NCS000502_PreAudit_City of Trinity Stormwater Management Report_20210316

STORMWATER MANAGEMENT REPORT
Supplement to the
NPDES STORMWATER PERMIT APPLICATION
for the
CITY OF TRINITY

STORM WATER MANAGEMENT REPORT
TABLE OF CONTENTS
1. Storm Sewer System Information Page 1
1.1 Population Serviced
1.2 Growth Rate
1.3 Jurisdictional and MS4 Service Areas
1.4 MS4 Conveyance System
1.5 Land Use Composition Estimates
1.6 Estimate Methodology
1.7 TMDL Identification
2. Receiving Streams
3. Existing Water Quality Programs
3.1 Local Programs
3.2 State Programs
4. Permitting Information
4.1 Responsible Party Contact List
4.2 Organization Chart
4.3 Signing Official
4.4 Duly Authorized Representative
5. Co -Permitting Information (if applicable)
5.1 Co-Permittees
5.2 Legal Agreements
5.3 Responsible Parties
6. Reliance on other Government Entity
6.1 Name of Entity
6.2 Measure Implemented
6.3 Contact Information
6.4 Legal Agreements
Page 2
Page 2
Page 2
Page 4
7. Stormwater Management Program
7.1 Public Education and Outreach on Storm Water Impacts Page 5
7.2 Public Involvement and Participation Page 6
7.3 Illicit Discharge Detection and Elimination Page 7
7.3.1 Regulatory Mechanism
7.3.2 Enforcement Actions
7.3.3 Detection and Elimination
7.3.4 Illicit or Allowable
7.3.5 Occasional and Incidental Discharges
7.3.6 Public Outreach for Illicit Connections

7.3.7 Program Approach
7.3.8 Measurable Goals
7.4 Construction Site Stormwater Runoff Control Page 10
7.5 Post -Construction Storm Water Management Page 11
in New Development and Redevelopment
7.6 Pollution Prevention and Good Housekeeping for Municipal
Operations Page 13
Attachment 1 — High Point Urbanized Area Map
Attachment 2 — City Organization Chart
Attachment 3 — Documentation of delegated Authority to City Manager
Attachment 4 — NCDENR — DWQ Letter requiring Application
Attachment 5 — Notice of Public Hearing
Attachment 6 — Record of Public Hearing

1. STORM SEWER SYSTEM INFORMATION
1.1 Population Serviced
The current population of the City of Trinity is 6,794. This data as of and taken from
the 2000 U.S. Census.
1.2 Growth Rate
The growth rate for Trinity of 30% over the next 10 years was taken from the
population projections from the Phase 2 Sewer System Expansion Preliminary
Engineering Report dated September 2, 2003
1.3 Jurisdictional and MS4 Service Areas
The MS4 service area and the Jurisdictional area for the City of Trinity are the same at
17.2 square miles.
1.4 MS4 Conveyance System
The Trinity stormwater systems within the City of Trinity utilizes primarily open
channels and swales to convey surface waters to receiving creeks. Most existing
residential and industrial subdivisions were constructed using ribbon -paved streets
with side ditches to direct surface waters to low lying areas, swales, creeks, and
streams.
The headwaters of the Little Uwharrie River and the Uwharrie River drain the City of
Trinity. Past and current growth of the stormwater systems in Trinity has not had a
noticeable impact on the quality/quantity of waters within the streams. See
Attachment One for a map of the High Point urbanized area which includes the City of
Trinity.
1.5 Land Use Composition Estimates
The estimated percentage of jurisdictional area within the City of Trinity contains the
following distribution.
Residential: 65% Industrial: 5%
Commercial: 5% Open Space: 25%
1.6 Estimate Methodology
The land use percentages were calculated based upon Randolph County GIS maps
and available land use information records.
Page 1

