HomeMy WebLinkAboutproposed revisions phase 2 small MS4 General Permit- - -= ti
BOARD OF SUPERVISORS
ADMINISTRATION CENTER
25 COUNTY CENTER DRIVE - OROVILLE, CALIFORNIA 959fi5
September 1, 2011
Jeanine Townsend, Clerk to the Boazd
State Water Resources Control. Board
P. O. Box 100
Sacramento, CA 95812-2000
TELERHONE: (530J 538-7224
BOAR pf ${}p~RVISORS
SEP ~.~ X019
~JR4VIL1.~, CALlt=4RhifA
RE: Proposed Revisions to Phase II Small MS4 General Permit
Dear Ms. Townsend:
STEVE LAMBERT, Chair
Fourth District
BELL CONNELLY
First District
LARRY WAHL
SECOnd Dfs#rict
MAUREEN KIRK
Third Districf
KIM YAMAGUCI~I
Fitfh Disfict
The Butte County Board of Supervisors hereby requests that the Water Resourr..es Control Board
delay the implementation of aay proposed revisions to the Phase II Small MS4 General. Permit
requirements until the State of California economy improves and funding for local entities becomes
more stable and predictable.
The County of Butte is very concerned about the State Water Resource Control Board's proposed
revisions to the Phase II Small 1t~fS4 General Permit {Permit) for many reasons, some of which are
shown below.
First, the State of California economy is still strt3ggling to recover from the recent recession and the
County is concerned about tl~e cast and impact the proposed General Permtit revisions will have on
local business as well as the County's ability to provide basic public safety services to its residents.
Second, extensive changes in the-draft revisions of the Permit have more ihan quadrupled the amount
of pages from the existing permit The proposed Permit is p.:rescriptive, iaflexible with a one-size-
fits~l approach to~ all local agencies across the state. CoFnpliance with the proposed permit will
have s~ignifi,cant f seal iumplications on permitted agencies az~d businesses across tie State. For
businesses, 'i~Y ~~ businesses, these proposed mandates could force them to pay for very
expensive retrofits and increase their costs of doing business within the State of California. The
County and otherlc~cal cones will be under i[tcre~sed. s station andwill need
to pass on these ash costs of compliance to laea~l l~siness ov~mers.
Finally, many of the new permit requirements listed below are onemus-and cost prohibitive:
• Storm water education to school.-age children. It should be noted that the education of
California's children is not the responsibility of the County's Public Works Storm Water
Program _
• Storm drain inlet cleaning on a Water Baazd mandated schedule
• Prohibition of green waste on streets
• Mandating municipal services, such as street sweeping, where such services are not currently
provided
• Compilation of rainfall data.
• Imposition of water quality runoff standards on new and redevelopment projects
• Water quality monitoring
The State is once again shifting a financial burden away from the State, where it belongs, to those
least able to afford it -local governments and businesses.
In summary, the County of Butte requests that the Water Resources Control Board delay the
implementation of any proposed revisions to the Phase II Small MS4 General Permit requirements
and further revise the proposed Phase II MS4 Permit by taking into accotmt the cost versus benefit of
compliance for small rural Counties and the limited resources that are available to them.
Sin ely,
Steve
Chair, Bu County Board of Supervisors
cc: Wally Herger, 2°d Congressional l~lStnct
Turn McClintock, 4~ Congressional District
Doug La Malfa, State Senate 4~" District
Jim Nielsen, State Assembly 2°~ District
Dan Logue, State Assembly 3`~ District
Paul Hahn, Butte County Administrative Officer
Tom Blixt, Administrative Analyst,. Butte County Public Works Storm Water Management