How to Develop a SWPPI Storm Water Pollution Prevention Initiative

1
How to Develop a SWPPI(Storm Water Pollution
Prevention Initiative)

• June 8, 2001

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Goal of the SWPPI

• The Goal of the SWPPI is to detail, in a single
  comprehensive document, the community/agency
  commitments needed to reduce the discharge of
  pollutants to the maximum extent practicable

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The SWPPI shall

• Be consistent with the WMP(s)
• Include actions to be implemented over the term
  of the permit (and beyond in some cases)
• Address specific actions to be implemented by an
  individual permittee to achieve the goals of the
  WMP(s)

4
The SWPPI shall contain

• Actions proposed in the WMP(s)
• Implementation timelines and priorities for
  proposed actions
• Evaluation of pollution prevention and good
  housekeeping activities
• Methods of assessing progress in meeting the
  goals of the WMP(s) and proposed actions

5
The SWPPI shall contain (cont...)

• Evaluation and implementation of site
  appropriate, cost-effective, structural and
  nonstructural BMPs for new developments and
  significant redevelopment
• Specific reasons for a WMP goal not being
  applicable within the community

6
Optional SWPPI Content

• Community specific priorities for the WMP goals
  and SWPPI actions
• Community specific history pertinent to the WMP
  and/or SWPPI
• Costs associated with SWPPI implementation

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Content and Guidance

• Major Sections (Text Portion)
• Permittee Contact Information
• Purpose of SWPPI
• Annual Reporting Requirements
• Requirements for Biennial Revisions
• Retention of Records
• Permittee Goals and Priorities
• Permittee Housekeeping/Pollution Prevention

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Contents and Guidance

• Major SWPPI Sections (Tables)
• Methods for Assessing and Measuring Progress in
  the subwatershed(s)
• Permittee Specific Actions to Address Goals

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Permittee Contact Information

• Permit number and Certificate of Coverage number
• Permittees name, address
• Contact person for questions
• Including name, title, and phone number
• Date SWPPI submitted
• Signature of person with authority to make
  financial and other commitments

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Purpose of SWPPI

• Boilerplate Language used for clarification
• Identifies if there will be a single document
  also incorporating the IDEP and PEP
• Summary of contents of SWPPI

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Annual Reporting Requirements

• Information must be submitted annually on the
  anniversary date of the COC. Includes
• Changes to goals or action contained in WMP
• Progress on goals and/or actions contained in the
  SWPPI
• Any other actions taken to reduce the discharge
  of stormwater pollutants
• (If you do not combine all the documents then you
  must continue to report on IDEP and PEP progress
  annually)

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Requirement for Biennial Revisions

• SWPPI and WMP shall be reviewed every 2 years
  (May 2003)
• Revisions to the WMP and SWPPI can be submitted
  together on the date specified for WMP revision
• Any proposed changes shall be submitted to MDEQ
  for approval by the specified date. If no
  changes are needed, a letter stating this is
  adequate

13
Retention of Records

• Permit Requirement
• SWPPI and its associated records must be retained
  by permittee for 3 years after permit termination
• Do not submit to MDEQ-but must be made available
  to us upon request
• Information includes analysis performed,
  calibration of instruments, recordings from
  continuous monitors, analysis performed

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Permittee Goals Priorities

• This Section can contain
• Council/Board support for document
• Describe character,development status, land use,
  unique features, etc. of community
• WMP of greatest priority and why
• Goals that are Not Applicable
• Applicable goals for all subwatersheds in COC
• Ongoing activities to illustrate commitment

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Permittee Housekeeping/ Pollution Prevention

• Purpose to reduce the discharge of pollutants to
  maximum extent practicable on permittees own
  properties and activities- municipal operations
• 5 specific areas need to be considered
• Maintenance of stormwater control structures
• Pollutants from roads, parking lots, etc.
• Disposal of OM wastes
• WQ impacts from flood management projects
• Pollution from fertilizers and pesticides

