HomeMy WebLinkAboutStormwater Program Update (9/6/13)
Program Update
City of Bozeman Stormwater Program
September 6, 2013
Compiled By:
Kyle Mehrens
GIS Technician
City of Bozeman
Jon Henderson
GIS Manager
City of Bozeman
Figure 1 - Stormwater Entering Bozeman Creek
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Executive Summary
“The Program evaluation resulted in eight (8) Commendable Elements, sixteen (16) Program
Deficiencies, twenty-three (23) Recommendations for Improvement, and one (1) Permit
Violation.”
- Results of the 2011 City of Bozeman Stormwater Program (MS4 Permit) Audit -
Overview:
The City of Bozeman’s stormwater system is a complex network of pipes (~70 Miles), manholes
(1,100), catch basins (2,750), outfalls (492), and detention ponds (~300). As Bozeman continues
to grow, responsibly expanding a comprehensive stormwater management program will promote
continued permit compliance and improve local water quality.
This document will outline Bozeman’s current approach, successes, and deficiencies relating to
the following six minimum control measures it must meet each year.
- Illicit Discharge Detection and Elimination Program
- Pollution Prevention and Good Housekeeping
- Public Outreach and Education
- Construction Site Stormwater Runoff Control
- Post Construction Stormwater Management
- Public Participation and Involvement
Information regarding these requirements has been compiled during the past year through an
extensive infrastructure inventory and condition analysis effort. With a newly developed
database, Bozeman is now in a position to leverage observed and documented information to
effectively move forward.
Current State:
With a limited maintenance program and inadequate enforcement practices, Bozeman’s
stormwater system is currently functioning at an impaired state. Additionally, other critical
components such as public outreach methods, pollution prevention programs, and construction
management work flows need extensive development. Without a program expansion, Bozeman
will face continued degradation of its stormwater assets and recurring permit violations into the
future.
Recommended Action:
Implementation of recommendations from the 2008 Stormwater Facility Plan, understanding of
industry best practices, collaboration across departments, and the use of data driven decisions
will assist in an effective program expansion. Understanding the complexities of stormwater
utility funding, including continued community outreach should be supported to ensure a
transparent and justifiable approach.
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Illicit Discharge Detection and Elimination Program
Illicit Discharge Defined As:
“...any discharge to an MS4 that is not composed entirely of stormwater...”
- Environmental Protection Agency
Introduction:
In response to an audit conducted by the Montana Department of
Environmental Quality (DEQ) and recommendations from a 2008
Stormwater Facility Plan, an illicit discharge detection and
elimination program (IDDE) was developed in the spring of 2012. In
total 514 outfalls and 7,200 features have been mapped, identified,
and inspected by four temporary technicians and one full time
employee. Multiple illicit discharges violations have been
documented, studied, and enforced promoting citizen awareness,
public safety, and improved water quality.
Description:
In order to remain in compliance with Bozeman’s Municipal
Separate Storm Sewer System (MS4) permit, it is required that
potential illicit discharges are continually identified and addressed.
Throughout Bozeman, these discharges occur as single or
reoccurring events and all must be managed effectively to protect
local water resources.
Examples:
Montana State University Paint Shop – Paint effluent was identified
to be discharging into Bozeman’s stormwater system through the
analysis of underground pipe video by city employees. MSU staff
was notified immediately and the illicit discharge was resolved
(Please see Appendix A-1 for a detailed report).
Leaking Oil from a Local Citizens Vehicle – A complaint regarding
an illicit discharge was identified and reported by Management
Associates to City of Bozeman staff involving oil leaking from a
tenets vehicle. The vehicle owner was contacted regarding the issue
and they took immediate action in addressing the complaint (Please
see appendix A-2 for a detailed report).
