In the joint application, the best management practices (BMPs), size of pipe flumes for stream crossings, and design of the required silt fences are based on engineering calculations of a 5-year storm event.1 CP considered 2-year, 5-year, and 10-year storm events, but is assuming a 5-year storm event as the basis for their 401 water quality certificate, and 4 related permits. There is no rational basis for this assumption.

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