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CR 2003-040 General Storm water Permit Application For Small Municipal Separate Storm Sewer Systems Project . . . w. March 4, 2003 Council Report 2003-040 APPROVE GENERAL STORM WATER PERMIT APPLICATION FOR SMALL MUNICIPAL SEPARATE STORM SEWER SYSTEMS PROJECT 02-05 Proposed Action Approve attached General Storm Water Permit Application to be submitted to the Mim1esota Pollution Control agency by March 10, 2003. Direct staff to complete the req uired Storm Water Pollution Prevention Plan for submittal to the Minnesota Pollution Control agency by May 9, 2003. Overview The National Pollutant Discharge Elimination System (NPDES) phase II permit program is part of the Environmental Protection Agency's Clean Water Act. The Milmesota PolIution Control Agency (MPCA) is responsible for implementing and enforcing this legislation locally. On February 14, 2003 the MPC A made available the General Storm Water Permit Application. Due to the short time frame between when the permit was available and the deadline for submittal the MPCA has modified the schedule. The new schedule requires the permit application to be submitted by March 10, 2003 and the Storm Water Pollution Prevention Plan (SWPPP) to be submitted by May 9, 2003.City staff has completed the required application and is in the process of completing the SWPPP. Primarv Issues To Consider . Permit application deadline . SWPPP submittal deadline Supportine Information . General Storm Water Permit ^pplication for Small Municipal Separate Storm Sewer Systems ~~~J~~ Assistant City Engineer Financial Impact: N/A Budgeted YIN Related Documents (eIP. ERP. etc.): Notes: Source: .. . MS Word Tern late Notice of intent to obtain coverage General Storm Water Permit Application (MN R 040000) for Small Municipal Separate Storm Sewer Systems (MS4s) (Noticed as MN R 580000) Minnesota Pollution Control Agency 520 Lafayette Road North, st. Paul, MN 55155-4194 Application deadline: March 10,2003 e ~~~ Minnesota Pollution Control Agency Please read the instructions carefully and use the "tab" key to move through the fields of this form. Enter responses using drop dovvn menus, check boxes and text as indicated. Use the "save as" featme in MS Word to save this template as a document. I. MS4 Information A. Application Type Application type: Single site or administrative area If multiple sites, number of attached application forms: MS4s with multiple sites such as campuses. dispersedfadlities, or state agency regions/districts, must attach a completed application for each site or administrative area. An authorized person with overall responsibility or an officially delegated representative must sign each application form. B. M$4 Owner City of Hopkins Community, municipality, agency or olher party having ownership or operational control oflhc MS4. 1 nl n "pi rcd- Srn::::,q::::.r Snllrn Mailing Address . City Hnpkin<=: MN 55343 Zip Code State Hennepin Mississippi River Twin Cities, Minnesota River Shakopee Major Watershed (see enclosed map) County 41-6005-247 Federal Tax ID 8022882 State Tax ill c. General Contact Anderson John Lasl Name First Name General conlact (official, slaffmember, consultant or other) for permit compliance issues. Assistant City Engin~pr Title 1010 First Street South Mailing Address Hopkins .MN City Slate c;l')~4~ Zip Code (952) 939-1356 Telephone (include area code) landerson@Hopkinsmn.com E-Mail Address II. Certification of the Storm Water Pollution Prevention Program (SWPPP) A. Have you developed a Storm Water Pollution Prevention Program for your MS4? DYes IXJNo Municipalities must demonstrate how their Storm Water Pollutioll Prevention Program will be implemented and enforced over the term of the jive-year permit. SWPPPs must incorporate appropriate educational components, BMPs and measurable goals. . Provide a brief description of the plan to complete the SWPPP if "No" is marked above. MPCA MS4 Storm Waler Pemlil Application 1 of 1 02/06/03 swppp will be submitted on or before May 9, 2003 deadline . Summary of the six minimum control measures. Complete items B. 1. through B. 6. Storm Water Pollution Prevention Programs must address the specific requirements contained in Part V. G. of the permit. SWPPPs must outline how the siY: minimum control measures will be addressed. the contact person, department in charge. lime frame and measures that will be implemented to meet the schedules required by the permit. B. 1. Public education and outreach measures Anderson Contact Last Name John First Name Engineering Departmellt 1010 Fir~~ ~~rpp~ ~outh Mailing Address City Hopkins MN (952) 939-1356 Telephone (include area code) 55343 State Zip Code janderson@Hopkinsmn.com E-Mail Address a) Have Best Management Practices (BMPs) that will be implemented for this minimum control measure been planned or developed? b) Have measurable goals for each BMP for this minimum control measure been planned or developed? c) Has an estimated timeline for implementing each BMP for this minimum control measure been planned or developed? Timelines should include, in parrative Of numerical form, the months and years required actions will occur, interim milestones, and frequency of action, as appropriate. . d) Have the educational components for this minimum control measure been planned or developed? e) Provide a brief description of the plan to complete any requirements marked "No" above. 