Why is the Illinois Department of Agriculture Determining Stormwater Rules for Cities?

Winter flooding across a farm field

Recently I wrote about the draft release of Post-Development Stormwater Runoff Performance Standards for Illinois. And in discussions with colleagues over the last few weeks, I have not heard any positive support from anyone who has a professional background in stormwater management or regulation. Instead the consensus among stormwater professionals regarding the draft is that the entire document should be rewritten and the recommendations reconsidered because they are based on few facts, will not work, and will increase project costs significantly. So it makes you wonder how did something that so poorly addresses the reality of stormwater management get this far, and why is the IEPA seriously considering accepting recommendations from a group with a majority of members who have absolutely no background in stormwater management or regulation?

To begin answering this question, you need to look at who is running the show. This was one of the first questions I heard from everyone – why in the world did the IEPA arrange to have the Association of Illinois Soil and Water Conservation Districts (AISWCD) lead this effort? There are so many counties who could have been consulted instead – they bring decades of stormwater management and regulation to the table. Yet none were contacted. They could have reached out to engineers who have spent their career formulating stormwater designs, managing stormwater projects, and maintaining and regulating stormwater facilities. Yet only one recognized engineering expert with a background in all of these was picked to be in the workgroup.

So again, why the AISWCD? And just who is the AISWCD? Their website explains the group is

"a not-for-profit organization governed by a board of directors who represent the state’s 98 Illinois Soil and Water Conservation Districts."

So the purpose of this private group is to represent the Soil and Water Conservation Districts in Illinois – a group of governmental agencies. In 2010, the group received $231,663.09 in dues from these districts. So the next question is what are the Soil and Water Conservation Districts? (Of course a side question is why does a group of governmental agencies need a private, non-profit group to represent their interests, but that's another story.) The districts were created through an act of the Illinois Legislature and appear to be part of the Department of Agriculture. There is an advisory board to oversee these districts – here is the State's page indicating those board members: http://appointments.illinois.gov/appointmentsDetail.cfm?id=256

As you can see, the members of the advisory board for the Districts are supposed to come from Agriculture – not stormwater related professions. This is particularly interesting to note when you take into consideration that one of the first statements made at the public hearing held in Aurora regarding the new stormwater recommendations was that anything related to agriculture was not on the table – would not even be considered. It is also interesting when you read the recommendations and see that there is no mention of relying on the State's 303d list of impaired waters to make any decisions. Of course when you look at the State's official report regarding land uses contributing to pollution of these streams, you will see that agriculture is one of top contributors – much more so than what is contributed by stormwater runoff from communities and significantly more so than what is contributed from highways.

Sources of Stream Impairments
Potential Source Stream Miles Impaired
Source Unknown 7097
Atmospheric Deposition – Toxics 3050
Crop Production (Crop Land or Dry Land) 2576
Channelization 2471
Agriculture 1395
Municipal Point Discharges 1374
Loss of Riparian Habitat 1245
Urban Runoff/Storm Sewers 1207
Animal Feeding Operations 652
Livestock (Grazing or Feeding Ops) 290
Combined Sewer Overflows 253
Highway/Road/Bridge Runoff 110


It also makes you wonder when you ask a work group member what the goals were for the recommendations and cleaning up the environment or improving our water quality was not the answer. So to summarize, the IEPA put the wolf in charge of the hen house – oh, I mean, the IEPA put the Department of Agriculture in charge of deciding stormwater standards and regulations to be imposed only on home and business owners, municipalities, and developers. And because no obvious goal has been stated in the recommendations, it makes you wonder is the goal really environmentally related or is it a protection of agricultural interests cloaked in the benevolent perception of helping the environment?



A Day in the Life of a Civil Engineer – Day 59

Day 59

Budget Analysis

As I mentioned in an earlier post, I had our intern create a spreadsheet so I could track the money that has been spent in the accounts related to my division. Today I started going through that document checking it against invoices and making sure each entry was coded correctly. I also need to check the remaining balance against what was budgeted and arrange to make any necessary changes if needed. Overall, it's a cumbersome and time consuming process because our software is so outdated that most of the comparison and checking has to be done manually. But it's important to do so any overages or amendments to specific line items in the budget are addressed. So far it looks like I am off in our uniform rental line item, and it looks like this happened because the safety shoes were coded here instead of under safety equipment. So that's at least one adjustment I'll need to make. 

City accounting is not something they taught us in engineering school. Yet it is an important part of my job. We had an economics class where we learned about calculating the value of money as it relates to interest and depreciation. But budgeting and accounting were not really covered, and from what I understand municipal accounting is very different from regular accounting. The first time I really got heavily involved in it was at my last job. Fortunately we had a really great comptroller who helped me understand how it all works.  I can't quite pinpoint exactly how she did it, but I always felt I had a good handle on where we stood with finances in each account. We also had an outstanding accountant who was very patient and explained the things we couldn't figure out on our own. I'd have to say it took me about five years or more of working with it to feel I really had a good understanding of how it all worked. And every now and then I'll find out there's still something I didn't know. 

