Erosion and Sedimentation Control Ordinances:

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					Erosion and Sedimentation Control Ordinances:

 A review of county and municipal erosion and
      sedimentation control ordinances

               Local Land Use Law
               Professor John Nolon

                  Kelly Coleman
                Michelle McCarthy

               Friday, April 30, 200
                           TABLE OF CONTENTS

Discussion of Topic                            3

Description of Types of Laws                   6

Sample Law                                     22

Change Agents and Local Leaders                26

Methods                                        36

Final Thoughts                                 40

Sources                                        44

Discussion of Topic:
Soil erosion and sedimentation can impact water quality, environmental health, public

safety and municipal maintenance costs.i As a nonpoint source pollutant, erosion is

often difficult to regulate. However, awareness about the importance of minimizing

erosion and sedimentation has increased and resulted in more effective regulation at all

levels of government.

According to the EPA, erosion can be defined as the “wearing away of the land surface

by wind or water.”ii Its counterpart, sedimentation, is defined as the “removal, transport,

and deposition” of small particles of soil or minerals which are often created by erosion.iii

Both construction and agriculture are important sources of sediment. Sediment runoff

rates from construction sites are “typically 10 to 20 times greater then those from

agricultural lands and 1,000 to 2,000 times greater then those from forest lands”.iv

However, in many watersheds, agricultural land accounts for a large percentage of the

watershed, and thus contributes more total sediment to a given waterbody then

construction. In the Chesapeake Bay area agricultural land is the largest contributor of

sediment to the Bay, contributing over 63% of the total sediment load in 2002.v

Erosion and sedimentation are typically regulated at the local level by municipalities,

counties, and natural resource districts. However, both the federal government and

states play a role in shaping erosion and sedimentation ordinances. The role of the

federal and state governments differs depending on the type of land use activity being

regulated. Many of the erosion and sedimentation ordinances discussed in this paper

were developed to satisfy state or federal mandates, but were innovative and thorough

as a result of localized pressure.

For this report, we look at three general categories of erosion and sedimentation control

ordinances (ESCs): construction, agriculture, and other natural area protection.

Construction ESC ordinances traditionally require land clearing permits and the use of

erosion and sedimentation control best management practices (BMPs) on construction

sites. They are by far the most common type of erosion and sedimentation control

ordinance. Agricultural ordinances are more infrequent. This report gives two

examples of such ordinances: one that regulates a specific production type, vineyards,

and one that regulates generally. Finally, this report looks at natural resource

ordinances which regulate land use activities in specific areas, such as along river

corridors, or which regulate land alteration prior to construction activities. Along with

full descriptions and comparative analyses, the change agents that helped develop or

spurred the existence of each law will be discussed.

Finally, one sample law is given specific attention. Through the analysis of the

Mecklenburg Erosion and Sedimentation Control Ordinance, the key elements of

construction ESC ordinances and the benefits and drawbacks of other types of

ordinances will be explored. Mecklenburg, North Carolina’s ordinance represents a

thorough ESC ordinance that contains crisp language, innovative approaches, and

strong enforcement language. It demonstrates one of the better-written ESC

ordinances available.

Erosion and sedimentation control ordinances have improved dramatically in the past

20 years, however they are not implemented evenly across the US, nor are they a

necessarily effective. Better education and enforcement about existing laws coupled

with a national effort to tighten regulations to include smaller parcels of land (including

in-filled construction) would greatly improve ESC. Additionally, and perhaps more

importantly, erosion and sedimentation control measures should be integrated into other

land use laws to create a more holistic approach to erosion and sedimentation.

Description of Types of Laws:

For the purposes of this report we shall classify erosion and sedimentation control

ordinances as 1) construction, 2) agricultural, or 3) natural resource related, based on

the major type of activity being regulated.


Construction is generally considered to be the phase of land use most susceptible to Indeed, construction oriented ordinances were by far the most common form

of erosion and sedimentation control. These ordinances set requirements for erosion

and sedimentation Best Management Practices (BMPs), permitting procedures, and

fines and processes for violations and appeals. These regulations differ based on the

size and type of construction being regulated, the level of erosion allowed, the level of

BMPs required, and the enforcement and fining mechanisms used. Many construction

ordinances explicitly exempted agriculture and forestry land uses.

Both the federal and state governments play a strong role in directing construction-

oriented regulations. The 1990, National Pollutant Discharge Elimination System

(NPDES) Phase I storm water rules under the Federal Clean Water Act established

requirements for pollutant discharges from construction activities that disturb more then

5 acres.vii Phase II rules, adopted in 1999, set discharge limits on all construction that

disturbs between 1 and 5 acres.viii NPDES Phase I and Phase II requirements must

be administered by the states and implemented by municipalities.

Many states have also promulgated their own minimum construction ESC standards.

These rules authorize and require that localities implement regulations that meet the

state minimum standards. Often state standards are expressed in handbooks of Best

Management Practices, such as the Virginia Erosion and Sediment Control Handbook.ix

State mandated ordinances were particularly common in the East Coast of the US (see

GA, DE, CT, etc.).

The majority of construction erosion and sedimentation laws we found were

implemented because of state or federal mandates. However, many of the ones that

stand out, and that we have highlighted in this report, were more thorough then required

as a result of unique local environments, local citizen pressures or staff expertise. The

most effective erosion and sedimentation construction ordinances were developed in

conjunction with the regulated community (especially the land developers), have

thorough enforcement, and strong public education components.

The following is a review of individual construction ordinances and the elements that

make them unique, innovative, or thorough. It is followed by a review of the similarities

and differences found within erosion and sedimentation construction ordinances.

Mecklenburg County Soil Erosion and Sedimentation Control Ordinance, Mecklenburg
This ordinance applies to all land-disturbing activities, except forest activity that follows

the state forest practice guidelines and agriculture, but requires a sediment and erosion

control plan only on activities that disturb more than one acre.x The ordinance controls

the length, location, and area of soil exposure and requires weekly monitoring and post-

storm event monitoring. In addition this ordinance is designed to facilitate the county’s

efforts to asses penalties on those in non-compliance by including a thorough list of

violations and fine amounts and defining the appeals process for challenging penalties.

The effectiveness of this ordinance stems from its uniquely steep penalties, up to $5000

dollars per violation, and the willingness of enforcement officers to use the fines.xi As a

result of several high-profile fines, the construction community is now aware of the

sedimentation and erosion control requirements and willing to follow them.