2. Public participation and involvement measures Anderson Contact Last Name John First Name Engineering Department 1010 First Street South Mailing Address Hopkins MN 55343 Zip Code City State (952) 939-1356 Telephone (include area code) janderson@Hopkinsmn.com E-Mail Address IXJYes ONo IilYes DNo Gf]Yes ONe IilYes DNo a) Have Best Management Practices (BMPs) that will be implemented for this minlinwu [X]Yes DNo control measure been planned or developed? b) Have measurable goals for each BMP for this minimum control measure been planned or IRlYes DNo developed? c) Has an estimated timeline for implementing each BMP for this minimum control ~Yes DNo measure been planned or developed? Timelines should include, in narrative Of numerical form, the months and years required actions will occur, interim milestones, and frequency of action, as appropriate. . d) Have the educational components for this minimum control measure been planned or ~Yes DNo developed? e) Provide a brief description of the plan to complete any requirements marked "No" above. MPCA MS4 Storm Water Pemlit Application 20f2 02106103 3. Illicit discharge detection and elimination . Anderson Contact Last Name John First Name Engineering Department 10]0 First Street South Mailing Address Hnpkinc:: City MN State 55343 Zip Code (9')2) 939-1356 Telephone (include area code) landerson@Hopkinsmn.com E-Mail Address a) Have Best Management Practices (BMPs) that will be implemented for this minimum ~Yes DNe control measure been planned or developed? b) Have measurable goals for each BMP for this minimum control measure been planned or ~Yes DNo developed? c) Has an estimated timeline for implementing each BMP for this minimum control lRIYes DNo measure been planned or developed? Timelines should include, in narrative or numerical form, the months and years required actions will occur, interim milestones, and frequency of action, as appropriate. d) Have the educational components for this minimum control measure been planned or ~Yes DNa developed? e) Provide a brief description of the plan to complete any requirements marked "No" above. 4. Construction site storm water runoff control measures . Anderson Contact Last Name John First Name Enqineering Department 1010 FirST Street SOUTh Mailing Address Hopkins MN 55343 City State Zip Code (952) 939-1356 Telephone (include area code) landerson@Hopkinsmn.com E-Mail Address a) Have Best Management Practices (BMPs) that will be implemented for this minimum !RIYes ONo control measure been planned or developed? b) Have measurable goals for each BMP for this minimum control measure been planned or ~Yes DNa developed? c) Has an estimated timeline for implementing each BMP for this minimum control ImYes ONe measure been planned or developed? Timelines should include, in narrative or numerical form, the months and years required actions will occur, interim milestones, and frequency of action, as appropriate. d) Have the educational components for this minimum control measure been planned or 5i]Yes DNo developed? e) Provide a brief description ofthe plan to complete any requirements marked "No" above. 5. Post-construction storm water management measures . Anderson Contact Last Name John First Namc Engineering Department MPCA MS4 Storm Water Permit Application 30f3 02/06/03 1010 Fir~t Street South Mailing Address City (952) 939-1356 . Telephone (include area code) Hopkins MN State ':1':1141 Zip Code janderson@Hopkinsmn.com E-Mail Address a) Have Best Management Practices (BMPs) that will be implemented for this minimum lli]Ves DNo control measure been planned or developed? b) I-lave measurable goals for each BMP for this minimum control measure been planned or IZ]Ves DNo developed? c) Has an estimated timeline for implementing each BMP for this minimum control lli]Yes DNo measure been planned or developed? Timelines should include, in narrative or numerical form, the months and years required actions will occur, interim milestones, and frequency of action, as appropriate. d) Have the educational components for this minimum control measure been planned or ~Ves DNo developed? e) Provide a brief description of the plan to complete any requirements marked "No" above. 