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BMPs for New and Redevelopment

• Evaluation and implementation of structural and
  nonstructural controls for new and significant
  redevelopment
• Goal is to protect designated uses from the
  effects of urbanization
• Can be included in Table of activities in SWPPI
  template

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Methods for Assessing Progress

• Methods to be used to measure progress toward
  achieving goals and reducing stormwater
  pollutants
• Should include both instream measurements as well
  as more subjective measurements
• Can be included as a component of a table in the
  SWPPI template

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Methods for Assessing Progress on the
Subwatershed-Wide Goals

• Table 1 in the SWPPI template
• Could also be in narrative form
• Necessary (and desirable) because
• A permit requirement
• Want to optimize allocation of resources
• Need to justify efforts to officials public
• Want to apply lessons learned to other locations

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Methods for Assessing Progress on the
Subwatershed-Wide Goals

• Can be accomplished by
• reporting on actions taken
• taking measurements (of water quality, fish
  populations, wetland acres, etc.)
• Assistance advice with Table 1 will be provided
  by the SWAGs and MDEQ

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Methods for Assessing Progress on the
Subwatershed-Wide Goals

• Contents of Table 1
• Subwatershed goal title, and number or
  abbreviation for later reference
• Indication of applicability of goal to permittee
• Method for evaluating progress
• with location(s), if appropriate
• Target for evaluating progress
• with schedule
• Party responsible for evaluating progress

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Methods for Assessing Progress on the
Subwatershed-Wide Goals

• Mostly accomplished by on-going, long-term,
  subwatershed-wide monitoring programs
• RPO/subwatershed monitoring program
• USGS flow monitoring
• MDEQ-GLEAS biological monitoring
• May want to augment with additional sampling

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Methods for Assessing Progress -
Subwatershed-Wide Goals

• Targets are important. They provide
• a benchmark against which to measure progress
• a focus around which to plan monitoring schemes
• Targets should be tied to beneficial uses, where
  appropriate

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Methods for Assessing Progress -
Subwatershed-Wide Goals

• Example 1 Goal Minimize upland soil erosion
• Method of Measuring Progress Training of
  community staff
• Target Have all staff trained, by 2002
• Responsible Party (for data collection)
  Community

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Methods for Assessing Progress -
Subwatershed-Wide Goals

• Example 2 Goal Protect restore natural
  features
• Methods of Measuring Progress fish benthos
  monitoring
• Targets improve fish benthos scores from
  poor to good at Eight Mile Road, by 2010
  maintain good scores at Grand River Ave.
• Responsible Party (for data collection)
  MDEQ-GLEAS

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Reporting on Permittee-Specific Actions

• Focus is on community-specific SWPPI actions
• Table 2 in the SWPPI template
• Could also be in narrative form

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Reporting on Permittee-Specific Actions

• Recommended contents of Table 2
• Action committed to by permittee
• Goal(s) addressed by each action
• Coverage of permit-required activities
• Method of implementation schedule
• Method(s) of reporting/measuring progress
• Should breakout IDEP and PEP actions separately
  from the other SWPPI actions

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Reporting on Permittee-Specific Actions

• Actions committed to by permittee
• Briefly summarize the action
• Direct from the WMP
• Goal(s) addressed by each action
• Must have at least one action for each goal
• Try only to list goals that are directly affected
  by an action

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Reporting on Permittee-Specific Actions

• Coverage of permit-required activities
• Actions in SWPPI template section 6.2.a-e, and
  6.3 (or Permit section B.2.a.2)
• Housekeeping activities
• Method of implementation and schedule
• Steps for implementing action
• Be as specific and quantitative as possible

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Reporting on Permittee-Specific Actions

• Reporting or measuring progress
• Be as specific and quantitative as possible
• Usually reported in Annual Report

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Reporting on Permittee-Specific Actions

