Construction Unresolved Issue: #1 Legal Authority Controversial issue: Definition of rainy season A.) October 1 – April 30, may be extended by written notice of Water Board B.) Period between October 15 to April 15th

Construction Unresolved Issue: #2 Enforcement Response Plan (ERP) Controversial issue: Level of response required by ERP A.) Require ERPs that specify a minimum list of enforcement actions and scheme for escalation of enforcement B.) Allow “Progressive Enforcement Options” to be guidance only

Construction Unresolved Issue: #3 Minimum Required Management Practices Controversial issue: Required of all Construction Sites or Voluntary A.) Specify minimum required management practices that permittees must require of all sites B.) Permittees will voluntarily include the practices in construction field manuals

Construction Unresolved Issue: #4 Plan Check Controversial issue: Level of Review conducted by Plan Checkers A.) Specify that plan checkers review with developers the Minimum Required Management Practices and ensure that their Erosion Control Plans address each required practice B.) Require the submittal of effective erosion control plans

Construction Unresolved Issue: #5 Frequency of Inspections Controversial issue: A.) Require inspections to be done at a specified frequency depending on site size B.) Set minimum guidelines for inspection frequency

Construction Unresolved Issue: #6 Tracking/Self Evaluation and Reporting Requirements Controversial issues: A.) Copy of relevant ordinances within one year or 18 months of permit adoption B.) Provide Water Board with a copy of entire database used to track inspections and enforcement actions as part of the annual report or only provide summary data C.) Provide schematic diagram and brief description of all departments who participate in construction stormwater oversight with first annual report and update annually or provide departmental level information and update in annual report as needed