HomeMy WebLinkAboutAGENDA REPORT 1992 0415 CC REG ITEM 11CIcy , 9) 7 QC—). 1 0-
ITEM `
MOORPARK
799 Moorpark Avenue Moorpark, California 93021
M E M O R A N D U M
TO: The Honorable City Council
FROM: Kenneth C. Gilbert, Director of Public Works
DATE: April 2, 1992 (Council Meeting 4- 15 -92)
SUBJECT: Approval of Implementation Agreement for the
National Pollutant Discharge Elimination
System (NPDES)
OVERVIEW
(805) 529 -6864
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This presents a number of actions required to participate in a
Joint NPDES Permit for the Callegaus Creek watershed (Zone 3).
DISCUSSION
A. Background
The Federal Clean Water Act was amended in 1987 to require the
Federal Environmental Protection Agency (EPA) to establish
regulations for the issuance of permits for stormwater
discharge. These regulations established the National Pollutant
Discharge Elimination System (NPDES) which sets forth policies,
regulations and procedures for the issuance of stormwater
discharge permits. The administration of this Federal program
has been delegated to the California Regional Water Quality
Control Board ( LARWQCB). The NPDES program applies to both
private organizations and public agencies.
B. Joint NPDES Permit
The LARWQCB requires payment of a $50,000 fee for each NPDES
permit issued. Although the City of Moorpark would not be
required to participate in the program until 1995, the City
would realize a considerable savings if these permit fees and
other related costs could be shared with other agencies. On
February 5, 1992, the City Council approved a Cooperative
Agreement between the City of Moorpark, the County of Ventura
(County), the Ventura County Flood Control District (VCFCD), the
City of Simi Valley, the City of Thousand Oaks and the City of
Camarillo, to look into the feasibility of participating in a
Joint NPDES Permit for the entire Callegaus Creek watershed
PAUL W. LAWRASON JR. BERNARDO M. PEREZ SCOTT MONTGOMERY ROY E. TALLEY JR. JOHN E. WOZNIAK
Mayor Mayor Pro Tern Councilmember Councilmember Councilmember
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(Zone 3).
Staff has been meeting with staff from these agencies in an
effort to formulate the Joint Permit application. With the aid
of a consultant [Camp, Dresser & McKee, Inc. (CDM)] retained by
the VCFCD to assist in this process, the group has developed the
draft structure of the permit application; and representative of
the group are scheduled to meet with the LARWQCB on April 15.
An outline of relevant points to be addressed in the permit
process is attached as Exhibit 1. As you can see from this
outline, the VCFCD recently decided to make this permit a
County -wide Permit, with Zone 3 as the phase 1 implementation.
This decision was in response to requests from cities outside of
Zone 3 to be included in the process.
C. Implementation Agreement
Another element of the work done by the above mentioned group,
was the develornent of an Implementation Agreement to formalize
the basis of understanding for the Zone 3 Joint NPDES Permit.
A copy of the final draft agreement is attached as Exhibit 2.
Due to certain time constraints discussed below, it is requested
that this agreement be approved at this time, subject to final
language changes and approval by the City Attorney and the City
Manager.
D. Stormwater OualitX Management Program
The NPDES regulations mandated by the Federal EPA require local
agencies to establish a program for the management of stormwater
pollution. Under Phase I of the program, every public agency,
which owns stormwater facilities, will be required to establish
a storm water quality monitoring program. An outline of some of
the objective of the program is attached as Exhibit 3.
Also included in the program are guidelines for identifying and
implementing the Best Management Practices (BMP) and the Best
Available Technologies (BAT) required to implemented program
requirements with the Maximum Effort Practicable (MEP). Again,
the focus of the Part 1 Permit will b e monitoring and
assessment. Future Federal regulations may require efforts to
intervene to reduce known sources of pollutants.
Many agencies have responded to these requirements by creating
a formalized storm water utility. Complying with the NPDES
regulations will require the City of Moorpark to develop a
number of resources in order to be able to implement an
effective program.
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E. Program Costs
The full extent of the demands to be placed on the City by this
program will not be fully known until the NPDES Permit is
developed, approved and implemented. Some of the efforts
required are listed in Exhibit 3.
