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Storm Water and TMDLs: Backdoor Numeric Requirements in Storm Water Permits?

Be prepared for specific numeric requirements in storm water permits.

For more than two decades, storm water dischargers have complied with permits that impose vague general requirements for implementing best management practices (BMPs). Recently, there has been pressure to include numeric requirements in storm water permits. Numeric requirements would make it easier for agencies and environmental groups to identify which dischargers are violating permit requirements. Those dischargers can then be sued and forced to pay penalties and attorney fees. There has also been pressure to give teeth to TMDL-based requirements, which are intended to bring water quality in ambient streams up to the fishable-swimmable criteria established through water-quality standards. Vague general requirements in storm water permits are likely to be replaced with specific numeric requirements. As a result, dischargers may find that they must comply with numeric requirements that arrived with little or no warning. This topic will explain what TMDL-based storm water requirements are, how they are imposed by regulatory agencies, and what can be done about them.

Runtime: 91 minutes
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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

Storm Water Basics

  • Why Does Anyone Care About Storm Water?
  • Historic Interest in Flood Control
  • Recent Interest in Water Quality

Clean Water Act Basics

  • History and Goals
  • What Is Prohibited?
  • How Discharges Are Regulated
  • Theory and Reality

TMDL Basics

  • What Is a TMDL?
  • How Are TMDLs Implemented?
  • Theory and Reality

Why Should Storm Water Dischargers Care About TMDLs?

  • Numeric Requirements
  • Prohibitions on Discharge?
  • Enforcement by Environmental Groups

What Can Be Done?

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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

OnDemand Course

This course was last revised on December 22, 2015.

Call 1-866-352-9540 for further credit information.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Lawrence S. Bazel, Esq.

Lawrence S. Bazel, Esq.

Briscoe Ivester & Bazel LLP

  • Partner at Briscoe Ivester & Bazel LLP in San Francisco
  • Former consultant to EPA on Clean Water Act issues
  • Environmental lawyer since 1984
  • Represents municipalities, companies, and individuals in permit negotiations and in litigation, including the defense of enforcement actions
  • Can be contacted at 415-402-2700 or [email protected]
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Product ID: 396860
Published 2015
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