1.7 TMDL Identification
To the City of Trinity's knowledge, the streams in Trinity do not discharge to any TMDL
listed waterways.
2. RECEIVING STREAMS
Receiving Stream
Name
Stream Segment
Water Quality
Classification
Use Support
Rating
Water Quality
Issues
Little Uwharrie
River
13-2-1
WS-III
FS
N/A
Uwharrie River
13-2-1
WS-III
FS
N/A
3. EXISTING WATER QUALITY PROGRAMS
3.1 Local Programs
The City of Trinity has an adopted watershed protection ordinances for one classified
watershed. The Lake Reese (Uwharrie River) watershed area is classified as WS-III
and covers the majority of the City's corporate limits.
3.2 State Programs
The City of Trinity is a participant in the State erosion and sedimentation control
program administered by the NCDENR. For parcels of greater than one acre in size
representatives of the Winston-Salem NCDENR office review all plans for site grading
and erosion control. The State Staff also perform periodic site inspections to insure
compliance with the approved plan. On occasion, NCDENR staff is called upon to visit
non -permitted sites that have been identified through citizen complaints or general
concern by local officials.
Ce1=iWk ir-A iren
4.1 Responsible Party Contact List
Contact Person for Overall NPDES Program:
Ann Bailie, City Manager
City of Trinity
PO Box 50
Trinity, NC 27340
336-431-2841
336-431-5079 (Fax)
[e-mail]
Page 2

Contact Person for Erosion Control: Steve Mauney, Regional Supervisor
NCDENR — WSRO
585 Waughtown Street
Winston Salem, NC 27107
336-771-4600
Contact Person for Stormwater Plan Review: Adam Stumb
City of Trinity Planning and Code
Enforcement Administrator
336-431-2841
336-431-5079 (Fax)
[e-mail]
Contact Person for Drainage System Maintenance:
.Ann Bailie
Contact Person for Public Information/Education:
Debbie Hinson, CIVIC
Trinity City Clerk
336-431-2841
336-431-5079 (Fax)
[e-mail]
Contact Person for Construction Site Inspections:
Adam Stumb
Contact Person for Issuing Public Notices for our Organization:
Debbie Hinson
4.2 Organization Chart
The City of Trinity was incorporated in 1997. Currently there are only 3 employees
and some services are contracted with sister Cities and private firms.
See Attachment 2 for the City Organization Chart relating to Stormwater issues.
4.3 Signing Official
James D. Shore, Mayor
4.4 Duly Authorized Representative
Ann Bailie, City Manager, See Attachment 3 for documentation of City Council action
delegating permit related authority to the City Manager.
Page 3

5. CO -PERMITTING INFORMATION (IF APPLICABLE)
The City of Trinity does not wish to pursue this option at this time.
5.1 Co-Permittees (N/A)
5.2 Legal Agreements (N/A)
5.3 Responsible Parties (N/A)
6. RELIANCE ON OTHER GO`✓ERNMENT ENTITY
At this time the only other government entity that the City of Trinity is relying on a
portion of its stormwater related permit application activity is the NCDENR Division of
Water Quality Sediment and Erosion Control Program. Listed below is the contact
information for the local sediment and erosion control office.
6.1 Name of Entity
NCDENR Division of Water Quality Sediment and Erosion Control Program
6.2 Measure Implemented
The City of Trinity will continue to rely on the NCDENR Sediment and Erosion Control
Program to comply with the construction site runoff controls portion of the NPDES
Phase II program rules (for sites greater tan 1 acre)
6.3 Contact Information
Name of Entity: NCDENR — Division of Water Quality (WSRO)
Contact Person: Steve Mauney, Regional Supervisor
Contact Address: 585 Waughtown Street Winston Salem, North Carolina
27107
Contact Telephone Number: 336-771-4600
6.4 Legal Agreements
The State NCDENR Division of Water Quality has authority to provide this service to
all projects in the City of Trinity.
Page 4

