Stormwater Pollution Prevention Plan - Phoenix Sky Harbor ...

3.3 Pre-Meeting. Aviation Department staff and a representative from the
City Attorney’s office shall meet before the meeting date to discuss the allegations and
the show cause meeting.
3.4 Control of Meeting. The meeting shall be conducted by the Director or
designee with assistance from the City Attorney’s office.
3.5 Compliance Status Meeting Attendees. At the meeting, a tenant
representative who is knowledgeable about the allegations in the Notice, a company
representative with decision making authority, an ES representative, other Aviation
Department staff as deemed necessary and a B&P representative shall attend. In
addition, a representative from the City Attorney’s office shall attend. Tenant may be
accompanied by legal counsel if desired.
3.6 Compliance Status Review Meeting Format. During the show cause
meeting Tenant will be presented with the facts that the Aviation Department staff
believes demonstrate noncompliance and asked to “Show Cause” why the City should not
initiate additional enforcement actions which may include civil penalties, termination of
the tenant’s NPDES Co-permittee status and/or tenancy agreement.
During the compliance status review, the follow events occur:
3.6.1 Introduction of all persons present.
3.6.2 Sign up sheet completed (names, titles, addresses, phone numbers)
3.6.3 Discuss background and history of the City’s storm water program
and federal and city requirements.
3.6.4 Review the City’s prior enforcement efforts with the tenant.
3.6.5 Explain the City’s authority and need for seeking penalties for the
violations.
3.6.6 Review the tenant’s violations and the potential civil penalties
associated with them.
3.6.7 Attempt to reach agreement on the penalty amount.
3.6.8 Establish a compliance schedule for the tenant, if necessary.
3.7 Additional/Remedies. Depending upon the severity of the violation(s),
the ES may recommend that Tenant be removed as a co-permittee on the airport’s
NPDES Permit and/or that the Tenant’s permission to use airport property for its business
operations be terminated.
-4-
Revised 4/22/99
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