One of the basic resources to be used by most cities in
developing a their program is a comprehensive a City wide Master
Drainage Study. This document normally sets forth a number of
important categories of information, including: topographic
features, relevant hydrological data, identification of
watershed areas, a current Storm Drain Atlas, preliminary
alignment and sizing of required future storm drains and
construction cost estimates for the full implementation of the
Master Plan. Although the City has had studies prepared for a
number of areas of the City, it is recommended that a Master
Drainage Study be prepared to pull this information together and
to develop like information for those areas not studied.
Again, it is difficult at this time to accurately identify
program costs. However, staff estimates that the start -up cost
(first two years' expenditures) will range from $50,000 to
$70,000.
F. Funding
1. Benefit Assessment District -- One benefit of participating
in the Joint NPDES Permit is the ability to exercise an
option to participate in the VCFCD's Benefit Assessment
Program to recover program costs. Those cities which choose
to utilize this program to fund all or only a portion of
their Stormwater Quality Management program, can do so in a
manner consistent with the guidelines set forth in the
Implementation Agreement. A brief description of the VCFCD's
Flood Control Benefit Assessment District is as follows:
a. Every property within the VCFCD's Benefit Assessment
District is assigned a number of Benefit Assessment Units
(BAU) based on the land use of the property. The formula
for computing the number of BAUs to be assigned, uses ONE
BAU for a typical single family lot.
b. The amount of the assessment levied by the VCFCD in Zone
3 last year was $24.12 per BAU (each single family lot was
assessed $24.12 last year for flood control).
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c. The number of BAU's within Zone 3 are listed as follows:
City of Moorpark 9,124
City of Camarillo 221248
City of Simi Valley 371045
City of Thousand Oaks 37,818
County unincorporated Area 27,700
Total 133,935
d. The amount of the assessment to be levied by the VCFCD
next year is not yet known. It is anticipated, however,
that the amount of next year's assessment will be slightly
higher than last year due to damage sustained by VCFCD
facilities during recent storms.
e. In addition, a certain increase in the VCFCD assessment is
anticipated to fund the efforts of VCFCD to comply with
the subject NPDES requirements.
2. City of Moorpark's Assessment -- If the City were to
participate in the VCFCD's program, an assessment of $3 per
BAU per year would generate sufficient funds to cover the
above mentioned anticipated program start -up costs over a
three year period.
3. Schedule for Setting Assessments -- If the City were to
participate in the VCFCD's program and request that
assessments be levied for Fiscal Year 1992/93, it would be
necessary to adhere to a very short timeframe. The schedule
for this action is as follows:
Date
Action
April 15
City approves Implementation Agreement
• City sets preliminary amount of
assessment
• City sets date for Public Hearing
(Assessments)
April 28
County approves Implementation
Agreement
May 20
City holds public hearing on
Assessments
• City approves, revises and approves, or
rejects the levying of assessments for
this program
May 22
County sends Final Report to the
publisher
May 27
Report to the Board
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Date Action
June 2 County sets public hearing
June 23 County public hearing date
July 1 Assessment due to Auditor
To participate in this program, the City Council would have
to set May 20, 1992, as the date of a Public Hearing to
consider levying the assessment.
4. Other Revenue Sources -- In the event the City chose to not
utilize the VCFCD's Benefit Assessment District to fund these
program costs, other options would be extremely limited. One
of the BMP's discussed in the federal guidelines is the use
of street sweeping as a means to reduce storm water
pollution. This program, or enhancements to this program,
could be funded by Gas Tax. Other requirements of the
programs, such as stormwater monitoring and the development
of a Drainage Study, may have to be funded partially or
totally by other sources. Unless the City decided to develop
its own benefit assessment program, these costs would have to
be funded by the General Fund or other eligible funds such as
Gas Tax.
G. Budget and Finance Committee
The Budget and Finance Committee has discussed the program and
recommends that the City proceed with the efforts required to
develop the program and participate in the proposed Joint NPDES
Permit. The Committee recommended that consideration of levying
assessments be deferred to Fiscal Year 1993/94. Prior to that
time, more specific information will be made available regarding
program costs and funding sources. Any costs incurred in FY
1992/93 can be funded by Gas Tax and /or the General Fund, or by
a loan from these or other sources to the Storm Water Utilitiy
effort.