7. STORMWATER MANAGEMENT PROGRAM
7.1 Public Education and Outreach on Storm Water Impacts
What pollutant source are you trying to address and why? List the targeted pollutants
and give a brief explanation as to why these are selected.
Write a narrative description of the approach you are going to take in your outreach
program.
The City of Trinity program as envisioned, will focus on bringing basic information to
the public about the importance of protecting the quality of our drainways, streams,
and rivers by preventing trash and other contaminants from being washed into our
water flowing streams.
Trash and litter are potential problems in drainageways and streams and necessitate
constant public outreach and education efforts. Plastic and glass bottles, fast food
wrappers, and cigarette butts are the most notable items of trash collected in stream
cleanup events. In addition to aesthetic impacts, trash also has an immediate
influence.on the storm drainage system, which can become clogged with trash and
debris and result in street and property flooding. Finally, trash is a serious threat to
local wildlife, which can easily mistake trash for food, ingesting it to their detriment.
Sediment runoff from construction sites, ill -managed lawns, eroding stream banks and
other exposed soil areas are a significant threat to local stream water quality.
Sediment in runoff causes increased turbidity and diminished flow capacity in area
waterways, which can lead to flooding and loss of property. Sedimentation also limits
available sunlight for aquatic plants and organisms, smothers fish eggs, clogs fish gills,
and harms beneficial aquatic life.
Washing vehicles on driveways and other impervious surfaces is a common practice.
This practice sends soaps, toxins, and grime down storm drains and into local
waterways. Toxins in car washing soaps such as phosphates can contribute to a
reduction in stream water quality. Outreach and education efforts are needed to
encourage citizens to wash vehicles on grass or to patronize a commercial car wash in
order to protect waterways and streams.
Dumping household hazardous chemicals, cleaners, grease and automobile fluids into
storm drains or ditches is an activity that may be occurring. Dumping these materials
can result in waterways that have high levels of pollutants including heavy metals,
toxins, oil, grease, solvents and nutrients. Pollutant levels can be high enough to
seriously degrade water quality and threaten aquatic life, wildlife and human health.
Outreach efforts focus on educating the public about the proper disposal methods of
hazardous chemicals and impacts of dumping them into storm drains or ditches.
Page 5

The application of fertilizers and pesticides is a common practice, particularly by lawn
care companies and single-family households in the spring. Outreach efforts will focus
on educating the public that fertilizers contain nutrients, which, in excess, can wash
into area waterways and result in lower dissolved oxygen levels, excessive weed and
algae growth, and impaired aquatic habitat. Education efforts will encourage the use
of soil testing kits to determine specific lawn nutrient needs an on saving the consumer
money by spending less on unnecessary fertilization.
Decision Process: describe the decision process used to create this program element.
Work on this element began initially be creating an informal group of staff representing
Phase I and Phase II cities within the upper Cape Fear basin. It was determined that
many of the public education requirements could be addressed regionally as well as
locally by partnering with a nearly Phase I community or other Phase II Cities. The
BMP Program chose by the City of Trinity will be performed locally, however the cost
of program development may be shared with other Phase I or Phase II cities.
BMP's may include an education plan targeted for school age children and youth,
business, gas station owners, "do-it-yourself" citizens, etc. Programs may include the
creation of mailers, brochures, web site links, and school classroom instructional
information.
7.2 Public Involvement and Participation
Are you going to comply with the public hearing requirement to meet this minimum
control measure?
Yes
Describe how you involved the public in developing your application.
A notice of Public Hearing was published in the High Point Enterprise (a paper of
regional distribution) and the local Archdale -Trinity Newspaper.
Describe the decision process used in developing your public participation process.
(Who was involved, what issues were important, what goals are you trying to achieve)
A public hearing was held on April 20, 2004 at the City of Trinity Council meeting for
the purpose of review and discussion of the Phase II application and rules. Randy
McNeill, our consulting Engineer of Davis -Martin -Powell and Associates presented a
Power Point presentation and discussed the goals of the program, the application
process and the benefits to future water quality by detecting and eliminating illicit
stormwater system connections. The public hearing was opened to those persons in
the audience allowing them an opportunity to ask questions or comment upon the
Phase II permit.
Page 6

7.3 Illicit Discharge Detection and Elimination
Storm sewer system map: Describe how you are going to complete a storm sewer
system map of outfall locations. (What sources of information will you use? What
form will the map take (digital, paper map)? What method will you use to verify the
accuracy of the locations? Will you do field verification ad if so, will you use any
specific technology? How will you update the map, once data collection begins? Who
will keep the map current? Where will the map be located within the organization for
the public to view or review if desired?
Over the 5 year permit period a City of Trinity stormwater system map will be
developed. In the first year a base map of the entire City showing state and city
streets, streams, floodways, drainage basins, and drainage sub -basins will be
prepared. In the second year any stormwater pipe in excess of 24 inch diameter will
be added to city owned streets based upon available subdivision Plan records. In
future years other stormwater features in current NCDOT Streets will be added as the
City takes over maintenance of more roads within the City.
7.3.1 Regulatory Mechanism
Do you have an ordinance in place that prohibits non-stormwater from your drainage
system?
No
Describe your process for developing a regulatory mechanism and when you plan on
doing so.
Currently, Trinity has ordinances in place that prohibit the connection of sanitary
sewers to the stormwater system. We plan to conduct an extensive review of this and
other municipal ordinances to determine the need to modify and create an illicit
discharge ordinance. The ordinance will include regulatory mechanisms that defines
and prohibits illicit discharges entering the stormwater system.
7.3.2 Enforcement Actions
Describe the methodology you will use to take enforcement actions needed when you
find an illicit connection. Include process you will follow if different from the method of
adopting or amending your current ordinance.
Currently, enforcement actions are as dictated in the relevant ordinance. For any new
ordinances, the enforcement actions will be very similar to any existing ordinances
and/or as dictated by State, Federal laws, or Local Regulations. Methodology for
enforcement will center on the right of entry, provisions, penalties, and legal
procedures for eliminating any identified illicit discharges.
Page 7

