Podcast

Upcoming Changes to the Ohio Small MS4 General Permit – What You Need to Know
03/26/2021
Podcast Transcript

Announcer: Welcome to CEC Explains, your deep dive into fascinating subjects from the worlds of engineering and the environment, brought to you by Civil and Environmental Consultants. And now from our CEC studios around the nation, this is CEC Explains.

Tim: Hello, my name is Tim Murphy and I’m a principal with CEC in the Toledo Ohio office. I also serve as the national leader of our Public Sector market group. Prior to joining CEC, I spent about 18 years working in the public sector for the city of Toledo. I served in several positions with the city, including providing oversight to the stormwater management program. So, I have firsthand experience with some of the things we’re going to talk about today. And today we’re focused on the municipal stormwater, separate storm sewer system permit changes in Ohio.

Today I have with me, John Matthews, who is the manager of Stormwater Technical Assistance for the Ohio EPA. Prior to joining the Ohio EPA, John worked in a similar capacity for the Ohio Department of Natural Resources. Hi, John, welcome to the podcast. We really appreciate having you on.

John: Hi. It’s nice to be here, good to hear your voice.

Tim: Once again, thank you so much for participating in this. So, we have some changes coming to the small municipal separate storm sewer system permit in Ohio. And so today we just wanted to cover some of the changes or all of the changes that are occurring and to help communities get prepared and make sure that they are maintaining compliance with their permit. So why don’t we start off first talking a little bit about, you know, what you can expect from the, you know, with regards to the timeline of this permit. When do you, would you, when should communities expect to see the permit come out and, you know, be public noticed and then you know, where they are effective date? When should we expect to see that?

John: We had a little bit of an issue that we wanted to fix in our application system before we issue the permit, the application permit system is called Streams. And so that’s being updated right now. And what it means to the permit holders is that the group permits, the big entity that holds the group, has to renew their permit first. And then the co-permittees will come in and renew their permits as well. So, we just had to clarify a few issues within our coding of that system. So that should be done by April 2nd. And we hope to issue the permit by mid-April. Maybe sooner than that.

Tim: Maybe John if you could provide us with some background on the history of the small MS4 general permit in Ohio.

John: So, this permit has been around since 2002. It’s in its fourth edition, when we basically issue this permit. And what it does is it permits any municipality under the size of a hundred thousand people in their jurisdiction. If they own a storm system, usually it’s, if you own roadways, you probably own a storm system that goes under those roadways or collects the curbs and gutters along that system. Or maybe the road ditches as well. And so, this covers some 600 communities a little bit more than that. And then some of those communities grouped together and have one permit together. So, Hamilton County, for instance, I believe has over 30 communities under one permit. So, it ends up being a little over 200 permits when you count it that way. The permit, if you own a stormwater system, it has six minimum control measures that are required. The first two are really about how you deal with the public and how you offer information to the public about stormwater issues and problems. So, information and education, an opportunity for those community members to get involved in the decisionmaking process. That’s the second, a minimum control measure. There’s an illicit discharge minimum control measure. That really means anything that’s not rainwater becoming runoff and running into your separate storm system has to be treated as an illicit discharge, and basically prohibited and captured. And if we can’t do that, then we need to work out a way to deal with those issues as they come up. So, if someone’s dumping pollution in a storm system, then that’s a part of an ordinance. And it’s part of a city’s response to that problem. The fourth minimum control measure has to do with construction site runoff, and it really entails, you know, making sure that mud stays on construction sites and those sites are seated and stabilized before they end. There’s a fifth aspect that also deals with development. And it really has to do with the post construction land use, the after land use, what happens to the runoff there and what kind of facilities are left there? So, the stormwater ponds, things like that are really dealt with in that fifth measure. And the last measure has to do with publicly owned facilities. So, if you store salt, other materials around one of those facilities, you need to have a stormwater pollution prevention plan. And so, all those six minimum control measures are what this permit is about. And every time that permit gets renewed, we usually look for issues that have come up where people didn’t quite understand the requirements. And we make clarifications to the permit. We may look for common problems when it comes to enforcement or some issue that keeps coming up and we get a lot of complaints about, and we may deal with it in the next generation of the permit, just to clarify and make sure that people know what’s expected of them in their permit and holding it. Last thing is something that we’re trying to do in this update. And that is to make sure that we’re responsive to the, what’s called a TMDL, plan for watershed. So, every watershed may have issues that impair that water. They may have to do with drinking water or recreational use. You know, the Clean Water Act talks about waters being fishable and swimmable, and we deal with drinking water as well. So, there are many TMDL plans in Ohio and they have issues from bacteria to nutrients. They may be sediment related. They may be urban stormwater related. Well, if any of these are urban stormwater related, then this permit really comes into focus. Is there something that we need to do in this Municipal Separate Storm Sewer Storm System permit? So, is there anything they can do in their permit in order to respond to their watershed TMDL plan?

