Stormwater Management Program Template
#OHQ000003
Chagrin River Watershed Partners, Inc.
P.O. Box 229
4145 Erie Street, Suite 203
Willoughby, Ohio 44096
(440) 975-3870 Fax (440) 975-3865
http://www.crwp.org
Notes on Using this Stormwater Management Program Template
This Stormwater Management Program (SWMP) template is designed to guide you on the format and content of your Small Municipal Separate Storm Sewer System (MS4)’s required SWMP update and submittal to Ohio EPA within 2 years of when your MS4 permit #OHQ000003 coverage is granted. The absolute deadline for submittal is December 22, 2016. However, depending on the permit coverage date for your MS4, your deadline may be earlier. If you are unsure when your permit coverage date is, you can check on the Ohio EPA website at http://www.epa.ohio.gov/dsw/storm/index.aspx#108452492-issued-permitspermittee-lists.
This template does not address all issues your community may encounter when updating your SWMP, but provides a framework in which you can address these issues. This template incorporates changes made in Ohio EPA’s NPDES General Permit #OHQ000003 issued September 12, 2014, and can be modified for use by both incorporated and unincorporated communities. Sample language has been provided for certain requirements as a way to assist permittees with crafting appropriate responses, based on BMPs in use by several Chagrin River watershed communities. You need to review and adjust this language; Ohio EPA will require additional detail from you in describing your specific BMPs, programs, and responsible parties for implementation to meet all six Minimum Control Measures (MCMs). This template is designed on the assumption that you will follow these guidelines when evaluating and updating your SWMP for each MCM under Phase II:
· Understand the general requirements of each MCM. These requirements are included in the template and are taken directly from Ohio EPA’s NPDES MS4 permit OHQ000003.
· Evaluate the Best Management Practices (BMPs) for each MCM and ensure alignment with Ohio EPA’s Total Maximum Daily Load (TMDL) reports where applicable. In addition to the general requirements under each MCM, Ohio EPA is requiring communities with endorsed TMDLs for their watershed(s) to enhance their MCM activities with BMPs that address TMDL pollutants. Review these TMDLs and make note of any that you can address with your existing activities. We have also developed a list of regional BMPs to address TMDL water quality problems that you can use to understand and facilitate your selection.
· Evaluate your existing SWMP activities as well as any activities you may not be currently including to meet MCM requirements. Many BMPs address multiple TMDL pollutants; do not commit to additional activities under Phase II until you have maximized the benefits of your existing efforts. Examine existing efforts and determine whether or not they are being successfully implemented. If not, then determine what changes should be made to ensure successful implementation, or what activities may be substituted.
· Ensure you have addressed each specific requirement as detailed in OHQ000003 and summarize your BMPs, both existing and new, in a list following each MCM.
· The Northeast Ohio Stormwater Training Council has developed guidance materials for updating your SWMP. These can be found on the NEOSWTC website at www.neohiostormwater.com under “Quick Reference Documents” on the main page. In particular, we recommend you download and utilize the SWMP Checklist while evaluating your existing SWMP. The TMDL factsheets will help you understand each TMDL pollutant and choose BMPs for your program that address these pollutants. You can use the Community Identifier Table to see what watersheds are in your community and what TMDLs are applicable to each watershed. We recommend that permittees identify all TMDLs applicable to their community and update their SWMP to uniformly address these TMDLs throughout their MS4. This ensures a consistent program throughout your MS4 and makes it easier to administer and enforce.
Table of Contents
List of Acronyms 4
Executive Summary 5
Legal Authorities to Implement the Stormwater Management Program 6
Financial Authorities to Implement the Stormwater Management Program 6
Overview of Community Stormwater System and TMDLs 7
Description of Program Development and Decision Process 8
Stormwater Management Program 9
MCM 1: Public Education and Outreach 9
MCM 2: Public Involvement and Participation 13
MCM 3: Illicit Discharge Detection and Elimination 17
MCM 4: Construction Site Stormwater Runoff Control 23
MCM 5: Post-Construction Stormwater Management in New Development and Redevelopment 28
MCM 6: Pollution Prevention/Good Housekeeping for Municipal Operations 36
Review and Update of the Stormwater Management Program 40
Evaluating, Record Keeping and Reporting 40
Appendices 40
Table 1: Public Education and Outreach Program Summary 11
Table 2: Public Involvement and Participation Program 15
Table 3: Illicit Discharge Detection and Elimination Program 21
Table 4: Construction Site Stormwater Control Program 26
Table 5: Post-Construction Stormwater Management Program 32
Table 6: Pollution Prevention/Good Housekeeping for Municipal Operations Program 38
List of Acronyms
In the preparation of this document, the following acronyms have been used:
NOTE: Depending on where this template is used, these acronyms may be revised.