6. Pollution prevention and good housekeeping measures Anderson Contact Last Name John First Name RnlJineE'rin'J Department 1010 First Street South Mailing Address Hopkins 55343 Slate Zip Code janderson@Hopkinsmn.com MN City . (952) 939-1356 Telephone (include area code) E-Mail Address a) Have Best Management Practices (BMFs) that will be implemented for this minimum iXlVes DNo control measure been planned or developed? b) Have measurable goals for each BMF for this minimum control measure been planned or lK!Yes DNo developed? c) Has an estimated timeline for implementing each BMP for this minimum control lli]Yes DNo measure been planned or developed? Timelines should include, in narrative or numerical form, the months and years required actions will occur, interim milestones, and frequency of action, as appropriate. d) Have the educational components for this minimum control measure been planned or ~Yes DNo developed? e) Provide a brief description of the plan to complete any requirements marked "No" above. c. Reporting and record keeping requirements. Have reporting and record keeping requirements for implementation of the Storm Water IKlYes DNo Pollution Prevention Program been planned or developed? Provide a brief description of the plan to complete the reporting and record keeping requirements if"No" is marked above. . MPCA MS4 Storm Water Penn it Application 40f4 02106/03 > . III. Summar of Storm Water Pollution Prevention Program (SWPPP) Required Application Attachments Complete a one page SWPPP Summary Sheet and a BMP Description Sheet for each type of BMP that will . be implemented. (See last two pages of the application form.) A. Is the SWPPP Summary Sheet attached? B. Is one BMP Description Sheet attached for each BMP7 C. How many BMP Description Sheets are attached 7 DYes IXINo DYes !ZJNo IV. Limitations of Coverage A. Part II Limitations on Coverage and Appendix C I have read Part II Limitations on Coverage and Appendix C ofthe MS4 general permit and certify that we intend to comply with the applicable requirements of those sections. IRIYes B. Special Waters Please refer to the Guidance Manual for Small Municipal Separate Storm Sewer Systems (MS4s) and the enclosed map to complete this section. 1. Does the MS4 discharge into Prohibited Waters as defined in Minn. R. 7050.0180, subp. 3,4, and 57 See Attachment Four of the Guidance Manualfor Small Municipal Separate Storm Sewer Systems (MS4s) for further information. If yes, please list below and contact Lou Flynn at (651) 296-6575 or louis.f1ynn@state.mn.us. Be advised that you will be required to obtain an individual permit versus a general permit. .2. Does the MS4 discharge into waters with a Restricted Discharge as defined in Minn. R. 7050.0180, subp. 6, 6a, and 6b? If yes, please list below and comply with Part IX, Appendix C, Item B. See Attaclunent Four of the Guidance Manualfor Small A1unicipal Separate Storm Sewer Systems (MS4s) for further information. DYes IZJNo DYes !ZJNo 3. Does the MS4 discharge into Trout Waters as defined in Minn. R. 6264.0050 subp. 2 & DYes IZ]No 4? rfyes, please list below and comply with Part IX, Appendix C, Item C. See Attaclunents Two and Three of the Guidance Manual for Small Municipal Separate Storm Sewer Systems (MS4s) for further information. 4. Does the MS4 discharge into Wetlands as defined in Minn. R. 7050.0130, subp. F? See DYes [K]No Attachment Four of the Guidance Manualfor Small Municipal Separate Storm Sewer Systems (MS4s) for further infoIDlation. 5. Does the MS4 have a process to evaluate discharges that require applicable [K]Yes DNo Environmental Review as required by State or federal laws? See Part IX of the Guidance Manual for Small Municipal Separate Storm Sewer Systems (MS4s) for further infonnation. .6. Does the MS4 have a process to evaluate discharges whose direct, indirect, interrelated, interconnected, or independent impacts may jeopardize a listed Endangered or Threatened Species or adversely modifY a designated critical habitat? See Part IX of the Guidance Manual for Small Municipal Separate Storm Sewer Systems (MS4s) for further MPCA MS4 Stann Water Permit Application 5of5 IKJYes DNo 02/06/03 . information. . 7. Does the MS4 have a process to evaluate discharges which may adversely affect properties listed or eligible for listing in the National Register of Historic Places or affecting known or discovered archeological sites? See Part IX of the Guidance Manual for Small Municipal Separate Storm Sewer Systems (MS4s) for further information. ~Yes DNa If you answered "No" to Item 5, 6, or 7, briefly explain how the MS4 will come into compliance with the requirements of Appendix C. V. Owner or Operator Certification The person with overall, site or administrative area SWPPP implementation responsibility must sign the application. This person must be duly authorized to sign the application (mayor, designated public works director, president of the university, ete.). I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons, who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete (Minn. R. 7001.0070). I also certifY under penalty of law that I have read, understood, and accepted all terms and conditions of the