Hi Phil,
Attached is the Draft Proposal that includes your numbered key points listed below to reference the sections. I’m assuming you will delete them after review. Please let me know if you have any questions. I’ve also included a few back up data attachments with one does include the photo of the drainage marker.
Thanks,
Jennifer Cline, P.E. | Public Works Director
Licensed in OR, WA
117 N Molalla Ave. | PO Box 248 * |Molalla, OR 97038
O: 503.759.0218 | F: 503.829.3676
From: Phillip Bender [mailto:PBender@ringbenderlaw.com]
Sent: Monday, November 02, 2015 5:59 AM
To: Jennifer Cline <jcline@cityofmolalla.com>
Cc: Dan Huff <dhuff@cityofmolalla.com>; Phillip Bender <PBender@ringbenderlaw.com>; J.W. Ring <JWRing@ringbenderlaw.com>; Christine Hein <CHein@ringbenderlaw.com>
Subject: Molalla: Supplemental Environmental Project Proposal
Jennifer,
I am waiting to hear back from DEQ on the proposed Supplemental Environmental Project to place storm drain markers within the City. I believe they will approve it as a concept. Assuming they do, we will need to prepare a formal written proposal to submit to DEQ. DEQ's SEP guidance outlines what must be in a proposal. That guidance can be found at: http://www.deq.state.or.us/programs/enforcement/SEPpolicy.pdf
In terms of key points, here is a suggested outline for the City's proposal.
1. A description of expected benefits and results and how benefits and results will be measured or assessed (e.g. the SEP will educate the public about the need to avoid dumping wastes into storm drains and hopefully help prevent such dumping);
2. A summary of the estimated value of the SEP, listing the costs that will be paid by the respondent and crediting any leveraged amounts that will cover other related costs (e.g., the SEP will cost 80% of the value of the penalty, or $3,480). This means you want to design the project so that you order enough markers and use the appropriate amount of staff time to install them to amount to $3,480;
3. A proposed schedule including milestones for completion, culminating in the submission of a Final Close-out Report to DEQ (e.g. the City will order the storm drain markers by [INSERT DATE], and will install all markers within 30 days of receiving them from the manufacturer); and
4. A description of what will be contained in the Final Close-out Report (e.g., the Final Report will include the number, location and cost of all markers; it will also include information to be shared with the public about the placement and intent of the markers).
Does that make sense?
Note that the total penalty amount is $4,350. The SEP is proposed to cover 80% of that, or $3,480. The City must pay the remaining $870 upon approval of the SEP.
Note that the current deadline for submitting the proposal is November 13.
Thanks.
Phil
Phillip M. Bender - Partner
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