Tim: Awesome. Thank you, John. That is a great background and an overview of the permit itself. Before we dive into the specific changes that you were, you started to mention with the TMDL, is there a little bit, can you give me a little feeling and give everybody a little feeling on what are the overarching goals the Ohio EPA has with this? You know, the fourth generation of this permit?

John: Well, there are some clarifications that we’ve made. Because each community has their own constructions site program. They have a regulation, they have a follow-up that’s required, some inspection. And then an enforcement process. We’ve tried to clarify some of those issues. So, if you use a checklist, it could be as simple as a online program, or you could just have a paper checklist that conforms to what Ohio EPA requires in their permit. That’s kind of thing that we’re looking for, that people actually have an objective means of measuring what they see on construction sites. And so that’s required during construction. For post-construction, we’ve found a number of communities didn’t really have a plan to go out and revisit those facilities, those stormwater ponds that have been put out. So, they have to be inspected a minimum of one time during a permit term. That’s every five years. That’s not really a very high bar, but that’s where we set it this time around just to see what communities were doing. We basically looked and some people do this annually. Some people were doing it, not at all. So that’s really where we set it this permit term. There were other issues say on the good housekeeping side of things at your public facility that we tried to address in this permit. Some of these have been addressed before with salt piles. We’ve had a number of communities that have groundwater issues because of uncovered salt piles. And I think the understanding is out there that if you have a salt pile, it needs to be under cover, but we made some additions that not only does it need to be under cover, but if you have brine tanks, they need to have jersey barriers or bollards in front of it. So that a truck couldn’t back right into one of these tanks. And it’s a kind of a funny story. But years ago, one of our inspectors was at a public facility and lo and behold, a truck is backing up and he backs right into a salt tank. And the salt tank basically went straight down to the catch basin and right out. So, there’s some motivation for dealing with these kinds of issues.

Tim: And it really sounds to me like you, the Ohio EPA, wants communities to really kind of take ownership of their stormwater program, right? Yes, the permit is there, and we want to comply with the permit, but it’s just a concept of really taking ownership of this. And it’s, it’s a program, right? And they want, and you want this program to continue to evolve and improve over time.

John: You bring up a good point. I mean, this is, if you thought of the program that you would want to have, this is what we want this permit to basically be, this is the program that you should own locally, and we’re not trying to push it into the extreme idealistic program. We’re basically saying, what what’s a medium level or even a minimum level program that we want everyone to have. And so more ownership makes a better program. There’s a document that’s required. You need to have a stormwater management plan. People say, call this the swamp. We all want to get out of the swamp because who wants to be in a big plan for years and years. But the truth is that if you do a good job of creating your stormwater management program documents, you’re really going to have a great program and it’s going to work for you. It’s going to be responsive to the people who live in your community, and it’s going to be dealing with the pollution sources that are hitting your stormwater system. So that’s the goal.

