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Interagency Cooperative
Agreement
An Urban Erosion Control
Partnership |
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History &
Background
Program
Development
Program Details
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History &
Background
Northeastern Illinois has the unprecedented
distinction of being one of the fastest growing
metropolitan areas of the nation. More
specifically McHenry County can lay claim to
being one of the fastest growing counties in
this region of rapid expansion. Farmland has
been consumed at incredible rates making room
for both rural development and municipal
annexations.
The Northeastern Illinois
Planning Commission forecasts suggest a rate and
pattern of growth markedly different from what
was experienced between 1970 and 1990. During
those two decades, the population of
northeastern Illinois increased by only 4
percent, from 6.98 million to 7.26 million
people. While overall growth was moderate, its
impacts were substantial because of the way the
growth was distributed. The population of the
growing suburban areas increased by 24 percent
or almost 1 million, while the City of Chicago
and eighty-nine suburban cities and villages
lost a total of about 770 thousand people.
These demographic changes were
accompanied by substantial changes in the use of
land. Between 1970 and 1990, while the region's
population increased by only 4 percent and
employment grew by 21 percent, the amount of
land in urban uses increased by over 33 percent.
Over 450 square miles of agricultural and vacant
land were converted to residential and
employment uses, streets, and public buildings.
This high rate of land consumption reflected the
generally larger lot sizes which have
characterized residential, commercial, and
industrial development and redevelopment
throughout the region. It also reflected a high
rate (20 percent) of household formation
relative to population increase as household
sizes declined. Still, the overall pattern was
one of a few more people occupying a lot more
land.
The result of this population
growth and farmland conversion has led to
significant sedimentation problems in downstream
waterways. For the past 15 years very little
attention was given to erosion and sedimentation
problems associated with development sites. Only
in the past five years have there been
communities willing to adopt stricter ordinances
dealing with this pollution problem. Communities
such as Crystal Lake who use their lake as a
focal point to promote tourism and economic
development have a tendency to adopt these
stricter ordinances to protect their natural
resources. Of the thirty municipalities in
McHenry County only six have adopted strict
erosion control ordinances.
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Development of
Program
Since 1986 the Corps has
administered a permit program under Section 404
of the Clean Water Act which regulates various
activities in waters of the United States,
including wetlands. As a condition of permit
issuance, the Corps requires appropriate soil
erosion and sediment control measures to be
implemented and maintained until the
construction site is vegetated and stabilized.
The Corps reviews the impacts of a proposed
project with the supposition that soil erosion
from the site will be negligible. For a number
of years E & S plans were submitted to the Corps
but because the Corps lacked sufficient staff
and expertise with urban erosion problems very
few plans were fully implemented, if at all.
When considering the geographical
location of the Corps office (downtown Chicago)
it makes regulation and enforcement a difficult
task in the six county metropolitan area.
The Corps contacted staff from
the McHenry County Soil and Water Conservation
District (MCSWCD) and USDA Natural Resources
Conservation Services (NRCS) to ask if each
agency could be of any assistance in both the
review of E & S plans and inspection of the
implemented plans. The idea of a cooperative
agreement was created as a means of clarifying
each agencies responsibilities. The Interagency
Coordination Agreement (ICA) was officially
signed into action by all three agencies on
January 7th 1997. The five remaining
northeastern Illinois counties of Cook, DuPage,
Kane Lake, and Will followed shortly after.
The ICA that was eventually
drafted created the framework and spelled out
the details and responsibilities of each agency.
For the past 50 years the NRCS and SWCD’s have
had very similar agreements called Memorandums
of Understanding (MOUs).
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Details of Program
Basically the ICA states the
Corps will:
1). Require the
permittee to consult with the SWCD on E & S
control plans.
2). Request the SWCD review plans
for adequacy and effectiveness.
3). Request the SWCD to attend a
pre-construction meeting
4). Request the SWCD review and
comment on inspection reports and proposed
corrective actions.
5). Request the SWCD to conduct
on-site inspections |
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The SWCD will:
1.) Utilize appropriate technical
references (Illinois Urban Manual, NRCS Tech
Guide).
2). Conduct onsite investigations
prior to the issuance of permit.
3). Review E & S control plans.
4.) Attend a pre-construction
meeting.
5). Conduct onsite inspections of
the active construction site for compliance.
6).Notify the permittee of plan
deficiencies.
7). Consult with developers and
contractors concerning design, installation and
maintenance of E & S practices.
8). Assume administrative
responsibilities.
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The NRCS will:
1.) Assist the Corps and the SWCD in carrying
out the provisions of the M.O.U.
2). Provide planning and
technical assistance.
3). Provide technical reference
materials.
4). Assume administrative
responsibilities
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The following Illinois SWCD’s
have signed the M.O.U.
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McHenry County Jan. 7 ‘97
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North Cook County May 8, ‘97
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Will /So. Cook County June
10, ‘97
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Kane/DuPage County June12,
‘97
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| Because many
developers work in multiple counties the SWCD’s
found it necessary to have some consistencies in
the forms used, fee schedules, plan review turn
around time, and other aspects of the program.
In an effort to have consistency between all
participating SWCD’s the following agreed to
items were created. |
| 1.) No fees
should be charged to State agencies such as IDOT
as per state statutes.
2). Review of fee schedule
shall have input from all participating SWCD’s.
3). Develop materials such as
checklists, fact sheets, sample E & S plans for
all Districts to use when distributing
information to developers.
4). SWCD’s will collaborate on
developments that straddle county lines.
5). Agree to a 15 day turn
around for initial comments to plans.
6). Changes to applications,
checklists, etc. shall have the approval of
SWCD’s
7). Provide Directors with
progress reports of E & S program.
8). SWCD’s should meet at
least once every 6 months to discuss
problems/solutions and any changes in forms or
procedure’s.
9). New information sent to
developers should have the approval of
participating SWCD’s
10). Any new "agreed to" items
shall have concurrence of all Districts.
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Development of forms
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Applications for Sites
1). Site plan
checklist
2). Narrative checklist
3). Fee schedule
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Inspection Report
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Sample erosion control plan.
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The Review
Process
1).
Application is filled out and returned (with all
other necessary info. and fees).
2). Plans are reviewed and comments submitted
back to the engineer.
3). A letter stating "Plans now
meet Technical Standards" (staying from words
such as approval which infers regulatory
authority).
4). A pre-construction meeting is
scheduled.
5). Follow-up on-site
inspections.
6). Deficiencies are made known
to the contractor for repair or maintenance.
Failure to comply will move the situation to the
next level.
7). Letters of deficiency are
mailed to the Municipality or County for action.
8). Corps could invoke stop work
order or fines.
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