Storm Water Pollution Prevention Initiative

Michigan General Permit Number MIG61000 Certificate of Coverage Number 610042

Municipality/Agency:Oakland County

Address:One Public Works Drive, Waterford, MI 48382

Contact Person: Philip Sanzica, P.E. Telephone:248-858-0958

Title:Assistant Chief Engineer Date:11/30/01 (revised 5/20/02)

Signature of Authorized Permittee Representative:

John P. McCulloch, Drain Commissioner

1. Purpose

The purpose of this Storm Water Pollution Prevention Initiative (SWPPI) is to bring together the goals and actions from the Watershed Management Plan (WMP), Illicit Discharge Elimination Plan (IDEP), and the Public Education Plan (PEP) into a single document containing the Oakland County commitments necessary to reduce the discharge of pollutants to the maximum extent practicable. The SWPPI includes those actions expected to be implemented over, and in some cases beyond, the term of the permit.

Oakland County agrees to address all of the WMP Goals associated with the Main 1-2, Middle One, and Upper subwatersheds. As the majority land area, Oakland County will be focusing upon the goals of the Main 1-2 subwatershed:

  1. Remove Sources of Pollution that Threaten Public Health (1)
  2. Restore/Maintain Aesthetically Appealing Conditions (2)
  3. Improve and Maintain River Ecosystems for Fish and Wildlife (3)
  4. Minimize the Amount of Soil Erosion and Sedimentation (4)
  5. Minimize Flow Variability and Associated Negative Impacts (5)
  6. Maximize Community Assets Related to the River (6)
  7. Preserve and Enhance the Quality of the Great Lakes (7)

We feel that the five goals from the Upper WMP and Goals 1-7 of the Middle One are relatively consistent with the above goals, either in whole or part with other parts of the above listed goals. The Middle One goals 8, 9 and 10 (below) from the Middle One will be addressed in addition to the Main Goals, as they are not clearly consistent with those goals:

  1. Integrate Stormwater Management in Planning and Land Use Approval Process. (M8)
  2. Establish Financial and Institutional Arrangements for the Fullfillment of the Management Plan (M9)
  3. Enforce Action Plans and Increase Accountability for Stormwater Management (M10)

This listing will be the basis for the reference in both Table 1 and Table 2. Although not directly reference, all of the Management Alternatives put forth by Oakland County within the 3 plans have all been reviewed and incorporated into the SWPPI actions as appropriate.

2. Annual Report to Assess Progress

In order to assess our progress, Oakland County will document the following on an annual basis (The annual report will be submitted on or before the date stipulated by the MDEQ in the letter accepting this SWPPI):

  • Changes to goals and/or actions in the WMP prior to the required permit date for biannual review and revision
  • Progress with respect to specific goals and/or actions as presented in Table 2.
  • Any additional actions taken to reduce the discharge of pollutants in storm water.

This report will incorporate items from the existing annual report that addresses the previously submitted IDEP and PEP documents and be part of a combined annual report and SWPPI progress report due on date specified under existing permit. All of the annual report items have been incorporated into the SWPPI.

3. Subwatershed Plan and SWPPI Revisions

The SWPPI will be reviewed and revised as necessary every two years. Revisions to date-specific commitments listed in Table 2 can be made with approval of MDEQ. The WMP and the SWPPI can be revised at the same time, but will be due on the revision date for the WMP.

4. Retention of records

Oakland County will retain the approved Storm Water Pollution Prevention Initiative and its associated records in-house for a minimum of three years after the termination of the permit. The records will be available upon request by MDEQ and shall include, but not be limited to:

  • Information regarding the effectiveness of these activities;
  • Records of analyses performed;
  • Calibration and maintenance of instrumentation, if used;
  • Recordings from continuous monitoring instrumentation.

5. SWPPI goals and priorities of Oakland County

The Oakland County Drain Commissioner’s Office, as the designated representative for Oakland County is dedicated to provide strong facilitation and support to all of the Rouge River Watershed 22 communities within the County as well as meeting all of the permit requirements and WMP goals the are within Oakland County control to protect and restore the Rouge River. The Drain Office has been actively involved in all three related subwatershed planning activities and leads the Main 1-2 effort. The recently elected Drain Commissioner, Mr. McCulloch, has affirmed the commitment to address water quality issues as an integrated part of stormwater management.

