List of Acronyms · Web viewThis template does not address all issues your community may encounter when updating your SWMP, but provides a framework in which you can address these

Stormwater Management Program Template

#OHQ000003

Chagrin River Watershed Partners, Inc.P.O. Box 229

4145 Erie Street, Suite 203Willoughby, Ohio 44096

(440) 975-3870 Fax (440) 975-3865http://www.crwp.org

[email protected]

mailto:[email protected]

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.

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http://www.neohiostormwater.com/

http://www.epa.ohio.gov/dsw/storm/index.aspx#108452492-issued-permitspermittee-lists

http://www.epa.ohio.gov/dsw/storm/index.aspx#108452492-issued-permitspermittee-lists

Table of ContentsList 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.....................................................................11Table 2: Public Involvement and Participation Program............................................................................15Table 3: Illicit Discharge Detection and Elimination Program....................................................................21Table 4: Construction Site Stormwater Control Program..........................................................................26Table 5: Post-Construction Stormwater Management Program...............................................................32Table 6: Pollution Prevention/Good Housekeeping for Municipal Operations Program...........................38

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List of AcronymsIn 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 PracticeCRWP Chagrin River Watershed Partners, Inc.DO Dissolved OxygenE&SC Erosion and Sediment ControlEPA Environmental Protection AgencyGIS Geographical Information SystemGPS Global Positioning SatellitesHSTS Home Sewage Treatment SystemMCM Minimum Control MeasureMOU Memorandum of UnderstandingMS4 Municipal Separate Storm Sewer SystemNEORSD Northeast Ohio Regional Sewer DistrictNOACA Northeast Ohio Areawide Coordinating AgencyNOI Notice of IntentNPDES National Pollutant Discharge Elimination SystemSWMP Stormwater Management ProgramTMDL Total Maximum Daily LoadTSS Total Suspended Solids

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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 Outreach2. Public Participation and Involvement3. Illicit Discharge Detection and Elimination4. Construction Site Runoff Control5. Post-Construction Runoff Control6. 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).

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In your Stormwater Management Program, you need to be very specific about the roles assigned to responsible parties and who those responsible parties are. The level of detail should follow that of your developed Table of Organization submitted with your Annual Report. At a minimum, the department or third party responsible should be identified for each component of your SWMP, and preferably names and titles. Any third party responsible for implementing portions of your SWMP must have an established Memorandum of Understanding with you that outlines their role, and this MOU should be included in your SWMP documentation as well as submitted with your Annual Report every year.

Legal Authorities to Implement the Stormwater Management Program

MUNICIPALITYThe [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.

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All communities should have their legal counsel review their SWMP and prepare the final version of this section.

Funding is needed to maintain the staff, equipment, and materials necessary to develop and implement an effective program. Adequate funding is critical to the success of the program but attaining it can be difficult as many other important programs compete for the same limited revenues from a general fund. While the general fund can be a successful way to finance your SWMP, the programs are at risk in each budget cycle. In addition, in order to increase funding levels for your program, other local government services may be affected or a general tax increase may be required. Evaluate your current funding strategy and consider alternative funding options such as: stormwater utility community cost share funds, connection fees, developer fees, capital improvement, legislative actions, stormwater bond funds, local improvement assessments, or inspection fees.

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 Rivero 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 Creeko Phosphorus, Habitat, Sediment/TSS

Grand River (Lower)o Phosphorus, Bacteria, Flow

Grand River (Upper)o Phosphorus, Nitrogen, Ammonia, Habitat, Bacteria, Sediment/TSS

Little Beaver Creeko Phosphorus, Bacteria, Sediment/TSS, Low DO/Organic Enrichment

Mahoning (Lower)o Bacteria

Mahoning (Upper)o Phosphorus, Habitat, Bacteria, Sediment/TSS

Nimishilleno Phosphorus, Habitat, Bacteria

Plum Creek (Rocky River)o Phosphorus, Nitrogen

Tuscarawaso Phosphorus, Habitat, Bacteria, TSS

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This section should already contain a description of your community stormwater system (information like your community population, land area, watershed drainage, receiving waters, etc.). The following language can be used to update your description to include information about Total Maximum Daily Load requirements. Include all watersheds that apply to your community.

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 ProcessTo develop its SWMP, [Community] followed the steps outlined below:

1. Step2. Step3. Step4. …

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This section should contain a description of the steps you took to develop your stormwater management program. This can include activities such as formation of a stormwater committee, assignment of stormwater management responsibility, review of the specific requirements of the MS4 permit, selection of measurable goals and assignment of responsible parties, public hearings, and finalization/approval process. You are required to show ways you have given the public opportunities to be involved in the development of your SWMP, such as holding public hearings, or putting your SWMP update up on your website for people to read and give comments on.

You should list the responsible entities for implementing your stormwater management program. The level of detail should be that of your established Table of Organization. Include your Table of Organization in your SWMP as an appendix.

Stormwater Management Program

MCM 1: Public Education and Outreach

Sample Language: Rationale for Themes and Target Audience SelectionOur 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

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To fulfill the Minimum Control Measures (MCMs) for Public Education and Outreach, you are required to have a public education and outreach program that accomplishes the following:

Contains a minimum of five themes or messages, one of which is targeted towards the development community.

A minimum of two mechanisms for delivery of your themes. Examples of mechanisms include but are not limited to billboards, a community newsletter or e-newsletter, a community website, a brochure or factsheet, or a public-access TV network.

Reaches 50% of your MS4 population by the end of the 5-year permit term. In coordination with MCM 6: Good Housekeeping and Pollution Prevention, you should also

provide an annual educational training for municipal staff.

In your description of your public education and outreach program, you should be very specific about the assignment of roles and who is responsible for each theme and mechanism of delivery. Your description needs to include a rationale for why you have chosen the specific audiences, themes, and mechanisms. Each mechanism should have an estimate of how much of the target audience you plan to reach, and a way of evaluating that reach. Some sample text has been provided below to guide you in your narrative, but additional detail will be required to pass review by Ohio EPA.

A recommended way to approach your public education and outreach rationales for your chosen themes is to determine what the primary TMDL pollutant concerns are for your relevant watersheds, and tailor your program to address those pollutants.

RELEVANT ITEMS YOU SHOULD INCLUDE IN YOUR SWMP APPENDIX: Any outreach strategy document produced by a third party service provider Samples of outreach materials (flyers, brochures, etc) Any studies done to identify and describe the knowledge, attitudes and perceptions of

public target audiences regarding stormwater (polls, surveys, questionnaires, etc.)

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:

1. Addressing nutrients and habitat degradation through promotion of reducing turfgrass and limiting fertilizer and pesticide usage on residential lawns

2. Addressing bacteria and nutrient pollution through a pet waste cleanup campaign3. Educating developers on construction site erosion and sediment control practices4. Promoting the benefits of riparian buffers for maintaining a healthy stream corridor and

reducing streambank erosion5. Promoting rain gardens and native plantings to teach residents about infiltrating stormwater on-

site and enable them to better manage stormwater on their properties6. 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 MechanismsOur 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

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objectives are being reached, the program will be re-evaluated and different mechanisms will be selected to meet our measurable goal.

Program Responsibility and OversightThe 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.]

Table 1: Public Education and Outreach Program Summary

MCM 1: Public Education and OutreachPerformance Standards: Must use more than one mechanism of delivery to residents. Must use at least 5 different themes, one of which must be for the development community. Must reach at least 50% of the population by the end of the permit cycle.Theme and TMDL Applicability

Mechanisms for Delivery (minimum of 2)

Schedule and Measurable Goal

Responsible Party

Theme 1: Honey I Shrunk the Lawn! Addresses the [watershed] TMDLs of nutrients and habitat degradation through promotion of reducing turfgrass and limiting fertilizer/pesticide usage on residential lawns

Targeted mailings, quarterly newsletters, annual theme-based poster and educational materials available at community locations, presentations to target audiences, annual county-wide teacher workshop, workshops for rain barrels, rain gardens, green cleaning and native plants and landscaping

Reach 10-15% of population annually with targeted message related to year's theme, with the goal of 50% being reached by the end of the five year permit cycle

Media Coordinator, County SWCD Education and Outreach Coordinator, Watershed Organization

Theme 2 Theme 3 Theme 4 Theme 5

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The above table includes an example of a theme/message, TMDL applicability, measurable goal, and responsible parties for your Public Outreach and Education program. You can use this Table to summarize your program for your internal use and documentation, and to facilitate your annual reporting. The narratives included in Table 1 are only examples of possible BMPs and language you may use. Alter these to reflect activities that do or will occur in your community. Updating this table alone will not be considered an acceptable level of detail by Ohio EPA for resubmitting your SWMP.