RECOMMENDED ACTION
It is the recommendation of staff and the Budget and Finance
Committee that the City Council take the following actions:
1. approve the establishment of a Stormwater Quality Monitoring
Program consistent with the requirements of the National
Pollutant Discharge Elimination System ( NPDES);
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2. approve City participation in efforts to obtain a Joint NPDES
Permit for the area encompassed by the Callegaus Creek watershed
(VCFCD Zone 3);
3. approve the attached Implementation Agreement (Exhibit 2)
setting forth parameters for the administration of said Joint
Permit, subject to final language approval by the City Attorney
and City Manager;
4. concur with the recommendation of the Budget and Finance
Committee to defer participation in the VCFCD's Benefit
Assessment District; and,
5. defer a decision on the funding of the first year's program
costs to the FY 1992/93 Budget deliberations.
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I.
II.
April 8, 1992
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VENTURA COUNTY -WIDE
PART 1 NPDES PERMIT APPLICATION
Benefits of County -Wide Approach
1. Allows consistent approach to ordinance development and
implementation.
2. Establishes unified implementation of BMPs to the MEP.
3. Allows for coordinated monitoring program, reducing the
number of monitoring sites and ensuring data sharing.
4. Prioritizes water quality problems and their solutions
throughout each watershed.
5. Directs resources to prioritized problems.
6. Provides for a cost savings over individual approaches.
7. Coordinates implementation of BMPs for many
municipalities.
8. Addresses multi - jurisdictional /interconnected storm
drain issues.
9. Integrates stormwater quantity and quality master
planning /CIPs to ensure cost effective approach.
lo. Opportunity to balance urban stormwater pollution
management with management programs for other pollutant
sources (e.g. point sources, agriculture).
11. Integrates data management /mapping approaches.
Issues to be addressed with RWQCB
1. Description of permittee and co- permittees and their
responsibilities and liabilities. How to address entities
(e.g. CalTrans, schools, federal facilities, etc) outside of
permittee /co- permittee's jurisdictions.
2. Prioritizing water quality problems (or watersheds) vis-
a-vis permitting schedules. Examples: Mugu Lagoon,
Calleguas Creek, Port Hueneme Harbor, Santa Clara River.
3. Scheduling of co- permittee's work, RWQCB defined vs
regulatory defined (e.g. Oxnard vs others).
4. Level of effort: follow Federal Part 1 application
requirements or RWQCB defined requirements.
Ventura County LX 1 ( Z oC Z i
Regional Approach to NPDES Application
Page 2
5. Coordination with other Federal /State programs, e.g.
Coastal Zone Management Act.
6. Impact from non -urban runoff, e.g. agricultural
practices on watershed quality.
7. Consistency in MEP implementation.
8. Impact of LA County permit on common jurisdictions.
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L101q)
Revised 4 -1 -92
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
IMPLEMENTATION AGREEMENT
STORMWATER REGULATION PROGRAM
CALLEGUAS CREEK WATERSHED
This AGREEMENT is entered into by and between the County of Ventura
hereinafter referred to as COUNTY, the Ventura County Flood Control
DISTRICT hereinafter referred to as DISTRICT, and the Cities of
Camarillo, Moorpark, Simi Valley and Thousand Oaks hereinafter
collectively referred to as CITIES, establishes the
responsibilities of each party with respect to compliance with
National Pollutant Discharge Elimination System (NPDES) Stormwater
regulations administered by the California Regional Water Quality
Control Board, Los Angeles Region (LARWQCB) by the authority
granted by the Clean Water Act (CWA) and its 1987 amendments and
the Water Quality Act (WQA).
RECITALS
Whereas, Congress in 1987 amended Section 402 of the Federal
Clean Water Act [33 U.S.C.A. 1342(p)] to require the federal
Environmental Protection Agency (EPA) to promulgate regulations for
applications for Permits for stormwater discharges; and
Whereas, these Permit regulations will require the control of
pollutants from stormwater discharges by requiring a National
Pollutant Discharge Elimination System (NPDES) Permit (PERMIT) for
the discharge of stormwaters into waters of the United States; and
Whereas, these EPA regulations require PERMITs for discharges
from municipal storm drains on a system -wide or jurisdiction -wide
basis; and
Wheras, the CITIES and the COUNTY have land use regulation
authority within their jurisdictional boundaries with associated
powers to require mangement practices consistent with EPA
regulations; and
Whereas, the DISTRICT has no land use regulation authority,
but only owns, operates and has regulatory jurisdiction over
improved and natural channels to which CITIES' and COUNTY's storm
drains are tributary;.and
Whereas, the Legislature, in enacting the Ventura County Flood
Control Act, created the DISTRICT to provide for the control of
flood and storm waters; and
Whereas, the Powers granted to the DISTRICT include carrying
on technical and other investigations, examinations or tests of all
kinds, making measurements, collecting data, and making analyses,
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studies, and inspections pertaining to water supply, control of
floods, prevention of contamination and pollution of surface waters
within the DISTRICT; and
Whereas, the CITIES, the COUNTY and the DISTRICT desire to
develop an integrated stormwater discharge management program with
the objective of improving water quality in the Calleguas Creek
Watershed; and
Whereas, cooperation between the CITIES, the COUNTY and the
DISTRICT to jointly file application for PERMIT is in the best
interests of the CITIES, the COUNTY and the DISTRICT; and
Whereas, the DISTRICT, COUNTY and CITIES have been jointly
designated as Permittees by the LARWQCB; and
Whereas, the DISTRICT has been designated as the Principal
Permittee in the PERMIT; and
Whereas, the COUNTY and the CITIES have been designated as the
Co- Permittees in the PERMIT.