Erosion and Sediment Control for Land Disturbing Activities, Minneapolis
The purpose this ordinance is to “control or eliminate soil erosion and sedimentation

within the City of Minneapolis.”xii It applies to all land disturbances and soil storage

activities. This ordinance refers permitees to a Manual of Standards that describes

acceptable Best Management Practices (BMPs) for use in controlling sedimentation and

erosion. It also sets a schedule for mandatory inspections by the issuing authority. It

requires active land to be monitored and inspected by the permitee at least once a day

and to monitor revegetated slopes to be monitored regularly until ‘adequate turf’ is


Louisville and Jefferson County Erosion Preventions and Sediment Control Ordinance,
Jefferson County
The purpose this ordinance is to protect Jefferson County’s natural resources, including

its soils, to control erosion and sedimentation resulting from development and to comply

with Phase II NPDES and other state and federal clean water laws.xiv The ordinance

was designed through a community consensus process that took place between 1997

and 2000.xv It applies to all construction and land moving operations that affect over

5,000 sq. ft. of land, excepting agriculture, but including single family uses. This

ordinance requires the Premitee to perform weekly inspections and maintenance on all

implemented sedimentation control measures and inspections after each 0.5 inch 24

hour storm event.xvi

Erosion and Sediment Control Regulations, City of Portland
These regulations are focus on ground disturbing activities regardless of whether or not

a permit is required, unless otherwise exempted. Minimum requirements include: a

threshold of no visible and measurable sediment or pollutant exiting the site or washing

into a water body or storm system; installation of BMPs selected from the Erosion

Control Manual, special requirements during the wet season (Oct 1-Apr 30); signage

requirements on sites where a permit is required; and inspection of BMPs within 24

hours of a storm events.xvii For sites requiring permits, ESC plans must be submitted in

conjunction with permit applications or contract submittals.

Clean Water Services Design and Construction Standards Resolution, Washington
The Clean Water Services (CWS) of Washington County is a public utility that utilizes

this Resolution to protect the water resources of the Tualatin River Watershed.xviii This

comprehensive standard has design specifications for construction, stormwater, erosion

control, etc. Like many of these model ordinances, it has a no visibility requirement for

erosion off-site. All erosion and sediment control requirements apply to all activities and

uses within the CWS service area, not just construction and development. Permitted

activities require an ESC plan for all phases of construction, including during pre- and

post-construction. An integral part to this county's ESC program is their Erosion

Prevention and Sediment Control Planning and Design Manual (available on the Clean

Water Services website).

Erosion and Sedimentation Control Ordinance, Fairfax County
This ordinance operates like most sedimentation and erosion control ordinances and

requires a permit for erosion and sedimentation control plans. It requires plans for lots

2500 sq ft.xix It not only requires that land disturbing activity meet Virginia best

management practice guidelines, it also lists several more stringent controls. For

instance, the use of brush or rebar-enforced straw bale barriers is not allowed, because

there are more effective tools available for controlling sedimentation and erosion.xx This

ordinance also lists a number of fees which must be paid prior to the issuance of any

land disturbing permits including: soil report fees, drainage study fees, and water quality


Single-Family Residential Drainage, Erosion and Sediment Control Requirements,
Douglas County
This ordinance establishes minimum sediment and erosion control requirements in

Douglas County to protect “life, property and the environment.”xxi It was awarded the

International Erosion Control Association (IECA)'s Environmental Achievement Grand

Award in 2004. It applies to all single-family lots and includes slope requirements for

final pervious and non-pervious grades on the lot, and the installation of Best

Management Practices before a Certificate of Occupancy can be issued. According to

the County, they already meet their Phase II requirements, four years ahead of

schedule. This law has been effective because of a combination of enforcement and

education efforts.

Erosion and Sediment Control Ordinance, City of Overland Park
This Erosion and Sediment Control Ordinance is designed to provide minimum

requirements for the control of erosion and sediment resulting from development. It

applies to all land disturbances that require a permit. The principles behind the

ordinance include minimizing soil exposure, retaining sediments onsite, and using

performance measures and outcomes. Requirements include: a time requirement that

limits soil exposure to no more than 21 consecutive days if there is site inactivity; an

Erosion and Sediment Control Plan written by a Kansas State licensed professional;

pre-construction erosion control requirements; routine inspection requirements of

erosion and sediment control measures; and perennial vegetation establishment

requirements. This ordinance also aims to protect against other pollutants such as liter,

building materials, and chemicals in addition to sedimentation.

Surface Water Management, King County
The Surface Water Management Title is a comprehensive set of regulations focused on

surface water management. A drainage review is required for projects that greater than

5000 sq ft of impervious surface, that are near sensitive or critical areas, or that are over

certain size and financial thresholds. A drainage review consists of several core

requirements including discharge requirements, off-site analysis, and flow control. There

is also a Water Quality section that implements a fee structure based upon the amount

of impervious cover on each serviced parcel of land. The King County Surface Water

Design Manual is also an important document that the county relies on for

implementation of requirements set forth in Title 9.

Erosion and Sediment Control, Manorhaven

This ordinance was designed to control erosion and pollution during development,

redevelopment and landscaping. In addition to requiring construction to follow the

State’s Natural Resource Conservation Service’s Urban Guidelines for Best

Management Practices, the ordinance requires that there be no measurable increase in

erosion off the construction site. This ordinance also includes pollution prevention

measures and waterfront building requirements to protect the Manhassett Bay and

waters feeding the Long Island Sound.

Stormwater and Erosion Control Regulations, Clark County
This chapter combines the county's stormwater and erosion control regulations and

applies to development or redevelopment activities that include adding 5,000 sq ft or

more impervious surface in rural areas and 2,000 sq ft or more in urban areas.

Stormwater requirements include off-site analysis of impacts ¼ mile downstream and

conveyance standards. Erosion control requirements include variable requirements for

small parcel and large parcel developments, signage at points of entry for subdivisions

or short plats, and formal erosion control training for contractors. Large parcels must

submit written plans; small parcel developments in erosion hazard areas are also

required to submit and implement written plans.

The many of the above laws regulate all construction, however some laws include

requirements on the size of lot that is regulated, and others regulate all lots but only

require erosion and sedimentation plans for lots above a certain size. The level of

regulation differs as well; several of the laws require that no visible or measurable

erosion be allowed off-site, while other attempt to maintain erosion at pre-construction

levels. For each specific element of regulation, a range of requirements is exhibited. It

is the small changes that have made many of these laws stand out in the eyes of of the

erosion and sedimentation control professionals that we were in contact with.

