3/30/2006

Draft Process/Goals/Ground Rules for MRP Steering Committee

Draft Revised

Goals for Municipal Regional Permit Development Process

  • Consolidate six Phase 1 municipal stormwater permits (including one USEPA permit) into one consistent permit for 76 co-permittees[GB1], including phasing of requirements where necessary
  • Establish a phasing mechanism to accommodate the fact that the permit will cover a combination of six individual programs that are currently: 1) an order of magnitude different in size – smallest to largest, 2) up to 4 years out-of-phase in their issuance dates, and 3) at different stages of development of permit provisions due to different technical and political needs
  • To address court decision, Iincorporate[GB2] detail currently in Stormwater Management Plans (SWMPs) into the permit by being more specific in requirements including new performance standard tables establishing (a) the required activities, (b) how much of each activity is required, and (c) reporting and effectiveness evaluation requirements for each activity
  • To address court decision, Aadd more specific and comprehensive stormwater[GB3] monitoring, including monitoring for 303(d) listed pollutants
  • Add actions or enhance existing actions, including monitoring to address 303(d) listed pollutants and TMDL Waste Load Allocations
  • Establish priorities based on drivers so actions and levels of effort are commensurate with priorities and, to the extent possible, the ability of the actions to effect a change in an effectiveness measure[GB4]

New requirements will be considered in the context of implementation priorities, resource constraints and existing requirements.

  • Required actions should be related to desired outcomes or effectiveness measurements, where possible[GB5]. Often, the reporting of required actions is the sole measure of desired outcomes[GB6].Establish a streamlining mechanism so that over time, the permit and SWMPs are focused on the most environmentally effective and financially efficient set of actions[GB7]

1

[GB1]Achieving a smooth transition from six disparate permits (five State permits and one Federal permit) to one regional permit is a significant and challenging goal and therefore a phasing mechanism for the MRP deserves its own bullet (see next bullet).

[GB2]Let’s tie goals to drivers when possible to demonstrate they are being addressed.

[GB3]This bullet should be focused specifically on this driver. 303(d) clause is redundant with next bullet.

[GB4]All requirements should be considered within a context of priorities. Priorities should be based on drivers.

[GB5]Redundant with bullet above.

[GB6]Not a goal statement.

[GB7]Achieving maximized efficiency and effectiveness is an important goal.