Subdivision Meeting

Several city staff members met with representatives of a bank that has an interest in an unfinished subdivision. Not all the improvements have been completed in this development, and the city still holds a letter of credit for the remaining work. Because nothing has been done for several years and no further building has taken place, the city is requesting the work be completed. So this group came in to find out what was left to be done. We need to send them the plans for the subdivision, and then they are going to come back with a proposal for moving forward.

Water Main Change

We had a call today from a contractor who is bidding on a water extension that will be built by an agency other than the city. He requested that we allow changes to the material used for the water main and changes to the location. Because we did not design the project – only approved it, we suggested he contact the engineer who did the design work. Our concern was we were not the designers – only the reviewers – and an IEPA permit has already been issued for the work. Later in the day we talked to the engineer and gave him an idea of what types of changes we would possibly approve. And we discussed the need to get a new IEPA permit if necessary. He is going to research what could be done and if a new permit would be needed. If any changes are made, he will also send us amended plans for approval.

ADA Ramps for Road Project

Because there always seems to be so much confusion over how curb ramps should be built to comply with the ADA law, I am thinking about drawing up some details for specific intersections to help everyone better understand what needs to be done at certain locations. Today I took our intern out to show him what information we would need from the field so that we could prepare these details.


A Day in the Life of a Civil Engineer – Day 44 and 45

Day 44

Hopefully today will be the last day I have to combine more than one day in a post – finally getting somewhat caught up. Today, I went through more emails. And I finished up the final approval letter for that development I worked on last Friday – it is for an industry in the city that is expanding. We had several meetings then throughout the day:

South Street Bike Trail

The county has been planning on building a bike trail underpass at one of the busiest roads we have in the city. Right now it is a four-land road with a 45 mph speed limit with plans to someday expand it to six lane. The number of cars is probably around almost 30,000 a day. So crossing it can be a challenge on a bike or as a pedestrian. In order to help get people across, the county is proposing this underpass. They have received funding for a portion of it from the state. So now, they are ready to move forward and finalize the design then go to construction. They told us today they are looking at building it in fiscal year 2013. We discussed some of the coordination needed between the city and the county to get the project done. They will be acquiring an easement from us, and we will be entering into an agreement. But the terms of all that still need to be worked out.

Utility Proposal

A utility has proposed an installation in our community that is unlike any other submittal we have yet received. So we met today to discuss the information. From my perspective, I had received an application for a right of way permit, but upon reviewing the plans I realized the proposed location is not within the right of way. So the application is not valid for this case.

Campbell Street Parking Lot

We also met to continue discussions about our plans to build a parking lot in our downtown area. We were mainly updating other staff members of the status. The city is still working out the easements with the adjoining owners that will be necessary to  finalize the design.

Concrete Construction

A couple of us also had to inspect a few areas throughout the city that are targeted for improvements. We are in the process of obtaining bids for a small amount of concrete repairs we want to finish up this Fall.


Day 45

Finally today! This morning I worked on a multitude of issues. I completed our mid-year goals and strategies report and sent it off to my supervisor. Then I made sure my forms were ready to conduct performance evaluations later this month. All of us also worked on writing up our monthly reports for all our projects.

We had a bid opening today for our culvert project. There were a few bidders and the project seemed to come in near the engineer's estimate so we will now prepare the information to take it to the council for approval. Before I mention anything else about this publicly, I am waiting for an official determination of the successful bidder.

And our contractor for our alley project finally was able to place half of the concrete pavement. After last week's rain, we have had to wait a few days for the base to dry out. But today, it was finally ready for the pour.

In the afternoon, we had a staff development review meeting to go over a small proposed development in the city. It's so helpful to have all of us get together at once and just discuss the project after we've had some time to look it over. Many people brought up good discussion points. So now the review engineer will incorporate the comments into his response and send it out later this month.



A Day in the Life of a Civil Engineer – Days 39 to 43

Day 39 through 43

Day 39—Monday, Sept. 26

On Monday I attended our staff development meeting. We discussed several of the projects that are either under review or construction. We also talked about the challenge of helping people understand and follow through our development process which is as follows: during the concept stage, our staff meets with the applicant and discusses the project and explains the steps necessary to move through the process. Then once we receive a submittal, all departments prepare a review and our development department sends out a comprehensive review letter. This submittal-review process then repeats until the plans have been approved. Then permits can be issued and construction can begin. If a special use or zoning change is required, then there is a planning commission meeting, recommendation, and subsequent council consideration prior to permits being issued and final approval of the plans.