• Example 1 Action golf course/recreation area
  management
• Goal addressed 3U (protect restore river
  ecosystem for fish wildlife)
• Permit-required activities 6.2.e
• Implementation Require training/certification
  for those applying pesticides, fungicides,
  fertilizers on city property
• Report progress certified applicators, in
  annual report

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Reporting on Permittee-Specific Actions

• Example 2 Action Encourage low-impact
  development practices
• Goals Addressed L1-1 (flow variability) L1-2
  (nutrient loading) and others
• Permit-required activities 2.b 2.e 3
• Implementation Develop standards for new
  developments begin 2nd quarter, 2002
• Progress report Document BMPs and practice
  standards, in annual report

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Methods for Assessing Progress

• Summary
• Two kinds of progress assessment
• subwatershed-wide goals
• mostly on-going monitoring programs
• permittee-specific actions
• mostly reporting on action progress
• Easily summarized in tables
• Asking for detail and forethought, to minimize
  ambiguity in defining progress in years to come

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Inkster SWPPI

• Inkster is a one sub-watershed example
• This SWPPI follows the generic MDEQ SWPPI
  Template
• The IDEP and PEP are combined into the SWPPI
  (reference Section 2)
• The SWPPI and the WMP will be reviewed and
  revised at the same time (reference Section 3)

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Inkster SWPPI

• Section 5 has been utilized by the City to
  present their specific programs and their unique
  situations
• Significant effort and resources
• Fully endorses Lower 2 SWMP
• Sewer system
• Demographics, land use, and economics
• No actual Rouge River shoreline
• Goals and Sub-goals

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Lower 2 Subwatershed Goals

• Improve water quality in the Rouge River and
  restore impaired uses
• Remove sources of pollution that threaten public
  health
• Educate the public regarding their impact of the
  River and the Rivers existing and future
  potential as a community asset and recreational
  source
• Improve the water quality of the river to
  increase recreational opportunities and remove
  fish consumption advisories

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Lower 2 Subwatershed Goals

• Enhance and preserve habitat, especially next to
  the river, for fish and wildlife compatible with
  subwatershed land uses
• Minimize the amount of soil erosion and
  sedimentation
• Reduce water volumes and velocities in the river
  during a storm event to minimize band erosion and
  flooding

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City of Inskter IN1 IDEP testing/study IN2 IDEP
correction IN3 TV Inspection of storm drains as
required IN4 GIS- storm sewer database IN5 Provide
support for Lower 2 public education web
site IN6 Catch basin cleaning/repair IN7 Street
sweeping IN8 Leaf removal IN9 Household
hazardous waste program
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City of Inkster IN10 Planning to build new salt
storage facility IN11 Yard waste composting
program IN12 Downspout disconnection
program IN13 On-site sewage disposal system
removal program IN14 CSO program
implementation IN15 Storm water pollution
prevention education in calendar, newspaper and
Inkster Inprint IN16 Business pollution
prevention education- "Clean Business Group
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Inkster SWPPI Table 1
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Inkster SWPPI Table 2
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Multiple SubwatershedsSWPPI Template

• FARMINGTON HILLS
• The city will be finalizing its SWPPI over the
  next few months and agreed to the presentation of
  this document as an example for illustrative
  purposes during the workshop

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Issues

• Sorting out priorities and relating to
  overlapping subwatershed goals
• Identifying any exceptions to goals/objectives

• Summarizing measures/short term targets
• Linking actions to multiple goals

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Sorting Out Community/Agency Priorities --
Overlapping Goals

• Template for Farmington Hills
• Focuses on priorities selected for the Upper
  Subwatershed
• Describes the basis for the citys priorities
• Outlines the relationship to the other
  subwatershed goal/objectives

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Identifying Exceptions to Goals/Objectives

• Table 1 in Farmington Hills SWPPI

Long Term Goals
Exceptions
Reasons
Listed 22 Goals of the Upper, Main 12 and Middle
1 Subwatersheds
Listed 11 exceptions to short-term objectives
Briefly described reasons for exceptions
Exceptions to any subwatershed goals required
while exception to short-term objectives optional
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Identifying Exceptions to Goals/Objectives