However, there were also key innovative features that exhibited themselves in several

laws. For instance, the requirement that erosion and sedimentation plans be met before

a Certificate of Occupancy will be permitted is particularly effective tool. The regulation

of single-family units is also a new and innovative element of several of these laws.

Finally, several of these laws demonstrate marked variances from the norm. The timber

harvesting stipulations in Mecklenburg Counties law is one such example. This

ordinance allows timber harvesting not otherwise controlled by the state to be regulated

under the ordinance. Fairfax County, in its law, limits the types of erosion and

sedimentation control measures allowed, requiring only those that the country deems

most effective.

The two agriculture ordinances described in this report are unique examples of how

local counties have sought to regulate agriculture activities, which are a large source of

sediment. In most of the country agricultural activities are exempt from standard

erosion and sedimentation control laws explicitly or are protected through Right to Farm

laws or farmland preservation laws. However the two ordinances below, demonstrate

ways that local communities can regulate agriculture through local ordinances.

Sonoma County Vineyard Erosion and Sedimentation Control Ordinance, Sonoma
The Sonoma County Vineyard Erosion and Sediment Control Ordinance contains

requirements for new vineyard development and for the replanting of existing vineyards

in order to reduce soil erosion and resulting sedimentation into area streamsxxii. Such

development was found to be a main source of sedimentation in water bodies in the

areaxxiii. The primary force of this code is that it classifies vineyards into three different

categories based on such things as soil type and slope, with each level having variable

requirements for review, inspection, and riparian setbacks

Agricultural Shoreland Ordinance, Brown County
The Brown County Agricultural Shoreland Management Ordinance also applies to

agricultural use, and is also designed to prevent soil erosion and sedimentation into

local streams and rivers. The primary force of this ordinance is to establish a 300 foot

zone/buffer around all perennial and intermittent streams and rivers, within which

agricultural practices must meet Natural Resource Conservation Service (NRCS)

guidelines. Additionally, 20-foot-vegetative buffers must be established at the water’s

edge, certain tilling and cropping may be limited in this area.

Each ordinances addresses resources unique to their area of the country, and finds an

appropriate solution to erosion and water quality problems. It is notable that both

ordinances rely on the use of riparian buffers to help control sedimentation into streams

and rivers. The Sonoma County Vineyard ordinance, however, applies to a single type

of agricultural practice whereas the Brown County ordinance applies to all agricultural

activity within the set buffers.

Other natural resource laws

This group is a relatively heterogeneous set of laws that local counties and

municipalities have employed to deal with problems of erosion and sedimentation.

Because this group is so heterogeneous, we have further divided those that primarily

regulate clearing and grading and those that regulate water flow through buffers or

stromwater components. It should be noted that during the course of research, it

became clear that many erosion and sediment control laws are being integrated into

stormwater regulations. While there are many excellent stormwater laws that include

erosion and sediment control, we have chosen only one stormwater law because it

shows a strong relationship between stormwater and erosion concerns.

Clearing and grading:
Land Clearing Ordinance, Bellingham
The City of Bellingham Land Clearing Ordinance is a short but effective law created by

the City in response to illegal land clearing in the early 1990sxxiv. Within the ordinance

there are exemptions for uses such as clearing lots/parcels not exceeding 5000 SF and

slopes less than 15%, but it does have tighter requirements for larger developmentsxxv.

For example, it prohibits the exercise of any State Forest Practice Permit (required for

cutting trees) prior to city approval of a site plan and development permits.

Land Alteration Ordinance, Little Rock
The Little Rock Land Alteration Ordinance serves a similar purpose. It was developed

and written by a citizens group and places limits on tree clearing and grading, requires a

landscaping plan and that a qualified superintendent be on site during all land clearing

activities. The ordinance requires a grading/landscaping permit for all land alteration

activities. Additionally, the ordinance requires that all but the building permit be issued

prior to the approval of the grading permit and that construction is ‘imminent.’

An important step in both these ordinances is where in the line of necessary permits the

land clearing permit can be approved. In Little Rock, the grading permit can only be

approved after all other necessary permits have been granted and in Bellingham, the

Forest permit can only be exercised after site plan and development plans are

approved. Both orders attempt to reduce the amount of time that a cleared site will be

left denuded, unregulated, and susceptible to erosion. An alterative method for

controlling denuded sites would be to make the standard sedimentation and erosion

control ordinance applicable to idle sites, as in Douglas County, CO.xxvi

Stormwater and Riparian Overlays:
Hellbranch Run Water Protection, Columbus
The City of Columbus Hellbranch Run Water Protection Overlay District is one tool the

City managers are using to help protect the watershed in response to encroaching

development in this areaxxvii. The overlay is designed to help prevent streambank

erosion, channel migration impacts, and sedimentation. It regulates by delineating a

stream corridor protection zone and regulating land use and impervious cover in

streamside parcels of land within the overlay. The overlay also calls for stormwater

mitigation measurements to help capture stormwater runoff before it ends up in the


Floodplain and Erosion Hazard Management Code, Marana
The Town of Marana Floodplain and Erosion Hazard Management Code is primarily a

floodplain management code, but is a good example of how municipalities in the

Southwest are responding to development pressures which threaten human life and

which contribute to flooding and erosion. Within the code are a serious of restrictions on

structure design (based on topography and water characteristics) and vegetation

removal. The code also provides for variable building setback requirements for minor

and major watercourses, and has water retention requirements for peak-flooding levels.

It also includes grading requirements which call for both temporary and permanent

measures demonstrated erosion and sediment control methods.

Stromwater Management Ordinance, Santa Fe
The City of Santa Fe Terrain and Stormwater Management Ordinance is primarily a

stormwater ordinance with strong implications for erosion control of this area’s sensitive

environment. This ordinance’s purposes are multiple, with its primary design being to

help capture stormwater and increase its infiltration in order to reduce substantial

erosion hazards due to uncontrolled runoff. The ordinance’s major provisions include

variable standards for minor and major development stormwater infiltration capabilities.

Major development requirements are also prohibited to discharge stormwater into

existing irrigation ditches, acequias, etc. Other developments include requirements for

designating land that is below the base flood elevation for a 100-year, 24-hour storm as

open space and drainage easement and public right of way requirements. Final

development plans and subdivision plats are required to include a long-term

maintenance schedule for the life of stormwater management measures.

