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EPA estimates that there are more than one million separate storm water <br />discharge points within the country's 366 major urban areas. EPA has <br />given municipal agencies two years to complete a complex and expensive <br />permit application for each dcher .a point which Includes detailed <br />sampling and laboratory test proce isuses <br />The cost of merely completing the applications easily could exceed $8.5 <br />•1 . tra.� the Federal Government 1 n• ♦e <br />Yllilui,j vi � vuuvi, ,Tivrr. ed_rs. p_a.._ <br />contribute to water pollution treatment facilities construction over the <br />next three years. The enormity of the problem for cities across the <br />nation strains credibility. Kansas City, Missouri's, waste treatment <br />system requires just 12 permits, and annual monitoring costs $160,000. <br />The city estimates it will need to apply for 20,000 storm water <br />permits, at a cost of more than $90 miilionl <br />The cost impact will vary for each of' Minnesota's cities, depending on <br />how many identifiable storm sewer discharge points there are in the <br />community. The Minnesota Pollution Control Agency wou:d issue the <br />permits. There is the possibility of issuing one or several permits to <br />cover all the cities in the state, as well as modifying the proposal to <br />mitigate the consequences of requiring permits but no League staff <br />member is confident thut the EPA r•:;ulations can be written to ensure <br />that Minnesota's cities will not be faced with another expansive federal <br />regulatory system. <br />Cities should also know that the issuance of .reguiatory permits is tilt <br />first step to requiring "best management practices" or treatment of <br />storm water discharges to eliminate any possible pollution. Cities <br />contemplating separation of their storm and sanitary sewer systems may <br />want to ask their Congressmen whether the systems should be separ"ted or <br />whether the city should seek federal funds to increase their treatmert <br />facility so that all storm water can be treatei. <br />I know it is difficult to take such an absurd proposal sFriously. Ma m <br />potentially affected parties whom I have talked to have thought the <br />Proposal totally insane and were amused to think that Congress might <br />actually do something so damaging to the gcali of the Clean Water Act. <br />I am afraid, however, that unless city officials speak up, and loudly, <br />that there is a very real possibility that Congress will allow the <br />permitting to begin. <br />It seems clear to League staff that the best solution to this Froblei is <br />to admit that the proposal to permit, regulate, monitor and/or treat <br />storm sewer discharges is not feasible at this time. The costs and <br />difficulties of applying the permit proQess to intermittent storm water <br />discharges are only now coming into focus. Congress must be requested <br />to act to ensure that the letter of th! Clean Water Act does not <br />overwhelm the spirit of the law -- to clean up the waters of the United <br />States effectively, efficiently and in a manner which addresses the <br />highest priority pollution control needs first. <br />