• Table 1
• Each of the 22 subwatershed goals given unique
  identifying number for later reference
• No exceptions to goals identified but specific
  objectives often did not fit Farmington Hills
• new ordinances to control site runoff from
  developments not needed in Farmington Hills a
  priority for some communities in Middle 1

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Progress Measures and Short-Term Targets

• Progress measures described -- with focus on
  those developed in Upper Subwatershed Management
  Plan
• Table 2
• Goal/Progress Measure
• Responsible Party
• Short Term Target
• Schedule

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Progress Measures and Short-Term Targets

• Table 2

Goals/Progress Measures (17)
Entity Responsible
Target
Schedule
Example
Enhance River Ecosystem D.O. Levels
Reduce
RPO or Upper SWAG
Re-sample previous sites by 2003
WQ Violations
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Linking Actions to Multiple Subwatershed Goals

• Table 3
• Listing of Actions (Best Management Practices)
• Identifying primary goals benefited from each
  action
• Citing where action is a requirement (PEP, IDEP,
  permit, management plan)
• Brief description of implementation/schedule
• Method of Reporting in annual report

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Linking Actions to Multiple Subwatershed Goals
Table 3
Methods of Reporting
Actions (46)
Methods/Schedule
Goals
Requirements
Example
Staff Training Erosion Control
5U, 4M, 3MD,7M
Send staff to training, complete 12-31-02
Number of staff trained each year
6(3)
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Sources of Information

• The three subwatershed plans identify goals in
  priority order
• Proposed actions were taken from list compiled in
  the Upper Management Plan
• Measures proposed were taken from those developed
  in the Upper Management Plan
• Short-term targets were developed based upon the
  short term objectives in Upper Management Plan

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Summary

• The goals of all three subwatershed - Upper, Main
  1-2, and Middle 1 - are considered in the SWPPI
• At least one action is included in the SWPPI for
  each of the subwatershed goals
• Actions and measures are linked to goals and
  permit requirements are cited
• Methods of reporting progress are identified
  along with short-term targets

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Rural Township SWPPI Example
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Rural Townshipunique attributes

• Rural community, limited jurisdiction/authority
• Land use primarily low-density residential, small
  agriculture, open space
• Permit coverage for entire community
• Covers two major watersheds Rouge and Huron
  Rivers
• Headwaters of both river systems
• Three associated watershed management plans Ford
  Lake, Flemming Creek, Lower 1 Rouge

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Rural Township Table 1 addressing
multiple watershed management plan goals and
objectives (28)
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Rural TownshipSection 5 community-specificgoal
s and priorities

• Protect existing wetlands
• Control the increase of impervious surfaces
• Manage and direct growth while protecting the
  environment
• Prevent excessive phosphorus loads
• Protect downstream recreational uses by
  controlling sources of bacteria
• Encourage the control of soil erosion and
  sedimentation

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Rural TownshipTable 2 how to measure progress?

• Headwaters currently show good water quality and
  habitat
• Progress minimize degradation of water quality
  and habitat
• Targets based on subwatershed goals
• Work with watershed groups to use data downstream
  to determine upstream changes
• Use biology (macroinvertebrates, amphibians,
  fish) as indicators of long-term stream health
  and water quality changes

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Rural TownshipTable 2 how to measure progress?
Example
Related WMP Goals/objectives
Methods for evaluating progress
Subwatershed target
Responsible Party
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Rural TownshipTable 3 Action Table
Examples
Permit Required Activities
Goal(s) addressed
Action
Method of implementation and schedule
Methods of reporting
Chose to combine the IDEP and PEP into the
SWPPI for one comprehensive plan.
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Rural TownshipTable 3 emphasis of our action
items

• 1. Public education and stewardship
• Watershed Newsletter
• Wetland education
• Septic system maintenance
• Educating developers
• Educating staff, board and commission members
• working with local creek groups and land trusts