Environment First, New Castle County
The Environment First amendments to the Unified Development Code (UDC) in New

Castle County, were introduced May 13, 2003. They tighten up the already strict and

thorough regulations of the UDC, which includes Article 23: Landscaping, Trees, and

Erosion.xxviii The Environment First amendments strengthen the riparian buffer

requirements in order to dissipate the velocity of runoff and control erosion, requires

stormwater management and grading efforts to use green technology best management

practices, requires that non-erosive velocities of runoff be maintained, and allows

herbaceous vegetation in lieu of shrubs on landscapes using green technology best

management practices.

Alpharetta Soil Erosion and Sedimentation Control Ordinance, Alpharetta
The purpose of this ordinance is to decrease erosion and erosion hazards and to

minimize flood damage by requiring permits for land disturbing activities. Undisturbed

vegetative buffers of at least 35 feet along all state waters and of at least 50 feet along

primary trout waters must be maintained with no exceptions. Runoff which results in a

defined turbidity increase in receiving waters is considered a violation.

Common themes of these other natural resource law are that they approach the issue of

erosion and sedimentation control activities based on their location and not their type.

They are also created to help mitigate the impacts of development on the area’s natural

resources. It is also clear that areas in the Southwest are responding to issues of

erosion control from the standpoint of large water event such as flooding and

stormwater. In the course of research it was also apparent that many municipalities are

using sensitive area designations and overlay districts to help protect natural resources

in general. Here we have provided a unique example of how a town has used the

overlay as one tool to respond to encroaching development.

Sample Law:
The Mecklenburg County Soil Erosion and Sedimentation Control Ordinance is an

example of a thorough ESC construction ordinance. We are using this law as our

sample in order to highlight a model construction ordinance, rather then an agricultural

or natural resource ordinance. Because construction is a major source of erosion and

because municipalities are facing increasing pressure to develop construction related

ordinances as a result of NPDES Phase II requirements, we felt that the Mecklenburg

County law would not only demonstrate an innovative law, but it would also represents a

type of law that is likely to be adopted in the near future in other areas.

The Mecklenburg County ordinance stands out because it is thorough, has a detailed

violations and appeals process, and does not wholly exempt timber harvesting. This

ordinance applies to all land-disturbing activities, but only requires a permit for those

activities that uncover more then one acre. It also applies to any timber harvests that do

not meet state Forest Practice Guidelines.

Some of the specifications of this ordinance are on par with the other construction

ordinances reviewed above. However, the Mecklenburg ordinance is consistently more

rigorous then other laws: it is the one single ordinance to look to for the most

comprehensive coverage of construction regulations. Under this ordinance, erosion and

sedimentation plans must identify and give special attention to critical areas, limit the

time and size of exposed areas, control surface water, control sedimentation, and

manage stromwater runoff.xxix For all lands over one acre, a County Engineer should

perform an on-site, pre-construction conference to discuss the approved sedimentation

and erosion plan.

This law includes more exact language than many similar laws. It requires that all

erosion and sedimentation control measures be calculated to provide protection under

“maximum peak runoff from the Ten-year storm.”xxx The law also states that local

rainfall data should be used to determine whether a Ten-year storm event has


Finally, this ordinance has a thoroughly defined process for assessing violations and

penalties and for appealing such assessments. The ordinance spells out exact

penalties (not maximum penalties as most laws require) for various violations, including

engaging in land-disturbing activity without a permit or leaving slopes exposed beyond

the maximum allowable days. With fine amounts increasing for violations that result in

off-site sedimentation. These penalties range from $500.00 per day per violation to

$5000.00 per day per violation, which is $1000.00 more than the maximum penalty

listed in the other ordinances we looked at.xxxii This level of penalties serves as a

deterrent against non-compliance. The county has found that as a result of several

high-profile fines, developers are making serious efforts to stay in compliance.xxxiii The

ordinance includes provisions for an appeals committee that can hear appeals related to

the original proposed ESC plan or related to violations.

In terms of the regularly controlled elements, this ordinance allows soils be exposed for

15 working days or 30 calendar days whichever is shorter and requires that the

permitee’s make weekly inspections of all control measures and monitor all control

measures after a 24 hour 0.5 inch storm event.xxxiv With of these elements the

Mecklenburg ordinance could be made more rigorous. For instance, Minneapolis

requires daily site inspectionsxxxv and Jefferson County requires that land be vegetated

within 14 calendar days.xxxvi These additional measures may not be necessary,

depending on the environmental conditions of the local area. Arguably areas with more

rain and more frequent storm events should implement stricter controls then areas with

little rain stress.

This law has been effective, but would be more effective if it had more inspectors or

could better prioritize sensitive sites. According to both of the officials we spoke with,

the need for inspectors far exceeded the capacity of the 36 that are currently on

staff.xxxvii Given the shortage of inspectors, Mecklenburg County has tried to prioritize

sites with the most environmentally sensitive areas for preferential inspections.   xxxviii

Ordinances such as Portland’s include specifications for ‘special sites’ that are more

environmentally sensitive.xxxix By codifying the types of land Mecklenburg considers

environmentally sensitive, it would be in a better position to regulate those lands. Such

an addition could strengthen any ESC construction ordinance.

The construction related erosion and sedimentation control ordinances rarely include

elements that seem above or beyond the purview of such a law. Although construction

related ESC ordinances have proven to be effective, they still represent a very narrow

approach to erosion and sedimentation in general. Erosion and sedimentation controls

should not be limited to construction related activities alone. Nor should other land use

ordinances shy away from including measures to protect against sedimentation and


Change Agents and Local Leaders:
Change agents and local leaders are the people and events that create the impetus for

the law in the first place and who Shepard the law into being. Change agents can range

from a crisis, to a group of concerned citizens, to mandates from state or federal

government. Or quite often, the change agents are some combination of the above

factors. Below are a listing of the change agents for each of the twenty laws we have


Mecklenburg County Soil Erosion and Sedimentation Control Ordinance, Mecklenburg
Mecklenburg County and Charlotte (the major municipality within Mecklenburg County)

developed this ordinance together so that the erosion and sedimentation control

standards were consistent throughout the county. The drivers for this law were county

and city staff that pushed for improvements to the previous erosion and sedimentation

control regulation. The new ordinance was developed over the course of a year with

stakeholder participation, including environmental representatives and developers.xl

Single-Family Residential Drainage, Erosion and Sediment Control Requirements,
Douglas County