MCM 2: Public Involvement and Participation

Sample Language: Public Involvement and Participation in the SWMP ProcessOur Stormwater Management Committee, which includes two community residents, met on [dates] to discuss the SWMP and its development. From these meetings, which were open to the public, the existing SWMP was evaluated for programmatic success. BMPs that were deemed unsuccessful were replaced and noted in the SWMP where this occurred. Specific BMPs to address watershed TMDLs were discussed and a list of preferred BMPs were rationalized and compiled. A public meeting targeted to community engineers, mayors, councilpersons, and service directors was held on [date] to provide an update to the public about the planning process, to outline recommended BMPs, and request comments from the public on the recommended BMPs. From this initial feedback, the update of the SWMP was drafted and presented to the public on [date] for comments, and Council voted to adopt the

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You must involve the public and allow them to participate in the implementation of your stormwater management program. To fulfill the Minimum Control Measures (MCMs) for Public Involvement and Participation, you are required to have a public involvement and participation program that accomplishes the following:

A minimum of five public involvement/participation events to be held during the permit cycle. Examples include but are not limited to stream cleanups, volunteer plantings, volunteer storm drain stenciling, hazardous waste drop-offs, community rain garden installations, public stormwater meetings, stormwater advisory committee meetings including residents and make-your-own rain barrel workshops.

In your description of your public involvement and participation program, you should be very specific about the assignment of roles and who is responsible for each involvement/participation event. Your description needs to include a rationale for why you have chosen the specific events, and why you have selected your target audiences. Be as detailed as possible in describing your stakeholders and target audiences- specific schools, organizations, and personnel where possible. Each event should have a way of evaluating its programmatic success. For many permittees, the MCM 1 and MCM 2 requirements are accomplished in tandem with each other, and often by the same third-party providers such as local watershed organizations or County Soil and Water Conservation Districts. Some sample text has been provided below to guide you in your narrative, but additional detail will be required to pass review by Ohio EPA.

A recommended way to approach your public involvement and participation program is to determine what the primary TMDL pollutant concerns are for your relevant watersheds, and tailor your events to address those pollutants.

RELEVANT ITEMS YOU SHOULD INCLUDE IN YOUR SWMP APPENDIX: Any events strategy document from a third-party service provider (typically included in an

outreach strategy document) Samples of public notice materials for events (email blasts, webpage/newsletter

announcements, flyers, etc.) Minutes from meetings documenting public input on the SWMP development process

plan at their meeting on [date]. Meeting minutes from these public meetings are included in the SWMP Appendix.

Our Stormwater Committee, comprised of community staff and local residents, hosts quarterly meetings which are open to the public and serve as a forum for the public to express concerns and offer future enhancements to the SWMP. A meeting agenda and roster of our Stormwater Committee as of [date] is included in our MCM 2 Appendix.

Public Information for Involvement OpportunitiesWe primarily inform the public of our involvement and participation events through our community website and newsletter. The website has an Events page on the main page that is updated weekly by our Media Coordinator and the site receives an average of 800 unique visitors a month. Our community newsletter includes upcoming events for the public and is mailed to every resident on a quarterly basis. Other mechanisms, depending on event, may include event-specific flyers to be handed out at our Home Days or other public gatherings, or distributed at public locations such as the Library or City Hall. Our Stormwater Committee meetings, which are open to the public, are announced in compliance with State and local public notice requirements.

Primary Involvement Audiences and RationaleAs described in our MCM 1 rationale, our primary audience will be homeowners as residential comprises over 80% of our community’s land use. We will work with [individual landowners, homeowner’s associations, block clubs, other residential groups, etc.] to help involve our residential population in our stormwater program. We also believe engaging and involving children in environmental programs is an important component of sustaining a successful long-term program, so we have established relationships with local scout troops and work with [teachers, troop leaders, program administrators, etc.] at our elementary and high schools to involve their students in stormwater-related activities. Based off of residential feedback, we have identified two residential neighborhoods along Street A and Street B where excessive stormwater flows are contributing to flooding and erosion. We will target these residents specifically for implementation of stormwater management practices such as rain barrels, rain gardens, and reduction of impervious surface.

Involvement Activities and RationaleDuring this permit cycle, we will offer a minimum of five public involvement activities. These activities may include but are not limited to:

a. Annual Make-Your-Own Rain Barrel workshop, hosted by the Service Department and the County SWCD

b. Stormwater Committee meetings that are open to the public and have residential representatives serving on the Committee

c. Stream clean-up or planting event sponsored by the community and a local scout troop or school

d. Storm drain stenciling with a local scout troop or schoole. Bi-annual household hazardous waste collection eventsf. Residential complaint hotline to the County SWCD for reporting potential violationsg. Community rain garden installation, hosted by our Service Department and County SWCD

These activities were primarily chosen based on their ability to improve in-stream habitat and reduce nutrient pollution, excessive stormwater flow, sediment, and low DO/organic enrichment, which are noted in our [watershed TMDL(s)] as issues of concern. Other public involvement activities not listed

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above may be included during the permit term to fulfill minimum requirements based on TMDL applicability, availability of resources and local opportunities. These events will be included in the Annual Report to Ohio EPA.

Program Responsibility and OversightThe Public Service Director is responsible for the overall management and implementation of our public involvement/participation program. The Public Service Director reports quarterly to the Stormwater Committee. To assist the community in implementing its public involvement activities under MCM 2, we have entered into a Memorandum of Understanding with the Watershed Organization and County SWCD. These MOUs are included in the SWMP Appendix. The SWCD’s Education and Outreach Coordinator prepares an annual Outreach Strategy document for our program that outlines the specific MCM 2 events they will be assisting us with for the permit cycle. The Watershed Organization works in tandem with the SWCD’s events and will also assist us at our request on other events, such as providing technical expertise in rain garden installation or helping to organize a stream cleanup or canoe tour. An example of an Outreach Strategy document from the County SWCD is included in the SWMP Appendix. The County SWCD also maintains the violation reporting hotline for the community. [Note: These are examples of MCM 2 services that some third party entities provide. Please verify if your third party service providers offer these services before including them in your SWMP.] Any relevant complaints will be compiled by the SWCD’s Stormwater Coordinator and investigated, and a report will be sent to the City Engineer and Building Inspector. The City Engineer and Building Inspector are responsible for any resulting enforcement action and escalation, such as a notice of violation or a stop work order.

Each year in November, the Stormwater Committee evaluates progress on the public involvement and participation program. They will review the year’s involvement event(s) for type of target audience involvement and amount of public participation. Our measurable goal is to host a minimum of five public involvement activities over the permit cycle.

Table 2: Public Involvement and Participation Program

MCM 2: Public Involvement and ParticipationPerformance Standards: Must hold a minimum of 5 public involvement and participation activities over the permit term.

Activity TMDL Applicability Schedule and Measurable Goal Responsible Party

Stream Cleanup Event

Addresses the [watershed(s)] TMDL recommendations for habitat degradation through direct improvement of in-stream habitat

At least 1 stream cleanup annually, and we will track the number of participants

Service Director, County SWCD

Build Your Own Rain Barrel Workshop

Addresses the [watershed(s)] TMDL recommendations for habitat degradation, flow alteration, organic enrichment, and nutrients through attenuation and reduction of stormwater flows to the MS4 and treatment of nitrogen pollution

At least 1 rain barrel workshop conducted in the community, where residents will build a barrel to install at their residence. We will track the number of participants


Rain Garden or Sustainable Landscape Installation

Addresses the [watershed(s)] TMDL recommendations for habitat degradation, flow alteration, organic enrichment, and nutrients

At least 1 rain garden or other sustainable landscape option, including reduction of

Service Director, Watershed Organization, County SWCD

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through attenuation and reduction of stormwater flows to the MS4 and treatment of nutrient pollutants

turfed areas, will be installed or implemented in the community

Tree Planting Event

Addresses the [watershed(s)] TMDL recommendations for habitat degradation, flow alteration, organic enrichment, and nutrients through attenuation and reduction of stormwater flows to the MS4 and treatment of nutrient pollutants

Conduct at least one volunteer tree-planting event with students from [local school]; number of participants will be tracked


Watershed-friendly lawn care and household cleaners workshop

Addresses the [watershed(s)] TMDL recommendations for habitat degradation and nutrients through reduction of fertilizers/pesticides and other chemicals entering the MS4 through residential activities.