NOW, THEREFORE, the parties hereto do mutually agree as follows:
I. FILING STATUS. The COUNTY, DISTRICT and CITIES will file
the applications for PERMIT as Permittees. The COUNTY,
the DISTRICT and each individual City will be a
Permittee.
II. INCORPORATION OF FEDERAL REGULATIONS. The terms of all
applicable Federal and State permit applicaion
guidelines, as presently written or as changed during the
life of this AGREEMENT are hereby incorporated by
reference and made a part of this AGREEMENT and take
precedence over any inconsistent terms of this AGREEMENT.
III. STRUCTURE AND RESPONSIBILITIES
A. All Permittees (Principal Permittee and Co-
Permittees) are independently responsible for
complying with the requirements of the PERMIT
within their own jurisdictional boundaries. For
storm drains owned and operated by the DISTRICT,
including those located within the jurisdiction of
the Co- Permittees, the Principal Permittee will be
responsible for facility operation and maintenance.
B. The Principal Permittee shall be responsible for
the following:
(a) Coordination of PERMIT activities, including
establishing a uniform mapping and data
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presentation format,
Permittees.
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to be used by all
(b) Serving as the liaison agency between the Co-
Permittees and the LARWQCB. The
responsibility shall include:
(1) Establishment of time schedules and
notifying Co- Permittees regarding such
schedules for the performance of tasks
and activities per the requirements of
the PERMIT.
(2) Preparation of the quarterly progress
reports and annual reports on PERMIT
activities for submittal to the LARWQCB.
For the annual PERMIT report, a draft
will be circulated to each Co- Permittee
for their review and comment prior to
forwarding to the LARWQCB.
(3) Upon receiv
submitted
compliance
packaging
submittals,
Permittees,
ing information and materials
by the Co- Permittees in
with PERMIT requirements,
and forwarding of these
on behalf of the Co-
to the LARWQCB.
(4) Upon receipt of all proposed plans and
their implementation schedules from all
Co- Permittees, arranging for public
review of these documents. Communicating
with Co- Permittees regarding public
comments. Packaging and forwarding of
the revised final version of these
documents for LARWQCB approval.
(5) Keeping all Co- Permittees updated on
LARWCQB and /or (EPA) regulations which
may impact stormwater discharge
activities and PERMIT compliance.
(6) Arranging for the collection and payment
of all annual PERMIT renewal fees
required by the LARWQCB.
C. Upon concurrence and in coordination with Co-
Permittees, the Principal Permittee shall secure
the services of consultants and administer contract
for consultant to prepare manuals, develop programs
or perform studies relevant to the Permitted area.
The cost of said consultant services will be shared
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in accordance with section IV D of this AGREEMENT.
D. For PERMIT submittals which do not involve the
public review process, each Co- Permittee shall be
responsible to submit these items, prepared in the
format specified by the Principal Permittee, to the
Principal Permittee 30 calendar days prior to the
deadlines specified in the PERMIT. This 30 -day
period will enable the Principal Permittee to
package and forward these documents, on behalf of
all Permittees, to LARWQCB.
E. For PERMIT submittals which involve the public
review process, the Co- Permittee shall be
responsible to submit these items, prepared in the
format specified by the Principal Permittee, to the
Principal "'Permittee 90 calendar days prior to the
deadlines specified in the PERMIT. The Principal
Permittee shall schedule the submittals for public
input, route public comment back to Co- Permittees
for possible refinement of documents, arrange to
receive final documents, and package and forward
documents to the LARWQCB for their review and
approval.