National Pollutant Discharge Elimination System (NPDES) General Storm Water Permit for MS4s that . authorizes storm water discharges identified in this application form. I understand that as a permittee, I am legally accountable under the Clean Water Act to ensure compliance with the terms and conditions of the NPDES General Storm Water Permit for MS4s. I also understand that MPCA enforcement actions (pursuant to Minn. Stat. SI15.07, 116.072, and Section 309 of the Clean Water Act) may be taken against me or the MS4 if the terms and conditions ofthe NPDES General Storm Water Penllit for MS4s are not met. Authorized Signature Date Stadler Steve Public Works Director Title Last Name First Name Official notices will be scnt tn person indicated here. 1010 First Street South Mailing Address Hnpkinc: City MN State S'i14'=l Zip Code Telephone (include area code) . E-Mail Address MPCA MS4 Storm Water Pennit Application 6of6 02/06/03 Attachment 1 SWPPP Summary Sheet . Develop a unique identification number for each BMP Description Sheet (Attachment 2) completed. List the unique identification number for each BMP under the following seven areas. A. Public Education and Outreach Measures BMP unique identification numbers: B. Public Participation and Involvement Measures BMP unique identification numbers: C. Illicit Discharge Detection and Elimination Measures BMP unique identification numbers: D. Construction Site Storm Water Runoff Control Measures BMP unique identification numbers: E. Post-Construction Storm Water Management Measures BMP unique identification numbers: F. Pollution Prevention and Good Housekeeping Measures BMP llilique identification numbers: G. Other portion of the permit (such as Record Keeping or Appendix C). . Portion of the permit that the BMPs addresses. BMP unique identification numbers. . MPCA MS4 Slorm Water Permit Application 70f7 02/06/03 Use the BMP Description template and "save as" feature in MSWord to complete this page for each BMP. Alternate fonnats are acceptable as long as all the requested infonnation is rovided. .A. Unique Identification Number: , (Assign a number.) B. Name or type ofBMP: C. BMP description: D. Minimum control measure addressed: Public Education and Outreach E. Describe the measurable goals that will be used to determine success or benefits of this BMP: F. Describe the timeline or implementation schedule for this BMP: G. Person or department in charge of implementing this BMP: Last Name First Name Department H. If this BMP is an educational component of your SWPPP, briefly describe the audience and educational . goals for this minimum control measure: . MPCA MS4 Storm Water Permit Application 80[8 02/06/03 . Phase II Storm Water Program League of Mj""esota Cities CUju promoti"g ....""/10""" Phase II Bulletin - February 17, 2003 Issue # 7 If you are with a "Designated MS4", a city outside any of the Urbanized Areas, please see the message at the end of this newsletter for a program schedule. Countdown to Completion - 4th Edition - Deadline Extension This is the fourth in a series of newsletters prepared at the direction of the LMC Guide Plan Steering Committee. These newsletters are intended to guide you through the specific and detailed steps to get your Permit application prepared. We are depmiing from this to convey and discuss a major piece of news in the Minnesota NPDES Phase II world. 1iIiII'Ifoo1e. \ "'''r~~ ~ 'Ifoo1~lSI e: \-......~Q\.I..o:'lI"2l..o:'l1 ...~'Ifoo\@\ AI~,gIAII'lI_I~ *~~'-'!I -.!!.~"!!;I!!.!3' ~~~g-~~ "!!;I!!.~~ ~~~~!!.!.~~~ I!:!,.,!!;I!!.~ ~91~~~';;',!l;!.91 .!!.v.r!!a- S_l'll'll hl:mr.l! ii"'~"'~"I.I_~ "'~'Ifool ~\ ~'I''{'''''Ji'~~~''f1 ~~.g,=:.l==a~-~~~!;~ -la~~~ @. YJllI ~~g;;.!D~ . On Wednesday, 2/12/03, we received an E-mail from the MPCA with the following message and instructions to distribute it: While the MS4 application is due to the MPCA on March 10, 2003, the MPCA also recognizes that, in some communities, it will be difficult or impossible in the time that remains to complete (1) the MPCA's application and SWPPP summary, and then (2) the community's own established internal procedures for review, approval and sign- off. The MPCA will allow communities who find themselves in this situation to submit a near-final application by March 10, but to take up to an additional 60 days (until May 9, 2003) to provide the final, fully signed application containing the final SWPPP summary, Under this procedure, the application provided by March 10 should be complete with the exception of those portions of the SWPPP summary that require further approval by the City Councilor manager, the County Board or administrator, etc. The application must be accompanied by a letter to the MPCA confirming that you intend to provide the final application, including the final SWPPP summary, by the 60-day deadline, What does this mean? Your NPDES Phase II Permit Application will have two parts: . the Application Form, and . the SWPPP and/or S WPPP summary. . The MPCA is authorizing separate deadlines for these documents. I f you decide not to submit your SWPPP on March 10, you would submit only a filled-in Application Form on that date. You would have an additional 60 days (May 9) to complete your SWPPP. League of Minnesota Cities. 