2006 Annual Report - Saginaw Area Storm Water Authority

2006 Annual
Report
Prepared by:
Spicer Group, Inc.
230 S. Washington Avenue
Saginaw, Michigan
October 15, 2006
Table of Contents
Saginaw Area Storm Water Authority (SASWA) 2006 Annual Report
Appendix A – Public Education Brochures
Appendix B – Spill Response Reports
Appendix C – Sediment Removal Documentation
Appendix D – Website Statistics – October 2005 to September 2006
Appendix E – Community Newsletters & News Articles
Appendix F – Annual Budgets 2006 & 2007
Appendix G – Attorney General’s Opinion
Saginaw Area Storm Water Authority (SASWA)
October 15, 2006
2006 Annual Report for the following NDPES Storm Water Discharge Permits:
MEMBER
Birch Run Township
Bridgeport Charter Township
Bridgeport Spaulding Community Schools
Buena Vista Charter Twp
Carrollton Township & School District
James Township
Kochville Township
Saginaw – City of
Saginaw County Road Commission
Saginaw County
Saginaw Charter Twp
Saginaw Township Community Schools
Saginaw Intermediate School District
Saginaw Valley State University
Spaulding Township
Swan Valley School District
Thomas Township
Tittabawassee Township
Zilwaukee – City of
NPDES Permit Number
MIG 610168
MIG 610181
MIG 610180
MIG 610167
MIG 610165
MIG 610164
MIG 610162
MIG 610161
MIG 610178
MIG 610171
MIG 610166
MIG 610176
MIG 610183
MIG 610179
MIG 610169
MIG 610175
MIG 610174
MIG 610172
MIG 610159
This report will follow the annual progress report guidelines as set forth in the NPDES
permit number MIG619000, section B, Watershed Management, Part 3 Annual Progress
Report. The report will be submitted to the MDEQ’s Saginaw Bay District Office by
October 15, 2006, as stated in each of the permits listed above.
a. Illicit Discharge Elimination Plan (IDEP)
The IDEP program has been implemented in Saginaw County. The dry weather
screening began during mid July of 2005 after the ground water level was down.
Since this time screening has taken place throughout the year, as permitted by
weather, vegetation condition, and groundwater table elevation. The goal is to screen
25% of the drainage districts in the SASWA watershed area in a year. The following
drainage districts have been completed to date:
•
•
•
•
•
•
•
•
•
•
•
•
Bebee
Br. No. 1 of Trickey
Brown & Mills
Chapman
Garey
Hagerl Tile
Lentz
Liskow
Liskow Tile
Metzler
Oldenburg
Parker Swamp & Branches
•
•
•
•
•
•
•
•
•
•
•
•
Scholtz & O’Hern
Hatch Run
Wiltse
Wolgast
Wurtzel
Wurtzel Tile
Dice
Alney
Union
Otto
Page
Shattuck Road
The following drainage districts are partially completed, and will be finished as soon
as weather permits;
•
•
•
•
Williams Creek
Amanda
Bishop
McCarty Road
•
•
•
New Freeland
Shattuck Outlet
Winterstein
The reports for the drains and point sources are being processed at this time and will
be sent to Saginaw Bay District Office when the technical aspects have been
completed.
Preliminary maps, necessary for IDEP screening, for each of the drainage districts
have been prepared. These maps are used as a basis for dry weather screening, and
have been prepared in order to allow progress whenever conditions permit.
The Strieter Subdivision was investigated on 13 June 2006 with representatives from
the Saginaw County Department of Public Health present. The subdivision was
identified by the IDEP program when sewage odors were detected. While sampling,
residents reported the smell of sewage was present from the storm system. Sampling
revealed two catch basins that exceed 100 col./100 ML, though odor was present at
many locations. The basins exceeding the limit were in the middle of the system; the
outfall tested clean. No further action has been taken to date. At this time it is felt
that the problem may be failing septic systems instead of the illicit connections as
originally thought. One more test will be done to determine what the problem could
be.
The acceptance of the IDEP included the contingency that a Strategy for Minimizing
the Seepage from On Site Sewage Disposal Systems be developed and submitted for
approval by November 1st, 2007. No work has begun on this plan. The SASWA
intends to develop the plan and submit by the required date. Additionally, SASWA
must address any references to the county wide ordinance in this plan to reflect the
recent Attorney General’s opinion.