Tim: Let’s look a little bit more specific at some of the changes that are now in the permit. And you touched on one right there that I think is one of the early kind of requirements that communities are going to have to do, where they’re going to have to put in place a stormwater management plan, right. And that plan is actually going to be submitted to you guys within, and it’s expected that they will, the communities will submit that within 180 days of the effective date of the permit. All right? So that’s a kind of a quick requirement that the communities should do now. Many of them probably already have stormwater management plans. It’s really just a matter of updating it to reflect the new permit and submitting it, but there may be communities out there that need, they need to do a little bit more with that piece. And so, can you talk a little bit about, you know, that first expectation for communities.

John: While I’m talking about it, I’ll get to relieve a few communities of a little burden because, because we’re going through COVID we understood that some of the timelines that we had in our draft permit were probably going to be difficult. And so, the 180 days has been changed to a year. So, if the permit’s renewed in April then we would expect that when they submit their first annual report, they’d also submit their updated stormwater management program document. So that’s, that’s kind of a relief. So, any changes as far as updated ordinances or new requirements that this permit has, should be incorporated into that plan or addressed in that plan. And just like any organization that has a plan for something you want to, you want to have smart goals about things. You want to describe it well. What are you trying to accomplish? Who’s going to do it? What’s your time schedule for doing it? Things like that. That’s really what a good stormwater program document talks about because some of these are actually relying on different communities. You know, one community may have the resources to do one aspect and they may have another agency do the stormwater inspection. And so, you really need to call those out and say who the contact folks are for that aspect of the program.

Tim: And so that’s, that’s great for communities that they have a little bit more time for that requirement. And that’s good. And I’m sure they appreciate that extra six months there. One of the things you mentioned there were ordinances. So something that these communities should consider probably doing in this first year process, I guess, the first year of the permit is to update their ordinances you know, to reflect the permit, whether it’s a construction general permit, or they really just need to update their ordinance to reflect if they don’t have one, they probably need to put one in place. And if they have one, maybe just it’s an update.

John: So, there are two permits that really need to be kept in mind. One is the state has a construction general permit that sets the minimum bar for erosion sediment controls, for stormwater controls. What the water quality volume is that first flush capture of runoff needs to be, as far as the volume and detention time for that. That sort of sets the standard for many of the aspects. And at least the minimums that would belong in these ordinances. You know, a community can go above and beyond that, but at least that sets a level ground for everyone. So, they have a year in order to update those ordinances. We proposed six months and then we kind of peeled it back, knowing that some of those things could be hard to do, especially now.

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Tim: So earlier you gave a nice overview of the six minimum control measures. And so, within the new permit, there is changes that are kind of specific to different minimum control measures, right? And so, I’d like to kind of go through those a little bit. And they’re tied, as I said to the minimum control measures, the first one I wanted to kind of talk a little bit about is the dry weather screening requirement that would fall under a minimal control measure number three. You want to talk a little bit about that?

John: So, every community, when they become a, a permit holder is required to screen all their outfalls. And if it has run off coming out of the end of that pipe, or has flow during a dry season, you know, there’s something going on there. It could be as simple as a spring, picking up a spring somewhere, and it’s got flow because the picks it off, up off the ground. And it’s not because of rainfall. So that’s explained away, but if somebody has an illicit discharge, that’s the concern that we’re really trying to aim at. Sometimes you have their garages that have their basement drain run into this. We’ve had bathrooms hooked up to the wrong drain and they come out to a storm sewer. Those are illicit discharges. And those are the kinds of problems that this is meant to address. So, once a community has gone through their whole system, all their outfalls, then the only thing that they’re required to do basically is have a strategy to do ongoing surveillance of their system. So, if, you know, you have more problems in one part of town, and maybe you revisit that part of town more frequently. We want that strategy to be in your plan. And so, we basically pulled back and said, communities know their issues better than we do. We’re not going to dictate this as much. And so, we’re going to basically give you a chance to put your strategy in there. And I think over time, we’ll sort of see how people are doing on surveilling their areas, or do we get a lot of complaints, but nobody actually is looking at these outfalls anymore once they’ve done it. So.