F. Each Co- Permittee shall agree to prepare all
PERMIT- required submittals using the format
specified by the Principal Permittee.
G. Upon the execution of this AGREEMENT, each
Permittee shall develop a program to address the
following issues within its jurisdictional
boundaries that occur during the term of this
AGREEMENT:
(1) Implementation of controls to reduce pollution
from commercial and residential areas.
(2) Implementation of structural /nonstructural
controls on land development and construction
sites.
(3) Implementation of controls to reduce pollution
from maintenance activities.
(4) Elimination of illegal connections, improper
disposal, spill prevention, containment and
response.
(5) Inspection, monitoring and control programs
for industrial facilities.
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(6) Implementation of public awareness and
training programs.
IV. EXPENDITURES
A. Each Co- Permittee shall be responsible for its own
costs of the implementation of the PERMIT
activities within its jurisdictional boundaries.
B. The Principal Permittee shall be responsible for
the cost of its PERMIT implementation efforts for
all storm drains and flood control facilities owned
and operated by DISTRICT.
C. The Principal Permittee shall also be responsible
for the cost of activities specified in Section
III -B.
D. The cost of all common or joint activities or
responsibilities shall be borne by Co- Permittees on
the basis of the ratio of the Benefit Assessment
Units (BAU)s within the Co- Permittee's boundaries
to the total BAUs in the watershed. Common or
joint activities and /or responsibilities may
include but shall not be limited to the following:
(1) Consultant fees for watershed wide Permit
related work.
(2) Legal fees for watershed wide Permit related
work.
(3) Penalties of watershed wide nature.
(4) Best Management Practices of watershed wide
impact or benefit.
V. FUNDING
A. The Co- Permittees may fund activities described in
IV A. through the DISTRICT's Benefit Assessment
Program. Co- Permittee.wishing to do so shall:
(1) Submit to DISTRICT a complete program
description and activity budget and the
amount of assessment required to finance the
program.
(2) Prior to making the request for the levy of
the assessment, hold a public hearing as
required by Section 6066 of the Government
Code.
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VM
(3) The hearing shall be on the program
description and budget, including the means of
financing.
(4) Upon adoption of the program and prior to the
first day of May of each calendar year, submit
a request to District for its inclusion in the
assessment. Said request shall be made by
resolution of the governing body of the Co-
Permittee.
The levying of the District's Benefit Assessment
Program and the amount thereof is within the sole
discretion of the District's Board of Supervisors.
B. All costs incurred by DISTRICT for processing for
the additional assessment (see Section V A.) shall
be borne by Co- Permittee either by direct payment
to DISTRICT or by deduction from the proceeds of
the Benefit Assessment levied on its behalf.
C. Distribution of funds from the Flood Control
Benefit Assessment collections to Co- Permittee will
be made on a schedule established by the Ventura
County Auditor - Controller for such disbursements.
D. The Principal Permittee shall finance the
activities specified in Section IV B. and IV C.
through the use of its Benefit Assessment activity
throughout the entire watershed.
VI. NON COMPLIANCE WITH AGREEMENT
A. Any Permittee not in compliance with the PERMIT
within its jurisdictional boundaries shall be
solely liable for any lawfully assessed penalties.
B. Common or joint penalties shall be calculated and
allocated in accordance with Section IV D.
VII. ADDITIONAL PARTIES.
A. Permittees executing this AGREEMENT shall, to the
extent allowed by law applicable to such entity,
comply with all provisions of this AGREEMENT.
B. Any entity which officially becomes a Co- Permittee
at a later date, subsequent to the signing of this
AGREEMENT, shall comply with all the requirements
of the PERMIT, except that the time frame for
completion of tasks shall be adjusted per mutual
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agreement between the new Co- Permittee in question,
the Principal Permittee, and the LARWQCB.
VIII. WITHDRAWAL FROM THE AGREEMENT.
A. A Co- Permittee may withdraw from the AGREEMENT 60
days subsequent to written notice to the Principal
Permittee and LARWQCB. The Principal Permittee
will notify the remaining Co- Permittees within ten
(10) business days of receipt of the withdrawal
notice.
B. The withdrawing Co- Permittee shall agree to file
for a separate PERMIT and to comply with all of the
requirements established by the LARWQCB. In
addition, withdrawal shall constitute forfeiture of
the said Co- Permittee's remaining funds collected
under the Benefit Assessment Program for the budget
year of withdrawal.
