(Update 3/4/2015): Capital Region Water is still working on our initial draft of new Stormwater Rules and Regulations (SWMRR).
All comments received were considered and some led to revisions of the SWMRR. To provide clarification about the process of developing the SWMRR and summarize our general response to several comments:
• Many of the comments will be addressed in future revisions of these Rules and Regulations in conjunction with other documents to be developed by CRW. CRW will continue to solicit public comment on future drafts of the SWMRR and other related documents.
• The adoption of this draft of the SWMRR is the initial step in establishing Capital Region Water as the “legal authority to manage stormwater” in Harrisburg. Under the “Intergovernmental Cooperation Agreement Between CRW and the City of Harrisburg to Facilitate and Assist in Environmental Compliance” (“Intergovernmental Agreement”), dated October 1, 2014, CRW and the City have agreed to coordinate regulatory compliance activities, including a complete review and coordination of City Code with CRW Rules. All City Code applicable to stormwater management remains in effect during this review. The Intergovernmental Agreement, which will be provided, obligates CRW and the City to define organizational responsibilities. Refinements will be reflected in future revisions to these Rules and Regulations as these responsibilities are defined.
• In reference to public comments directed towards the City of Harrisburg code, our responses only reflect the authority CRW has in developing the new SWMRR. As a municipal authority and not the municipality, CRW is legally limited in our authority over the regulated community.
• CRW acknowledges the involvement of other public agencies like Dauphin County Conservation District and we will coordinate with these agencies to avoid regulatory inconsistency that may cause confusion with the regulated community.
• In reference to public engagement and accountability, CRW anticipates extensive public outreach, education and public reporting under its various wet weather programs, but does not consider statements about these items appropriate for its Rules and Regulations. Please be assured that CRW will hold true to our “pledge to be proactive, open and transparent [and] community-focused.”