Douglas County’s law was developed after a number of complaints about erosion, street

sedimentation, and drainage problems reached the County Commissioners. The

Commissioners then requested that staff develop a new ordinance that would address

the public concerns. Staff member Carlo Turchiano, a Drainage Erosion and

Sedimentation Control administrator, noted that a thorough ordinance was developed so

that it would be in compliance with whatever NPDES PHASE II requirements were

subsequently established by the federal government.xli

Clean Water Services Design and Construction Standards Resolution, Washington
Clean Water Services (CWS), the public utility for Washington County, is reportedly the

most influential organization that creates erosion and control regulations in Oregon

statexlii. The original impetus for the Clean Water Services Design and Construction

Standards was a lawsuit by a coalition of environmental groups against the county in

the early 1990s in which the court handed down a decision that forced the county to

more stringently regulate construction and development near a local riverxliii. Fred Wright

of CWS was instrumental in building the ESC program from the ground up through,

among other efforts, significant educational outreach.xliv He worked with the

International Erosion Control Association, the local engineering community, and the

local associated contractors and home builders among others, who helped provide or

review information during the development of the program.

Erosion and Sediment Control for Land Disturbing Activities, Minneapolis

This ordinance has been in place since 1996 and is regularly cited as a model law (see

EPA model laws for natural resource protection). However, the woman we spoke with

about the law was unable to offer us any insight on why or how the law was passed.

We believe that the original impetus for the law was the federal Phase I NPDES


Louisville and Jefferson County Erosion Preventions and Sediment Control Ordinance,
Jefferson County

The Louisville and Jefferson County Erosion Prevention and Sediment Control

Ordinance, as passed, would not have existed without the NPDES Phase I and II

requirements. The development of the ordinance was flanked by controversy because

developers, largely self-employed, fought the regulations for three and one half years

during the negotiation and development process.xlv The final ordinance represents a

compromise between the regulated community, largely developers, and the county.xlvi

Erosion and Sediment Control Ordinance, City of Overland Park
The Overland Park ESC ordinance is a relatively new ordinance (taking effect in March

2003) and was a direct result of the federal Clean Water Act NPDES Phase II

regulationsxlvii. No single local leader was responsible for crafting the ordinance, but

Tony Meyers, Supervisory Civil Engineer with the City, has a strong background in the

history, implementation, and enforcement details surrounding the ordinance.

Surface Water Management, King County
King County has had a surface water management law in some form since 1979, but it

went though a major overhaul in 1990. In 1990 the Surface Water Design Manual was

issued, and this has been a strong component of King County’s program. The listing of

salmon on the Endangered Species List has reportedly gotten politicians and

developers more serious about implementing the regulations. More stringent standards

are being proposed right now, but have not passed through review yet. Local leaders in

crafting the regulations were not directly identified, likely because the regulations are so

comprehensive and have such a long history.

Erosion and Sediment Control, Manorhaven

As of 1998, Manorhaven still lacked any controls to prevent polluted stormwater

runoff.xlviii That year Deputy Mayor-Trustee, Jennifer Wilson-Price, was elected. She

wrote the MS4Stormwater Management Plan and has been active in regional

environmental organizations. She, with support from the staff, and training from

Nonpoint Education of Municipal Officials (NEMO), developed the ESC ordinance, to

improve the town’s environmental record. According to the Superintendent of Buildings,

Len Baron, the ordinance had little resistance.xlix

Erosion and Sediment Control Regulations, City of Portland
Portland initiated erosion control requirements for public works projects into its

regulations in the early 1990s, and started working on Title 10 of the city code in 1999 in

response to Phase I Clean Water Act requirementsl. The code now covers both public

and private projects. Portland reportedly developed their regulations internally, in part by

taking the Clean Water Services (Washington County) ordinance as a model because it

was a successful regulation that was formed by involving multiple stakeholdersli. Dawn

Hottenroth at the Bureau of Environmental Services has been central to getting the Title

10 regulations created and passed.

Erosion and Sedimentation Control Ordinance, Fairfax County
This ordinance has been in place for nearly 20 years. Over this time period,

amendments have kept the ordinance effective and up to date. Most updates have

been a result of staff pressure and influence, but the county is generally well aware of

erosion and sedimentation issues because of Chesapeake Bay education efforts.lii

Stormwater and Erosion Control Regulations, Clark County
The County’s first ESC ordinance was adopted in 1993 as a response to flooding,

aquatic habitat damage, increased maintenance costs, property damage, and

eutrophication within the countyliii. The county has noted increased awareness of the

more recent Endangered Species Act and listing of the salmon, which has resulted in

greater understanding of and ability to enforce regulations. Current changes in the

ordinance have been in response to the Municipal NPDES Stormwater permit, and

came out of an inter-disciplinary committee of stakeholders, including developers and


Sonoma County Vineyard Erosion and Sediment Control Ordinance
There were a few key change agents for the Sonoma County Vineyard Erosion and

Sediment Control Ordinance. In the late 1980’s, a vineyard development was found to

be a significant contributor of sedimentation into an important drinking-water municipal

reservoir in Napaliv. Napa shortly thereafter created the first vineyard erosion and

sediment control ordinance, which was challenged by Sierra Club lawsuits. Sonoma

County followed suit in response to environmentalist pressures, and created their own

vineyard ESC law, building on the Napa model and lessons that Napa learned during

implementation. Gail Davis in the Agricultural Commissioner’s office was the key staff

member who was charged with implementing the law. Ms. Davis helped get the local

community educated and informed about the law and its requirements, resulting in

effective working relationships and enforcement. Ms. Davis is also reportedly working

on creating the first erosion and control BMPs for agriculturelv.

Agricultural Shoreland Management, Brown County
In the mid 1980’s the state of Wisconsin developed a farmland preservation program

that provided property tax relief to agricultural land owners who kept working their land

and followed certain conservation standards. As a result of this law Brown County was

able to get 100% of the counties livestock out of the stream and protect riparian areas.