Tim: And, and really every community obviously is different so that, you know, some communities may not have that many outfalls and then you’ll have other communities that have a lot of outfalls. So they, you know, that program, it can be smaller or more robust really, depending on the community.

John: Right, I think there’s an implication that you should be relooking at the whole system over time. And maybe over a permit term. We want to leave it up to the permit holders to be proactive and to choose how to be strategic in how they do it.

Tim: Earlier, you mentioned also about storage of salt and maybe just good housekeeping on, you know, public sites, publicly owned facilities, right? And so, there are specific requirements for salt storage again. And as you mentioned, you know, protection of above ground tanks, I guess that has the brine in them. These would be considered more capital improvement-type requirements. So there’s a longer lead time on something like this, too. Right?

John: Right. We gave a minimum of two years to make any changes like that. There’s an aspect too, that I should bring up because if, if people were following along with the draft proposals, versus what we have now, there was a proposal basically to regulate private salt storage. And so, as we looked into that, as we look at the comments that we got in response to the draft permit, we think that the illicit ordinances and the agency’s own ability to regulate storm systems, give some control over that already. So, if you have an illicit discharge and you see someone who’s storing their salt incorrectly, basically no cover on it, and that runs to part of your system, you could use your illicit discharge ordinance basically to have a fining for that property. If you can’t get a response by asking for it.

Tim: And with the illicit discharge identification, there are notification requirements also, right? So that if a community does identify some sort of illicit discharge in a storm sewer system, they need to report that in a 24 hour period, is that correct?

John: Right now, this doesn’t cover all illicit discharges because we would be on the phone or sending emails day in, day in and day out. Because Ohio has significant home septic treatment system issues. And some of these are long-term and they wait for money to become available for someone to upgrade or fix their system. This really is about sanitary discharges. For instance, years ago, or a few years ago, we had a restaurant. They went in and the restaurant hookup went to the wrong drain. And as soon as somebody knew about it, you know, then we wanted to make sure that was kept, kept on their attention until it was fixed. That’s not the kind of thing we want to let go. So, this, there’s an email on the permit for each Ohio EPA district. And that’s a email that entities with individual permits already use to notify us of things. So, if you have a sanitary discharge, then we want to hear about it. If it doesn’t get dealt with, and we want to be able to basically call attention to it, bring maybe a little more pressure to fix that.

Tim: The items that we talked about; they all fall under the minimum control measure number three. And so, let’s move on and talk a little bit about changes that come into play maybe with a minimum control measure number four, and number five. And some of this, it goes back to a community’s program in general, right? So, the first item, we’ll talk a little bit about us, you know, how the community goes about documenting a plan reviews and inspections. Can you, can you talk a little bit about that?

John: One is, we found communities that really didn’t keep good notes on their inspections. And so, you might have a site that’s actually out of compliance. And if you’re visiting that same site, with the same issue over three or four times, without any enforcement being applied, we’re really saying we don’t do enforcement in this area. So, we want good documentation and of the correspondence that goes with plan reviews and site inspections. Basically, what are the problems that you found and how was it addressed? And when it’s, for instance, when it’s dealt with well, then people should get a notification basically saying, okay, thank you for taking care of that issue or, you know, that one’s dealt with and it’s not on the next inspection report. The implication also is that it’s not an implication in the permit, we’ve actually asked for communities to have an enforcement protocol, you know, how many strikes, and then you move up, up the chain to someone else. You know, when does the prosecuting attorney get sent a letter and say, you need to deal with this or else, or what, what’s the next step? Just clarify those steps and put that in your stormwater management documents.