BMP Best Management Practice
CRWP Chagrin River Watershed Partners, Inc.
DO Dissolved Oxygen
E&SC Erosion and Sediment Control
EPA Environmental Protection Agency
GIS Geographical Information System
GPS Global Positioning Satellites
HSTS Home Sewage Treatment System
MCM Minimum Control Measure
MOU Memorandum of Understanding
MS4 Municipal Separate Storm Sewer System
NEORSD Northeast Ohio Regional Sewer District
NOACA Northeast Ohio Areawide Coordinating Agency
NOI Notice of Intent
NPDES National Pollutant Discharge Elimination System
SWMP Stormwater Management Program
TMDL Total Maximum Daily Load
TSS Total Suspended Solids
Executive Summary
The previous NPDES Small MS4 general permit (#OHQ000002) required the development and implementation of a Stormwater Management Program that satisfied the appropriate water quality requirements of Ohio Revised Code (ORC) 6111 and the Clean Water Act. This document must identify and describe the best management practices (BMPs) the MS4 has selected to address the six MCMs in the permit, why those particular BMPs were selected by the MS4 in light of local water quality issues, and performance standards for BMP implementation. The six MCMs are:
1. Public Education and Outreach
2. Public Participation and Involvement
3. Illicit Discharge Detection and Elimination
4. Construction Site Runoff Control
5. Post-Construction Runoff Control
6. Pollution Prevention/Good Housekeeping for Municipal Operations
The NPDES Small MS4 permit was reissued on September 11, 2014 (#OHQ000003), and requires MS4 communities which are renewing coverage under this permit to update their SWMP to be consistent with #OHQ000003 and submit to Ohio EPA for review. #OHQ000003 requires that where applicable, BMPs shall be selected to address U.S. EPA approved TMDL recommendations for identified water quality problems associated with MS4 discharges within [Community]’s watershed(s).
Legal Authorities to Implement the Stormwater Management Program
MUNICIPALITY
The [Community] has the legal authority to implement the following Stormwater Management Program under Article XVIII, Section 3 of the Ohio Constitution granting municipalities the authority to adopt land use and control measures for promoting the peace, health, safety and general welfare of their citizens.
TOWNSHIP
[Community] has the legal authority to implement the following Stormwater Management Program under its governmental authority granted by Title 5, Chapters 501 to 521, Chapter 1502, and Chapter 5571 of the Ohio Revised Code. In addition, Ohio Attorney General Opinion No. 85-053 holds that a township may enact zoning resolutions which regulate land use in such a manner as to control sediment and stormwater runoff from urban development. In this context, “urban development” may include large-lot housing subdivisions and low density, semi-rural commercial or industrial development, and does not necessarily imply the higher-density type of development associated with cities.
Financial Authorities to Implement the Stormwater Management Program
Sample language: [Community] will fund the additional activities necessary to implement its SWMP through dollars from the general fund. Periodically, the [entity] will evaluate the SWMP and, if necessary, suggest alternative funding arrangements.
Overview of Community Stormwater System and TMDLs
The subsequent watersheds in [Community] have had U.S. EPA-approved TMDL reports prepared for the following water quality problems and pollutants:
· Black River (East Branch)
o Phosphorus, Nitrogen, Bacteria, Sediment/TSS, Low DO/Organic Enrichment
· Black River (Main Stem)
o Bacteria, Low DO/Organic Enrichment
· Black River (West Branch)
o Phosphorus, Nitrogen, Bacteria, Sediment/TSS, Low DO/Organic Enrichment
· Chagrin River
o Phosphorus, Nitrogen, Habitat, Bacteria, Sediment/TSS
· Cuyahoga River (Lower)
o Phosphorus, Nitrogen, Habitat, Bacteria, Low DO/Organic Enrichment
· Cuyahoga River (Middle)
o Phosphorus, Ammonia, Sediment/TSS, Low DO/Organic Enrichment, Flow
· Cuyahoga River (Upper)
o Phosphorus, Habitat
· Euclid Creek
o Phosphorus, Habitat, Sediment/TSS
· Grand River (Lower)
o Phosphorus, Bacteria, Flow
· Grand River (Upper)
o Phosphorus, Nitrogen, Ammonia, Habitat, Bacteria, Sediment/TSS
· Little Beaver Creek
o Phosphorus, Bacteria, Sediment/TSS, Low DO/Organic Enrichment
· Mahoning (Lower)
o Bacteria
· Mahoning (Upper)
o Phosphorus, Habitat, Bacteria, Sediment/TSS
· Nimishillen
o Phosphorus, Habitat, Bacteria
· Plum Creek (Rocky River)
o Phosphorus, Nitrogen
· Tuscarawas
o Phosphorus, Habitat, Bacteria, TSS
In order to maintain compliance with #OHQ000003, [Community] will use the recommendations made in the TMDLs for the above watersheds to better tailor our BMP selection to address noted water quality problems attributed to MS4 discharges.