The Drain Office jurisdiction within the Rouge River Watershed consists of a piecemeal of open watercourses, enclosed drains and other detention ponds and systems of Chapter 4 Drains, Chapter 20 Drain and Chapter 18 Drainage Areas that are the headwaters not only the Main Branch, but the Upper and Middle Branches as well. Approximately 160 square miles of the Rouge basin is situated within Oakland County. The land use is mostly urbanized, with a mix of residential and commercial/industrial use and is home to over 290,000 people.

In addition to the stormwater system, the Drain Office also administers the Soil Erosion Control program for some of the communities, as well as operates and maintains municipal water and sewer supply for a large portion of the watershed and manages lake improvement programs as designated by the State of Michigan. Oakland County has also established a high quality Illicit Detection Elimination Program that not only has completed an inventory within the County Drains, but has a program available to all the communities as well. The Drain Office has also led the public education efforts through a sub-committee of community representatives to provide the staff and citizens with coordinated programming and outreach.

Within Oakland County, other departments such as the Road Commission, Planning Department, Health Department and Parks and Recreation play additional roles in water quality/stormwater management. The Drain Office is working diligently with these departments to coordinate efforts and convey the importance of cooperation to achieve our goals and requirements. We are diligently working with the Executive Branch and its Administration to integrate these programs into the essential structure of the necessary departments. We are providing an advisory role to the Health Department study by U.S.G.S. for updating the comprehensive water resources assessment; will work with the Road Commission to continue to focus there efforts on watershed/stormwater issues; and continue to collaborate with all other watershed groups and stakeholders throughout the County. Although not listed specifically, the Oakland County Drain Office will not only be concentrating efforts for the programs within the Rouge Watershed, but also be applying these program, as applicable to the other four watersheds and associated communities within the County.

As further listings in the SWPPI document will show, Oakland County will be undertaking many new initiatives that will be beneficial for watershed protection, including a coordinated on-site disposal system program, stormwater standards review, and coordinated subwatershed drainage program.

6. Storm Water Pollution Prevention Development

This SWPPI has been designed and will be implemented to reduce the discharge of pollutants to the maximum extent practicable and is consistent with the Main 1-2, Middle One, and Upper subwatershed Management Plan(s) developed under Part I.B.1 of the General Permit, and includes those actions to be implemented over the term of this permit. This SWPPI will be implemented upon approval of the District Supervisor, and includes:

  1. Actions required of Oakland Countyin the Main 1-2, Middle One, and UpperSubwatershed Management Plan(s) as described in Table 2;
  1. Evaluation and implementation of pollution prevention and good housekeeping activities, as appropriate, having considered the following practices (as described in Table 2):
  2. Maintenance activities, maintenance schedules, and inspection procedures for storm water structural controls to reduce pollutants (including floatables) in discharges from our permitted separate storm water drainage system;
  3. Controls for reducing or eliminating the discharges of pollutants from streets, roads, highways and parking lots;
  4. Procedures for the proper disposal of operation and maintenance waste from the permitted separate storm water drainage system (dredge spoil, accumulated sediments, floatables, and other debris);
  5. Ways to ensure that new flood management projects assess the impacts on the water quality of the receiving waters and, whenever possible, examine existing projects for incorporation of additional water quality protection devices or practices; and
  6. Implementation of controls to reduce the discharge of pollutants related to application of pesticides, herbicides, and fertilizers applied in our permitted jurisdiction.
  1. Evaluation and implementation of site appropriate, cost-effective structural and nonstructural best management practices (BMPs) to minimize the water quality impacts from areas of new development and significant redevelopment, with the understanding that the goal is to protect the designated uses in the receiving waters from the effects commonly associated with urbanization.
  1. The methods of assessing subwatershed progress in storm water pollution prevention, as summarized for each of the Subwatershed Management Plan(s) Goals in Table 1.