The IDEP has been effective in locating areas of concern within the SASWA’s
defined watershed area of responsibility. The program is utilized by the Saginaw
County Public Works Commissioner to gage the status of each drain inspected.
Suspicious outfalls or drain maintenance issues are identified and summarized in a
quarterly report to the Public Works Commissioner’s engineer. The program is
helping to develop accurate records of the MS4 in Saginaw County’s urbanized area.
IDEP maps and reports will be submitted with the completion of the CMI Grant
obtained by the SASWA in 2005.
IDEP education:
The SASWA website’s home page provides the general public with the opportunity to
report any spills or dumping in the SASWA watershed or the county as a whole. The
website provides the public that uses this form of communication and information
transfer with the ability to view information on what comprises illicit discharges and
how to report them. The ability to report spills or discharges by the website will be
communicated to the public during the implementation of the IDEP. To date no
reports of spills or illicit discharges have occurred via the website.
Brochures distributed to school systems, from CVT offices or as information in
Township newsletters provide the public with a more conventional form of
communication about spill reporting. To augment this form of education SASWA
has been begun preparation of refresher training for the member’s staff and personnel
on spill reporting procedures. The SASWA has determined that it will begin annual
refresher training for spill reporting.
The SASWA website now includes a map of IDEP progress and planned future
inspections. This allows SASWA members and the general public to stay appraised
of IDEP activity. The map is updated monthly.
Proposed County wide Storm Water Quality Ordinance:
The SASWA developed a County wide Storm Water Quality Ordinance and approved
the document. The ordinance was sent to the County’s attorney for review and
comment. The SASWA was made aware of a decision made by an opinion letter
issued to Grand Traverse County from Michigan’s Assistant Attorney General stating
that a county does not have the authority to regulate storm water quality unless
specifically empowered to do so by legislation enacted in this state. A copy of the
opinion is included as Appendix G .
At this time the SASWA has asked their project manager to approach Saginaw
County’s Public Health Department to determine if this ordinance can be enforced
through the county’s public health enforcement. If not at that level then the
municipalities have the option of implementing the ordinance individually. However,
the communities do not wish to pursue this option yet.
The meeting with the Saginaw County Public Health Department took place on
October 10, 2006. Bryant Wilke will review and report to the SASWA executive
committee in it November 22, 2006 meeting. He will be reviewing it for adaptability
for adoption as an enforcement ordinance for the Health Department to address illicit
sanitary connections and failing on-site disposal systems.
Spill Response Reports:
To date there have been three (3) spill reports. Each incident was discussed in a
SASWA executive committee meeting to provide for a sharing of information and to
determine if procedure was followed properly. Each report is briefly described
below, more detailed information is provided in Appendix B.
1. Garner Subdivision, Tittabawassee Township. The Garner Subdivision
is located at the corner of Garner and Webster streets. A complaint of
excessive sediment due to construction site runoff was reported to Keith
Noble at the MDEQ. It is estimated that 0.5 yd3 of sediment entered the
MS4. The incident was reported to the Saginaw County Public Works
Commissioner, the local CEA.
2. Waldo Street, City of Saginaw. A report of sewage being pumped into
the street from a flooded basement was reported to Jim Koski, the
Saginaw County Public Works Commissioner. The pumping was in a
combined sewer district; no action was taken and investigated by the City
of Saginaw’s environmental staff.
3. Home Depot, Kochville Township. An individual was reported to have
dumped approximately 0.25 – 0.5 gallons of gasoline into a storm drain at
the Home Depot located at 3132 Bueker Drive. The report was made via
9-1-1, prompting police and fire departments to respond. The gasoline
was never located in the on-site detention pond; no cleanup was performed
as the spill was never located.
4. Olive Garden, Kochville Township. An individual spilled about 1 gallon
of gasoline in the parking lot. The fire department responded to a 9-1-1
call and cleaned the site. It is believed any pollutant not cleaned by the
fire department evaporated due to the heat of the day.
The county has enacted an ordinance to deal with Soil Erosion and Sediment Control
issues as civil infractions in 2004. Authorized members of the Saginaw County
Public Works Commissioner’s office will continue to enforce the ordinance.
b. Public Education Plan (PEP)
The SASWA began implementing its PEP during its formation in 2002.
