size of storm to be detained?
The TMDL discsussion is interesting and leads to the question of how will these be tied into the new oridnance (if at all)?

Also, I have a few minor typos/comments:
Page 2 – add “and” between ordinances approaches
Page 2 – add “without County certification.” at the end of the first bullet
Page 3 – section 3 first paragraph, there are redundant “that”s

By: StormBlog52

StormBlog52 — Thu, 12 Nov 2009 20:39:41 +0000

The National review was well done and difficult to do. This review immediately raises the issue of what we are fundamently doing. Are we just reorganizing the ordinance or are we seeking to completely revamp the ordinance? The National reivew suggests we may reorganize, reshape and rethink the fundamental nature of the ordinance to bring it to cutting edge thinking for our current times. The challenge is how far do we go in this process. How much does it cost to come to the cutting edge of water quality issues? And who pays for this work? What is reasonable middle ground? The review did not appear to mention the cost of government regulations to local government and the private sector. It was also not clear what the state environmental philosophy was for each of the governmental entities considered to be leaders in the review. I suspect each state is also a leader and that they help the successful entities that we are looking at.