1

Table 1. Goal-Specific Long Term Assessment of Progress in Oakland County Rouge Subwatershed

# / Oakland County Goal
(Main 1-2 based) / Methods for Evaluating Progress in River / Target for Evaluation in the Subwatershed (per the M1 Rouge Subwatershed Management Plan) / Responsible Party for Evaluating Progress
1 / Remove Sources of Pollution that Threaten Public Health /
  1. Dry weather water quality monitoring for E. coli at RPO sites: M01, M03, M05, G45, G46, G47, G58, G59, & US5. (and upper/middle one sites)
  2. Wet weather water quality monitoring for bacteria at selected RPO sites.
/
  • A. & B. Achieve partially body contact standard for E. coli at all locations in dry weather by 2015.
/
  1. RPO
  2. RPO

2 / Restore/Maintain Aesthetically Appealling Conditions /
  1. Aesthetics Survey
  1. Dry and wet weather water quality monitoring for Total Phosphorus (TP) at RPO sites: M03, G45, & US5 (and upper/middle one sites).
/
  • A minimum of 85% of Rouge River Aesthetic Indicator (RRAI) scores that rank “good” or “excellent” at all locations surveyed or improvement scores when compared to 1996 surveys by 2015.
  • Annual average TP values at or below 0.05 mg/l by 2015
  • Based on achieving desired aesthetic use, maintain or achieve TSS concentrations below 80 mg/l in dry weather conditions, by 2015.
/
  1. Communities/Agencies (Oakland County)

3 / Improve and Maintain River and Ecosystem for Fish and Wildlife /
  1. Biological monitoring (fish) at various sites.
  1. Macroinvertebrate monitoring at various sites.
/
  • Improve score for fish to “Good”-Excellent” at all sites by 2015.
  • Minimum score for macroinvertebrates “fair” by 2015.
/ A. Communities/Agencies (Oakland County)
4 / Reduce soil erosion and sedimentation /
  1. Monitor instream Total Suspended Solids (TSS) concentrations at two RPO locations in both dry and wet weather.
  1. Habitat assessment, bottom deposition and embeddedness measures
  2. Aesthetics monitoring.
  3. Macroinvertbrate monitoring
/
MDEQ/GLEAS habitat evaluations of embeddedness and bottom deposition, showing trends of decreasing sedimentation in Rouge by 2006
  • Achieve TSS concentrations of 80 mg/L in dry weather conditions at both monitoring stations by 2010.
  • Show decreasing trends of sedimentation by 2010.
/
A.RPO
  1. MDEQ/GLEAS
  2. Communities/agencies, Volunteers

5 / Reduce flow variability /
  1. Macroinvertebrate monitoring
  2. Monitor stream flows at USGS stream gauges US4, US5, & US6 and others.
  3. RPO/OCDC rainfall monitoring at R15-R23 & R30-R33.
  4. Monitoring at sites (D02, D03, D08) and others.
/
  • For macroinvertebrates, maintain GLEAS 51 scores at all sites. Review 2000 MDEQ data and revise targets to reflect changes.
  • Meet Wiley/Seelbach numbers by 2015 (knock down peak flows and increase baseflows) Peak flow trends will be observed with new data from new USGS gage at downstream end of M1 subwatershed in 2001.
/
  1. RPO, USGS
  2. Wayne Co.
  3. RPO
  4. FOTR volunteers

6 / Maximize Community Assets Related to the River (6) /
  1. Workshop/meeting attendance.
  2. Telephone or mail survey of watershed residents.
  3. Dry and wet weather sampling at at least 5 sites.
  4. Recreation use and aesthetics monitoring/surveys
/
  • Increase in meeting attendance
  • Improve the public perception of the river when compared to previous surveys by 2010.
  • Improve aesthetic conditions where feasible, by 2010.
  • Based on achieving desired aesthetic use, maintain or achieve TSS concentrations below 80 mg/l in dry weather conditions, by 2015.
  • Increase recreation potential and use by 2015.
  • Maintain or achieve partial body contact in dry weather conditions (1,000 colonies per 100 ml) for main branch and tributaries with a base flow of, or greater than, 2 cfs, by 2010.
/
  1. RPO
  2. FOTR volunteers
  3. Communities/agencies, Volunteers

7 / Preserve and Enhance the Quality of the Great Lakes /
  1. Track the types and amount of PE materials distributed and the number of households reached.
  2. Report on the number of schools involved in Rouge Education Project (REP).
  3. Report on the number of visitors community watershed/ stormwater websites.
  4. Telephone or mail survey of watershed residents, Improve the public perception of the river when compared to previous surveys by 2010
/
  • Establish a subwatershed based, or community based, monitoring plan as needed to determine progress toward goals.
  • 100% of households reached with various PE messages by 2006.
  • Work with monitoring agencies (RPO, DEQ, FOTR, etc.) to support and enhance existing monitoring programs.
  • All water quality data available.
  • Improve the public perception of the river when compared to previous surveys by 2010.
/
  1. Communities
  2. OCDC
  3. FOTR

