Reso 2001-391 - Laserfiche WebLink

Home Browse Search

NOVA CONSULTING, INC. Mr, Christopher J. Russo October 8, 2001 intent for requesting a conceptual approval for phased projects is to assure that the SFWMD's review of individual phases will be consistent from start to finish and that later reviews will not invalidate previous or future phases. Therefore, a conceptual approval will assure the applicant that significant modification of the proposed system will not result from a phased permitting approach. Upon approval of the conceptual permit, applications for construction can be processed more cost effectively and expeditiously. Given that the stormwater management system proposed is composed of a 1) conveyance system (catch basins, manholes, and piping), 2) pump station (trash rack, wet well, pumps, controVvalve box, and control panel), and 3) discharge system (drainage manifold and drainage wells), and the entire project is likely to be constructed in phases (with each phase requiring independent permitting), obtaining a conceptual permit is more appropriate. An added benefit of obtaining a conceptual ERP prior to construction is that the project can be released for bidding, in its entirety or in phases, and with confidence that the process of obtaining individual construction permits (for individual phases) will not result in substantial changes imposed by the reviewing agency (Le., SFWMD). These changes could result in substantial change orders due to scope changes and/or delays. In other words, the conceptual ERP will serve as the umbrella permit under which all construction ERPs will be obtained. Construction and operation ERPs, obtained after conceptual approval, can be further classified as general or individual based on numerous criteria. Generally, small projects (less than 40 acres) are issued general ERPs while large projects (greater than 40 acres) are issued individual ERPs.ln addition, the FDEP currently administers and regulates stormwater pollution prevention for construction under the NPDES program. Formerly, this was the responsibility of the EPA. Compliance with NPDES requires the preparation of Storm Water Pollution Prevention Plans (SWPPPs) for all phases of construction. The SWPPP preparation, submittal (to FDEP), and review (by FDEP) are directly influenced by the ERP process. For projects requiring ERPs, the preparation of a SWPPP is simple and the plan is not submitted for review but used by the City and contractor(s) as a guide for compliance with NPDES. For projects not requiring an ERP, SWPPPs must be prepared for all phases of construction and submitted to the FDEP for review and approval. This submittal and review process is repeated for each phase of ) construction and may result in added costs and project delays. Under the proposed approach, where a conceptual ERP will be prepared and approved prior to construction, submittal of SWPPPs to FDEP will not be required. The most critical criteria to be addressed in an ERP are the water quality and water quantity criteria for pre-development and post-development conditions. Pre-development refers to existing conditions while post-development refers to conditions following implementation of the proposed stormwater improvements. Addressing these criteria requires extensive modeling and documentation of the existing and proposed conditions. A summary of essential items that must be addressed are listed in Appendix 1 of the Surface Water Management rules contained in Chapter 40 E-4. A copy of Appendix 1 is included as Attachment 1. Under Task 2.0, NOVA will prepare a conceptual ERP for submittal to the SFWMD. This will include attending meetings with the City and the SFWMD (pre-notice conference) as well as coordination with the SFWMD during the review process. Items listed in Appendix 1, Chapter 40 E-4, and criteria defined in the "Basis of Review for Surface Water Management Permit Applications within the SFWMD" will be addressed. Where possible, work completed by the Department of Environmental Resources Management (DERM) and by NOVA, under the direction of (DERM), will be utilized to reduce the cost and time to complete the ERP and facilitate the review process. Specifically, pre-development and post- development modeling completed by DERM and NOVA, respectively, will be reviewed and recompiled Page 3 of 4 J:110200\ 10201\P\ 1 020 lPOO2,doc 70108101