The new Permit requires monthly non-storm-water visual inspections. Inspections have been required since September, 2015. Municipal and Regional Water Board inspectors are verifying that these reports are being completed by requesting to see them.
Failure to complete these monthly inspection report forms is a Permit violation. The report form is Table 2, Monthly Non-storm Observation Log in the BI Workbook. Conduct the inspection once a month on days when it is not raining, and record the observations on the correct monthly report form.
When a storm water sample is collected, a Storm Discharge Visual Observation is to be completed. This form is Table 3, Storm Discharge Visual Observation Log Sheet in the BI Workbook.
The Table 3 Storm Discharge Visual Observation Log Sheet is used to record visual observations of the storm water being discharged from the site when a sample is collected. It needs to be completed only when a storm event sample is collected.
The absence of either of these reports could lead to the issuance of a Notice Of Violation, and a fine. It is imperative that these forms are completed and available when an inspector requests them.
The new Industrial General Permit will go into effect on July 1, 2015. Every Permittee will receive a letter detailing the requirements for the new Permit.
Our clients and group members will not need to do anything as we will assist you through the process.
All client will be visited starting in February, 2015 to start the New Permit process which requires:
• Evaluating if a Permit is required.
• Enrolling Permittees into the SMARTS Program
• Preparing a New SWPPP
• Preparing a New Site Map
• Preparing a New Sampling and Monitoring Program
• Preparing New Permit Registration Documents (PRD)
The group will remain intact and annual sampling is reduced from the required 4 to 2, for group members.
The Storm Water Program Fee Branch recently notified Brash Industries that it intends to implement a Tiered Permit Fee system based upon facility acreage. A smaller facility will pay less than a larger facility. This tiered fee program was proposed by Brash Industries’ SoCal Storm Water Group Monitoring Program Manager, Marvin H. Sachse, P.E., with the support of the California Auto Dismantlers and Recyclers Alliance (CADRA).
The tiered Stormwater Permit Fee concept was initially proposed by Mr. Sachse to the State Water Board three years ago and Mr. Sachse has been encouraging its adoption ever since. At the June 20, 2014, Permit Fee Branch meeting of the State Water Board Fee Branch, Mr. Marvin Sachse, again proposed consideration of an annual fee rate based upon a measure of permittee size, such as: number of employees, facility area, or gross revenue, with smaller facilities paying a lower fee than larger facilities.
The Water Board Fee Branch staff appreciated Mr. Sachse’s presentation and requested a formal submission of his request for tiered permitting along with his presentation material demonstrating Arizona and Washington State’s size-based fee programs. The backup information also demonstrated that Stormwater Permit fees for Nevada and Oregon are significantly lower, ½ to ⅛ that of the fees charged in California.
A Water Board Fee Branch staff member recently advised Mr. Sachse that the Water Board Fee Branch will endeavor to adopt the tiered fee system in FY 2015-2016, but in all likelihood it will not be fully implemented until FY 2016-2017.
Additionally, BI also received information that the Permit Fees for FY 2014-2015 have been proposed with an 8.2% fee reduction.
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At the June 20, 2014 Permit Fee meeting, the Water Board Fee Branch staff indicated that they would consider implementation of a sliding scale Stormwater Program Permit Fee as proposed by CADRA, SoCal GMP, and Brash Industries. The Sliding Scale Proposal was presented by Mr. Marvin Sachse, the only meeting attendee representing industrial permitees. The proposed program establishes an annual fee rate based upon a measure of permitee size, such as: number of employees, facility size, or gross revenue, with smaller facilities paying a lower fee than larger facilities.
The Sliding Stormwater Permit Fee concept was proposed by Mr. Sachse to the State Water Board three years ago and Mr. Sachse has been encouraging its adoption ever since. Water Board Fee Branch staff members advised Mr. Sachse that the Water Board Fee Branch supported the concept and would be working to implement fee reductions and fee scaling when the new Industrial General Permit is implemented on July 1, 2015.
The Water Board Fee Branch staff appreciated Mr. Sachse’s presentation and requested a formal submission of his presentation along with the backup material used in the presentation that demonstrated Arizona’s utilization of a sliding fee schedule based upon acreage and Washington State’s program based upon gross sales which includes a fee reduction provision for hardship, ability to pay, and small businesses. The Stormwater Permit fees for Nevada and Oregon are, respectively, ½ to ⅛ that of the fees charged in California. Mr. Sachse pointed out that California municipalities were also charging Stormwater fees, giving the perception of double charging for the same program.
Mr. Sachse also described the overall condition of the State’s economy and the impacts the large Permit fees have on the small business operator which could result in Stormwater program abandonment which, ultimately, reduces the number of permitees and the overall level of compliance. In a conversation with one of the Water Board Fee staff members, it was mentioned that there would not be a fee increase next year.
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