Conduct at least one hands-on workshop, where participants will create their own environmentally-friendly lawn care and household cleaning products for use; number of participants will be tracked


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The above table includes examples of possible activities, TMDL applicability, measurable goals, and responsible parties for your Public Participation and Involvement program. You can use this Table to summarize your program for your internal use and documentation, and to facilitate your annual reporting. The narratives included in Table 2 are only examples of possible BMPs and language you may use. Alter these to reflect activities that do or will occur in your community. Updating this table alone will not be considered an acceptable level of detail by Ohio EPA for resubmitting your SWMP.

MCM 3: Illicit Discharge Detection and Elimination

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At this point, you should have an ordinance or other regulatory mechanism in place to prohibit illicit discharges, including illegal dumping, to your MS4. The ordinance or regulatory mechanism needs to address the following:

Prohibition of illicit discharges to the MS4 Any exclusions (non-stormwater discharges) allowed (if determined not to be a major

contributor of pollution to your MS4); a complete list is found in the MS4 general permit. Any authorized occasional incidental non-storm water discharges (example: charity car

washes), with an explanation of why it is not a significant source of pollution to the MS4 either through the nature of the discharge or the controls you have put in place to manage the discharge

Community authorization to access private property to conduct IDDE investigations (if not, describe in your SWMP what limitations to investigation exist and how have you addressed these limitations)

Provisions for and types of enforcement mechanisms to eliminate illicit discharges (notices of violations, administrative fines, stop work orders, civil penalties, criminal penalties, etc.)

You should also have completed: An initial dry-weather screening of all stormwater outfalls in the MS4. A storm sewer map, updated annually, showing the location of all HSTS connected to the

MS4, the types and size of conduits/ditches in the MS4 that receive discharges from HSTS, and the water bodies receiving the discharge from your MS4

A comprehensive storm sewer system map (different from the storm sewer map), updated annually, showing the locations of all outfalls and the names and locations of all surface waters of the State that receive discharges from those outfalls. The comprehensive storm sewer system map should include:

o Catchbasins, pipes, ditches, flood control facilities, and public and private post-construction BMPs installed to comply with post-construction stormwater water quality requirements.

o If this map is already complete, describe how you developed this map, and make sure to note how it will be regularly updated and who is responsible for the updates.

o If this map is NOT complete, describe the sources of information you will use for the map, how you plan to verify the outfall locations with field surveys, and how the map will be developed, updated, and who the responsible party is. The map must be complete by the end of this permit cycle.

In describing your IDDE plan, in addition to the above information, you must include the following: Procedures for locating priority areas, including areas with higher likelihood of illicit

connections (areas with older sanitary sewer lines, for example) Procedures for tracking the source of a potential illicit discharge, including the specific

techniques you will use to detect the location of the source Procedures for removing the source of the illicit discharge Procedures for program evaluation and assessment

Sample Language: Adoption of Illicit Discharge Detection and Elimination OrdinanceOur community adopted an illicit discharge and illegal connection control ordinance on [date] that prohibits illicit discharges into the MS4. We chose this mechanism as it is the most efficient and enforceable way to prohibit illicit discharges to the MS4. A copy of the ordinance is included in the SWMP Appendix.

Development and Update of the Storm Sewer and Comprehensive Storm Sewer System MapsOur community has mapped our HSTS locations into a storm sewer map and the stormwater collection system into a comprehensive storm sewer system map using the County GIS mapping as the base. Our two named receiving waters for our MS4 drainage are Lake Erie and the Chagrin River. Outfalls were located using existing topography supplemented by GPS field groundtruthing of outfall pipes by our Engineering Department. The storm sewer map was completed in 2009, and the comprehensive storm sewer system map was completed in 2014. Both maps are maintained by the City Engineer who updates them annually to include any HSTS removals, catchbasins, pipes, ditches, flood control facilities, and public and private post-construction water quality BMPs installed to satisfy Ohio EPA’s NPDES Construction General Permit or local post-construction water quality BMP requirements. The 2015 storm sewer map

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The content of the IDDE plan will vary based on the community. Some communities handle their IDDE program in-house while others may be able to enter into a third-party agreement for outfall monitoring, sampling, and reporting with the County Board of Health. If a third party is used for your IDDE program, it is strongly recommended to choose the enhanced BMP of scheduling regular meetings between the MS4 manager and the third party provider to ensure clear communication and implementation of the IDDE plan. This BMP addresses the following TMDLs: sediment/TSS, nutrients, habitat, DO/organic enrichment, and bacteria. Regardless of who performs the IDDE plan, the permittee is responsible for ensuring the plan is implemented and the plan needs to be described in full in the SWMP, using as much detail as possible for the persons responsible and their roles. Some sample text has been provided below to guide you in your narrative, but additional detail will be required to pass review by Ohio EPA.

RELEVANT ITEMS YOU SHOULD INCLUDE IN YOUR SWMP APPENDIX: Copy of IDDE ordinance Enforcement escalation plan or procedures Map of MS4/Outfalls Map of HSTSs Address List of HSTSs Written description of dry-weather field screening procedures Sample inspection checklist or reporting form Prioritization plan for locating areas with higher likelihood of illicit connections Sample notification form letter to Interconnected MS4s Examples of IDDE outreach materials (can also be included under MCM 1) Description or printout of tracking system for spills, complaints, illicit discharges

and 2015 comprehensive storm sewer system map are included in the SWMP Appendix. Updated copies of the map are available on request at the City Engineer’s office.

Determination of Priority AreasInitial dry-weather screening of all outfalls was completed during the #OHQ000002 permit period by the County Board of Health, and priority areas have been determined based on age of infrastructure, flow rates, fecal coliform or E. coli counts and other data. A map of priority areas is included in the SWMP Appendix. Every year, the Board of Health conducts a dry-weather outfall screening of these priority areas first, and we prioritize identification and elimination of illicit discharges in these areas. Additionally, we screen 20% of our other outfalls per year with the measurable goal of 100% of all outfalls screened by the end of each permit term. We implement this enhanced BMP to address our [watershed(s)] TMDLs for nutrient and bacteria pollution. Any illicit discharges identified in the non-priority areas may be added to the priority area map and prioritized for elimination depending on the severity of the discharge and recommendations of the Board of Health.

Enforcement and Escalation Procedures for Illicit Discharges and Illegal Dumping and SpillsOur Service Department is responsible for locating, tracking, and eliminating illicit discharges. The City will issue orders to eliminate the discharges and enforce corrective action under their authority according to the following enforcement procedure: [Describe procedure here. All permittees need to have an enforcement and escalation procedure for dealing with illicit discharges. For some, this procedure is outlined in your ordinance.]

The following procedure is used for identifying and correcting illicit discharges in previously established priority areas and any newly identified areas that meet priority criteria:

1. Service Department personnel visit all outfalls in the priority area during dry weather (at least 72 hours after the last rainfall of 0.10 inches or more) to observe which are flowing.

2. For any flowing outfalls the Service Department personnel record any odorous or visual observations.

3. Service Department personnel visit these “suspect” outfalls and perform field tests to determine if sampling is warranted.

4. Outfalls with a [fecal coliform, E. coli, etc.] count of [insert parameter here like 576 colony forming units per 100 ml] are placed on a list for further investigation and elimination.

5. Priority areas determined from the previous round of screening and any new outfalls that meet the priority criteria are targeted first for elimination. A list of the current identified illicit discharges that have not yet been eliminated is included in the SWMP Appendix.

6. Where the collection system is open ditches, Service Department personnel visually track the flow back to the source.

7. Where the collection system is piped, Service Department personnel use a closed circuit television camera to search for connections that are contributing flow.

8. Where discharges are traced back to a corporate boundary line, the upstream community is notified of our findings. A sample notification letter is included in the SWMP Appendix.

9. Illicit dischargers within the community are sent notices ordering corrective action to remove the source of the discharge. The Director of Public Service and the Building Commissioner will coordinate on notice and mitigation of required correction actions.

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Sanitary flows in the storm sewer system are evaluated as part of our illicit discharge program. [Chapter here] of our code requires [point-of-sale connection inspections or other form of reliable inspection]. This section of our code is included in the SWMP Appendix. This program has been successful in finding improperly connected storm and sanitary laterals. When found, corrective measures to eliminate the discharge are required of the property seller.

The following procedure is used for illegal dumping and spills:

1. Action will be initiated when a spill or dumping is reported to any community staff.2. Hazardous materials are referred to the Fire Department for clean-up in conjunction with

the procedures and guidelines in the Ohio EPA’s Emergency Response Program, found here: http://www.epa.state.oh.us/derr/ersis/er/er.aspx.