The following section overviews activities related to the PEP, progress, and their
perceived effectiveness.
Activities 1 and 2: Brochures have been developed relating to a number of watershed
education topics. These have been submitted previously. SASWA members continue
to distribute educational materials, and they are also available through the website.
The website, www.saswa.org, has continued to be a multifaceted resource that can be
used by the general public and SASWA membership.
The site is used by members to provide:
• watershed education by video streaming the MWEA Watershed
Education CD to residents on the website,
• information on storm water regulations,
• information on storm water pollution prevention,
• a method to report illicit discharges / connections,
• educational materials for children,
• educational materials for adults,
• resources related to NPDES compliance,
• resources related to administration of SASWA,
• progress map on IDEP program,
• watershed maps,
• drainage district maps,
• existing storm sewer map,
• access to the watershed management plans for the Upper Saginaw,
Lower Cass and Lower Tittabawassee
The website also provides the members with the opportunity to measure the
effectiveness of the World Wide Web as a public education venue. The SASWA
keeps track of all hits to the website, pages accessed, survey results. The results of
the cumulative summary of statistics on the SASWA website from October 1st, 2005
to September 30th, 2006 are available in Appendix D. To view the website and its
contents one can visit www.saswa.org.
The following members have linked their websites to the SASWA website to provide
the public with education related to storm water and stormwater activities:
• Carrollton Township,
• Saginaw Charter Township,
•
•
•
Saginaw County,
Saginaw Valley State University,
Thomas Township.
A summary of the statistics for the SASWA website are in the following Table:
TABLE 1.
Hits
Total Hits
Average Hits per Day
Average Hits per visitor
Cached requests
Failed requests
Page Views
Total Page Views
Average Page Views per Day
Average Page Views per Visitor
Visitors
Total Visitors
Average Visitors per Day
Total Unique IPs
Bandwidth
Total Bandwidth
Average Bandwidth per Day
Average Bandwidth per Hit
Average Bandwidth per Visitor
20,142
55
7.00
3,967
1,088
5,409
14
1.88
2,878
7
1,045
2.33 GB
6.54 MB
121.37 KB
849.33 KB
The website and brochures appear to be the most effective public education tools
utilized thus far. The website is a source of a wide range of informational tools and
resources, and is slated for revision in 2007. The SASWA believes this web-based
tool is one of the most effective means of education, both in terms of cost and
accessibility.
SASWA brochures continue to be developed, as discussed below, and are distributed
by members in their offices. These brochures provide a tangible
Informational Articles developed related to Activity Number 3 were published in
2006. An article in the NMWEA outlined the SASWA’s progress. Pipeline
magazine published an article outlining the IDEP program in their 2nd quarter 2006
edition. See Appendix E for copies of these publications.
Inclusion of newsletter articles is an effective means to communicate the SASWA’s
message to the general public. The SASWA hopes to increase the use of this forum
in the future.
Activity number 4 related to watershed education is providing access to the
Michigan Water Environment Association’s educational CD on watersheds. This CD
was finalized and made available to the public in late Fall of 2004. The video is
available as a streaming file or download from the SASWA website. No additional
showings of the video took place during the reporting period.
The MWEA educational program is an effective introduction to watersheds and
watershed management. This video is not utilized often, with the exception of initial
public briefings on the subject.
Activity number 5 was to complete a database of riparian landowners in the Saginaw
Urbanized Area. This task was completed with the assistance of the Saginaw Area
GIS Authority (SAGA). This database of addresses has been completed and a
mailing done to all riparian owners.
This activity was effective. The database has been developed.
Activity number 6 is to develop a series of messages on watershed hygiene. The
SASWA’s various activities are all designed to revolve around this theme.
Additionally, brochures highlighting pumping stations for RV and marine sewage
were distributed at the SVSU boat show.
Effectiveness of these messages is reflected by the general health of the watershed
and public awareness. The SASWA believes its efforts have been effective in
increasing public knowledge.
Activity number 7 is to sponsor three (3) informational workshops or seminars for
area contractors, developers, builders, landscapers, and engineering firms has been
delayed because of funding issues. SASWA has submitted a grant application to the
Saginaw Bay Watershed Initiative Network. This grant is currently under revision and
will be pursued further in 2007.