When the state proposed eliminating the program, staff in Brown County started to

develop a local ordinance that would achieve the same conservation goals. The result

was this law, which was very controversial with farmers in committee but easily passed

the county board. According to Jim Jolly, the County has not begun to enforce the law

yet, but has instead, focused efforts on accessing state and federal money to help

farmers come into compliance with the new law. In the next couple of years, Jim Jolly

expects to begin a more aggressive enforcement effort.lvi

Other natural resource laws
City of Bellingham Land Clearing Ordinance

This land clearing ordinance was developed as a direct response to one episode of

illegal clearing of land within the city in the early 1990s. At the time of the illegal

clearing, the city council decided to “do something about it”lvii, which resulted in this


City of Columbus Hellbranch Run Watershed Protection Overlay

This overlay was a result of collaborative efforts between the City of Columbus, other

state agencies, environmental advocacy groups (such as The Nature Conservancy),

and major local builders. The overlay is part of a larger effort to protect the Big Darby

Watershed from impacts of development, and was put in place on the outskirts of town

where development is anticipated to occur in the future. Cheryl Roberto with the City

played a strong coordinating role in getting the overlay passed.

City of Santa Fe Terrain and Stormwater Ordinance

According to the local planner we consulted with, Santa Fe has always had terrain

ordinances to help protect its natural drainages and sensitive ecosystemlviii. In the

1990’s, local planners obtained a 2-year grant to put on a model demonstration project

for erosion control purposes higher up in the watershed, and the current ordinance in

part, came out of this project. There has also been tremendous development pressure

on Santa Fe in recent years, which has increased water stress, and as a result

stormwater has become a valuable resource. As a result, the city is responding by

trying to maintain as much infiltration area as possible. Marian Shirin helped draft up

and advocate the current Terrain and Stormwater Ordinance, and the town planners are

looking towards strengthening this regulation and integrating all water related laws more


Town of Marana Floodplain and Erosion Hazard Management Code

This code was first written in the mid-1990s and began issuing floodplain permits in

1996.lixThe town is an arid town with the Santa Cruz river running through its

jurisdiction, and storm floods have few places to go. The Town tries to stay consistent

with Pima County regulations.

Land Alteration Ordinance, Little Rock
Little Rock’s Land Alteration Ordinance was brought about by citizens who developed

the concept of the law and who wrote the ordinance language as part of a Little Rock

task force. Citizens for the Land Alteration Ordinance, as they became called, were

concerned about the large number of hillside construction sites that were cleared of all

vegetation and frequently graded and then left to sit for months on end. The ordinance

was developed with developers, environmentalists, and city officials over the course of

almost two years.

Environment First, New Castle County
The state of Delaware has a comprehensive model erosion and sedimentation

requirements that municipalities must adopt. New Castle County has gone above and

beyond the state by addressing erosion and sedimentation through a whole suite of

ordinances including the Unified Development Code (UDC) and the Environment First

Amendments to that law. The Unified Development Code was originally adopted in

reaction to fast growth in the county. The Environment First amendments, tweaked the

original ordinance to improve its effectiveness.

Alpharetta Soil Erosion and Sedimentation Control Ordinance, Alpharetta

The buffer aspect of this law was appears to have been adopted to protect fish and

particularly trout populations. The Ordinance was adopted in 1990, but our contact was

not able to provide any insight on how or why it was adopted.

Research Methods

Information about the regulations and ordinances discussed in this report was collected

for input into the Land Use Law Center and National Land Use Law Library project

hosted by Pace University.

The first step to finding innovative or effective ESC regulations was to gain an

understanding of the basic common structure of ESC regulations. Only once the

common structure and standard elements of a “typical” ESC regulation were identified

could the unique and more innovative elements of a regulation became more apparent.

This baseline, or background, information was collected through a review of ESC

regulations previously posted on the TWEN website, the EPA Model Ordinance website,

and general internet searches, utilizing major search engines (i.e. Google and Yahoo) to

find on-line trade journals, soil conservation organizations, and water quality advocacy

organizations. On-line trade journals were also very useful sources that helped us

identify municipalities and counties that were implementing new practices.

During the collection of baseline information, certain trends became apparent. For

example, change in ESC regulations was occurring in many towns as a response to

EPA Clean Water Act Phase I and Phase II requirements. It also became apparent that

there are very few local laws involving agriculture. As a result, we were able to target

research on key words such as: “agriculture” or “Phase II.” As a result we found some

of our innovative laws and gained a better understanding of how local law makers were

integrating the Clean Water Act requirements.

We also emailed multiple local representatives of the International Erosion Control

Association in order to get directed to the more innovative laws by the professionals

themselves. The results were mixed, with some contacts pointing us directly to

innovative town ordinances and others providing good background information. We

were also able to connect with local leaders who we would have not found otherwise.

We initially focused our innovative law search on regions of the country that are

generally known as more progressive. We conducted a sampling of research in other

areas of the country to confirm our suspicions that change is occurring in these more

progressive areas. We also conducted research in geographically/climatologically

unique areas of the country in order to get a more holistic assemblage of laws. For

example, we collected laws from both very wet and very dry environments in order to

get representation across the spectrum of environments, and to compare the regulatory

methods used in these environments.

Once we found what we considered were innovative/unique laws, we conducted

personal interviews with appropriate local government representatives, and solicited

additional information regarding other regions of the state or country they might

recommend we consult with. Since we found that many laws were modeled on other

area’s laws, this approach was extremely helpful to identify some of the primary

individuals and organizations that first developed the law.

We also found in our research, that it was often easier or more helpful to email

prospective local leaders instead of calling. If these individuals had a list of prepared

questions in advance, or a combination of an email with questions and a voice mail,

they seemed to respond more positively. Local leaders were also very interested in

knowing that their information might be included in an internet-based law library, and

asked to be informed of the web-link when we uploaded all the information.

The identification of local leaders was the most difficult information to acquire. Unless

there was a published web or newspaper article about the law with contact information,

we often resorted to simply calling the local planning department in an attempt to find

the appropriate person to talk to. This resulted in many “blind” or “cold call” voice mails,

emails, and follow-up calls. Calls to engineering departments too often resulted in

conversation with technical field managers who did not have much background about

the law or its implementation. It was also extremely useful to be “referred” to one local

leader by another local leader; this gave us some sense of legitimacy as researchers,

and resulted in more candid, willing conversations.

Final Thoughts
A substantial amount of time and effort was required to sort through the various ways

that local governments regulate the problem of erosion and sedimentation. We tried to

look at regulations that went beyond the normal scope of construction regulation and

ones that targeted specific land uses such as: land clearing, agriculture, flood plains

(particularly where flooding is the biggest erosion threat), and the use of overlay

districts. By expanding our search we were able to compensate for the fact that many

of the most innovated ESC laws were already uploaded in TWEN.

