MCSC discussion so far has raised these concerns and questions on Section 22:
This section adds a set of new reporting and documentation requirements to the Permit. Streamlined tracking that focuses on the specific information needed to determine TMDL compliance will better allow MS4s to focus on implementation and maintenance of their BMPs and MS4 systems.
– What benefit does the additional data listed in the draft permit provide? Is it all really necessary to gauge TMDL and WLA progress?
– Are the requirements applied to new BMPs constructed after the date of reissuance or is this data required retroactively for all of the MS4’s BMPs that address WLAs?
– Does the requested information directly correspond with data required in the planned GIS-based tracking system?
– Which of these new requirements mirror information that was required only in the past TMDL reporting forms? Which of these new requirements go beyond the information sought in the forms?
– Under the reissued permit as currently written, BMPs for new impervious surfaces would require “documented rationale” to justify its use to address WLAs. Why are there special provisions for how BMPs in new developments or projects should be addressed? What type of documentation is expected to support application of a BMP for new impervious to a WLA?
What are your thoughts on the TMDL section?
lisa_admin.