Attachments: image001.png; image002.png;
Hi Nancy,
There isn’t a specific form for the variance request, so you may have been looking at something else. You’re just writing a memo explaining why samples weren’t taken at MP-001. With the memo, you’ll provide documentation such as dated photos showing that no stormwater discharged from the swales.
Here is a link to a fact sheet about requesting a variance: https://www.oregon.gov/deq/FilterDocs/1200zmonreqFS.pdf. The fact sheet has an example variance request. You don’t necessarily need to include all the calculations in that example- just a paragraph along with dated photos should suffice.
Let me know if you’d like to chat about this on the phone sometime this week, or if I can clarify further over email.
Best,
Melanie Roy
Permit Manager, City of Portland Bureau of Environmental Services
Industrial Stormwater Program
(503) 865-6929
(she/her)
The City of Portland ensures meaningful access to City programs, services, and activities to comply with Civil Rights Title VI and ADA Title II laws and reasonably provides: translation, interpretation, modifications, accommodations, alternative formats, auxiliary aids, and services. To request these services, contact 503-823-7740, City TTY 503-823-6868, Relay Service: 711.
From: Nancy Fischer <nfischer@standardsteelnw.com>
Sent: Monday, February 5, 2024 11:36 AM
To: Roy, Melanie <Melanie.Roy@portlandoregon.gov>
Subject: RE: Variance & DMR Instructions
Good morning Melanie,
When I try to pull up a monitoring variance form, I am asked for a user name and password?
Is there another way to request one?
Thanks,
Nancy
From: Roy, Melanie <Melanie.Roy@portlandoregon.gov>
Sent: Wednesday, January 31, 2024 1:11 PM
To: Nancy Fischer <nfischer@standardsteelnw.com>
Subject: FW: Variance & DMR Instructions
Importance: High
Hi Nancy- here is the email I sent you about the Monitoring Variance. You need to submit this because you did not take samples at MP-001 (swale overflow point) in Q1 or Q2. The Monitoring Variance is a formal document stating that you did not take samples because there was no discharge from the swales during Q1 and Q2. See my email below for more details and instructions.
The Monitoring Variance needs to be emailed to me by February 15, 2024. Failure to submit this will result in a permit violation for missed monitoring. Let me know if you have questions!
Melanie Roy
Permit Manager, City of Portland Bureau of Environmental Services
Industrial Stormwater Program
(503) 865-6929
(she/her)
The City of Portland ensures meaningful access to City programs, services, and activities to comply with Civil Rights Title VI and ADA Title II laws and reasonably provides: translation, interpretation, modifications, accommodations, alternative formats, auxiliary aids, and services. To request these services, contact 503-823-7740, City TTY 503-823-6868, Relay Service: 711.
From: Roy, Melanie
Sent: Tuesday, January 2, 2024 12:31 PM
To: Nancy Fischer <nfischer@standardsteelnw.com>
Cc: Gage Martin <gmartin@standardsteelnw.com>
Subject: Variance & DMR Instructions
Importance: High
Hi Nancy,
Happy New Year! I received your Q2 DMR in the mail. I have a some instructions and guidance for you moving forward:
- * Monitoring Variance instructions
- * Since you all have not collected samples from MP-001 (swale overflow point), you need to request what’s called a “Monitoring Variance”. A Monitoring Variance is a formal document stating that in Q1 and Q2, there were no rain events of sufficient magnitude to produce a discharge at 001.
- * In other words, you would be claiming that the swales have retained all the rain events in Q1 and Q2, so you were not able to collect samples at 001 because there was no flow.
- * The permit requires you to submit “supporting data” along with the variance request. This could include photo documentation, rain gauge data, and/or the infiltration rate of the swales.
- * Submit the variance request and supporting documentation to me by February 15, 2024.
City of Portland Bureau of Environmental Services