The SASWA has arranged to speak with the Tri-County Contractors’ Association
(TCCA) and Home Builders’ Association of Saginaw in 2007 regarding construction
site stormwater management, and general watershed information. These seminars
will take place in February of 2007.
Contact with construction and development industries is an import part of the
SASWA’s watershed message. It is expected these seminars and educational sessions
will be effective in improving watershed health.
Activity number 8 is related to development of signage indicating where storm
drains discharge. The SASWA will not pursue stenciling, as this is a liability
concern. SASWA members are encouraged to revise their storm water management
plans / ordinances and will require all new construction catch basin castings to have
forged lettering “DUMP NO WASTE – DRAINS TO RIVER” which will last the
lifetime of the product. Additionally, SWMPs developed as a required part of the
SWPPI document will include this requirement. To date, Thomas Township,
Kochville Township, and the City of Saginaw have updated their storm water
management plans to include this feature. Plans have been reviewed for over 18 new
developments and redevelopments in these communities and these castings are on the
construction specifications
The requests for installation of the castings have been effective. The zero-cost
premium incurred by developers is encouraging the acceptance of these simple
devices. The constant reminder that the storm drains reach natural waters with no
treatment is hoped to be an effective reminder of watershed health.
Activity number 9 has not yet started. Contact was made with MMWA but no
calendar was planned for 2006. The SASWA will make further contact in 2007.
Activity number 10: the SASWA distributes a brochure on proper disposal of
sanitary waste water from recreational vehicles and marine craft. This brochure
provides information on proper disposal and locations in Saginaw, Bay, and Midland
counties, where sanitary wastes can be pumped out. Phone numbers, addresses, and
any associated fees are provided. This brochure was printed in early 2005 for
distribution at area recreational vehicle and boat shows. Over 2000 have been
distributed to area RV and Marine Dealers and at the RV and Boat shows in the
Spring of 2006. The document has been updated on the SASWA website to reflect an
additional marine pump out facility added by the request of the facilities owner.
Also, the US Coast Guard Auxiliary is handing out this brochure during their Boating
Safety Courses. The brochure has been previously submitted, and is available on the
SASWA’s website.
This brochure has been distributed by the SASWA for 2 years. The fact that a
cleanout station has been added, per a business’ request, indicates the brochure has
reached a wide audience. This brochure includes directions to and contact
information for sanitary pump-out stations, and is a convenient reference for RV and
boat owners. This brochure is effective in the delivery of its message.
Activities number 11, 12, and 13 have had their respective messages on watershed
hygiene, application, and disposal of pesticides, herbicides, and fertilizers and
procedures for residential car washing developed into brochure formats for
distribution to the general public. The MWEA watershed education CD also delivers
a message related to this information. The SASWA website provides the public with
additional links for more education related to these topics.
Brochures are widely distributed by the SASWA’s membership, and are available as
downloads from the website. Brochures are believed to be an effective tool in
communicating the watershed message. The SASWA promotes brochures as a
jumping-off point for watershed education, with each brochure providing resources
where additional information can be obtained.
Activities 14 and 15 have been covered in the IDEP portion of this report.
Activity number 16. The SASWA has a PowerPoint presentation on Soil Erosion
and Sediment Control. It has been utilized to teach in area schools and 62 fourth
grade students from List Elementary in Frankenmuth and 20 third graders of
Hemlock’s Ling Elementary have partaken in this program this year. The students
had to write letters to the instructor on what they learned in this program.
Spicer Group hosted a training session for participants to achieve the status of
Construction Site Storm Water Operation. 26 participants attended, including 14
representing SASWA members.
Training sessions for building professionals and administrators are effective, as the
decision makers and administrator must be educated to help further the message of
watershed health.
c. New Point Sources of Storm Water Discharges:
The following subdivisions have been approved to discharge storm water in the
SASWA watershed area:
Name of Subdivision
Mackinaw Meadows Condo
Ponds at Thomas Village
Tuscany Villas
Township and Section #
Saginaw Charter Twp - 10
Thomas Twp - 26
Saginaw Charter Twp - 3
Outlet Drain
Universal Drain
Wolgast Drain
McCarty Road Branch of
Universal Drain
To date, not all of these storm water conveyance systems have been built, they have
been approved through the storm water management plans and ordinances instituted
in the respective townships. Once the systems have been built, they will be added to
the developing storm water conveyance system GIS layer for the SASWA. The
outlets will be positioned appropriately on the developing GIS map with coordinates
supplied by GPS during the IDEP program implementation. During the summer of
2006, 4 new point sources were added to the storm sewer map and 18 storm sewer
networks were added to existing systems. Some of these were private systems,
however, because of their size (Wal Mart Supercenter’s with regional detention areas)
they were added to the GIS layers being developed by SASWA.