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Rural Township Table 3 emphasis of our action
items

• 2. Partnerships and inter-agency communication
• Washtenaw County assistance
• Illicit discharges, illegal dumping
• Storm Water Ordinance
• Soil erosion inspection and compliance
• Public education support
• Michigan Department of Agriculture and NRCS
• Generally accepted agricultural management
  practices (GAAMPs)
• Wetland stewardship

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Rural Township Table 3 emphasis of our action
items

• 3. Institutionalizing storm water protection
• Natural features inventory and assessments
• Wetland ordinance and Wetland Board
• Growth Management Plan
• Low-impact development through Planning
  Commission
• Additional part-time staff

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Rural Township Table 3 emphasis of our action
items

• 4. Looking at community facilities
• Participate in Drain Commissioners Community
  Partners for Clean Streams
• Construction of wetland detention system in
  Township park adjacent to creek, to address
  flooding, aesthetics and water quality problems

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Rural Township Summary

• Important to identify community priorities based
  on various management plans, across two different
  watersheds
• All 28 goals/objectives have been addressed
  through at least one action
• Advantage of whole community coverage under one
  permit
• Actions focus on protection
• Important to recognize and utilize partnerships

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Canton CommunitySWPPI Example
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Canton CommunityUnique Attributes

• Developing community
• Located in two Rouge subwatersheds
• Large residential population
• Emphasis on both protection and restoration
• Strong public education emphasis

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Canton CommunitySWPPI Focus

• Integrated IDEP and PEP into SWPPI
• Storm water management in new developments
• Public education
• Recreational opportunities
• Detention pond retrofits
• Partnerships

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Storm Water Management

• Additional Staff
• Public Works Foreman
• Storm Water Management
• Storm water ordinance
• Street sweeping
• Catch basin cleaning
• Minor detention pond maintenance

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Public Education

• Homeowners association workshops
• River Day
• Household Hazardous Waste Collection Day
• Liberty Fest
• Neighborhood clean up

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Public Education

• FOCUS newsletter
• Website
• Cable television
• Tip cards
• School demonstrations

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Recreational Opportunities

• Community pathway system
• Park enhancements

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Detention Pond Retrofits

• Demonstration grant for 4 ponds
• Community pond retrofit combined with educational
  signage
• Residential ponds/work with homeowners
  associations
• Utilize storm water funds

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Building Partnerships

• Subwatershed Partnerships
• Continue participation in subwatershed groups to
  share information and challenges
• Identify activities that can be utilized across
  community boundaries
• Wayne County
• Soil erosion inspection and compliance
• Septic system inspection and compliance
• Illicit discharge inspection
• Public education assistance

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Canton Community Summarywhy is this important?

• building long-term relationships within and
  between jurisdictions to protect and restore our
  shared river resources

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SWPPI Submittal Process

• Develop draft SWPPI in conjunction with any other
  responsible parties (internal not submitted
  to MDEQ)
• Obtain commitment/sign-off from other
  responsible parties (internal not submitted
  to MDEQ)

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SWPPI Submittal Process (cont. . .)

• Review with Council/Board as appropriate and
  obtain a resolution adopting the SWPPI, if
  necessary (The MDEQ strongly recommends the
  adoption of a resolution)
• Transmit SWPPI to MDEQ with a signature block in
  the SWPPI signed by an appropriate Permittee
  Representative (Person with the authority to make
  financial and other commitments necessary to
  reduce the discharge of pollutants to the maximum
  extent practicable and to be consistent with the
  watershed management plan)

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SWPPI Review Checklist

• Draft checklist to be used by MDEQ to review
  SWPPIs (copy in your packet)
• Generally follows permit requirements
• Ensure there is at least one action for each
  applicable goal for all subwatershed listed in
  COC
• Check to ensure all IDEP and PEP approved
  activities have been transferred, if applicable
• Check for any disagreements with WMP