Description of Program Development and Decision Process
To develop its SWMP, [Community] followed the steps outlined below:
1. Step
2. Step
3. Step
4. …
Stormwater Management Program
MCM 1: Public Education and Outreach
Sample Language:
Rationale for Themes and Target Audience Selection
Our MS4 is located in the Chagrin watershed, which has TMDLs for sediment, nutrients, bacteria, and habitat. We also have numerous coldwater habitat streams in our MS4 area. Because the majority of these pollution problems are caused by increases in impervious cover and the resulting increases in storm water volume and velocity, we will focus much of our Public Education and Outreach program on increasing public awareness of the links between land use practices and stormwater pollution. We will target pollutant sources identified in our TMDL such as sediment pollution from stream bank erosion and improperly controlled construction sites and habitat alteration due to land use changes. Our education and outreach program focuses on addressing these pollutants as well as special recommendations to preserve and improve coldwater habitat. During our permit term, we will choose at least five of the following themes:
- Addressing nutrients and habitat degradation through promotion of reducing turfgrass and limiting fertilizer and pesticide usage on residential lawns
- Addressing bacteria and nutrient pollution through a pet waste cleanup campaign
- Educating developers on construction site erosion and sediment control practices
- Promoting the benefits of riparian buffers for maintaining a healthy stream corridor and reducing streambank erosion
- Promoting rain gardens and native plantings to teach residents about infiltrating stormwater on-site and enable them to better manage stormwater on their properties
- Ways to reduce runoff on residential properties (soil amendment, aeration, rain barrels)
[Note: These themes are examples of the level of specificity required by Ohio EPA when choosing your themes. Ohio EPA will not accept more general “stormwater awareness” or “water quality issues” as appropriate themes.]
Our community’s population was 6,000 at the 2010 census. Our primary target audience is residential landowners as single-family residential comprises over 80% of our community’s land use, so their actions on their properties contribute significantly to stormwater runoff in our MS4. We also target the development community as they contribute significant amounts of sediment pollution to our MS4.
Rationale and Description of Chosen Mechanisms
Our primary mechanisms for delivery are the following:
· An article in our community newsletter, prepared by the Education and Outreach Coordinator of the Soil and Water Conservation District. The newsletter is edited by our Media Coordinator and mailed to every residential address on a quarterly basis, reaching 100% of our population annually. It also includes upcoming events for informing people of public involvement opportunities. A copy of the newsletter is included in the MCM 1 Appendix.
· Our community website (link here), which is updated by the Media Coordinator and receives an average of 250 unique visitors a month. We have a “Stormwater Information” section on the website that the Media Coordinator updates on an annual basis with information relevant to the year’s chosen theme, as well as archiving information from prior themes. We estimate that the website reaches 50% of our population annually.
· Our community Facebook page (link here), which currently has 600 likes. The Media Coordinator updates the Facebook page periodically with educational stormwater information and links to upcoming events. We estimate each post reaches 10% of our population.
· Community events and workshops. Some examples include our annual Home Days event, which draws an average of 3,000 visitors. We also work with the Education and Outreach Coordinator at the Soil and Water Conservation District to host informative annual workshops on our relevant stormwater themes.
In addition to these primary mechanisms, we may use other mechanisms such as posters, flyer mailings, permit inserts or new resident outreach mailings. Any additional mechanisms used will be documented by the Media Coordinator for reach and success, and included in the annual reporting to Ohio EPA. Our measurable goal is to reach a minimum of 50% of our MS4 population over five years, using a minimum of five themes with at least two mechanisms of delivery for each theme. If it does not appear that these objectives are being reached, the program will be re-evaluated and different mechanisms will be selected to meet our measurable goal.
Program Responsibility and Oversight
The Public Service Director is responsible for the overall management and implementation of our public education and outreach plan. The Service Director reports annually to the Storm Water Management Committee. The Stormwater Committee will conduct public opinion and awareness surveys in 2017 and 2019 with the goal of evaluating the state of public knowledge and awareness of stormwater issues and to what extent the public has adopted appropriate BMPs.
To assist in implementing our SWMP under MCM 1, we have entered into Memorandums of Understanding with the Watershed Organization and the County Soil and Water Conservation District. These MOUs are attached in the Appendix and these partner organizations are listed in Table 1. The SWCD’s Education and Outreach Coordinator prepares an annual Outreach Strategy document for our program that outlines the specific themes and activities they will be assisting us with for the permit cycle. A copy of the most recent Outreach Strategy document is included in the SWMP Appendix. [Note: This is an example of an MCM 1 service that some third party entities provide. Please verify if your third party service providers offer this service before including it in your SWMP.]