Tim: So then we’ll move on a little bit more to minimum control measure number five. And this is something that I know of when I was overseeing the program, the city of Toledo, the post-construction component, and, you know, we’re requiring developers and other folks to do post construction BMPs, right, to implement them. But, you know, it was and is an ongoing struggle to kind of track them, inspect them, making sure they’re being maintained, all those kinds of things, you know, can you talk a little bit about the changes in the permit from that perspective?

John: And I guess I’ll distinguish between what would be best and ideal versus what we’re requiring as a minimum, because I think there’s still a big difference between those two things. The truth is that you want us, you put in a practice to perform a service that protects downstream resources, protects communities downstream from the pollution or the flooding, whatever that stormwater facility that pond is trying to do, and you want it to be maintained for those purposes. So, the permit basically requires that, you know, where those practices are, that you have them on a map. And so that, that was in the permit before, but people didn’t understand that. And we clarified that point. You need to put this on a map, know where they are. There were communities that didn’t know where their BMPs or their best management practices. So we had them, had it spelled out.

John: The other thing is that you actually inspect those sites, and this is a little difference between what a really healthy system does and what the minimum is. Healthy stormwater system, a manager will basically make sure that what was in the plans has been built. So that’s right after construction and making sure that there’s some inspection, maybe some as build that’s submitted to the community. There’s some confirmation that what was designed is what we have on the ground today. And then long-term, then we have an inspection process that just makes sure that that facility continues to function. So it’s not clogged with logs and debris, and it’s not flooding and backing up onto the neighbors’ properties or into yards, things like that. So we don’t, we have a regular, at least once every five years, hopefully annually, I think is probably a more appropriate measure that you’d go out and at least the drive by that says the outlets working well, the pond seems to be functioning well, we’ve looked at the, the checklist that was developed by the designer and it’s still functioning.

Tim: And it is very important to make sure those BMPs because they’re there for a reason. Right? And you know, you don’t want to create a volume issue downstream or water quality issue downstream. It’s, they they’ve been there and implemented for a reason. You mentioned you know, the, the requirement to map them. Yeah. It’s put them on some sort of maps, so we know where they’re at. Right. And I think communities today using GIS or the ability to use GIS is, is something that, you know, I, it’s become easier, I guess, to map some of these things and then maybe tying it together with an annual inspection or something along that with regards to getting it logged into a GIS type format is probably a good way to go.

John: I think you’re right. We didn’t specify that because we know that we’ve got everything from a small village to a big city, so, or a medium-size city.
Tim: Yeah, absolutely. It speaks to their, to their capabilities a little bit. Right?

John: Yes.

Tim: And available resources.

John: One question that people have is that, do I have to do those inspections? You know, it may be on private property. Maybe it’s owned by someone that’s willing and able to do the inspection. So, a homeowners association hires an entity to do their annual inspection or their once-every-five-year inspection. So, it doesn’t have to be done by the city as long as it’s done. And they, they know how to keep a record of that.

Tim: Yeah, as long as it’s done and documented.

John: Right, you got it.

Tim: Okay. Well, I think we’ve covered a lot of the changes, but I want to get one more and maybe this is we’re going to require a little bit more of a discussion is the, you mentioned earlier the inclusion of TMDLs into the program and making sure communities kind of understand what that means. You know, it was in, I think it was in past permits, correct?

John: It was there.

Tim: It was there, right now you’re kind of trying to evolve it, I guess, the next step. Correct? And so why don’t we talk a little bit about making sure people understand what one, you know, what the TMDLs may be for their community. And it can be different in every community, but you know, what, what it is, and then what exactly does this permit kind of require them to do with regards to TMDL?