So we are trying to come up with a solution that will readily convey the process and provide guidance throughout. We have a few ideas, but will continue the discussion over more meetings.

ARRA Project Close-out

I’ve been working on closing out last year’s federal ARRA project for some time now. It is always amazing to me that design can take a couple months, construction can be completed in a month or two, but finalizing the close-out documents can take a year or more. This can happen for many reasons, but in this case, it’s been because I’ve been waiting for certifications for materials used on the job. And I need this information because I cannot determine the final quantities used on the job or send in pay requests for items unless the contractor provides proof that the material meets the specification. Finally for one of our items, we had to just delete it because the subcontractor simply would not provide the documentation. The general contractor and I even tried to get it from the supplier of the material, but they also would not provide the information.

So today I went through all my material documentation and made sure it met the requirements and that I had all the forms filled out correctly and signed. I also checked all the quantities and created what is known as a balancing authorization. This is necessary to prepare and submit for approval at the end of the job because we can only pay for the actual amount of an item that has been approved. For example, if the project was bid out at 700 tons of asphalt, but we actually used 750 tons, I would need to first send in an authorization asking to add 50 tons of asphalt to the project before I could pay the contractor the full 750 tons. Until I received approval for that extra 50 tons, I could only submit a pay request for 700 tons. And in reverse, if we only used 650 tons, I could pay for the whole amount, but at the end of the job, I would need to deduct 50 tons from the project so the final amounts equaled exactly what was actually used.


Day 40—Tuesday, Sept. 27

On Tuesday, we had a meeting about a few developments that still have outstanding letters of credit. The reason we are looking into the status of these projects is because they’ve been out there for some time, and there are still some public improvements that need to be made. It seems like many cities are dealing with this because of the economy and housing crisis. People stopped building in subdivisions that were not yet completed and the developer never finished the improvements. But the people who did build don’t want to wait for the economy to turn around to get the road finished, the trees planted, and their sidewalks placed. So cities are moving forward to complete those improvements, particularly in cases where a letter of credit was filed that can help pay for them.

After lunch, our intern and I drove up to IDOT to drop off the documents I had prepared yesterday. We like to do this because some paperwork is too important to just put in the mail. It was nice because I was able to meet some of the people I have been working with only over the phone, and our intern was able to see the process and meet some of the people we work with.


Day 41—Wednesday, Sept. 28

This morning we had our bi-weekly staff meeting. Everyone shared the status of their projects as usual. We have one culvert lining project out to bid and have already started getting ready for next year’s road project. Then during the lunch hour, the group of us who were traveling to Prairie State left to drive down south. This trip took up the remainder of our day.


Day 42—Thursday, Sept. 29

Prairie State

Prairie State Power Plant

On Thursday, we toured the Prairie State Power Plant and Lively Grove Mine. Our city is one of eight partners making up the ownership of this facility. So our staff regularly attends meetings, and a group of staff and elected officials take an annual trip to see the progress of construction of the plant. This was my first year to go on the annual trip, and it was particularly interesting because the plant is nearly complete. The first coal was fired last week in the first unit, and the operators expect to feed into the grid for the first time next week. There is another unit that is currently under construction and has a completion date of mid 2012.

Our day started with a quick update on the facility. Then several of us were taken down into the mine in groups of six. This was the first time I had ever been in a coal mine. The Lively Grove Mine is about 250 to 275 feet deep with tunnels laid out in a grid pattern and measuring 18 feet wide by about 7 feet tall. I wish I could have taken pictures to share with everyone the experience, but they were strict about no photography allowed. Before we could go in the mine, we were outfitted with safety equipment and taught how to use an oxygen container in case something happened while we were down there. I even wore a hard hat with a little miner light on it.

We drove down into the mine in a small open metal vehicle down a steep slope. Once at the bottom we followed a main corridor excavated out of the coal and now lined with lime dust. Eventually we stopped and got out to walk. Our guide took us to where a machine was cutting out the coal and conveying it to a vehicle. This vehicle when full would then take the load of coal, up to 10 tons, to the main conveyor and discharge it onto the belt. Then it would return to be loaded again.

We also watched a crew installing the metal mesh and supports for the roof of the tunnel. They showed us the metal rods and “glue sticks” they would push up into the roof to create a header. Then a wire mesh would be anchored over these. While the ceiling of the tunnel seemed to be made of rock, the floor appeared to be clay covered in lime and coal dust.

One of the interesting things I eventually figured out was to look at something, I would need to turn my head directly towards it. This was because the only light came from the lights on our hats. And I noticed when you talked to someone, you had to make sure you were not focusing the light on their face.