Figure 2 - Mapping in Progress
Figure 4 - Illicit Discharge
Figure 3 - Illicit Discharge
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Common Practices:
Multiple factors must be examined prior to fully engaging in a long-term program such as
growth potential, amount of aging infrastructure, funding mechanisms, state and federal permit
requirements, overall citizen engagement, and extended goals. Once these factors are weighed, a
fully developed program can be implemented. Industry best practice is to have an employee on
staff fully educated and involved with the IDDE program, which is then able to clearly
communicate, educate citizens, and enforce municipal code (Please see appendix A-3 for an
example).
Recommended Action:
Based on recommendations taken from the 2008 Facility Plan, in combination with field
observations compiled throughout the last fifteen months, it is suggested that additional staff
resources may be necessary in order to maintain a long-term commitment to this program.
Future Work
Develop a scope of work regarding the continuation of the
IDDE program and merge it into the job description of the
newly funded Public Works Technician.
Coordinate and standardize stormwater enforcement
efforts, education practices, and violation proceedings
with Bozeman’s code enforcement officer, GIS staff,
engineering department, and building permit division.
Train select crews on how to identify illicit discharges and
develop a consistent procedure in alerting proper internal
staff.
Figure 5 - Illicit Discharge
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Pollution Prevention and Good Housekeeping
In reference to the 2013 condition assessment:
“…the majority of the issues uncovered by TV footage and inspection are related to ‘Operational
and Maintenance’…”
- Mike Dilbeck, Stormwater Foreman
Introduction:
To remain in compliance with the City’s MS4 permit, Bozeman must
establish a sustainable, documented, and efficient stormwater
maintenance and replacement program. Based on recommendations
from the 2008 Stormwater Facility Plan, including updated inventory
and condition information of critical infrastructure, it is imperative
that Bozeman define a clear process for operating and maintaining its
system.
Description:
Information gathered in the field upon inspecting over 7,000 stormwater features and 10 miles of
underground pipe through the past year has provided insight into a variety of issues. The
following list represents critical components that must be addressed.
Maintenance
Private vs. Public
Enforcement
Capital Planning
Examples:
Inlets/Manholes-
All catch basins/manholes require a consistent level of maintenance. Based on the scope (3,872
total) and condition of recent field observations, including known areas of flooding, it is evident
that we need to expand our current operations in order to support continued improvement in
function and water quality (Please see Appendix B-1 for images of
this issue).
Gravity Mains-
Through an extensive TV analysis (~25% of System), cracking, root
intrusion, sediment in fill, improper segment replacements, and pipe
material deterioration has been identified and recorded. (Please see
Appendix B-2 for images of this issue).
Figure 6 – Stormwater Entering Creek
Figure 7 - Sediment in Inlet
Figure 8 - Pipe Deterioration
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Detention/Retention Ponds-
Most ponds exist on private property. Many of the detention
basins have not been maintained properly (Please see Appendix B-
3 for images of this issue).
Common Practices:
An effective maintenance program requires a guaranteed funding mechanism, dedicated staff
resources, and a well developed process. Montana cities such as Kalispell and Helena currently
fund established utilities to manage both long and short-term stormwater goals.
Recommended Action:
A meaningful level of service should be defined for all assets
consistent with Commission and community goals. Once
Bozeman fully understands its budget potential, decisions
regarding the expansion of the program should be addressed as
follows:
Personnel
Equipment
Maintenance Responsibility
Enforcement
Future Work
Create and implement goals relating to the cities approach
to continued compliance, water quality preservation efforts,
and continued level of service.
Expand the programs efficiency, transparency, and
documentation using GIS and Cityworks.
Figure 11 - Crews Cleaning Sediment
Figure 10 – Non-Functional Pond Outlet
t
Figure 9 – Buried Pond Inlet
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Public Outreach and Education
In response to a failed attempt at establishing a stormwater utility in Dover, NH:
“… but we could have used more outreach in advance of the vote. I would strongly encourage
others to take the time to do this, even if they don’t think it’s necessary.”
- GHD Consulting
Introduction:
With the rapid growth of the City of Bozeman’s Stormwater
Program, it is necessary to educate the public in order to
maintain continued expansion and remain in compliance with
Bozeman’s MS4 permit.
