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FL-11. Regulation of Incinerator Emissions (cont <br />understood that proposals would expand the list to include as many as <br />26 new chemicals and metals. Application of required new technology <br />to existing as well as new facilities would also be a serious matter <br />of local concern for costs and benefit to the environment. Phasing <br />in of such requirements for currently operating facilities would be <br />an essential modification of those requirements. <br />it is encouraging to observe that proposals being considered do <br />include an updated timetable for EPA action in the regulation of <br />such air emissions. Cities anticipating construction and operation of <br />such new facilities need timely and accurate infornation with regard <br />to regulatory action in, order to design operations to meet those <br />requirements. <br />Other concerns which the League is monitoring deal with the disposal <br />of incinerator ash by-products. Questions of potential liability for <br />cities under Supertund for clean-up of improper disposal practices <br />must be clarified and guidance provided to assist cities in planning <br />disposal methods. <br />FL.-12. Stormwater Permits <br />Because of indications gat : 'ditional cities in urbanized areas may be <br />required to comply with the a program regulating storm sewer <br />discharges, the League urges the EPA to reflect sufficiently on local <br />circumstances in providing direction to state and local officials in <br />adjusting permitting requirements to fit local and regional stormwater <br />management planning priorities and to provide a framework within which <br />to address jurisdictional and legal issues surrounding control of <br />nonstormwater run-off in those locations. <br />According to draft regulations, all municipalities in designated urban <br />areas would be required to apply for stormwater permits by <br />December 31, 1987, for all industrial stormwater discharges and for <br />stormwater run-off that discharges into the waters of the U.S. It <br />would appear that such requirements would apply to systems serving <br />populations between 100,000-250,000 in such census -designated <br />urbanized areas, potentially increasing the number of affected cities <br />in Minnesota. <br />Direct consultation with state and local officials in both the <br />• developmei.t of EPA stormwater management policy, as well as in the <br />-75- <br />