7.3.3 Detection and Elimination
Describe the plan you are going to follow to find and eliminate illicit connections.
Address spills and illegal dumping controls as well. Include procedures for locating
high priority areas in the community; procedures for tracing the source of an illicit
connection; procedures for removing the discharge and procedures for program
evaluation and assessment.
Periodic inspection of the storm sewer outfalls will allow city staff and our consulting
engineer to identify and eliminate illicit connections. Industrialized areas will be an
area of high priority and special focus given the potential for future illegal connections
and dumping. Spills and illicit connections will be addressed using established
remedies found in the City's ordinances.
How will you find illicit connections?
Our staff and consulting engineer will conduct periodic inspection of our storm sewer
outfalls to identify illicit connections. They will also perform dry weather field screening
and act on complaints received from the general public.
How will you address spills, within your own operation and within the community?
Every effort will be undertaken to contain the spill and remove the discharge material
to the betterment of the stream or creek. Assistance from other resources may be
called upon (i.e. Fire Department, City of Thomasville, city of Archdale, NCDENR or
Environmental Clean-up contractor) if necessary.
How will you eliminate an illicit connection or discharge?
Staff will eliminate connections through aggressive enforcement of local codes and
ordinances related to any identified illicit connections.
How will you evaluate your program and make changes over time?
Success of the program will be measured by reviewing the activity of the various
components of the program annually as well as feedback from the community.
7.3.4 Illicit or Allowable
The City of Trinity has determined that the following discharges will be considered
allowable discharges for the purpose of this permit application.
Page 8

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
Allowable
Allowable
Allowable
Allowable
Allowable
Allowable
Allowable
Allowable
Allowable
Allowable
Allowable
Allowable (Unless found to
exceed State Standards)
Footing drains: Allowable
Lawn watering: Allowable
Individual residential car washing: Allowable
Flows from riparian habitats and wetlands: Allowable
Dechlorinated swimming pool discharges: Allowable
Street wash water: Allowable
Water line flushing:
Landscape irrigation:
Diverted stream flows:
Rising ground waters:
Uncontaminated ground water infiltration
(as defined at 40 CFR 35.2005 (20)):
Uncontaminated pumped ground water:
Discharges from potable water sources:
Foundation drains:
Air conditioning condensation:
Irrigation water:
Springs:
Water from crawl space pumps
Are there other incidental discharges that you will define as NON-STORMWATER and
ILLICIT for purposes within your community? If yes, describe them and how you will
address them in your program.
At this time, The City of Trinity is not considering adding any additional items as illicit
discharges.
7.3.5 Occasional and Incidental Discharges
Given the infrequent nature of charity car washes, the municipality considers this to be
an acceptable occurrence.
7.3.6 Public Outreach for Illicit connections
How will you inform the public and your employees about the hazards of illicit
connection and illegal dumping? This activity should be coordinated with you Public
Education Program and your Good Housing Keeping Program.
As indicated in the Public Education portion of the program, every effort will be made
to educate the public, City employees, city consultants, and contractors on the
importance of protecting our stormwater system by acting proactively to prevent waste
and illegal discharges from entering the system. See Public Education/Public
Involvement.
Page 9