Description:
In order to effectively advance stormwater related programs, Bozeman must keep their processes
transparent and justifiable. Leveraging outreach and education opportunities such as community
events, collaboration with local organizations, and attraction of positive media attention will help
in creating greater public awareness.
Examples:
Stenciling Effort –
Collaboration with two local non-profits allowed for a
successful outreach campaign. With extensive media attention,
employees were able educate citizens city-wide, display
Bozeman’s continued commitment to its stormwater program,
and demonstrate its dedication to the natural resources
surrounding the city (Please see Appendix C-1).
Educational Materials –
The development of stormwater related posters, pamphlets, and maps have introduced a broader
stormwater discussion among staff, elected officials, and the public. This increased level of
understanding favorably impacts the environment, public perception, and Bozeman’s ability to
advance its program (Please see Appendix C-2).
Common Practices:
Cities regulated under Phase 2 MS4 permits across the country employ staff directly involved
with establishing and furthering stormwater education and outreach.
Figure 12 - Teaching Local Students
Figure 13 - Stenciling Stormwater Inlets
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Recommended Action:
Detailed recommendations from the 2008 Stormwater Facility Plan suggest that Bozeman
employ additional staff to develop and implement this work. As the scope of the program
expands, these positions may have to be adjusted.
Future Work
Continue to plan and implement stormwater
community outreach practices focused around
utility discussions through the next year.
Address staffing issues which will alleviate
pressures currently placed on supporting
departments.
Figure 14 - Teaching Students about Stormwater
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Construction Site Stormwater Runoff Control
“During a short Period of time, construction activity can contribute more sediment to streams
than is naturally deposited over several decades.”
- Department of Environmental Quality, Best Management Field Guide
Introduction:
Improper construction site stormwater management is a
prohibited offense and subject to enforcement under both local
and state laws. Bozeman’s MS4 permit requires the city to
regulate the proper permit coverage and best management
practice (BMP) implementation for active construction sites
contained within its boundaries.
Description:
Through field work, it has been documented that improperly
regulated construction sites of all sizes contribute to water quality pollution and increased
maintenance costs. Currently, permitting and enforcement is underutilized and could result in a
future MS4 Permit violation and continued degradation to local waters.
Examples:
Active Construction Under 1 Acre –
Construction sites of this size exist throughout the city and if
unregulated they have the potential to significantly impact local
waters and infrastructure. Without a consistent permit and
enforcement program in place, effectively addressing the
source issue is difficult.
Active Construction Over 1 Acre-
Although regulated by a SWPP permit issued by the DEQ, Bozeman officials must regulate these
sites in order to reduce intervention from state agencies. Upon continued non-compliance and
the exhaustion of in-house staff, DEQ officials reserve the right to enforce as necessary.
Common Practices:
To properly manage and enforce an effective stormwater program, a dedicated staff resource and
a well defined process is necessary. Education is utilized as the primary enforcement tool, but
upon continued non-compliance many cities will pursue violations until the problem is resolved.
Figure 15 - Construction Site Runoff
Figure 16 - Improperly Protected Inlet
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Recommended Action:
Recommendations from the 2008 stormwater facility plan
and documented issues identify a need for a full time
employee. Additionally, it may be necessary to re-develop
the current permitting system to provide an easy approach
for contractors to apply, enact, and reach compliance for all
developments.
Future Work
Discuss the potential to hire additional staff to
support the expansion of this program.
Further understand the current permitting process
and append to fill current gaps.
Continued collaboration with DEQ officials to
ensure a strong working relationship.
Figure 17 - Proper BMP Implementation
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Post Construction Stormwater Management
Measure Designed to:
“… develop strategies for planning, design, and construction of development to reduce pollutant
loads and storm flows after construction is complete.”
- Environmental Protection Agency
Introduction:
With the consistent growth throughout Bozeman, the city
must responsibly plan and design all new developments to
promote continued natural resource health and MS4 permit
compliance.