I also couldn’t help thinking while down there about my ancestors, many of whom worked in coal mines in Kentucky and in England. The safety precautions now are so much more intense than they were back then. We had ventilation, gas detection, oxygen, lights, power, wireless GPS, and many more features they did not have in the early 1900s.

After the mine tour, we were taken through the actual plant. Here power is generated from turbines turned by steam. The steam is created by burning the coal taken from the mine. They told us this is the largest coal-fired power plant that has been built in the U.S. in the last 30 years. It had to be built to meet strict air quality regulations—$1 billion was spent just on the air quality treatment and components.

The plant also uses 25 million gallons of treated water a day for their operation. They have an onsite pond and treatment facility to produce high quality water. When finished the power plant will produce 1600 MW of power for the grid and 150 MW for its own operation.


Day 43—Friday, Sept. 30, 2011

On Friday, I worked to catch up on emails and other issues that had come up while I was gone. Most of my day was spent working with other staff to resolve the review of a development. They owners of this project had considered changing the design of some of the infrastructure, but since they already had their plans approved, they decided not to go ahead with the change. It would have required them to re-submit and wait for another review. We also had a conference call with the owner/developer and explained they could not begin construction on any work requiring an IEPA permit until it was approved and a copy sent to us.

Smith and Richardson Tour

A few of us also were fortunate to be able to tour another manufacturing business in our city—Smith and Richardson. This company has been in Geneva for many years and moved to their current location in the 1940s. They make all different kinds of parts for many different industries. An interesting issue brought up during our tour is that our country does not seem to be training people to work in these types of industries. This company has job openings for skilled labor, but they have difficulty finding people who can work that type of job. This is something we have been hearing at several of our tours. Because U.S. schools are so focused on pushing kids to go to college, few end up pursuing careers in manufacturing or other trades. So these industries have job openings, but there is no one to fill the jobs.

Retirement Lunch

Today was also the last day for one of our co-workers who worked at the wastewater plant. So during lunch the people at the plant arranged to cook food, and we were all invited to eat down at the plant. Only a bunch of public works people would gladly show up to eat lunch on the lawn of a wastewater plant next to the clarifiers and think nothing of it.


A Day in the Life of a Civil Engineer – Day 29

Day 29

Automatic Meter Reading Research

For about a year we've been researching automatic meter read (AMR) systems. Because our neighboring communities to the north and south have also been going through this process, we decided to combine our efforts and collaborate on the research. So as a group we've met with several vendors over the course of the past year. Today we all got together to summarize our findings and to discuss where we go from here. We decided to call in one of the vendors to discuss a few of the options we thought about pursuing. Although I think the AMR technology is awesome and very much enjoy researching the options, what has really been rewarding has been the opportunity to work with the other cities on this project. Like my co-workers, the staff in these cities are very knowledgeable, professional, and great to work with.

Special Service Areas (SSA)

Later in the day a few of our staff met to continue the discussion about creating an SSA for a certain area in our community. Again, these SSAs help provide a funding vehicle for improving  a specific subdivision. Although we dont' always levy taxes in each SSA, it's still good to have it in place in case the neighborhood needs to have maintenance or work done within the common areas of their subdivision.

Permits and Development

One of the utilities in our area is still trying to get a line installed in our downtown area. They submitted a new plan showing where they want to install their line, but they showed no other utilities on the drawing. So I had to let them know I cannot really review it without knowing where the other utilities are. On Monday, I'll have to make a copy of our utility maps for that area and send them to the utility so they can add them to the drawings. I also worked a little bit with a development that has re-submitted plans for review. We are still waiting for them to resolve the location of the electric so I could not move forward with their approval this week. Hopefully it will be resolved next week so I can complete by review.



A Day in the Life of an Engineer – Day 18

Day 18

Unfortunately today I don't have much to post because I took part of the day off to take care of things at home. But this morning, before I left work, I did work again on some permits finalizing the utility permits. Also, because of some new information related to the development for which I sent out the review letter yesterday, our staff spent some time today working to take care of and address the related issues.

The other task I primarily worked on this morning was filling in the remainder of the missing information on the grant survey for our DCEO grant. Then I gave it to my supervisor to check.

And we also discussed the schedule and approach for setting up the sealcoating of our parking lot. This is the third weekend we will try to get it done – it rained all the other weekends when they were scheduled to do the work.

One of the things I did at home which is related to work was participate in a conference call with some other great people who work for local government. The folks at GovLoop had arranged the call so we could give feedback on their site. If you work in or for government, it's a great site to join, and I highly recommend clicking over there and checking it out: http://www.govloop.com. As of today, they have about 46,000+ members, most of whom work for government. Not only have I learned a lot by reading the blog posts and comments from people, but I've met a lot of awesome people by interacting on the site. If you do join (it's free to do so!) make sure and add me as a connection! 

Well, anyway, back to a full day tomorrow!