145 University Avenue West. St. Paul, MN 55103-2044 . (651) 281-1200 . (800) 925-1122 . www.lmnc,org Copyright (iJ 2002 2003 League of Minnesota Cities. All rights reserved. Not for reproduction or distribution. . . . 2 When your SWPPP is finalized, you would submit a revised Application Form and your SWPPP and/or SWPPP summary. The statement instructs MS4s to submit "a near-final application by March 10". Please note that we strongly recommend against submitting draft or incomplete materials to the MPCA. If your City Council is going to review and approve your SWPP and Permit Application, we strongly recommend against submitting these draft materials before the Council has reviewed and acted on them. We believe that MS4 can meet the conditions of this statement by submitting only the Application Form filled out to indicate that the SWPPP is not complete. What should the incomplete submittal on March 10 look like? We are working on this question. The legal staff at the LMC will consider some of legal questions related to this. We will provide recommendations about how the Application Form should be filled out. We will also provide a sample letter that will be appropriate. The Application Form recently distributed by the MPCA includes the following section: A. Have you developed a Storm Water Pollution Prevention Program for DVesDNo your MS4? Municipalities must demonstrate how their Storm Water Pot/lltioll PrevellUoll Program wil! be implemented and enforced OWl' the term of the jive-year permit. SWPPPs mllst incorpurate appropriate educatiolw/ components, BMPs amI measurable goafs. Provide a brief description of the plan to complete the SWPPP if "No" is marked above. We expect that you would simply mark the check box labeled "No" and include a brief letter describing your plan to complete and submit your SWPPP before the extended deadline of May 9, 2003. What do you recommend that we do now? We recommend that you not rush to complete your Permit Application. If you were on schedule to be done by March 10 and are comfortable with your process, you may want to continue ahead as planned. If you were rushing to get it done and approved by March 10, you may want to slow down a bit and move ahead with more deliberation. Now you have the time to take it to your Council and make any appropriate revisions. Now you have the time to compare your BMPs and final SWPPP with SWPPPs from other cities. Consider the pros and cons listed below. Pros & Cons Submitting a complcte Permit Application on March 10, 2003 - Application Form & SWPPP and/or SWPPP summary Pros . You will be done with it! . You will meet the letter of the Federal rule League of Minnesota Cities. 145 University Avenue West. 51. Paul, MN 55103-2044. (651) 281-1200 · (800) 925-1122 · www.lmnc.org Copyright If) 2002-2003 League of Minnesota Cities. All rights reserved. Not for reproduction or distribution. 3 . Cons . You will not have a chance to see many other S WPPPs before you submit yours . Your Application will have a greater chance of being read by the MPCA and other groups. When you submit your Application, there may not be a great many other submittals and the agency and groups will have additional time. Being "on the point" is not always a good idea with this sort of regulation. . We still have not seen the final version of the Guidance Manual for this Permit. You will have less time to make any adjustments that may be appropriate after you have read through the Guidance Manual. Submitting only the Application Form on March 10 and submitting the complete Permit Application later, but before May 9, 2003 . Pros . You will not have to rush the preparation of your SWPPP. You will have the time to: o have meaningful review and comment from your Council and/or other review bodies o . review and compare other cities' SWPPP to get a bettcr "feel" for where your SWPPP stands - discuss it with your peers o proceed in a deliberativc manner that allows for appropriate involvement and review by various departments within your city o make any adjustments that may be appropriate after you read through the Guidance Manual. . Your Permit Application would not "stand auf' because of being submitted early. . This Permit process has been quite fluid. By submitting your Permit Application later, you will have a chance to see how things "settle auf' before finalizing your submittal. . You would not have to complete your Permit Application under pressure. A more deliberative process could result in a better Application. Cons . There is a very small chance that some party could step forward and file a lawsuit claiming that you had not met the