Description:
Current Bozeman design standards effectively address this minimum control measure. Ensuring
proper enforcement and continued support by all departments is necessary to remain in
compliance.
Examples:
City of Bozeman Design Standards -
All new development is required to return post construction flow levels to a pre-construction
state using designed stormwater infrastructures.
Common Practices:
Design standards and strict planning protocols are standard for many municipalities under MS4
permit coverage.
Recommended Action:
Continued interdepartmental communication will be necessary to continually maintain these
standards as Bozeman’s planning and engineering processes change over time.
Figure 18 - Smart Growth
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Public Participation and Involvement
Goal of Minimum Control Measure -
“Raise public awareness of the stormwater system so the public understands and supports the
city stormwater program”
- 2008 Facility Plan Completed by HDR
Introduction:
Establishing favorable public perception is necessary to meet the
long and short-term goals of Bozeman’s stormwater program.
Through continued interaction and consistent effort, it is possible
to gain support regarding a utility that could be a victim to public
misconception.
Description:
With the complexity of stormwater, appropriating time to educate citizens and listen to their
opinions and thoughts is necessary. Decisions such as the type of assessment technique, overall
utility goals, and long term planning should contain input from citizens. In planning for future
decisions, having program supporters with varied backgrounds will provide positive momentum
that can be used overcome any possible friction that many arise.
Examples:
Workshops – Bringing together citizens and representatives across Bozeman will provide an
informal meeting that could generate a helpful discussion.
Common Practices:
Sharing a similar workload with minimum control measure #3 (Public Outreach and Education),
the best practice is to have a staff member employed to work directly with both control
measures.
Recommended Action:
Detailed recommendations from the 2008 Stormwater Facility Plan, suggests Bozeman employ
additional staff to design and implement this program.
Figure 19 - Public Involvement
Appendices
City of Bozeman Stormwater Program
Figure 1 - Stormwater Mapping Crew
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Appendix A-1
City of Bozeman Illicit Discharge Elimination Program
Illicit Discharge Source: Montana State University – Facilities/Paint Shop
Date Inspected: June 13, 2013
Discharge Description: A white greasy effluent discharging into the City of Bozeman’s (COB) Manhole
swM_G0058 through a lateral line which originates on Montana State
University’s (MSU) property to the south west.
Description of Issue:
On June 12th, a possible illicit discharge was identified by Kyle Mehrens of the COB while analyzing
underground stormwater pipe condition data (TV Data). It was noticed that a white discharge was
flowing through the particular line inspection video (swGM_G0058_G0059) taken on June 5th at 10:53
am by the COB Water and Sewer Department. Upon recognition, it was decided that the suspicious
discharge should be investigated.
An investigation was completed on June 13th at 1:30pm by three COB employees (Kyle Mehrens, Jamie
Merrill, and Greg Johnson). Once an investigation was completed, it was found that the potential illicit
discharge source area was located directly to the south of manhole swM_G0058. At the time of the
inspection, two laterals were discharging water (no precipitation was occurring) and both were found to
be originating on MSU property. It was also noted that the liquid in the manhole was the same color and
held the same greasiness quality as the runoff suspected in the condition data taken nine days earlier.
Dan Stevenson, the Assistant Director of Facilities Services for MSU, was immediately contacted and
visually inspected the discharge. Realizing a substantial issue was occurring that needed immediate
action, it was determined two COB employees (Jamie Merrill, and Greg Johnson) would return the
following day to perform a dye test in order to identify the source of pollution. (See appendix A for map
reference)
Testing Methods:
With the assistance of Dan Stevenson, dye testing was used to test flow connection between three
separate potential sources stemming from MSU’s “Paint Shop” and the corresponding stormwater
manhole (swM_G0058) on June 14th. The three potential sources were identified as:
1. A floor drain in the in northwest corner of the “Paint Shop” building
2. A toilet and sink in the bathroom of the “Paint Shop” building
3. A sink in the main room of the “Paint Shop” building
Green dye was administered to the floor drain in the northwest corner of the “Paint Shop” by Stormwater
Technician One, while Stormwater Technician Two observed flows entering through the suspected lateral
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Appendix A-1
lines discharging into manhole swM_G0058. After seven minutes, the green solution was seen entering
the manhole by Stormwater Technician Two. This provided conclusive evidence of a cross-connection
and identified the source of illicit discharge that had been previously observed on TV footage nine days
prior.