d. Storm Water Pollution Prevention Initiative (SWPPI)
SWPPIs for each SASWA permittee’s were developed through a collaborative
process. The SWPPIs for Birch Run Township and Saginaw County Road
Commission (SCRC) were based upon proposed goals and objectives for the Lower
Flint River watershed, obtained from the Genesee County Drain Commissioner. The
SCRC also uses goals and objectives from the 3 WMPs of Saginaw County in
conjunction with the Lower Flint. The remaining SWPPIs were based upon the
Upper Saginaw, Lower Cass, and Lower Tittabawassee Watershed Management
Plans.
SASWA members attended a SWPPI training session prior to development of the
documents.
With the exception of the City of Saginaw, all SASWA Members submitted their
SWPPI to MDEQ for review on April 14, 2006. The City of Saginaw is still
reviewing their SWPPI and is awaiting final approval and signature of the cover sheet
from municipal government.
Tracking of SWPPI-related activities is managed through the SASWA’s website.
This is accessible only to members, and is used to track progress throughout the year.
It is expected that this will assist with more accurate and regular documentation of
watershed related actions.
As a result of the SWPPI activities, several actions have begun to take place. The
Saginaw County Road Commission has documented approximately 490 cubic yards
(approximately 761 tons) of sediment collected through their sweeping program.
This includes approximately 24 cubic yards (37 tons) in the Lower Tittabawasse
watershed and 466 cubic yards (724 tons) in the Upper Saginaw watershed.
Bridgeport Charter Township has reported approximately 4 cubic yards of sediment
removed from MS4 catch basins on township property Documentation is located in
Appendix C.
SASWA members have ordered 30 gallon spill kits for facilities that were otherwise
without. A total of 24 kits were ordered by 10 members in the Fall of 2006. Kits
include materials to detain and remediate small spills of oils, chemicals, and other
pollutants that are regularly encountered in municipal and educational facilities.
e. Nested Drainage System Agreements –
None reported for 2006, all known within the Saginaw Urbanized Area are accounted
for.
f. Public Participation Plans
The SASWA has submitted the Swan Creek Watershed PPP to MDEQ for review and
comment. Planning for this watershed is slated to begin in October 2006.
g. Watershed Management Plans
Watershed Management Plans for the Upper Saginaw, Lower Cass, and Lower
Tittabawassee watersheds were submitted to MDEQ for review and comment on
November 1st, 2005. The completion of these WMPs indicates significant progress
for the SASWA, as these plans are the result of effective public education, public
participation, and sustainable leadership from the SASWA’s organizational structure.
Review and comment were received from MDEQ and revisions to the WMPs have
been made. Per this process, the plans have been updated and the Upper Saginaw
WMP was submitted to the MDEQ for further review.
h. Other Actions
Monthly Education sessions are held at general meetings of the SASWA. Each
month a short presentation is made regarding watershed management in some aspect,
or a discussion of SASWA policy is held. Presentations have been made by both the
SASWA’s consultant and outside speakers (including David Russell of the Saginaw
Conservation District.
To ensure completeness of this report and to assure that no items were missed the
Agendas and Minutes for the Executive Committee and General Board meetings of
SASWA are available on our website: www.saswa.org. The SASWA has taken the
position that the website is the format that they will communicate information from
the public meetings.
The annual budgets for the SASWA’s fiscal years 2006 and 2007 are in Appendix G.
These annual budgets are approved by the trustees representing the municipal
membership’s governing bodies. Each member has a specified or apportioned share
of these costs for the project. The apportionment must be approved by a two thirds
majority of the CVT’s before acceptance for application to the approved 2007 budget.