John: So, there are numerous TMDLs across the state. You know, we’re probably more familiar with some of the things that hit the news, so we’re familiar with Western Lake Erie basin, the issues that Toledo had with their drinking water system and nutrients coming from the Maumee River basin. So that’s now a TMDL that Ohio EPA is putting together, you know, their study plan on and there’ll be working through that process. There are also within that big watershed, there are a number of smaller watersheds that have their own TMDL for different purposes. And so, they can range, like I said, from anything from sediment as a pollutant to nutrients, it could be something that might have to do with a past industrial use of a watershed, something like that, could be bacteria, home septic tree treatment systems or animal waste-caused issues. So the ones that are common for urban sources or urban stormwater would be total suspended solids, that would be basically sediment or siltation, nutrients, e-coli, that’d be a bacteria, or other bacteria issues, metals, you know, a lot of the things that run off in urban stormwater either have to do with air deposition or what basically wears off our cars, that would be a source of metals, dissolved oxygen, organic enrichment. Those are a little bit related with nutrients as well, or maybe the load of organics within that waterway pull the oxygen out. And so poorly treated sewage can be related to that. So those are the, that’s sort of the most common, that we see for urban stormwater related TMDLs. And what we tried to do was, it was in the past permits, that basically said, if you have a TMDL, you need to do make sure your plan incorporates changes accordingly, but it didn’t prescribe what to do. And so, in the absence of any ideas of what to do, many communities, weren’t doing very much about it. And you really can’t blame somebody, but do I know about this and how do I apply something to it? So, we tried to find action items that really applied to what you could do about it.

Tim: So, and those action items are kind of tied back to the minimum control measures. Right?

John: Right.

Tim: And so, I think, one, hopefully communities understand you know, what a TMDL is a total maximum daily load. And if there’s TMDLs applied to their receiving streams, their stormwater receiving streams, and now, you know, they understand that component at least, but now it’s about, you know, adjusting your program to put in place the necessary actions to address these, so you’re not contributing more to the receiving stream, whatever. When I say contributing more, contributing more of what is identified in the TMDL that we’re concerned about. If it’s blended solids or whatever it is, right? So that’s where, that’s how they need to be thinking a little bit.

John: Yeah. If there’s a source that’s related to urban storm water and we can address it, you know, if there’s a source that’s related to your stormwater system and what it collects, then hopefully there’s an action we can take. And so, we’ve tried to prescribe. And when I say prescribe, I, I don’t mean that we’re trying to capture every bit of water and treat it for every bit of that pollutant. I’m really prescribing an action that basically will hopefully lift the knowledge of it or the actions taken that can help to treat that.

Tim: Can you give us some examples of what you’re thinking about with regards to that?

John: We basically sliced and diced this up according to the minimum control measures. So, I said the first two were sort of public facing, you know, what information education are you going to put out there for people and how are you going to give them a chance to participate? So, the first way that we did this was asked you to target your messages based on those TMDL. So, if you have an issue about e-coli and you have some home septic treatment systems, maybe you would do some information related to maintenance of your home septic treatment system in your community. Many of, you mean the communities are primarily sewered, but many of them have edges that aren’t sewered. And those systems being maintained is well connected to the amount of e-coli in waterways. Another one would be targeting the part of the community that you think produces the pollutant identified in your TMDL.