It is apparent that a strong impetus for change in ESC regulations has been from state

or federal requirements. For example, the EPA’s Clean Water Act requirements for

compliance with Phase II have spurred municipalities and counties to update or create

their ESC requirements. Some states, such as CT, GA and RI have also required that

municipalities adopt the state model ordinances.

We also found that particularly innovative laws were created in response to strong

pressure from the public and from actual or anticipated development pressures on the

area. Particularly comprehensive laws were created in areas of the country that could

be considered more progressive, or areas that experienced extreme wet or dry

conditions throughout the year.

Through the course of research, it was also clear that there was a discrepancy between

the regulations and enforcement. The communities that seemed best positioned to

enforce their regulations held in common a multi-discipline participatory approach to

creating the regulation. Not only did this get the local environmental advocacy groups,

home builders’ associations, developers, and citizens involved and “on board” with the

regulation at the outset, but there were also no surprises in the final regulation, and a

more effective working relationship from which to build.

Another successful component to building effective working relationships between

builders and local government was educational outreach and more informal consultation

efforts. Many local governments recognized that they needed to have a substantial

educational campaign to help builders understand the requirements of the regulations

before they resorted to stricter enforcement tactics such as stop-work orders or financial


The other trend we commonly found was a lack of capability of the local governments to

enforce the regulations. In areas where enforcement was more difficult, we found that

local governments often had understaffed erosion control inspectors, or that the

governments charged the regular already over-worked building inspectors with the

additional task of enforcing erosion control. Multiple governments reported to us that

they felt presence of erosion control-specific inspectors was key to enforcement.

In the course of our research, it seems that local governments are beginning to address

the problem of erosion and sediment control from a multiplicity of angles. Historically,

ESC regulations have centered primarily on large construction or development projects.

Today, we see that these regulations are targeting resources and uses that have

historically been exempt, such as land-intensive agricultural practices and single-family

residential uses. We have also seen that local communities are beginning to respond

preemptively to development pressure, and are preserving water quality and preventing

erosion through the use of streamside buffer overlays, and development requirements

that require non-impervious surfaces and open space.


Single-Family Residential Drainage, Erosion and Sediment Control Requirements,
Douglas County
Carlo Turchiano
Drainage Erosion Sedimentation Control administrator, Douglas County
303-660-7490 x 2283
Personal interview 4/19/04

Turchiano, Carlo. TECH SESSION.ppt application/

Turchiano, Carlo. IECA TECHNICAL PAPER and BIO.doc application/msword

Douglas County Website.

Clean Water Services Design and Construction Standards Resolution, Washington
See references for Portland.

Clean Water Services website. <>.
provide or review information during the development of the program.

Erosion and Sediment Control for Land Disturbing Activities, Minneapolis
Laura Huseby
Code Compliance Officer Environmental Management, Minneapolis

Personal interview 4/13/04 and 4/30/04

US EPA, Model Ordinances to protect local resources, at (last accessed 4/40/04).

Louisville and Jefferson County Erosion Preventions and Sediment Control Ordinance,
Jefferson County
Flint Holbrook
Personal interview 4/30/04

Sarah Lynn Cunningham
Email interview 4/19/04

Erosion and Sedimentation Control Ordinance, Fairfax County
Bill Schell
General Superintendent for Environmental Facilities Inspection
Fairfax County
Personal interview 4/30/04

Asad Rouhi
Urban Conservation Engineer, Northern VA Soil and Water Conservation District
Personal interview 4/30/04

Erosion and Sediment Control Ordinance, City of Overland Park
Tony Meyers, P.E.
Supervisory Civil Engineer
Engineering Services Division
City of Overland Park, KS
Electronic mail interview 4/23/04

City of Overland Park website.

Surface Water Management, King County
Steve Foley
Senior Engineer
King County Water and Land Resources Division
201 S Jackson, Seattle 98104
Personal conversation 4/23/04

Steve Townsend
King County Department of Development and Environmental Services
900 Oakesdale Ave. SW
Renton WA, 98055-1219
Personal conversation 4/27/04

King County Department of Development and Environmental Services website.

Erosion and Sediment Control, Manorhaven
Len Baron
Superintendent of Buildings
Manorhaven, NY
Phone: (516) 883-7000
Fax:     (516) 883-4535
Personal Conversatio 4/26/04, 4/30/04

NEMO, New York NEMO program, at (last accessed 4/30/04).

Manorhaven website. <>

Mecklenburg County Soil Erosion and Sedimentation Control Ordinance, Mecklenburg
Rusty Rozzelle
Mecklenburg County Department of Environmental Protection
Water Quality Program Manager
Personal conversation 4/26/04


Erosion and Sediment Control Regulations, City of Portland
Dawn Hottenroth
City of Portland
Bureau of Environmental Services
1120 SW 5th Ave, Room 1000
Portland, OR 97204
Personal interview 4/26/04

Fred Wright
Private consultant
Formerly of Clean Water Services
Washington County, Oregon
Personal interview 4/26/04

John Nagy
Clackamas County Water Environment Services
9101 SE Sunnybrook Blvd. #441
Clackamas, OR 97015
Personal interview 4/26/04

City of Portland Auditor’s Office website.

Stormwater and Erosion Control Regulations, Clark County
Maureen Knutson, Manager
Clark County Engineering Services
1300 Franklin Street, Vancouver, WA 98660
P.O. Box 9810, Vancouver, WA 98666-9810
(360) 397-2375 ext. 4559
Electronic mail interview 4/26/04

Clark County, WA website.

Clean Water Services Design and Construction Standards
See references for Portland.

Clean Water Services website. <>.

Sonoma County Vineyard Erosion and Sediment Control Ordinance

Environmental Center of Sonoma County website.

Gail Davis
Sonoma County
Agricultural Commissioner’s Office
133 Aviation Blvd, Suite 110
Santa Rosa, CA 95403-1077

Personal interview 4/16/04.

Sonoma County Agricultural Commission’s website. <http://www.sonoma->.

Stephen Ferry, Stormwater Regulations in California’s Vineyards, 2002 (3:5)
Stormwater, at <>.

Agricultural Shoreland Management, Brown County
Jim Jolly
Program Manager
Brown Co Land Conservation Department
1150 Bellevue St.
Green Bay, WI 54302
Personal interview 4/19/04

Seth J. Wenger & Laurie Fowler, Protecting Stream and River Corridors: Creating Effective
Local Riparian Buffer Ordinances, at < >.

Other natural resource laws
City of Bellingham Land Clearing Ordinance

City of Bellingham website. <>.