3. Other spills and small scale dumping are referred to the Service Department for cleanup.4. The offending party receives educational material on the impacts of spills and illegal

dumping to stream and wetland habitat, which addresses our [watershed(s)] noted TMDL for habitat degradation. We have developed educational brochures through our MOU with the Watershed Organization and all violators receive a brochure. A copy of the brochure is included in the SWMP Appendix. Repeat offenders are referred to the Police Department for investigation and possible citation.

5. Large-scale spills and illegal dumping are reported to Ohio EPA and the Police Department for investigation and possible citation. We follow the guidelines and procedures outlined in Ohio EPA’s Emergency Response Program, found here: http://www.epa.state.oh.us/derr/ersis/er/er.aspx.

Coordination with MCMs 1 and 6Our plan coordinates our MCM 3 program with our MCM 1 and MCM 6 programs. The fifteen restaurants in our entertainment district have been identified as a target audience in our MCM 1 program, and one of our themes for this permit cycle is proper kitchen cleanup and grease disposal. We will produce educational posters with assistance from the Board of Health and distribute them to the restaurant managers and owners for them to hang in their kitchens to inform the restaurant staff on proper waste disposal. The “Lake Erie Starts Here” theme described earlier in MCM 1 will also educate the public on the environmental impacts of illicit discharges to the storm system through an article in our quarterly community newsletter, which every resident receives. All municipal facilities subject to our Pollution Prevention and Good Housekeeping program receive an annual staff training on MCM 6 held by our Watershed Organization that includes training on identifying illicit discharges and disposing of waste properly at their facilities.

Program Responsibility and OversightThe Director of Public Service is responsible for the overall management of the illicit discharge detection and elimination program. The Director meets twice a year with the Board of Health to review the IDDE plan and ensure clear communication and implementation of the IDDE plan. We selected this enhanced BMP to our program to address our [watershed(s)] TMDLs for TSS/sediment, nutrient, habitat, low DO, and bacteria pollution. The Director of Public Service and the Stormwater Committee meet once a year in conjunction with the annual reporting to Ohio EPA and evaluate the success of this plan by ensuring the following objectives are met:

Annual updates to the storm sewer map as needed to include catchbasins, pipes, ditches, flood control facilities, public and private post-construction water quality BMPs

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http://www.epa.state.oh.us/derr/ersis/er/er.aspx

http://www.epa.state.oh.us/derr/ersis/er/er.aspx

installed to satisfy Ohio EPA’s NPDES Construction General Permit or local post-construction water quality BMP requirements;

Implementation and enforcement of the IDDE code according to the schedule and procedure defined in the code;

All outfalls receiving a dry weather screening by the end of the full permit term (enhanced BMP to address bacteria and nutrient TMDLs); and

Annual training for municipal staff on IDDE protocol. A measurable goal of all illicit discharges eliminated within a year of their identification.

Our goals were selected to reflect TMDL recommendations, permit requirements, current practices, and staff capacity to implement the BMPs.

Table 3: Illicit Discharge Detection and Elimination Program

MCM 3: Illicit Discharge Detection and Elimination program

Required BMPSchedule and Measurable Goal

Responsible Party

Ordinance or other regulatory mechanism that prohibits illicit discharges and illegal dumping to the MS4

Adopted June 2006 City Council

Maintain and continue updating the MS4 map on an annual basis (i.e., outfalls, names and locations of surface waters that receive discharges from those outfalls, catchbasins, pipes, ditches, flood control facilities (retention/detention ponds), post-construction water quality BMPs and private post-construction water quality BMPs which have been installed to satisfy Ohio EPA's NPDES Construction Stormwater general permit and/or local stormwater management code requirements.

Annual review of map to ensure all necessary updates are made

Community Engineer, Stormwater Committee

Develop and maintain a list and map of Sewage Treatment Systems that discharge to the MS4

Annual review of list and map to ensure all necessary updates are made

Director of Public Service, County Board of Health

Prioritization schedule for ongoing dry-weather screening of outfalls

Annual review to determine if procedure is being followed correctly

Director of Public Service, County Board of Health, Stormwater Committee

Implement IDDE plan that clearly defines responsible parties for investigating and resolving confirmed sources of illicit discharges, including escalation enforcement plan

Enforcement and implementation of the adopted IDDE code


Train street, service, public works, building, and parks and recreation staff to Annual training Director of

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identify sources of illicit dischargein conjunction with MCM 6 for municipal staff

Public Service, Watershed Organization

Enhanced BMP TMDL Applicability


Responsible Party

All dry-weather outfalls screened during the permit term

Addresses [watershed(s)] TMDL recommendations for bacteria and nutrients.

100% of dry weather outfalls screened within each 5-year permit term


Hold regular meetings between the County Board of Health staff and the Director of Public Service to ensure proper communication and implementation of IDDE plan

Addresses [watershed(s)] TMDL recommendations for TSS/sediment, nutrients, bacteria, habitat, and low DO/organic enrichment.

A minimum of twice yearly meetings between the Public Service Department and County Board of Health


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The above table includes required BMPs, examples of enhanced BMPs, TMDL applicability, measurable goals, and responsible parties for your Illicit Discharge Detection and Elimination program. You can use this Table to summarize your program for your internal use and documentation, and to facilitate your annual reporting. The narratives included in Table 3 are only examples of possible BMPs and language you may use. Alter these to reflect activities that do or will occur in your community. Updating this table alone will not be considered an acceptable level of detail by Ohio EPA for resubmitting your SWMP.

MCM 4: Construction Site Stormwater Runoff Control

Sample Language: Update of Erosion and Sediment Control OrdinanceIn 2016, we reviewed our existing Erosion and Sediment Control code and updated it for compliance with the latest NPDES Construction General Permit (#OHC000004), following the model ordinance developed by Chagrin River Watershed Partners, Inc. The updated code was adopted on [date]. A copy of the code is found in the SWMP Appendix.

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At a minimum, your Construction Site Stormwater Runoff Control program must include: An ordinance or other regulatory mechanism that requires erosion and sediment controls

and sanctions to ensure compliance to the extent allowable under State or local law Requirements for construction site operators to implement appropriate erosion and

sediment control BMPs Requirements for construction site operators to control waste such as, but not limited to,

discarded building materials, concrete truck washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impacts to water quality

Procedures for stormwater pollution prevention plan review which incorporate consideration of potential water quality impacts

Procedures for receipt and consideration of information submitted by the public Procedures for site inspection and enforcement of control measures

The majority of a community’s requirements for this MCM, including the authority to implement the program, can be directly addressed through the adoption and enforcement of an Erosion and Sediment Control code. Chagrin River Watershed Partners, Inc. have developed a model Erosion and Sediment Control code that is fully compliant with the new requirements in the Ohio EPA’s Construction General Permit #OHC000004, and offers recommendations for additional protections to address TMDL pollutants. A link to the model code can be found here: http://crwp.org/index.php/member-services/model-regulations/erosion-sediment-control.

Communities are required to document their decision process in implementing their Construction Site Stormwater Control program. You should be as detailed as possible in describing your program, noting at least the department but preferably the titles of the personnel responsible for implementing the program, including any third party organizations. Your description should include elements like your chosen BMPs, measurable goals, enforcement procedure, TMDLs addressed, and how you evaluate the efficacy of your program. Some sample text has been provided below to guide you in your narrative, but additional detail will be required to pass review by Ohio EPA.

RELEVANT ITEMS YOU SHOULD INCLUDE IN YOUR SWMP APPENDIX: Copy of your Erosion and Sediment Control Code Enforcement escalation plan/procedure for construction sites Sample Notice of Violation letter from the community – Note: in municipalities, letters from

the SWCD are not considered NOVs unless the community’s ordinance specifically gives the SWCD enforcement authority (typically not the case). The SWCD is simply notifying the community that there are compliance issues on the site, but they have no inherent enforcement authority in a municipality.

http://crwp.org/index.php/member-services/model-regulations/erosion-sediment-control

Our community has adopted special requirements in our Erosion and Sediment Control (ESC) code to reduce runoff and erosion and address TMDLs. A summary of these special requirements is as follows:

Require a Pre-Construction Meeting between the City Engineer and the developer, engineer and contractor (and any other principal parties) no less than seven days prior to soil-disturbing activity at the site.

o Erosion and Sediment Control Section XXXX.06(f)o Applicable TMDLs: habitat, sediment/TSS, and flow.

