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Erosion and Sediment Control

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Background
The National Pollutant Discharge Elimination System (NPDES) Phase II requirements issued by the United States Environmental Protection Agency seek to implement a program to protect the quality of surface waters (such as lakes and streams) by controlling pollution from storm water discharges. What this means for the City of Bloomington, and most other cities, is enhanced storm water sewer system maintenance, and the implementation of new storm water management activities.

These activities include public education programs, public participation in storm water management functions, controls on storm water runoff from new developments both during and after construction, an ongoing search for illicit discharges into the storm sewer system, and municipal pollution prevention programs such as increased frequency of street sweeping.

All parcels, regardless of their location in a watershed, have an impact on our water resources. Pervious surfaces, such as lawns, allow rain to seep into the ground. Impervious surfaces, such as roofs and parking lots, block this absorption, which increases runoff volumes. The City of Bloomington's storm water management system collects the runoff through a series of gutters, inlets, storm sewers, detention basins, and stream channels. In the older section of the City, the existing sewer systems are mostly "combined" sewers. A combined sewer conveys both domestic sewage and storm water runoff in the same pipe.

Why is an Erosion and Sediment Control Ordinance Needed?
In the past, storm sewer system planning focused on flood control, utilizing sound practices of sewer system sizing, flood routing, and storm water detention. The growing pressures of urbanization and increased federal regulation have dictated that modern storm water system management must take a total water resources management point of view, considering not only the volume of storm runoff, but also pollution prevention.

Most people think storm water runoff is a relatively harmless, natural occurrence, and do not realize it has the potential to pollute one of our most precious natural resources, our lakes and streams. Storm water frequently has high levels of sediment, litter, phosphorus, nitrogen, heavy metals, oil, grease, and organic materials. Soil erosion annual deposits approximately 4 tons of sediment/silt into our creeks, streams, rivers and lakes in Illinois. It also compromises the effectiveness of our storm sewer system.

The City of Bloomington has chosen to take a socially responsible, proactive approach to systematically manage the storm water discharged by our community. By managing runoff and preventing the pollutants from entering the environment, we are striving to avoid the potentially high costs of flooding, future treatment and increased federal regulation.

The United States Environmental Protection Agency has set forth specific requirements regarding Construction Site Run-off Control and Post Construction Storm Water Management in New Development and Redevelopment. The U. S. EPA has issued permitting authority to the Illinois Environmental Protection Agency thereby tasking them with ensuring all communities required to comply with the Clean Water Act Phase II requirements do so. The following requirements can be found in the December 8, 1999 Federal Register, on pages 68758 and 68759 or in any ILR10 form issued by the Illinois Environmental Protection Agency:

Construction Site Runoff Control
The City must:
  1. develop, implement, and enforce a program to reduce pollutants in any storm water runoff to your small MS4 from construction activities that result in a land disturbance of greater than or equal to one acre. Reduction of storm water discharges from construction activity disturbing less than one acre must be included in your program if that construction activity is part of a larger common plan of development or sale that would disturb one acre or more or has been designated by the permitting authority.
The City's program must include the following:
  • An ordinance or other regulatory mechanism to require erosion and sediment controls, as well as sanctions to ensure compliance, to the extent allowable under state or local law;
  • Requirements for construction site operators to implement appropriate erosion and sediment control best management practices;
  • Requirements for construction site operators to control waste such as discarded building materials, concrete truck washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impacts to water quality;
  • Require all regulated construction sites to have a storm water pollution prevention plan that meets the requirements of Part IV of NPDES permit No. ILR10 including management practices, controls and other provisions at least as protective as the requirements contained in the Illinois Urban Manual, 2002.
  • Procedures for site plan review which incorporate consideration of potential water quality impacts and review of individual pre-construction site plans to ensure consistency with local sediment and erosion control requirements;
  • Procedures for receipt and consideration of information submitted by the public;
  • Procedures for site inspections and enforcement of control measures.
Post-construction Storm Water Management in new development and redevelopment
The City must:
  1. develop, implement, and enforce a program to address storm water runoff from new development and redevelopment projects that disturb greater than or equal to one acre, including projects less than one acre that are part of a larger common plan of development or sale or that have been designated to protect water quality, that discharge into your small MS4. Your program must ensure that controls are in place that would protect water quality and reduce the discharge of pollutants to the maximum extent practicable;
  2. develop and implement strategies which include a combination of structural and/or nonstructural BMP's appropriate for your community that will reduce the discharge of pollutants to the maximum extent practicable;
  3. use an ordinance or other regulatory mechanism to address post-construction runoff from new development and redevelopment projects to the extent allowable under state or local law;
  4. require all regulated construction sites to have post-construction management that meets or exceeds the requirements of Section IV (D)(2)(b) of NPDES permit No. ILR10 including management practices, controls, and other provisions at least as protective as the requirements contained in the Illinois Urban Manual, 2002.
  5. ensure adequate long-term operation and maintenance of Best Management Practices (BMP's); AND
  6. define appropriate BMPs for this minimum control measure and measurable goals for each BMP. These measurable goals must ensure the reduction of all of the pollutants of concern in your storm water discharges to the maximum extent practicable.
The City of Bloomington City Council passed amendments to the existing Chapter 24 of the Bloomington City Code on July 25, 2005. The amendments created new regulations regarding Erosion and Sediment Control and amended some existing ordinance language. The amended Ordinance became effective for enforcement on August 8, 2005. Chapter 24 of the Bloomington City Code can be viewed here.

Please visit the United States Environmental Protection Agency's
National Pollutant Discharge Elimination System (NPDES) website at:

 
To report a storm water, sanitary sewer, or water issue, call 309-434-2225 during regular office hours. For emergency issues (i.e. backup, illicit discharge, unreported water main break) after hours, call 309-820-8888.

Questions or Comments?
We consider our customers to be a vital part of our organization. It is only through your feedback that we may determine if we are meeting the needs of our residents. Please contact us with any questions or comments you may have regarding this program.

If you have any questions regarding the City’s Storm Water Management Utility, the Bloomington Storm Water Credit Manual or other activities of the Public Works Department, contact us at:

City of Bloomington
Public Works Department
115 E. Washington St.
PO BOX 3157
Bloomington, IL 61702-3157
(309) 434-2225

 

  • Erosion and Sediment Control Background Information

    • What is the intent of Phase II of the Clean Water Act?

    • The City of Bloomington is under home-rule. Why do we have to comply with the requirements of the Clean Water Act?

    • When will the City implement the new Ordinance?

    • Specifically, how will the City deal with lots that have not been started within existing subdivisions?

    • Is the City willing to enforce the old codes for current subdivisions and the new ordinance for additions to any existing subdivision or any new subdivisions that start after the ordinance is passed?

    • Are there any more requirements similar to the Erosion and Sediment Control Ordinance planned for the near future?

    • What is meant by best management practices (bmps)?

    • What procedures are currently used by the City to locate field tiles in new subdivisions?

    • Why not use Utility Accounts to send informational flyers to new homeowners regarding City requirements?

    • What exactly is meant by "relevant State and Federal permits" as stated in Chapter 24, Section 6.3.7?

    • Are Environmental Groups allowed to file an appeal using section Chapter 24, Section 6.3.9?

    • Who helps fill in when the Erosion Control Inspector gets overloaded or is out sick?

    • Will the City consider creating an Adhoc Committee of 7 people consisting of members of local builders, excavators, developers, engineers, environmental groups and City Staff to help address the issues associated with this and future ordinances?

    • Will the City provide assistance in resolving parking issues in subdivisions under construction?

    • What provisions will the City have in place to abate properties not in compliance with the new ordinance?

    • What criteria will the City use for conducting inspections?

    • What criteria will the City use for handling complaints regarding Erosion and Sediment Control measures?

    • Is the Illinois Urban Manual available online?