7.3.7 Program Approach
Describe how you developed your program approach to illicit discharge elimination.
How did you choose your BMPs and your measurable goals?
Our program will be developed with the assistance of the North Carolina League of
Municipalities and our consulting engineer. BMP's will be chosen after careful
consideration and discussion by municipal staff and our consulting engineers.
The new programs will include development of ordinances to address illicit
connections, right of entry, prohibition of certain discharges, enforcement actions, and
penalties. The emerging stormwater system map ultimately showing pipes, bridges,
streams, etc., will aid in tracing pollution locations and potential system impacts.
7.3.8 Measurable Goals
Explain how you will evaluate the success of your program. What are the measurable
goals for each BMP?
Success of the program will be measured by reviewing the activity of the various
components of the program annually as well as feedback from the community.
7.4 Construction Site Stormwater Runoff Control
Are you going to use the State Sedimentation and Erosion Control program to comply
with this minimum control measure?
Yes
If yes, who is responsible for the program in your community?
NCDENR Regional Office —Winston-Salem (WSRO)
How will you evaluate the program? What are your goals and measures for each of
your BMPs?
City staff will perform periodic inspections of all construction sites under the jurisdiction
of NCDENR, Should the requirements specified in the approved Erosion Control
permit be in violation, the WSRO will be notified immediately. Citizen complaints and
concerns will be forwarded to WSRO staff for follow-up inspection as required.
Page 10

7.5 Post -Construction Storm Water Management in New Development and
Redevelopment
Do you currently have development standards that address stormwater management
on new or redevelopment projects that disturb more than one acre of property?
0
Do you have requirements for structural BMPs to control stormwater on site for new or
redevelopment activities to control water quality?
101
If no standards and controls exist to control water quality, describe the process you will
use to select the on -site controls and standards.
City staff and consulting engineer will determine the methods and on -site controls that
are most appropriate for our community and drainage area. Our ordinance will include
requirements from the State including buffers and structural BMP's in high -density
areas to control the difference in pre and post construction runoff from the one year 24
hour storm event and removal at least 85% of the total suspended solids. This portion
of our stormwater management plan will be implemented by May, 2005.
Do you have a regulatory mechanism to address post -construction controls for water
quality?
m
Describe how you will develop a mechanism, what you are considering and when you
will develop it.
The requirement for the necessary BMP's will be included in our current site plan
review process. A requirement for follow-up inspections will be added to our
procedures. The ordinance will also establish a process for the inspection of BMP's
and define who will inspect them and establish any necessary fees related to such
activity. This portion of our stormwater management plan will be implemented by May,
2005.
If yes, do you have standards to control water quality, is long-term maintenance
required and how is it regulated? If no, describe how you will incorporate maintenance
requirements. If no long-term maintenance strategy is included in your program,
describe the process you will use to establish a long-term maintenance strategy and
the schedule you will follow.
Long term maintenance will be required and regulated by ordinances and include
language requiring maintenance easements, maintenance covenants, as well as
inspection, operation, and maintenance of stormwater management structures.
Page 11

The City of Trinity will develop standards for the inspection and long-term maintenance
of structural BMP's. This policy will be inn effect by May, 2005.
Describe the process you followed in determining your plan of action for this minimum
control measure.
We concluded that this procedure was required by the regulation.
What are your priority areas?
Areas of high priority are highway commercial and industrial areas requiring large
amount of paved parking to support those uses where 85% TSS removal from the first
inch of precipitation volume controls, integrated management practices and the use of
structural and non-structural controls.
What conditions exist in your community that are unique or require tailored BMPs?
The City of Trinity has a moderate topography that does not generally require tailored
BMP's. Areas of steep slopes, riparian corridors, and water supply watersheds may
require tailored BMP's.
Describe your measurable goals and evaluation process.
The City of Trinity plans to track and report the number of BMP's created under the
regulation, track the number of those successfully inspected, and annually reviewed
the status of those requiring maintenance.
Page 12

