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Committee raises timeline and target concerns over draft Municipal Roads General Permit
Summary
CCRPC planner Chris Dubin briefed the Clean Water Advisory Committee on the draft Municipal Roads General Permit, which would run Jan. 26, 2023–Jan. 26, 2028. Members, led by Christine Dougherty, urged longer timelines for upgrading Very High Priority segments and recommended simplifying permit requirements; public comments were due Oct. 24.
Chris Dubin of the Chittenden County Regional Planning Commission presented key provisions of the draft Municipal Roads General Permit to the Clean Water Advisory Committee on Oct. 11, 2022. He summarized the draft permit’s schedule and compliance targets and invited committee input on whether the committee should submit a formal comment letter.
Dubin said the second five‑year permit cycle is proposed to run from Jan. 26, 2023, to Jan. 26, 2028, and that municipalities would need to reapply for coverage by Jan. 26, 2023. He said towns must perform Road Erosion Inventory (REI) reassessments between May 1, 2023, and Oct. 31, 2027. The draft would require municipalities to upgrade at least 7.5% of their non‑compliant road segments annually and to include at least 20% of a town’s Very High Priority (VHP) segments in that annual target. The draft removes the “Partially Meets” erosion score and proposes a more detailed rubric so that gullies, steep slopes and eroded culverts generate higher erosion scores. The draft also adds green stormwater infrastructure (GSI) practices as an allowed best management practice for catch‑basin outlet stabilization and gives the Department of Environmental Conservation authority to re‑assess scores under Section 4.1.b.
Committee member Christine Dougherty expressed concern that the implied two‑year push to upgrade VHP segments is too aggressive, saying that design work and contractor availability can make a two‑year target infeasible; she urged removing the two‑year requirement or allowing extensions to three to five years. Dubin said the county currently has about 68 VHP segments and encouraged members to send comments to DEC; he said he was clarifying details with DEC by email and did not plan to send a committee letter. Co‑chair Annie Costandi said members could submit individual comments. Dubin noted public comments were due Oct. 24 and that DEC would prepare a Comment Responsiveness Report; he expected the permit to be reissued in late November 2022.
The committee did not take a formal vote to send a joint comment letter at this meeting. Members were invited to send their comments directly to DEC.