Require bond or deposit to be deposited with the Finance Department for the minimum amount of [$XXXX], plus any additional amount to cover the cost to fully stabilize (vegetate) the construction site in the event of non-performance.

o Erosion and Sediment Control Section XXXX.12(a)o Applicable TMDLs: habitat, sediment/TSS, nutrients, and dissolved oxygen.

Require stormwater pollution prevention plan for all commercial and industrial site development or for projects less than one acre.

o Erosion and Sediment Control Section XXXX.05(a)o Applicable TMDLs: habitat, sediment/TSS, nutrients, flow and dissolved oxygen.

Procedures for Stormwater Pollution Prevention Plan (SWP3) ReviewOur requirements for construction site operators to implement appropriate erosion and sediment control BMPs and control waste at construction sites are established in SWP3s which are reviewed by the City Engineer and the County SWCD and must be approved prior to any work commencing on the site. We have chosen to require a full SWP3 be developed and implemented for all commercial and industrial site development, which addresses our [watershed(s)] TMDLs for habitat, sediment/TSS, nutrients, flow, and low DO/organic enrichment. For residential sites that disturb less than one acre, an abbreviated SWP3 is required. The City Engineer may require a full SWP3 for these sites at their discretion. [Section XXXX.05] of our Erosion and Sediment Control ordinance details the general requirements for SWP3 development, and a copy of the ordinance is in the SWMP Appendix. Additional site-specific requirements may be mandated at the City Engineer’s discretion. Work is not allowed to commence until a fully-approved SWP3 is in place. [Section XXXX.08] of our ordinance outlines the required elements of a SWP3, which must take into account potential water quality impacts from construction. Our community averages about XX active sites per year that must have SWP3s prepared and approved.

In addition, our community requires a pre-construction meeting between the City Engineer and the developer, engineer, contractor and any other principal parties no less than seven days prior to soil-disturbing activity at the site to ensure that erosion and sediment control devices are properly installed, limits of disturbance and buffer areas are properly delineated, and construction personnel are aware of such devices and areas. We chose this enhancement to our SWMP to address [watershed(s)] TMDLs for sediment/TSS, flow, and habitat degradation.

Construction Site Inspection, Enforcement and Escalation ProceduresWe have a MOU with the County SWCD for the inspection of construction sites. Active construction sites are inspected on a monthly basis by County SWCD. All active construction

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sites are inspected at least once prior to final inspection. Inspections may be more frequent on a priority basis, determined by the City Engineer and based on County SWCD recommendations. Factors affecting County SWCD priorities are soil type, slope of land, amount of acreage disturbed, and quality of receiving water body. Letters are sent to non-compliant contractors, and follow-up inspections are conducted by the County SWCD with enforcement referred to the City Engineer where necessary. The County SWCD notifies the City Engineer and contractors when erosion control measures are deficient, and the City Engineer enforces the Erosion and Sediment Control code against contractors who do not meet the requirements of the approved SWP3 using the following enforcement and escalation procedures:

The City Engineer may issue an immediate stop work order if the violator failed to obtain any federal, state, or local permit necessary for sediment and erosion control, earth movement, clearing or cut and fill activity.

Failure to maintain and repair erosion and sediment controls per the approved SWP3 may result in the following escalation:

o First violation: The City Engineer will issue a Notice of Deficiency to the owner or Operator. All controls are to be repaired or maintained per the SWP3 within three days of the notification. If controls have not been corrected after this time, the City Engineer may issue a stop work order for all activities until corrections have been made.

o Second violation: The City Engineer may issue a formal Notice of Violation which includes a $XXX administrative fee against the SWP3 bond or site plan deposit. All controls are to be repaired or maintained per the approved SWP3 within three days of the Notice of Violation. If controls have to been corrected after this time, the City Engineer may issue a stop work order for all activities until corrections have been made.

o Third and subsequent violations: The City Engineer may issue a stop work order for all construction activities and charge a $XXX administrative fee against the SWP3 bond or site deposit. The stop work order will be lifted once all controls are in compliance with the approved SWP3.

A bond is required to ensure compliance with the requirements and citations can be issued at the amount of [$XXX] per day penalty for non-compliance. We have also chosen to update our Erosion and Sediment Control code with an enhanced bond or deposit requirement to ensure the amount covers the cost to fully stabilize (vegetate) the construction site in the event of non-performance (e.g., foreclosure/bankruptcy). This enhancement to our program addresses the [watershed(s)] TMDLs for TSS/sediment, nutrients, habitat, and low DO/organic enrichment.

We maintain a public hotline on our website for the public to report potential site violations. Residents can either email or use a phone number to report violations. We also have a MOU with the County SWCD who maintains their own construction site hotline. All complaints to our hotline and any complaints reported to us from the County SWCD hotline are filed and investigated by the Engineering Department within 2 business days of receipt. If the resident leaves their contact information, they may be contacted for a brief post-investigation follow-up.

Program Responsibility and OversightThe City Engineer is responsible for overall management and implementation of our construction site stormwater control program. Success under this MCM is evaluated through

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the milestones identified in Table 4. Many of the BMPs selected have specific schedules and timeframes for completion required either in the Erosion and Sediment Control ordinance or as part of the MS4 permit. An annual review is performed by the City Engineer and the Stormwater Committee in conjunction with the required annual reporting to Ohio EPA to evaluate the program and determine if the schedules and timeframes set are being achieved. Our goals were selected to reflect TMDL recommendations, permit requirements, current practices, and manpower requirements of the BMPs.

Table 4: Construction Site Stormwater Control Program

MCM 4: Construction Site Stormwater Runoff Control


Responsible Party

Update existing construction runoff control code to meet or exceed the requirements of the NPDES Construction General Permit (OHC000004), including the federal effluent limitations in Part II.

Review and adopt updated CRWP model code by December 22, 2016

City Engineer and City Council

Ensure the most current erosion, sediment and non-sediment control BMP standards are required to be utilized (e.g., Rainwater and Land Development)


City Engineer

Complete Stormwater Pollution Prevention Plan (SWP3) reviews and approval prior to construction commencement

All SWP3s reviewed and approved prior to construction

City Engineer, County SWCD

Conduct monthly site inspections throughout construction, as well as a final site inspection to ensure correct implementation of erosion, sediment and non-sediment control BMPs in the approved SWP3

All active sites inspected monthly and a final site inspection completed

Engineering Department, County SWCD

Implement enforcement escalation plan that outlines how and when we address noncompliance with approved erosion, sediment, and non-sediment control plans

Enforce procedures for noncompliance outlined in erosion and sediment control code


Implement a standard operating procedure to respond to complaints

Continue to implement complaint procedures as established in SWMP rationale

Engineering Department, County SWCD

Enhanced BMP TMDL Schedule and Responsible

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Applicability Measurable Goal Party

Require on-site protected areas (i.e. wetlands, riparian areas, other valuable resources) to be physically marked in the field prior to commencement of earth disturbing activities

Addresses [watershed(s)] TMDL recommendations for TSS/sediment, nutrients, bacteria, habitat, and low DO/organic enrichment.

Update erosion and sediment control code to include this requirement by December 22, 2016

City Engineer,County SWCD

Require MS4 compliance inspectors to provide a written report of findings to construction site operators for every site inspection; the report will summarize compliance and non-compliance matters and establish deadlines for corrective action

Addresses [watershed(s)] TMDL recommendations for TSS/sediment, nutrients, bacteria, habitat, low DO/organic enrichment, and flow.

Establish this procedure in MOU with County SWCD and update erosion and sediment control code to include this requirement by December 22, 2016


Require a sediment and erosion control bond equivalent to the cost to stabilize (vegetate) disturbed areas of the sites in cases of nonperformance (i.e. developer foreclosure/bankruptcy)

Addresses [watershed(s)] TMDL recommendations for TSS/sediment, nutrients, habitat, and low DO/organic enrichment.

Update erosion and sediment control code to include this requirement by December 22, 2016


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The above table includes required BMPs, examples of enhanced BMPs, TMDL applicability, measurable goals, and responsible parties for your Construction Site Stormwater Control program. You can use this Table to summarize your program for your internal use and documentation, and to facilitate your annual reporting. The narratives included in Table 4 are only examples of possible BMPs and language you may use. Alter these to reflect activities that do or will occur in your community. Updating this table alone will not be considered an acceptable level of detail by Ohio EPA for resubmitting your SWMP.

MCM 5: Post-Construction Stormwater Management in New Development and Redevelopment

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At a minimum, your Post-Construction Stormwater Management program must include: A program to address stormwater runoff from new development and redevelopment

projects that disturb greater than or equal to one acre, including projects less than one acre that are part of a larger common plan of development or sale, that discharge into your small MS4. Your program must ensure that controls are in place that will prevent or minimize water quality impacts.

