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arrowre: DEQ critical of City stormwater management

I'd like to clarify statements I made discussing the City's Stormwater Management issues with Mary Keck.

I should have worded my comments regarding the street sweepings differently. They have "hazardous components" in them but are regulated as a "special waste". None the less, the manner in which they have been "managed" is high risk relative to Stormwater. A sight like this falls out of the concern of the Hazardous Waste division due to staffing issues and much bigger fish to fry. When it comes to Haz Waste, its insignificant in the big picture.

However, when it comes to stormwater management its a very big deal.

Point Source pollution is the type you find discharging from a factory where there is a discrete pipe or conveyance. Its regulated under the same permit system referred to as NPDES (National Pollutant Discharge Elimination System). These sources are not allowed to discharge pollutants above certain concentrations.

Stormwater is about "NON POINT source pollution and its much more insidious because it deals with COLLECTIVE pollution vs a single point source. Its difficult for many city officials to "get" because they don't see the collective, they see the small bits which seem to them insignificant. This is where thinking needs to be expanded to effectively manage runoff.

Although the dump site is "small" when considering "point source", its massive when you look at it from the collective. It is a Point Source within the collective.

Think of it this way. Take a salt shaker and pour it on the pavement next to a storm drain prior to a rain event, and it doesn't seem like much. But expand that view and consider a large parking lot, the size of great lakes crossing, covered with that white crystalline salt after a snowstorm. Expand that to consider all the salt we use on our roads for safety. Now we're talking about a significant quantity, a collective impact.

The same is true about street sweepings. Heavy metals are mixed in with all the sediment and debris from our automobiles. A small amount might be coming from your personal vehicle, but collectively its significant.

The sight at depot park is representative of everything you could do WRONG in management. Its exactly the sort of situation that a stormwater pollution prevention plan of the type the DPW has, should be targeted towards and eliminated. I'm not sure how it got missed, but it signals to me that there is a lack of understanding of the intent of the program by those who are regulated by it, and by those vested with oversight.

I have been requesting opportunities to do trainings in the area ever since my return in 04, due to what i have observed as inadequate practices. Its been difficult to be taken seriously on this subject. Where the township is concerned, Linda Richardson has the responsibility of the permit, but not the authority for the things that can reduce our impact, such as planning decisions. The regional stormwater plan is not just outdated, but using large scale detention/retention ponds are known to be breeding grounds for mosquitoes and other disease vectors. The median along Sashabaw is concave, when it could have been developed convex to receive runoff and treat treat it, also reducing the physical impairments caused to river profiles from the effects of urbanization. So its not just the City that lacks training, but our township board as well.

Training is expensive to do, and this is why I have offered my services to the City, and would like to extend that to the Township free of charge. I was trained by the EPA and I've conducted countless training's for construction, industry and MS4s. I've even trained the trainers. This is my profession and I'd like to be of service to my community and help defer some of their cost.

Relative to the ordinances, although the county standards "encourage" Low impact development, studies repeatedly demonstrate that lacking specific language which requires LID practices, they will not be implemented. Don Carpenter from LTU developed a brilliant LID manual for SEMCOG, so the practices have already been presented in usable form. LID or green infrastructure is less expensive to install and maintain, and if there is a problem it is centralized rather than affecting an entire region. Given that the EPA will soon be regulating volume of water as a pollutant, adopting current county ordinances is just plain short sighted.

One of the MINIMUM requirements under the stormwater permit is public participation. By creating a stakeholders group to help develop green ordinances, this is a meaningful way to fulfill that requirement. There is an opportunity to work together with the township as well. Given the School District is also a permitted MS4, it would be smart for them to be involved too.

Tammie Heazlit
August 29, 2012

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