Sustainability of SASWA and its programs is guaranteed by the commitments of its
membership to meeting the requirements of the general permit and by the
organization of SASWA. SASWA was formed as a legal authority under PA 233 of
1955 and has publicly printed its Articles of Incorporation and subsequent
amendments to these Articles. Each member municipality has passed a resolution
supporting the formation of the SASWA. The authority has developed its 6th annual
budget and 5th annual apportionment. The apportionment must be annually approved
by resolution of each member municipality. This assures that communities and non
municipal members are on-board with the actions of the authority. To date there is no
question of the sustainability of this authority. Also, SASWA has been working with
and fielding questions from other parts of the state of Michigan to assist with
sustainability issues with other NPDES Phase II groups.
APPENDIX A
Public Education Brochures
Want to Know More?
Michigan State University Saginaw County Extension
989-758-2500
[email protected]
A Riparian Landowner’s Guide
Michigan Groundwater Stewardship Program,
Michigan Department of
Agriculture Environmental Stewardship Division
517-241-0236
Center for Watershed Protection
www.cwp.org
Michigan Water and Environment
Association
www.mi-wea.org
Saginaw County Public Works
Commissioner
989-790-5258
Brochure financed by members of the:
SAGINAW AREA STORM WATER AUTHORITY
www.saswa.org
c/o Bridgeport Charter Township Governmental Center
6206 Dixie Highway
Bridgeport, MI 48722
Telephone:
(989) 790-5258
FAX:
(989) 790-5259
www.saswa.org
Mid Michigan Waste Authority
www.ggg3.org
Tips to Protect and Preserve
Your Watershed
Why did you receive this
brochure?
This brochure has been sent to you because
you are a riparian landowner in Saginaw
Important Tips for Riparian Landowners
Buffer It Up
County. This means you own property that is
adjacent to some type of waterway, such as a
Developing a buffer strip out of natural vegetation be-
drain, stream, creek, river, or drainage ditch.
tween your lawn and adjacent waterway will help stabilize banks, filter storm water, and create important
What does Riparian
mean?
natural habitat. More importantly,
it will reduce the amount of lawn
Riparian means those areas located between
waterways and upland areas. Riparian areas
you have to mow and water.
are important because they provide wildlife
and aquatic habitat, erosion protection, and
A great way to start is by planting
native vegetation such as prairie
serve as a natural filter for storm water
runoff.
or wildflower seed mix in the
buffer zones. This is one of the best ways to stabilize
Look For Outfalls
Inspect your property
along the waterway and
look for any outfalls in the
form of pipes or ditches
entering the waterway. Do
you know what is coming
out of them and what they
are transferring into the water? Outfalls are a major
source of erosion to the banks of waterfront property
and are sometimes responsible for contributing pollutants to the watershed.
banks and filter runoff.
What is the purpose of this
brochure?
The waterway you live or own property on directly affects the health of the Saginaw Bay
Watershed - the largest watershed in Michigan. As a riparian landowner, it is important
for you to know how you can protect, promote, and preserve the watershed by implementing practical and environmentally safe
Fertilize Wisely
Let It Grow
Mow grass to a minimum of three inches. The longer
grass helps clean storm water before it reaches the
waterway you live near. Longer grass also grows more
slowly and actually helps prevent weeds from growing by shading them out.
Cover Up The Bare Spots
practices that reduce the negative impacts to
your waterway. Use this brochure as a guide
Bare soil is easily eroded by storm water runoff. By
to understanding actions that impact the waterway near you.
establishing vegetation on bare areas of your property, you will help keep sediment out of the waterways. This will prevent erosion, which can severely
impact your property.
Save money and the environment by using only the
fertilizer and weed killer your lawn really needs. Keeping fertilizer away from waterways will reduce algae
and promote the health of aquatic life. Reducing the
amount of fertilizer used will also help protect drinking water supplies.
Dumping Yardwaste
Don’t dump yardwaste (grass clippings, leaves) into
your waterway. Yardwaste can clog the normal flow
of the waterway and damage the natural environment.
Use the waste management services available.
Learn more by visiting www.saswa.org
APPENDIX B
Spill Response Reports - 2006
APPENDIX C
Sediment Removal
Documentation
APPENDIX D
Website Statistics
October 2005 to September 2006
Daily Visitors
Daily Hits
Activity By Month
Activity By Month
Daily Page Access
Most Popular Pages
Daily File Access
Most Downloaded Files
APPENDIX E
Newsletters / News Articles for
2005/06
APPENDIX F
Annual Budget 2006
Annual Budget 2007
APPENDIX G
Attorney General’s Opinion