Jackie Lynch
Planner II

City of Bellingham
210 Lottie St Bellingham, WA 98225
Personal interview 4/19/04

City of Columbus Hellbranch Run Watershed Protection Overlay
Cheryl Roberto
Public Utilities Director
City of Columbus
910 Dublin Rd
Columbus, OH 42315
Personal interview 4/26/04

LexisNexis Municipal Codes Library website.

City of Santa Fe Terrain and Stormwater Ordinance
Marian Shirin
Senior Planner
Planning and Land Use Department
City of Santa Fe
(505) 955-6925
Personal interview 4/27/04.

City of Santa Fe website. <>.

Town of Marana Floodplain and Erosion Hazard Management Code
Jennifer Christelman
Environmental Manager
Town of Marana
Marana Development Services Center
3696 W. Orange Grove Road
Tucson AZ 85741
Personal interview 4/21/04

Town of Marana website. <

Land Alteration Ordinance, Little Rock
Vince Floriani
Environmental Compliance Engineer
Little Rock Public Works
Public Works Department
701 West Markham
Little Rock, AR 72201
Personal interview 4/29/04

Bob Brown, Plans Development Administrator,
Planning and development,
City of Little Rock
501- 371-4864
Personal interview 4/30/04

Cliff Roberts
Email contact 3/29/04

Contact the Citizens FOR the Land Alteration Ordinances/ Little Rock Tree Foundation


Environment First, New Castle County
John Gysling, Civil Engineer
New Castle County Department of Land Use
Personal conversation 4/27/04

Alpharetta Soil Erosion and Sedimentation Control Ordinance, Alpharetta
Rebecca McDonough, Senior Civil Engineering, Alpharetta
Personal conversation 4/14/04

General References

LexisNexis Municipal Codes Web Library website.

Municipal Research & Services Center of Washington website.

International Erosion Control Association website. <>. website. <>.

Soil and Water Conservation Society website.

Forester Communications website. <>.

Storm Water Center. <>

i    The Center for Watershed Protection, A Presentation on Erosion and Sediment Control (ESC) , at (last visited April 30, 2004).
ii    EPA, Adopt your watershed, at (last visited April 30,
iii   EPA, Mid-Atlantic Integrated Assessment, at (last
accessed April 30, 2004).
iv    VT Agency of Natural Resources, Federal Clean Water Act and NPDES, (last visited April 30,
v     The Chesapeake Bay Program, Sources of Sediment Loads to the Bay, at (last visited April 30, 2004).
vi    The Center for Watershed Protection, A Presentation on Erosion and Sediment Control (ESC) , at (last visited April 30, 2004).
vii    VT Agency of Natural Resources, Federal Clean Water Act and NPDES, (last visited April 30,
viii   VT Agency of Natural Resources, Federal Clean Water Act and NPDES, (last visited April 30,
ix    VA Soil and Water Conservation, Virginia's Erosion and Sediment Control Program (last visited April 30, 2004).
      Mecklenbrg County Code, Soil Erosion and Sedimentation Control Ordinance §Section 6.a (2002).
      Personal conversation, Rusty Rozzelle, 4/26/04.
xii    Minneapolis Code of Ordinances §Title3.52.10 (1996).
xiii   Minneapolis Code of Ordinances §Title3.52.270 (1996).
       Jefferson County, Kentucky Code of Ordinances §159.01C (2001).
       Personal Conversation with Flint Holbrook April 30, 2004.
       Jefferson County, Kentucky Code of Ordinances §159.04 A (2001).
        Portland Code §10.10 (2000).
        Washington County Code §8.00 (2004).
       Fairfax County Code § 104.01.07.
       Personal Conversation Asad Rouhi, 4/30/04.

xxii    Sonoma County Code §5216.30v5 (2000).

xxiii    Stephen Ferry, Stormwater Regulations in California’s Vineyards, 2002 (3:5) Stormwater, at
xxiv     Personal interview with Jackie Lynch, 4/19/04.
xxv      City of Bellingham Land Clearing Ordinance (1992)

xxvii    Personal interview with Cheryl Roberto, 4/26/04.

         Mecklenbrg County Code, Soil Erosion and Sedimentation Control Ordinance §Section 7. (2002).
         Mecklenbrg County Code, Soil Erosion and Sedimentation Control Ordinance §Section 9. (2002).
         Mecklenbrg County Code, Soil Erosion and Sedimentation Control Ordinance §Section 12. (2002).
         Mecklenbrg County Code, Soil Erosion and Sedimentation Control Ordinance §Section 13. (2002).
         Personal conversation with Bill Schell, April 30, 2004.
          Mecklenbrg County Code, Soil Erosion and Sedimentation Control Ordinance §Section 8. (2002).
         Minneapolis Code §52.270.
      Jefferson County Code §159.03 B(2001).
        Personal conversations with Bill Schell and Asad Rouhi, 4/30/04.
        Personal conversation with Asad Rouhi , 4/30/04.
      Portland Code §10.30.030 (2000).
    Personal conversation with Rust Rozzelle, 4/26/04.
    Personal converation with Carlo Turchiano, 4/19/19/04.
xlii    Personal interviews with Dawn Hottenroth and John Nagy, 4/26/04.
xliii   Personal interview with Fred Wright, 4/26/04.
xliv Personal interviews with Dawn Hottenroth, John Nagy, and Fred Wright, 4/26/04.
     Personal communication Sarah Lynn Cunningham, 4/19/04.
     Personal conversation Flint Holbrook, 4/30/04.
xlvii    Electronic mail interview with Tony Meyers, 4/23/04.
xlviii   Natural Resources Defense Council, Long Island Sound Municipal Report Cards (1998), At
     Personal communication Len Baron, 4/26/04.
l    Personal interview with Dawn Hottenroth, 4/26/04.
li    Personal interview with Dawn Hottenroth, 4/26/04.
      Personal communication with Bill Schell, 4/30/04.
liii   Electronic mail interview with Maureen Knutson, 4/26/04.
liv    Stephen Ferry, Stormwater Regulations in California’s Vineyards, 2002 (3:5) Stormwater, at
lv     Personal interview with Gail Davis, 4/16/04.
       Personal communication with Jim Jolly, 4/19/04.
lvii    Personal interview with Jacki Lynch, 4/19/04

lviii   Personal interview with Marian Shirin, 4/27/04.
lix   Personal interview with Jennifer Cristelman, 4/21/04


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