John: If you think it’s construction and maybe you would aim some information and education towards construction. You would maybe do some training workshops for contractors. Maybe that would be a good idea if you want to target some information towards that group. Maybe it’s illicit discharges and sanitary disconnections, you know, are you sure your garage drain goes to the right source? We’re going to be doing smoke testing and here’s what’s coming. So, you put out some public information about what you’re doing. Just some examples on the first minimum control measure on the illicit discharge. That’s the third minimum control measure that’s focused on what doesn’t belong in runoff. We really are looking at doing some annual employee training, which includes illicit discharged detection and elimination. So basically, making sure the employees of the city or village or County know exactly what the best ways to look for those discharges are. And make sure that they get some annual training or refreshers on that topic.
When it comes to the fourth minimum control measure, construction sites, we basically tried to up the ante on inspection that if you have a site that’s out of compliance and it’s been out of compliance before it’s a problem site, basically that you have to inspect it once every 14 days until their issue goes away. That goes from 30 days to once every two weeks. So that ups the ante a little bit. We also asked that in the post construction that we do some education towards contractors on green areas infrastructure. So basically, if we have sediment or nutrients in a TMDL, we, each one of these requirements sort of tells you if you see this pollutant, then here’s the action that you need to look at. So, if you see total suspended solids, that’s sediment or siltation or TSS or nutrients, then you need to have an educational opportunity to contractors, your stormwater plan designers, or employees on the higher level green infrastructure practices. And then we give a number of choices, basically four choices that you could pick one, a specific action to take that’s actually gonna do some good in the post construction area. So, we tried to basically create a number of choices that a community could take if you don’t have any of one, you might look to a different choice. So one is that you could retrofit an older stormwater basin that doesn’t have the water quality component, the more frequent detention of runoff. And it only has sort of the big storm detention. You’d retrofit that basin. You could do restoration of stream, a channelized or unstable stream at least 300 feet of restoration, or you could update your ordinance or your stormwater requirements to require sort of as the first refusal, the higher level green infrastructure practices, you know, you’d have to show, Hey, it’s not feasible on this site before you went back down to the average practice. Then the last option there was that you could install an acre of a new practice on an untreated area. So you have an acre of impervious area. I could put it in a practice that treats that area. So, you might pick up an old shopping area and we’ve got some open land next to it. And we’re going to put in a stormwater practices that captures the runoff from that area. So, we tried to give choices. So, you know, if one doesn’t fit, hopefully the other three will. And then on the last pollution prevention, good housekeeping for municipal operations, we basically gave some choices there as well that you’d develop a street sweeping program or a catch basin cleaning program, or implement a yard waste collection program. Or you would take one of your facilities, take your facilities that don’t fit the industrial permit that Ohio EPA has. I mean, because they’re public, they often don’t, don’t have to, they don’t have to have that permit, but develop a stormwater pollution prevention plan for those facilities, even though you don’t have to, this could be one of your choices that you go through all your sites, that store materials, and you would develop stormwater pollution prevention plans for them. So those are the four choices for that last minimum control measure, dealing with municipal facilities.

Tim: That is a lot of information, John, and thank you for sharing that. And it’s nice that communities have those options that you’re allowing them to really kind of look at different options and choosing what best fits their needs and capabilities. So that’s, that’s fantastic. I think we’ve done a good job of covering all the changes. Is there anything else we missed that you want to make sure people are aware of?

John: I was just thinking of a joke while you’re talking that, you know, I’m trying to put the ‘reasonable’ in the name of the agency. So.

Tim: There you go.

John: Don’t forget that, right?

Tim: Yeah. And I feel that when I hear everything that you’ve talked about, you know, starting off with the extending the 180 days out to a year, that’s certainly reasonable in this. And of course, you know, in these times that that’s very helpful to communities.

Tim: So yeah, I think, I think there is a lot of you know, flexibility in here, which is good. But at the same time, I think communities, when they see the program come out and they look at it, they, they, you want them to take it seriously, you know, and to really, as we discussed the whole way through, you know, make sure it’s a program and that they treat it as a program and they really start to, you know, take ownership and then a little bit.

John: That’s good. It’s good to emphasize that take ownership part. We don’t want, we don’t want a system that always makes us do something. You know, there are many things that we ought to do, but sometimes we don’t do it until we realize, you know, there’s a problem that’s trying to be fixed by addressing it this way.

Tim: Well, John, we’ve covered quite a bit here. We look forward to the permit coming out in mid-April. Once again, just thank you for your time. And we really appreciate it. A lot of good information has been shared here with the communities.

John: It’s been great being with you. It’s also been great to hear ‘I look forward to the permit coming out,’ because I’ve never heard those words before in one sentence. But it’s been great talking with you.

Tim: Great. Thank you.

John: Thank you.

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