National Flood Insurance Program (NFIP) &
EPA Municipal Separate Storm Sewer System (MS4):
Enforcement Request

Eric Castelli

379 Carr Creek Dr, Columbia, IL

City Council Meeting

Initial Public Comments Presented August 4, 2025, 6:30 PM CT: You Tube Video

Follow up Public Comments Nov 3, 2025, 6:30 PM CT (Public Comments Blocked from Live Feed): You Tube Video

November 19, 2025 Republic Times Article

September 22, 2026 60 Day Notice of Intent to Sue for EPA Clean Water Act Violations

September 30, 2026 Republic Times Article Clean Water Act Notice

Overview

• I have been a resident of Columbia, IL since 2007
• Part of my property is in a designated AE flood zone and considered a Special Flood Hazard Area (SFHA).
  • Flood Zone Aerial
  • LOMR
  • City Inspector Communication
• FEMA NFIP community participation requires communities adopt standards to protect properties in a SFHA
• To qualify for the NFIP program, Columbia added Chapter 15.60 to the Columbia Municipal Code (Flood Hazard Protection Regulations)
• Columbia, IL is permittee of the EPA MS4 (Permit# ILR400318) program and obligated to enforce post-construction stormwater drainage system designs for all developments, regardless of whether these developments occurred before or after this permit was issued in 2016.
• The Burroughs Neighborhood to the North of the Joy View Acres neighborhood has a base elevation of approximately 50 feet higher
• The Burroughs stormwater drainage system design sends select stormwater drain flows on Carl Street downhill toward the Joy View Acres subdivision
• Chapter 15.52 (Stormwater Management) of the Columbia Municipal Code requires a development's stormwater runoff to be detained on site and not impact downstream property owners
• The plats for Burroughs Phase II were filed in 1987 and at this time stormwater drainage designs were not required to be filed along with the with the road tract plats.
• While there are no public records of the approved stormwater drainage design for Burroughs Phase II, these should have complied with Chapter 15.52 of Columbia Municipal Code. Per the "Don't Pollute. Flows to Waterways" stickers on the drains, the Burroughs drainage design would have appeared as illustrated here
• The stormwater drainage system design for Phase II of the Joy View Acres was approved by the City of Columbia in September, 2002.
• The final plat for development of Phase II of the Joy View Acres subdivision where my property is located was filed and approved on November 9, 2006.
• In November, 2006, the exact same time when Phase II plans for Joy View Acres were approved, the developer or previous owner of 349 Carl Street added unpermitted drains under the natural damn in this detention basin, redirecting this stormwater flow into Joy View Acres as illustrated and shown in this drone footage. The water flow from this drain flows directly into Carr Creek via the drain located at 355 Carr Creek Dr (no detention).
• While the lot numbers changed between the Joy View Acres drainage design and Phase II filings, it is clear to see that the approved stormwater drainage designs did not anticipate drains flowing water into the Joy View Acres stormwater drainage system from 349 Carl Street.
• In April 2023, the City’s Engineering firm, Millennia Professional Services, issued a report indicating that the Burroughs overflow redirection was a significant contributor to flooding around Carr Creek Drive
• My property has faced flooding risks since purchasing our home in 2018. On July 16, 2024, the designated flood zone on my property flooded and water was within feet of reaching my home
• The Mayor and City Administrator have communicated that the City of Columbia does not have an easement for the presumably intended detention area located at 349 Carl Street and it has no rights or legal obligations to act.
• The Monroe County Deputy Clerk has confirmed that there are no drainage easements on this property which would make the presumed City-approved Burroughs drainage plans in violation of the property rights of the owner of 349 Carl Street

• By allowing this unpermitted drain flow, it is my position that the City of Columbia is currently not in compliance with the following regulations:
  • Columbia Municipal Code Chapter 15.52 (Stormwater Management - Detention Basin Required)
  • Columbia Municipal Code Section 15.60.060 (Flood Hazard Protection Regulations: Preventing Increased Damages)
  • NFIP regulations protecting properties in a flood zone and requiring municipalities prevent increased damages
  • EPA MS4 requirements to enforce and maintain a development's approved stormwater management system design

• To protect my property and remain in good standing with the National Flood Insurance Program and the EPA MS4 program, I formally request that City Council reach an agreement with the property owner of 349 Carl Street and approve a resolution to remove the unpermitted drains and restore the stormwater drainage designs of these developments within 90 days.
• Should the City believe my claims are unmerited or it has no obligation to act, I will be publicly presenting the escalation actions I will be taking and the possible implications for the City of Columbia at the November 3, 2025 scheduled City Council meeting

Next Steps (Nov 3, 2025 Public Comments)

After 3 years of trying to get the City to take action to protect my property and the properities of my neighbors, I will be proceeding on escalating this issue as outlined.

Planned Action	Agency / Target	Potential Implications
Submit MS4 Violation Complaint	EPA Region 5 / IEPA	Investigation under Clean Water Act Possible Fines and Enforcement Actions
Report AE Zone Protection Failure	FEMA / IDNR	Audit of Floodplain Management NFIP Probation Increased Flood Inusrance Rates
Request Review of Illegal Modifications	Army Corps of Engineers	Review of Compliance Order to Restore Site Compliance Actions
Filing Formal Liability Notice	City Clerk	Triggers Legal Record Retention Opens City to Civil Claims

If agency enforcement stalls, I along with other impacted residents will explore all available legal options, including those authorized under the Clean Water Act.

Contact Information

Eric Castelli

379 Carr Creek Dr, Columbia, IL 62236

314-496-5500

castellillc@gmail.com