M8 / Integrate storm water management in planning process /
  1. Reporting on activities performed and evaluating success.
/ Evaluation method(s) provided in Table 2. /
  1. Communities/agencies

M9 / Establish financial and institutional arrangements for the fulfillment of the plan / A. Reporting on activities performed and evaluating success. / Evaluation method(s) provided in Table 2. /
  1. Communities/agencies

M10 / Enforce action plans and increase accountability for storm water management / A. Reporting on activities performed and evaluating success. / Evaluation method(s) provided in Table 2. /
  1. Communities/agencies

It is recognized by the permittee and the MDEQ that the subwatershed targets and schedules in Table 1 are intended to track effectiveness and progress of the SWPPI actions, and progress towards the subwatershed goals. The targets and schedules are not enforceable compliance items required by the permit, and the permittee will not be found in noncompliance with the permit if they are not achieved. If, during SWPPI revisions, it is determined that progress towards achieving the subwatershed targets is not being made, the permittee and the MDEQ will negotiate additional and/or alternative actions, schedules, or targets. We recognize that the Permitee is the ultimate Reponsible Party for the Evaluation Method.

TABLE 2. STORMWATER POLLUTION PREVENTION INITIATIVE FOR OAKLAND COUNTY
Activity / Goals / Detail / Timeline / Method of Measuring Progress
Main 1-2 plan & permit / * all months indicate end of the month
Planning/Reporting
1 / Subwatershed Management / M10 / Participate with a leadership role in the Main 1-2 subwatershed group and provide representation for the Middle One and Upper watershed. / On-going / Activity Report (Including all relevant details- date, numbers, findings and progress).
2 / Annual Report / (I.B.4.d) / Submit report annually summarizing all permit requirements and all SWPPI items. / Permit due date / Document
3 / Local Program Coordination / M8, M10 / Assist local communities in developing subwatershed or coordinated multi-community projects to meet any of the planning objectives or goals. / On-going / Activity Report.
4 / Private Institution/Stakeholder Assistance / M8, M9 / Work with Cranbrook or other private landowner stakeholders to coordinate activities and/or projects that would improve the Rouge River. / On-going / Activity Report.
5 / Drainage District Development / M9, M10 / Review a strategy to implement a comprehensive drainage district funding mechanism and proceed with implementation of recommended changes as they are reviewed and approved with the appropriate stakeholders. / December 2002 / Activity Report.
6 / County - Other departments activity coordination / M8 / Coordinate activities and share information between various departments regarding watershed issues, I.e. Planning, MSUE, Environmental Health, Parks and Recreation, Road Commission / On-going / Activity Report.
7 / SEMCOG Water Quality Plan / M8 / Support the efforts of SEMCOG with the sharing of information and programming related to their water quality planning activities. / On-going / Activity Report.
8 / Mapping / 6, 7, M8
PEP / Work with existing data from OC Planning/GIS regarding stormwater, hydrology, natural features and other environmental features to develop maps for planning, education, and programs. / On-going / Activity Report.
9 / County Roads - Agency Involvement / M8, M9 / Continue to oversee RCOC activities (see 5/17/02 report). Develop a detailed strategy to work with local agencies or other groups to address issues related to Roads under the jurisdiction of Road Commission. / August 2002 / Report/Plan Document
Operation & Maintenance
1 / Storm Drain maintenance/inspections / 1
IDEP
PPGH / Continue to perform inspections of storm drains for evidence of sedimentation, blockage, or improper function as requested or staff/resources are available. Enhance program for database tracking and reporting, including a formal visual observation and notation of out-falls and potential problems on each field report. / On-going, Enhanced program starting in January 2002 (fully implemented by 9/02) / Inspection report log with # of inspection and listing of actions.
2 / Sanitary Sewer maintenance/inspections / 1, 3
IDEP
PPGH / Continue to perform routine inspections on sanitary sewer systems to insure proper operation and prevent overflows and/or release of sewage to surface waters / On-going / Existing annual report (with problems and corrections).
3 / Facilities Inspections / 1, 3
IDEP
PPGH / Inspect all Drain Office and other County Department facilities within the Rouge Watershed Basin to insure that proper protection of stormwater is in place and that good housekeeping practices are being followed. This will include outfall inspection. / Complete all facilities by December 2002. Reinspect every 5 years. / Provide data