requirements of the Federal rule. . This would hang over your head for a bit longer. There would be less pressure, but it would still be there. Do you have any other pros and cons to suggest? Please send them to us at phaseii({l)lmnc.org and we will include them in the next newsletter. The story behind this extension The story behind this extension is instructive. Without the Guide Plan project, it is possible that this extension would not have happened. The LMC Guide Plan project organized a demonstration of a software program on January 23rd. The presenter from the software company has been marketing his product in many states throughout the country. [n the course of his presentation, he mentioned that some states have set different submittal dates for their Application Forms and their SWPPPs. Barb Huberty (City of Rochester) picked up on this comment and raised it in discussion immediately after the presentation. . League of Minnesota Cities. 145 University Avenue West. St. Paul, MN 55103-2044 . (651) 281.1200 · (800) 925-1122 · www,lmnc.org Copyright iD 2002-2003 League of Minnesota Cities. All rights reserved. Not for reproduction or distribution. . 4 Based on Barb's comments, I contacted the MPC ^ staff to ask them to consider this idea. Within a couple days, I received an E-mail from the MPCA indicating that the idea had received a positive response in preliminary discussions. To support the idea, I contacted the Permit writer for the State of Connecticut and got some of the details 011 how they had set up their submittal schedule. I passed that information and the contact details to the MPCA staff. On 2/11, the MPCA distributed a draft of this message. I commented on this draft immediately. The revised language you see above was distributed on 2/12. News & Other Items Documents From the MPCA The MPCA distributed documents, including the Application Form for the MS4 Permit, late last week. Here are hyperlinks to the Application Form in Word temple (.dac file) and Adobe Acrobat (.pdf file) formats: MS4application.doc MS4Application. pdf We still await the Guidance Manual. Next Week's Newsletter Measurable Goals . Please post your questions to the Web site Please E-mail your questions to phascii({v.lmnc.org and we will post the questions and answers as soon as we can. Designated MS4s We have been hearing from several cities that are outside of any of the Urbanized Areas recently. These cities may fall into the category of Designated MS4s. Here is what the MPC A has to say about these cities on their Web site: Designated MS4s Designated MS4s include any small MS4 that is physically interconnected to a regulated MS4 and substantially contributes pollutant loadings to the system, The designation criteria apply to any MS4 with a population density of at least 1,000 people per square mile and a population of at least 10,000. Additional designation criteria will be based on potential significant water quality impacts of storm water discharges. . The most recent list of cities to be evaluated under this program includes: Albert Lea Austin Bemidji Big Lake Big Lake Township Brainerd Buffalo Cloquet Faribault League of Minnesota Cities. 145 University Avenue West. St. Paul, MN 55103-2044. (651) 281-1200 . (800) 925-1122 . www.lmnc.org Copyright @ 2002-2003 League of Minnesota Cities. All rights reserved. Not for reproduction or distribution. . . . 5 Fairmont Fergus Falls Forest Lake Hastings Hibbing Huthcinson Mankato Marshall Monticello New VIm North Mankato N orthfield Owatonna Red Wing St. Michael Stillwater Willmar Winona Worthington The list of cities regulated under this program may include other municipalities. The list above is not intended to be complete at this time. The schedule for the Designated Cities was discussed with representatives from the MPCA at the last LMC Guide Plan Steering Committee meeting. Here is what we were told. The MPCA is obliged, under the Federal rule, to develop and apply selection criteria to determine which cities that are outside the Urbanized Areas will be regulated under the NPDES Phase II MS4 General Permit during this pennit cycle. The MPCA told us that they hope to have the criteria developed and the selection determined by May 2003. They said that the summer may be more realistic. We were fmiher told that, after the Designated MS4s are informed that they are to be regulated, they will have from 12 to 18 months to complete and submit their Permit Applications, including their SWPPPs. According to this proposed schedule, the earliest that a Designated City would need to complete and submit their Permit Application would be May 2004. A later date may be more realistic. Please breathe easier. You have some time. League of Minnesota Cities. 145 University Avenue West. St. Paul, MN 55103-2044 . (651) 281-1200 . (800) 925-1122 . www.lmnc.org Copyright (0 2002-2003 League of Minnesota Cities. All rights reserved. Not for reproduction or distribution.