Implementation of strategies which include a combination of structural and/or non-structural BMPs appropriate for your community.

An ordinance or other regulatory mechanism to address post-construction runoff from new development and redevelopment projects to the extent allowable under State or local law.

Adequate long-term operation and maintenance of BMPs. A sample Inspection and Maintenance Agreement can be found on CRWP’s website at http://crwp.org/files/Model_Inspection_and_Maintenance_Agreement_Dec_2015.pdf.

The majority of a community’s requirements for this MCM, including the authority to implement the program, can be directly addressed through the adoption and enforcement of a Comprehensive Stormwater Management code. Chagrin River Watershed Partners, Inc. have developed a model Comprehensive Stormwater Management code that is fully compliant with the new post-construction requirements in the Ohio EPA’s Municipal Separate Storm Sewer System permit #OHQ000003, and offers recommendations for additional protections to address TMDL pollutants. A link to the model code can be found here: http://crwp.org/index.php/member-services/model-regulations/storm-water-management.

Communities are required to document their decision process in implementing their Post-Construction Stormwater Management program. You should be as detailed as possible in describing your program, noting at least the department but preferably the titles of the personnel responsible for implementing the program, including any third party organizations. Your description should include elements like your chosen BMPs, measurable goals, enforcement procedure, TMDLs addressed, and how you evaluate the success of your program. Some sample text has been provided below to guide you in your narrative, but additional detail will be required to pass review by Ohio EPA.

RELEVANT ITEMS YOU SHOULD INCLUDE IN YOUR SWMP APPENDIX: Copy of your Comprehensive Stormwater Management code and any other relevant non-

structural post-construction BMP codes Enforcement escalation plan/procedure for post-construction violations Sample Notice of Violation letter from the community – Note: in municipalities, letters from

the SWCD are not considered NOVs unless the community’s ordinance specifically gives the SWCD enforcement authority (typically not the case). The SWCD is simply notifying the community that there are compliance issues on the site, but they have no inherent enforcement authority in a municipality.

Sample Inspection and Maintenance Agreement

http://crwp.org/index.php/member-services/model-regulations/storm-water-management

http://crwp.org/index.php/member-services/model-regulations/storm-water-management

http://crwp.org/files/Model_Inspection_and_Maintenance_Agreement_Dec_2015.pdf

Sample Language: Update of Comprehensive Stormwater Management OrdinanceCity Council adopted a comprehensive stormwater management regulation on [date] that addresses both stormwater quality and quantity and encourages the use of low impact development practices on commercial and institutional areas. The ordinance has been updated to be compliant with the technical requirements set forth in the Ohio EPA NPDES Construction General Permit #OHC000004 and the Ohio EPA NPDES Small Municipal Separate Storm Sewer System General Permit #OHQ000003. A copy of our ordinance is included in the SWMP Appendix.

Our community has adopted special requirements in our Comprehensive Stormwater Management (CSM) code to improve stormwater management, promote the use of green infrastructure and address TMDLs. Code provisions include:

Require stormwater management for all commercial and industrial site development or for projects less than one acre

o Comprehensive Stormwater Section XXXX.05(a)o Applicable TMDLs: habitat, TSS/sediment, nutrients, flow and dissolved

oxygen.o Rationale:

Require soil preservation and post-construction soil restoration. o Comprehensive Stormwater Section XXXX.09(a)(11) o Applicable TMDLs: flow and habitat o Rationale:

Require use of stormwater control measures to reduce the temperature of runoff for development projects in watersheds draining to coldwater habitat streams.

o Comprehensive Stormwater Section XXXX.09(C)(2)(e) o Applicable TMDL: habitat o Rationale:

Credit volume reduction attained through low impact development stormwater control measures toward peak discharge requirements.

o Comprehensive Stormwater Section XXXX.09(D)(9)o Applicable TMDLs: flow, habitat, nutrients, dissolved oxygen and bacteria

(bioretention only for bacteria).o Rationale:

Require redevelopment projects to manage greater than 20% of the water quality volume and incentivize infiltration-based SCMs for redevelopment.

o Comprehensive Stormwater Section XXXX.09(E)(1)o Applicable TMDLs: TSS/sediment, nutrients, habitat, flow, dissolved oxygen

and bacteria.o Rationale:

[Note: If you choose to address TMDLs using these code updates, be sure to include in your rationale why you chose these updates, for example, you specifically chose to prioritize SCMs that reduce the temperature of stormwater because your MS4 is in a watershed with coldwater

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habitat streams that are threatened by heated stormwater from upstream development or redevelopment.]

Comprehensive Stormwater Management Program OverviewWe use a combination of planning activities, education, non-structural and structural practices to address post-construction stormwater runoff from new development and redevelopment projects. As our community has a significant amount of undeveloped land area still, these will be our targeted priority areas for our program. Our major tracts of undeveloped land are outlined on a map in our SWMP Appendix.

Our community is a residential community with well-defined commercial and institutional developments. Our water quality concerns are those defined in our [watershed(s)] TMDLs: sediment/TSS, nutrients, habitat degradation, and bacteria. These concerns are related to increases in stormwater runoff as impervious cover increases and include sedimentation due to streambank erosion, increased flooding due to increases in stormwater volume, increases in stormwater temperature in detention facilities, and habitat loss as riparian and wetland areas are impacted by development.

To address these impacts we have completed a comprehensive land use plan through our Community Planning Committee, detailing remaining undeveloped parcels and the natural resource features and functions, including flood control, erosion control, and water quality protection of these parcels. A link to our land use plan can be found here: [link]. We have also endorsed the Chagrin River Balanced Growth Plan in our community, where we have identified Priority Conservation areas and Priority Development Areas to promote better land-use planning and preserve existing beneficial natural areas. A map of our designated PCAs and PDAs are included in the SWMP Appendix. Our community is also a member of the Chagrin River Watershed Partners, Inc. (CRWP) and works with CRWP on identifying and implementing local stream restoration and stormwater retrofit projects outlined in the Chagrin River Watershed Action Plan to improve post-construction water quality and restore and maintain pre-development runoff conditions.

We feel that education on structural and non-structural stormwater BMPs for landowners, developers, planners, engineers, and others is necessary to support the implementation of our comprehensive stormwater management program. We provide this education through our membership in CRWP, who work with our City Engineer and Media Coordinator to provide educational post-construction opportunities. As members of CRWP, we participate in educational workshops designed to inform both professionals and the general public of stormwater management techniques that can reduce TSS/sediment, nutrient pollution, and habitat degradation, which are identified in the Chagrin River TMDL as pollutants of concern for our watershed.

Structural BMPs in the ProgramOur community allows for various structural water quality measures such as bioretention cells, sand filters, infiltration trenches, and permeable pavements through the adoption of our comprehensive stormwater management regulation. We promote infiltrative stormwater management practices as a way to restore a more natural hydrology, improve water quality, and mitigate stormwater runoff in our watershed, as recommended in our TMDL. Our comprehensive stormwater management ordinance is enforced and updated to be equivalent

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with the technical requirements set forth in the Ohio EPA NPDES General Construction Permit #OHC000004, and a copy of the ordinance is included in the SWMP Appendix. Existing structural BMPs mapped in our community include the following:[list of structural BMPs here]

These BMPs are mapped and documented in our Comprehensive Storm Sewer System map, a copy of which is included in the SWMP Appendix. The map is updated by the City Engineer on an annual basis to ensure all new BMPs are noted.

Non-Structural BMPs in the ProgramThe non-structural mechanisms we use to address post-construction runoff from new developments and redevelopment include our riparian setback ordinance, an improved comprehensive storm water management ordinance, and an ordinance providing landowners with the option of developing conservation designed subdivisions. We chose these mechanisms because they address our TMDL water quality concerns which are related to increases in storm water runoff as land is developed. These mechanisms provide flexibility to landowners, while ensuring that new impervious cover is minimized; the flood control, erosion control, and water quality functions of our watercourses and wetlands are maintained; and that when stormwater is created, it is managed for both quality and quantity.

Our community adopted a riparian setback ordinance on [date]. This ordinance follows the CRWP model and a copy is included in the SWMP Appendix. It directly addresses our [watershed(s)] TMDL recommendations for TSS/sediment, nutrients, habitat degradation, DO/organic enrichment, bacteria, and flow. Review and enforcement of the riparian setback is the responsibility of our City Engineer, who reviews any proposed development plans for compliance with the setback ordinance and evaluates any variance requests. Any new development or redevelopment, regardless of acreage, is required to comply with the setback unless a variance is requested and granted. [Insert specific enforcement procedure here if applicable.] Our community is developing a conservation development zoning classification in 2016 to encourage preservation of larger percentages of contiguous open space in subdivision development. The open space created through conservation subdivisions is preserved through permanent conservation easements.

