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Houston Lack of a Comment Period for Cosmetic Cleaning BMPs

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The following information is at Storm Water Program Litigation .

April 2004: EPA Guidance on the Ninth Circuit Court Decision for MS4s [PDF Format] - This memo provides interim guidance on implementing the Stormwater Phase II program for Municipal Separate Storm Sewer Systems (MS4s) in light of the decision by the U.S. Court of Appeals for the Ninth Circuit (Environmental Defense Center, et. al. v. EPA, September 15, 2003). The guidance covers several issues related to the implementation of the MS4 program, including public availability of NOIs, opportunities for public hearings, and review of NOIs by permitting authorities.

Houston did not give the industry a chance to comment on their BMPs before implementation.

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