Document j6XGpGdXQxnzoy6BXwXL8qqN

To: Cc: From: Sent: Subject: Dravis, Samantha[dravis.samantha@epa.gov] Ward, Thomas[TWard@nahb.org] Birk, Eva Mon 4/17/2017 2:18:42 PM FOLLOW-UP to NAHB ADMINISTRATOR MEETING - Stormwater Ms. Dravis, Jim Rizzo and NAHB's senior officers met with yourself and Administrator Pruitt earlier this month to discuss a number of issues. Thank you again for this opportunity. I'm writing in regards to follow-up on stormwater specifically. If possible, we'd like to set a short meeting with you sometime this or next week to provide a more in-depth briefing on two time-sensitive topics: 1. Streamlined Small Lot Permit for Residential Sites o NAHB would like to continue to work with the agency to develop a streamlined "small lot" construction stormwater permit. We are concerned that these efforts may be stalled. NAHB worked with Office of Wastewater Management (OWM) staff over the past three years to develop a streamlined voluntary compliance plan template for residential sites. However, we do not yet have a green light on developing an EPA permit based on this model. NAHB believes the cost savings to single family builders from shrinking the current -300 page permit down to 20 pages would be enormous. Work needs to start soon to allow time for NAHB and other stakeholders to provide feedback, develop new software, and organize outreach to our membership. As of now we are not confident that OWM is committed to pursuing this project. 2. Federal Overreach in the NPDES Stormwater Program o In the four states where EPA is in charge of stormwater permitting, we've seen actions that far outreach the scope of the Clean Water Act. Most recently, Region 3 included a provision in D.C.'s draft MS4 permit which actually mandates that the city spend $12.75 million local dollars to establish a Stormwater Retention Credit (SRC) purchase agreement program. We are gravely concerned with this type of federal meddling in municipal affairs and the precedent this permit will set. The timeline for action is tight here as well. Region 3 will likely finalize the permit in the next few weeks/months. We look forward to discussing these issues in person. Thank you again for your time earlier this 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008177-00001 month, and feel free to contact me at the number below with any questions. Kind regards, Eva ogram Manager, Environmental Policy National Association of Home Builders 120115th Street, NW ' Washington, DC 20005 oooo d: 202.266.81241 M - 1 ' r . m > t - We Build Communitie April is New Homes Month - celebrate with your favorite home buyer! Members saved $20 million last year with Member Advantage! Jump on those member discounts at nahb.org/ma. * * `This electronic message, including attachments, may include information that is confidential, proprietary and/or legally privileged. It is intended solely for the use of the individuals) named as recipients in the message. Any unauthorized use, disclosure, copying or distribution is prohibited. If you are not the intended recipient or have received this e-mail in error, please contact the sender by replying to the e-mail and delete all copies of the original message.* * * 17cv1906 Sierra Club v. EPA 6/22 Production ED 001523 00008177-00002