However, to assure there were no other sources, sites two and three were also tested. Dye testing for
possible additional sources two and three were performed one hour after test one to assure residual waters
were sufficiently flushed out. Results from the supplementary tests failed to identify any additional cross-
connections.
Future Work:
Results of the dye testing were communicated to Dan Stevenson who immediately shut down the “Paint
Shop” buildings sink sytem and assured that the issue would be resolved permanently and in a timely
manner. The City of Bozeman Stormwater Technicians will continue to monitor the situation for the next
few weeks to ensure the issue is resolved completly. If necessary, a follow up TV inspection of the
affected manholes and pipe segements may be completed.
Update:
7/1/2013 – A follup up inspection was completed to ensure the issue has been resolved. Greg Johnson
and Jamie Merill, COB employees inspected the MSU paint shop and found a sign posted on the door
(See Appendix B). Contact with Dan Stevenson was not made. The issue has not been permantly
resolved, so another inspection will be completed in two weeks.
Prepared By:
Kyle Mehrens
GIS Technician
City of Bozeman
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Appendix A-1
Appendix A:
Figure 1 - Map of Illicit Discharge
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Appendix A-1
Appendix B:
Figure 2 - Posted Sign at MSU Paint Shop
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Appendix A-2
City of Bozeman Illicit Discharge Elimination Program
Illicit Discharge Source: 4050 Ravalli #84
Date Inspected: June 28, 2013
Discharge Description: Noticeable amount of oil dripping from a parked vehicle on
Ravalli Street.
Description of Issue:
On June 27th, a possible illicit discharge was identified by Davia Jackson of Management Associates. It
was noticed that during the morning of the 27th, oil was actively dripping from a parked vehicle residing
on a street outside of one of their properties. She contacted Jayne Lister, COB Administrative Assistant,
in order to further understand the potential for the city to act on the issue. Jayne discussed that she would
have to look into the issue and determined that the best course of action would be to call her back with
more information.
After circulating the issue through a few members of the COB Streets Department, it was determined that
the city has no authority to enforce a conclusion to this issue. At this point, Jane contacted Kyle Mehrens
of the GIS department to further investigate and understand the issue. During the afternoon of the 27th, it
was communicated with Jayne, that Kyle Mehrens would take over the issue and address it properly. A
follow up phone call was placed to Davia Jackson and it was explained that there was a limited amount of
enforcement we can conduct, but we would conduct an investigation.
An investigation was completed on June 28th at 9:00 am by two COB employees from the GIS
Department (Kyle Mehrens, Morgan Beesauw). Once conducted, it was found that the potential Illicit
Discharge was not actively leaking, but did show evidence of past pollution. The source, a black truck,
had three barrels in the bed of the truck, which contained an unknown fluid (see Appendix A).
On July 1st, contact was made with Charlie Gappmayer, COB Police Department, in order to discuss
potential action against this individual. It was decided that an education approach would be preferable.
Upon this decision Davia Jackson, of management associates, was contacted in order to obtain contact
information for this individual. Information for Justin Sharp was transferred to City of Bozeman staff and
it was communicated that he would be contacted by COB Employees in order to discuss this issue. It was
also stated that communication would continue between management associates and the COB if the issue
continues to deteriorate.