In addition to protecting contiguous natural areas in our MS4 through zoning, our community has a long history of preserving open space. We currently have XX acres (X%) of land area under permanent preservation through conservation easements. This preserved land performs stormwater control functions for both water quality and quantity. A map of our City-owned property under conservation easement is included in the SWMP Appendix.

Non-structural BMPs including riparian and wetland setbacks are maintained as any other setbacks are maintained in the [Community]. As with all setbacks, landowners proposing activities in setbacks must request a variance and this request is reviewed, modified, and approved or disapproved by the City Engineer and the Planning and Zoning Commission. When considering variance requests, the Planning and Zoning Commission may consider the extent to which the requested variance impairs the flood control, erosion control, water quality protection or other functions of the riparian setback based on technical and scientific data. The ordinance states that soil disturbing activities permitted in the setback through variance should minimize clearing and use BMPs to minimize and control erosion and sediment and that

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variances should not be granted for asphalt or concrete paving. The Planning and Zoning Commission prioritizes granting variances where feasible to other area or setback requirements in order to maintain the riparian setback.

BMP Inspection and Maintenance Procedures and EnforcementStructural BMPs created through our improved stormwater management regulation are maintained by post-development landowners. If these landowners do not complete necessary operation and maintenance, the City will reserve the right to complete this work and assess these landowners. An Inspection and Maintenance Agreement is required by the City to be in place for every applicable site that delineates responsibilities for maintenance of post-construction BMPs, including requiring the establishment of funds to support the maintenance of the BMPs. The Agreement is required to be established as part of the Comprehensive Stormwater Management Plan outlined in [Section XXXX.X] of our Comprehensive Stormwater Management ordinance and is reviewed for compliance by the City Engineer prior to the issuance of a building permit by the Building Inspector. Copies of the Inspection and Maintenance Agreements are kept on file at the Engineering Department. A sample Inspection and Maintenance Agreement is included in the SWMP Appendix.

The owner must inspect structural stormwater BMPs regularly as described in the Inspection and Maintenance Agreement. The City has the authority to conduct inspections as necessary with prior notification of the property owner, to verify that the BMPs are being maintained and operated in accordance with our Comprehensive Stormwater Management ordinance. If a deficiency or violation is noted, the City Engineer gives a written notification to the responsible party detailing the need for maintenance or compliance. Once notified, the responsible party has either five working days or other mutually agreed-upon time to make repairs or submit a plan with detailed action items and established timelines for the City Engineer to approve. If the repairs are not made or an approved plan is not in place within this time, City staff may undertake the necessary repairs and assess the responsible party. A sample notification letter is included in the SWMP Appendix.

Program Evaluation and OversightThe City Engineer is responsible for overall management and implementation of our post-construction stormwater management program, with site inspection and plan review assistance from the County SWCD. We evaluate the success of this minimum measure through our ability to continue to implement our comprehensive stormwater management regulation and our riparian setback regulation, and ensuring that Inspection and Maintenance Agreements are in place and enforced for all relevant sites. The City Engineer meets with the Stormwater Committee annually to report on the success of these goals. Our goals were selected to reflect TMDL recommendations, permit requirements, current practices, and manpower requirements of the BMPs.

Table 5: Post-Construction Stormwater Management Program

MCM 5: Post-Construction Stormwater Management in New Development and Redevelopment


Responsible Party

Update existing stormwater management code to meet or exceed the Review and City Council,

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requirements of NPDES OHC000004, including the federal effluent limitations in Part II

adopt updated CRWP model code by December 22, 2016

City Engineer

Ensure the most current post-construction BMP standards are required to be utilized (e.g., Rainwater and Land Development)


City Council, City Engineer

Complete Stormwater Pollution Prevention Plan (SWP3) reviews and approval prior to construction commencement; ensure SWP3 includes an executed Maintenance Agreement and Long-Term Maintenance Plan for post-construction BMPs

100% of SWP3 plan reviews approved prior to construction where larger common plan of disturbance/sale disturbs one or more acres


Conduct monthly site inspections throughout construction, as well as a final site inspection to ensure correct implementation of post-construction BMPs in the approved SWP3

All active sites inspected monthly and a final site inspection completed


Establish a program to ensure long-term maintenance of post-construction BMPs including a protocol for enforcement escalation of stormwater management codes

Enforce procedures for establishment of O&M and noncompliance as established in stormwater management code

City Engineer



Responsible Party

Enforce our riparian setback ordinance.


Continue to enforce community riparian setback legislation passed on [date]

City Engineer, Planning and Zoning Commission

Require soil preservation and post-construction soil restoration.

Addresses [watershed(s)] TMDL recommendations

Update stormwater management code to include


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for flow and habitat.

this requirement by December 22, 2016

Require use of stormwater control measures to reduce the temperature of runoff for development projects in watersheds draining to coldwater habitat streams.

Addresses [watershed(s)] TMDL recommendations for habitat.

Update stormwater management code to include this requirement by December 22, 2016


Require stormwater management for all commercial and industrial site development

Addresses [watershed(s)] TMDL recommendations for TSS/sediment, nutrients, habitat, low DO/organic enrichment, and flow.



Credit volume reduction attained through low impact development stormwater control measures toward peak discharge requirements.

Addresses [watershed(s)] TMDL recommendations for bacteria (bioretention only), nutrients, habitat, low DO/organic enrichment, and flow.



Require redevelopment projects to manage greater than 20% of the water quality volume and incentivize infiltration-based SCMs for redevelopment.

Addresses [watershed(s)] TMDL recommendations for TSS/sediment, nutrients, habitat, low DO/organic enrichment, bacteria, and flow.



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The above table includes required BMPs, examples of enhanced BMPs, TMDL applicability, measurable goals, and responsible parties for your Post-Construction Stormwater Management in New Development and Redevelopment program. You can use this Table to summarize your program for your internal use and documentation, and to facilitate your annual reporting. The narratives included in Table 5 are only examples of possible BMPs and language you may use. Alter these to reflect activities that do or will occur in your community. Updating this table alone will not be considered an acceptable level of detail by Ohio EPA for resubmitting your SWMP.

MCM 6: Pollution Prevention/Good Housekeeping for Municipal Operations

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At a minimum, your Pollution Prevention/Good Housekeeping (PPGH) program must include: An operation and maintenance program that includes a training component and has the

goal of preventing or reducing pollutant runoff from municipal operations.o The training should use materials that are available from Ohio EPA or other

organizations and must be held at a minimum of once per year for municipal employees.

A list of industrial facilities (if applicable) that are subject to Ohio EPA’s Industrial Stormwater General Permit (currently #OHR000005) or individual NPDES permits for discharges of stormwater associated with industrial activities that ultimately discharge to your MS4.

A Stormwater Pollution Prevention Plan (SWP3) in accordance with the SWP3 requirements of Ohio EPA’s Industrial Stormwater General Permit for all municipal facilities not required to obtain coverage under the Industrial Stormwater General Permit (examples include but are not limited to vehicle maintenance facilities, bus terminals, composting facilities, impoundment lots and waste transfer stations). Each applicable facility should have its own SWP3.

Documentation of your decision process and rationale for your PPGH program.

Your rationale in your SWMP narrative for your PPGH program should already be developed by this point per the requirements of previous MS4 permits. It is strongly recommended to examine your existing program and in your description, note which activities specifically address TMDL pollutants. Your PPGH program applies across your MS4 and your rationale must describe your maintenance activities, schedules (annually, monthly, etc) for those activities, and what staff are responsible for implementing those activities. At a minimum, the responsible department should be named. Any programs or controls you’re using to reduce discharge of pollutants to the MS4 should be described, such as your salting/winterization program and waste disposal program. You should also describe your procedures to show that new flood management projects are assessed for impacts on water quality and any previous projects are assessed for potential retrofit of additional water quality protection devices or practices. A “flood management project” can be thought of as any project the permittee undertakes which is intended to control, reduce, or minimize high flows and associated damage in the MS4. This may include projects like drainage ditch extensions or basin retrofits as well as projects designed to mimic or improve natural conditions in a waterway, such as stream restorations.

Some sample text has been provided below to guide you in your narrative, but additional detail will be required to pass review by Ohio EPA.