  • Erosion and Sediment Control Forms

    • Where can I find a sample log sheet for weekly inspections?

    • Where can I find a blank Incidence of Non-compliance form?

    • Where can I obtain a blank copy of a Notice of Termination form?

    • Where can I obtain a blank copy of a Notice of Intent to start construction?

  • Erosion and Sediment Control Measures

    • What are the minimum Erosion and Sediment Control measures that can be installed on a lot within Bloomington and still be deemed in compliance with the new ordinance?

    • What are the additional costs associated with installing the erosion and sediment control measures associated with the new Erosion and Sediment Control Ordinance?

    • Why does the City use Percent Grades instead of Velocities when determining types of erosion control materials to be used on a lot?

    • A common engineering practice involves the use of detention Basins as sediment traps when the area around the detention basin inlet is over dug. Will the City continue to allow this practice to be used?

    • When can a curb cut be made?

    • What are the distance requirements, from the curb, for installing erosion and sediment control measures in front yard areas?

    • Will the City allow silt fencing to be "knifed" in?

    • What recommendations is the City willing to provide in instances where the silt fencing must be installed near an existing regular fence?

    • How many days will the City allow the silt fencing to be down PRIOR to the installation of sod on a lot?

    • How long can the silt fencing be left down to allow the dirt to dry for final grading of a job site?

    • How does the City propose silt fencing or other erosion and sediment control measures to be installed during the winter?

    • What erosion and sediment control measures are recommended for use during the Winter season?

    • What are the requirements for temporary seeding on a residential development?

    • At what point in time will the City require permanent seeding to occur?

    • Does the City realize the amount of time involved in installing a lawn irrigation system?

    • If a home under construction has a finished shell, but no mechanicals, will the new Ordinance proposed by the City require permanent seeding to be installed?

    • Proposed changes to the Manual of Practice require soil storage piles containing more than 10 cubic yards of material to be located with a minimum downslope drainage length of 25 feet to a roadway or drainage channel. Can this be reduced to 3 feet?

    • What are the requirements for concrete/cement washout areas?'

    • Will the City change the process for erosion and sediment control measures to the following?

    • Other municipalities specify where to install the erosion sediment control measures. Is the City of Bloomington willing to do the same?

    • How much slope is required before erosion and sediment control measures are required?

    • Does the City realize that most dirt gets hauled out through the backyard via adjacent streets? If so how does the City propose the developer get this done when this ordinance goes into effect?

    • Will the City allow landscape architects to design erosion and sediment control measures?

    • Is the City going to require the erosion and sediment control measures to be installed immediately prior to performing any grading or excavating activities?

    • Will the City allow the stabilized construction entrance to be installed after the foundation is back filled?

    • Will the City consider having anyone subject to the provisions of this proposed Ordinance provide the City with a Storm Water Pollution Prevention Plan prior to issuing any permits for work on the property in question?

    • Will the City consider having builders maintain log books for each lot under construction, which would parallel the current requirement for log books for the entire subdivision?

    • What is a "Storm Water Pollution Prevention Plan?"

    • Where can I find information about developing a Storm Water Pollution Prevention Plan?

    • What are the requirements for temporary seeding?

    • What are the requirements for permanent seeding?

  • Erosion and Sediment Control Street Cleaning

    • Why should the builders/developers be expected to pay for this? Why is the City not willing to provide street sweeping free of charge to builders/developers as the City ultimately benefits from the increased tax moneys generated from the new homes?

    • What is the City's policy for street cleaning and why does it not apply to subdivisions under development?'

    • Is the City allowed to legally fine a delivery company for getting mud on the streets?'

    • Does the proposed ordinance allow the owner of a property to be fined for mud on the streets?'

    • The proposed ordinance requires street cleaning at the end of each work day. Will the City allow the developers or builders to clean the streets once a week or when they deem it necessary to clean the streets?'

    • Should the developer be responsible for mud in the streets or will the individual contractors be held responsible for the mud they get in the streets?'