On July 3, 2013 Kyle Mehrens contacted Justin Sharp using a number provided from management
associates ((559)280-7739). A conversation was held regarding the oil on the street with an emphasis on
our concerns and best practices to clean up spills. Justin was aware of the issue and very open to
managing future problems responsibly. He explained that a spill did occur and he used cat litter and
degreaser to remove as much as he could. Overall, a positive outcome was received by educating him on
the concerns we have and why it’s important. Further, it was explained we do have code regulating illicit
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Appendix A-2
discharges of this type and if needed we have the ability to help clean up spills in the event something
occurs he can’t control.
Testing Methods:
No nesting methods were completed. A visual inspection was sufficient to understand the issue present.
Future Work:
A follow up inspection will be completed in one month inorder to guraentee this Illicit Discharge is being
handeled responsibly. Further, open communication has been achieved with Managmernt Associates and
Justin Sharp in the event of future issues and communication will be necessary.
Prepared By:
Kyle Mehrens
GIS Technician
City of Bozeman
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Appendix A-2
Appendix A:
Figure 2 Barrels of Oil Used for Fuel
Figure 1 – Oil Residue Post Spill
Figure 2 - Potential Source
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Appendix A-2
Figure 3 - Truck Parked Over Oil Leak
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Appendix A-3
Illicit Discharge Detection and Elimination Program
City of Bozeman
P.O. Box 1230
Bozeman, MT 59715
August 6, 2013
Qdoba Mexican Grill
855 S 29th Ave #2
Bozeman, MT 59718
Dear Business Owner,
On August 2, 2013, a citizen reported to city officials that an employee of Qdoba Mexican Grill was
improperly “disposing of mop water” into a City of Bozeman stormwater inlet. Under local requirements, this act is
in violation of Bozeman Municipal Code Sec. 40.04.200 which prohibits illicit discharges and is subject to
enforcement by local officials. Stormwater systems within the city are disconnected from sanitary sewers and drain
to local rivers. All polluted water, trash, chemicals, and sediment which enter this system, eventually will discharge
into local waterways impacting water quality, environmental health, and public safety. In an effort to protect local
natural resources and preserve community health, the City of Bozeman reserves the right to regulate necessary
actions regarding any pollution. All enforceable offenses identified (below) must be ceased immediately in order to
ensure compliance and to avoid further enforcement.
Identified Enforceable Offense:
1) Dumping of polluted mop water into a City of Bozeman stormwater inlet.
Three Tiered Process to Compliance:
1) Education -
A City of Bozeman employee will provide you with the proper information needed in order to remain
compliant with all City of Bozeman municipal stormwater codes. It is expected that all necessary
actions are completed in a timely manner.
2) Follow Up Action –
A follow up inspection may be completed in order to ensure continued compliance. If the identified
issue is still present or occouring, a follow up notification will be delivered.
3) Enforcement –
Upon a failed follow up inspection, aswell as no action once the follow up letter has been received,
proper enforcement will take place involving a citation for the liable offense.
If you have any questions reagarding this notification or any other stormwater realted inquires, please
contact Kyle Mehrens of the City of Bozeman at (406)582–2270 or kmehrens@bozeman.net.
Your quick response to this issue is greatly appreciated.
Sincerely,
Kyle Mehrens
Stormwater GIS Technician
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Appendix B-1
Figure 2- Manhole Full of Sediment Figure 3 - Manhole Full of Rocks
Figure 4 - Inlet Full of Sediment Figure 5 - Manhole Full of Trash
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Appendix B-2
Figure 6 - Broken Underground Pipe Figure 7 - Sediment Protruding into Underground Pipe
Figure 8 - Backed Up Water in Manhole Figure 9 - Sediment Filled Pipe
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Appendix B-3
Figure 10 - Clogged Detention Pond Inlet Pipe Figure 11 - Clogged Detention Pond Outlet Structure
Figure 12 - Overgrown Detention Pond Vegetation Figure 13 - Submerged Detention Pond Inlet Pipe
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Appendix C-1
Figure 14 - Article Printed on the Front Page of the Bozeman Chronicle
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Appendix C-1
Figure 15 - Article Continued
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Appendix C-2
Figure 16 - Stormwater Pamphlets
Figure 17 - Stormwater Poster