C. The withdrawing Co- Permittee shall be responsible
for all lawfully assessed penalties as a
consequence of withdrawal. The cost allocations to
the remaining Co- Permittees will be recalculated in
the following budget year.
IX. AMENDMENTS TO AGREEMENT
A. This AGREEMENT may be amended by consent of the
Principal Permittee and a two - thirds majority of
the Co- Permittees.
B. Any amendment shall comply with the requirements
and regulations set forth by the LARWQCB.
C. No amendment to this AGREEMENT shall be effective
unless it is signed and approved by the governing
bodies of the majority of the parties.
X. APPENDAGE OF AGREEMENT
Any Permittee may negotiate a separate AGREEMENT with
other Permittees or with all Permittees regarding
stormwater /urban runoff discharge management issues.
Such AGREEMENTS will not be appended to this AGREEMENT
but will be regarded as a separate AGREEMENT. However,
they may reference this AGREEMENT.
XI. LIFE OF THE AGREEMENT
The term of this AGREEMENT commences on its execution by
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each of the duly authorized representatives of the
Permittees. The life of the AGREEMENT shall extend as
long as a PERMIT regulating stormwater /urban runoff
discharges encompassing the Calleguas Creek Watershed is
required.
XII. NOTICES
All notices and correspondences shall be deemed duly
given, if (a) sent by certified U.S. mail; (b) delivered
by hand; (c) three (3) days after deposit in the U.S.
mail, postage prepaid and notice to the addressee of such
mailing by phone immediately after deposit in the U.S.
Mail, or faxed to the Principal Permittee and
confirmation by phone immediately after sending the fax.
XIII. GOVERNING LAW \
This AGREEMENT will be governed and construed in
accordance with laws of the State of California. If any
provision(s) of this AGREEMENT shall be held to be
invalid, illegal, or unenforceable, the validity,
legality, and enforceability of the remaining provisions
shall not in any way be affected or impaired hereby.
XIV. AUTHORIZED SIGNATORIES
The Engineer- Manager of DISTRICT, the Public Works
Director of COUNTY and the City Managers of CITIES (or
their designees) shall be authorized to execute all
documents and take all other procedural steps necessary
to file for and obtain a PERMIT(s) or amendments thereto.
XV. CONSENT TO BREACH NOT WAIVER
No term or provision hereof shall be deemed waived and no
breach excused, unless such waiver or consent shall be in
writing and signed by the party waiving or consenting.
Any consent by any party to, or waiver of, a breach by
any other party, whether expressed or implied, shall not
constitute a consent to, waiver of, or excuse for any
other different or subsequent breach.
XVI. APPLICABILITY OF PRIOR AGREEMENTS
This document constitutes the entire AGREEMENT between
the parties with respect to the subject matter; all prior
agreements, representations, statements, negotiations and
undertakings are superseded hereby.
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XVII. EXECUTION IN COUNTERPARTS
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This AGREEMENT may be executed and delivered in any
number of counterparts or copies ( "counterpart ") by the
parties hereto. when each party has signed and delivered
at least one counterpart to the other parties hereto,
each counterpart shall be deemed an original and, taken
together, shall constitute one and the same AGREEMENT,
which shall be binding and effective as to the parties
hereto.
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MINIMUM OBJECTIVES OF THE S`� _ Ni PROGF XNI
A. Controls for Commercial /Residential Areas
1. Maintenance for Existing /New Structural Controls
2. Implement Structural /Nonstructural Controls as Land Develops Redevzops
3. Reduce Pollution from Roadway O &M Acti-ities
4. Retrofit Flood Control Facilities
5. Reduce Pollution from Municipal Waste Facilities
6.
Controls for Fertilizers, Pesticides, & Herbicides
B. Eliminate Illegal Connections /Improper Disposal
1, Prevent New Illegal Connections
2. Detect & Eliminate Existing Illegal Connec zior.-�
3. Spill Prevention, Containment & Response
4. Detect & Report Improper Disposal
5. Prevent Improper Disposal
6. Stop Exfiltration from Sanitary Sewers
C. Monitor & Control Industrial Facilities
1. Inspection & Control Program
2. Monitoring Program
D. Controls for Construction Sites
1. Define Requirements during Site Planning Process
2. Implement and Inspect Controls
3. Training Programs