7.6 Pollution Prevention and Good Housekeeping for Municipal Operations
Is your community certified Environmental Management System community?
Describe your program.
No
What are you currently doing that could be considered as SMP strategies under the
Permit? List measures and check to indicate that you are going to use these to
comply with the permit requirements.
The City of Trinity is a young City currently having only 3 employees and one City
vehicle. City Hall is a renovated single family residence with a gravel parking area.
The City has only taken over a small percentage of the ribbon paved streets located
within the City. The Public Water system located throughout the City is owned by a
private water company. Most areas of the City are served by individual septic sewer
systems. The City is currently aggressively pursuing the establishment of a public
sewer system. One pump station has been installed and several others are planned.
The pump station includes a standby power system with a dual contained fuel supply
system to avoid wastewater overflows during power outages or fuel spills.
List the municipal operations that will be impacted by this measure. Do you operate or
maintain: List the municipal operations that must have a separate Industrial NPDES
permit. They may include:
❑ Vehicle maintenance, fueling and repair facility for transportation vehicles
(public transit, ambulances, school buses, dump trucks, garbage haulers, parks
vans for special activities such as programs for the elderly, boat maintenance)
o Wastewater treatment plant over 1 mgd capacity
o Landfill
❑ Recyclable processing center for co -mingled materials
❑ Airport
❑ Mining operations (i.e., borrow area for landfill operation)
❑ Marinas
An initial assessment of municipal operations which includes City Hall, one City
vehicle, and onewastewater pumping station does not require industrial permitting.
Describe your procedures for controlling floatable and other pollutants from the
drainage system. If you do not have a plan, how will you address this in your permit?
The community's citizens currently participate in the Clean Sweep and Adopt -a -
Highway programs.
Describe your procedures for maintenance of the drainage system including inspection
of the system. If you do not have a plan, how will you address this in your permit?
Page 13

At this time, inspection and maintenance of the system is infrequent and performed
only as needed. Beginning in Year 3 and after adequate training has been given, City
Staff will perform seasonal inspections of the system that may coincide with other
maintenance activities such as mowing of sewer right-of-ways, etc.
Describe controls for reducing pollutants from parking lots, storage yards, waste
transfer stations, outdoor storage areas at vehicle maintenance shops, salt storage
and snow disposal areas. If you do not have a plan, how will you address this in your
permit?
We plan to develop a pollution prevention plan for municipal operation to address
material storage, equipment storage, equipment maintenance, and general
housekeeping practices.
Describe your procedures for the proper disposal of waste removed from your
drainage system? If you do not have a plan, how will you address this in your permit?
The disposal of white goods and other debris will be sent to an approved permitted
solid waste landfill. Household and other hazardous waste from City operations will be
sent to the Household Hazardous Waste Facility located in Greensboro, North
Carolina.
What are your procedures to incorporate water quality controls within flood
management projects? If you do not currently consider this in your program of flood
management, how will you address this in your permit.
The City will require developers to incorporate NCDOT stormwater quality/quantity
BMP's into their site plan designs.
Describe how you developed your pollution prevention plan for this permit. What
important factors did you consider?
Act to eliminate stormwater pollution potential at municipal facilities and through local
government policies and procedures, encourage the citizens of Trinity to comply with
similar measures.
What are your measurable goals and how will you evaluate them?
To train all of our municipal staff that work with or around equipment that uses or
carries POL products. Conduct spot inspections at each municipal facility to assess
good housekeeping, pollution prevention and OSHA practices.
Page 14

Attachment 1 - High Point Urbanized Area Map

Attachment 2 - City Organization Chart

Planning
Administrator
CITY OF TRINITY
STORM WATER MANAGEMENT SYSTEM
ORGANIZATION CHART
Mayor
and
City Council
Ma
City
Clerk
Consulth
Engim
Attachment 1

Attachment 3 e Documentation of delegated
Authority to City Manager

MOR
CITY OR TRINITY
1997 /
AUTHORIZING RESOLUTION BY THE CITY OF TRINITY
WHEREAS, The City of Trinity is required to submit a NPDES Stormwater Permit Application
to the State of North Carolina that details a Stormwater Management Program for implementation
during the five year permitting period; and
WHEREAS, The City of Trinity has prepared said application for submission to the State.
NOW THEREFORE BE IT RESOLVED, BY THE CITY COUNCIL OF THE CITY OF
TRINITY:
That the City of Trinity will submit the Stormwater Application, and;
FURTHERMORE, that James D. Shore, Mayor, and successors so titled, is hereby authorized to
execute and file the Stormwater Application on behalf of the City of Trinity, and;
FURTHERMORE, that Ann Bailie, City Manager, and successors so titled, is hereby delegated
the authority to represent the City and sign on behalf of the City for all further activities
associated with the Stormwater Management Program.
ATTEST
20°i day of April, 2004
ebbie Hinson, City Clerk CMC