RELEVANT ITEMS YOU SHOULD INCLUDE IN YOUR SWMP APPENDIX: Inspection checklist for municipal facilities Any other inspection forms used by the community to evaluate catchbasins, etc. Samples of training materials used for annual employee training Inventory of flood management projects

Sample Language: Pollution Prevention/Good Housekeeping Program OverviewThe Service Director inventories municipal activities throughout the MS4 that may impact stormwater. These include:1. Vehicle maintenance [summarize current vehicle maintenance practices]2. Salt application [summarize current salt procedures]3. Ditch cleaning [summarize current practices including hydroseeding]4. Street sweeping [summarize procedure – minimum of once per year, for example]5. Recycling location for household hazardous waste [summarize location description]6. Composting facility [summarize facility type, location]

The Service Department sweeps streets once every season (weather permitting) or more often as needed. A general street sweeping schedule and description of the equipment used is included in the SWMP Appendix. Storm sewer catchbasins are generally equipped with sumps and traps that prevent most objectionable material from entering the MS4. These are cleaned on an as-needed basis by the Service Department based on quarterly inspections. A copy of the inspection report form is included in the SWMP Appendix. Street sweeping and catchbasin cleaning are enhanced BMPs we have chosen to address our [watershed(s)] TMDLs for TSS/sediment, nutrients, DO/organic enrichment, and bacteria.

All community-owned parking lots have catchbasins with sumps that are cleaned on a regular basis (see above) by Service Department staff. Vehicles are repaired and maintained within an enclosed facility at the Service Department. Engines and other component parts designated for disposal are not allowed to remain in uncovered storage. Oils and other fluids from maintenance activities are collected and disposed of by a licensed contractor. The debris from catchbasin cleaning is allowed to drain before being transported to an approved landfill. All salt used by the community is stored under cover in an enclosed structure at the Service Department. In this permit cycle, the Service Director, with technical assistance from CRWP, will direct the evaluation of all of our municipal parking lots by the end of the permit term to locate and use snow disposal areas where there are wide vegetative buffers or within berms. This is an enhancement to our program that will address our [watershed(s)] TMDLs for TSS/sediment, nutrients, habitat degradation, DO/organic enrichment, bacteria, and flow.

Facilities Subject to Pollution Prevention/Good Housekeeping ProgramOur facilities subject to the PPGH program include the following:

Facility 1o Addresso Summary of activities/procedures at facility

Facility 2o Addresso Summary of activities/procedures at facility

Facility 3…

A SWP3 is prepared for each of our facilities and a copy is kept on file at each facility as well as with the Service Director. Each facility SWP3 is updated to be compliant with the SWP3 requirements stated in the Ohio EPA Industrial Stormwater General Permit.

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Evaluation of Flood Management ProjectsFor any flood management projects undertaken by municipal staff, construction and maintenance activities within the jurisdictional waters of the United States are done in compliance with Sections 402 and 404 of the Clean Water Act. Plans and specifications of such activities requiring permits and NOI are forwarded to the Ohio EPA and the US Army Corps of Engineers when appropriate. We require the use of sediment and erosion control measures on all municipal projects per our Erosion and Sediment Control ordinance. The City Engineer, the Public Service Director, and the Building Commissioner review municipal projects as appropriate to determine the feasibility of additional water quality protection devices and practices.

Municipal Staff TrainingThe Service Director coordinates with CRWP, Ohio EPA, OSHA, and ODOT to secure available employee training materials and ensure they are up to date and relevant to the community operations. Some examples of past training materials are included in the SWMP Appendix. The Service Director is responsible for the scheduling and organization of the training. We partner with CRWP to provide a minimum of one training per year to community staff on MCM 6, including how to identify illicit discharges and handle hazardous spills. The Service Director is responsible for the overall management and implementation of our Pollution Prevention/Good Housekeeping program, and reports to the Stormwater Committee on an annual basis for program evaluation.

Program Evaluation and OversightThe Service Director is responsible for management and oversight of the Pollution Prevention/Good Housekeeping program. Where distinct milestones are noted for BMPs under this MCM, they are tracked by the responsible parties noted in the below table. The Service Director meets with the Stormwater Committee for an annual review in conjunction with the annual reporting required by Ohio EPA to evaluate whether these specific milestones and other ongoing BMPs are being met. Our goals are selected to reflect TMDL recommendations, permit requirements, current practices, and manpower requirements of the BMPs. The Stormwater Committee evaluates the success of these BMPs with the Service Director and suggests changes if warranted.

Table 6: Pollution Prevention/Good Housekeeping for Municipal Operations Program

MCM 6: Pollution Prevention/Good Housekeeping for Municipal Operations Program

Required BMP


Responsible Party

Update and implement facility SWP3s to reflect minimum requirements of the Ohio EPA General NPDES Permit for Stormwater Associated with Industrial Activities (OHR000005): perform quarterly routine facility inspections, quarterly visual assessment of stormwater discharges, and annual comprehensive site inspection with annual report

Update all required SWP3s to be compliant by December 22, 2016

Service Director

Implement pollution prevention and good housekeeping practices at the following municipally-operated facilities: streets, roads and highways; municipal parking lots; maintenance and storage yards (including but not

Continue to implement SWP3

Service Director, Parks and

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limited to municipal composting facilities and leaf collection yards); golf courses, parks, and related maintenance facilities; waste transfer stations, compost facilities, solid waste facilities (e.g. municipal solid waste landfills and construction/demolition landfills); marinas; fleet and/or maintenance shops; salt/sand storage locations; and snow disposal areas

procedures at all relevant municipal facilities

Recreation Director

Conduct annual staff training for pollution prevention/good housekeeping

One annual training to managers and staff of all relevant municipal facilities

Service Director



Responsible Party

Conduct street sweeping program on municipal streets

Addresses [watershed(s)] TMDL recommendations for TSS/sediment, nutrients, bacteria, and low DO/organic enrichment.

100% of streets swept on bi-monthly schedule [change this according to community procedure]

Service Director

Locate snow disposal areas where there are wide vegetative buffers or within berms


Identify and establish new snow disposal areas wherever feasible at municipal facilities by December 22, 2016

Service Director

At community-owned and operated facilities, maintain, protect and restore permanent natural vegetative buffers between developed areas and water resources


Identify, restore, and maintain buffers wherever feasible at all municipal facilities by end of permit term

Service Director

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Review and Update of the Stormwater Management Program

We perform an annual review of our SWMP in conjunction with preparation of the annual report to Ohio EPA required under Part IV.C of the MS4 Permit #OHQ0000003. Any proposed additions to the SWMP during the life of the permit are made upon written notification to Ohio EPA. Changes replacing an ineffective or infeasible BMP specifically identified in the SWMP with an alternate BMP are requested of Ohio EPA according to the procedure outlined in accordance with Part V.G of the MS4 Permit #OHQ000003 and include the following information:

1. An analysis of why the BMP is ineffective or infeasible (including cost prohibitive),2. Expectations on the effectiveness of the replacement BMP, and3. An analysis of why the replacement BMP is expected to achieve the goals of the BMP to be

replaced.Unless specifically denied by Ohio EPA, the requested changes proposed in accordance with the criteria above shall be deemed approved and may be implemented 60 days from submittal of the request.

Evaluating, Record Keeping and Reporting

Through the procedures established in each MCM rationale, we evaluate our program compliance, the appropriateness of identified BMPs, and progress toward achieving identified measurable goals and satisfying the performance standards. We retain copies of all reports and documentation required by Part IV.B.1 of the MS4 Permit #OHQ000003 and will retain and make our required documentation accessible to the public if requested to do so in writing according to Part IV.B.2 of the MS4 Permit OHQ000003. For the 5-year term of the permit, yearly reports are prepared detailing the progress of our community in meeting the measurable goals of the program using the reporting forms provided by Ohio EPA. Reports are filed annually in accordance with the requirements of Part IV.C of the MS4 Permit #OHQ000003.

Appendices

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The above table includes required BMPs, examples of enhanced BMPs, TMDL applicability, measurable goals, and responsible parties for your Pollution Prevention/Good Housekeeping for Municipal Operations program. You can use this Table to summarize your program for your internal use and documentation, and to facilitate your annual reporting. The narratives included in Table 6 are only examples of possible BMPs and language you may use. Alter these to reflect activities that do or will occur in your community. Updating this table alone will not be considered an acceptable level of detail by Ohio EPA for resubmitting your SWMP.

Include any needed Appendices here- including but not limited to any third-party Memorandums of Understanding, local codes, storm system map, address list of community HSTS, etc.