how to develop a swppi (storm water pollution prevention initiative) june 8, 2001

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Clean Water Rules! How to Develop a SWPPI How to Develop a SWPPI (Storm Water Pollution Prevention (Storm Water Pollution Prevention Initiative) Initiative) June 8, 2001 June 8, 2001

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Page 1: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

CleanWaterRules!

How to Develop a SWPPIHow to Develop a SWPPI(Storm Water Pollution Prevention (Storm Water Pollution Prevention

Initiative)Initiative)

June 8, 2001June 8, 2001

Page 2: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Goal of the SWPPIGoal of the SWPPI

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

Page 3: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

The SWPPI shall:The SWPPI shall:

• Be consistent with the WMP(s)Be consistent with the WMP(s)• Include actions to be implemented over Include actions to be implemented over

the term of the permit (and beyond in the term of the permit (and beyond in some cases)some cases)

• Address specific actions to be Address specific actions to be implemented by an individual permittee implemented by an individual permittee to achieve the goals of the WMP(s)to achieve the goals of the WMP(s)

Page 4: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

The SWPPI shall contain:The SWPPI shall contain:

• Actions proposed in the WMP(s)Actions proposed in the WMP(s)• Implementation timelines and Implementation timelines and

priorities for proposed actionspriorities for proposed actions• Evaluation of pollution prevention and Evaluation of pollution prevention and

good housekeeping activitiesgood housekeeping activities• Methods of assessing progress inMethods of assessing progress in

meeting the goals of the WMP(s) meeting the goals of the WMP(s) and proposed actionsand proposed actions

Page 5: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

The SWPPI shall The SWPPI shall contain: contain: (cont...)(cont...)

• Evaluation and implementation of site Evaluation and implementation of site appropriate, cost-effective, structural appropriate, cost-effective, structural and nonstructural BMPs for new and nonstructural BMPs for new developments and significant developments and significant redevelopmentredevelopment

• Specific reasons for a WMP goal not Specific reasons for a WMP goal not being applicable within the communitybeing applicable within the community

Page 6: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Optional SWPPI ContentOptional SWPPI Content

• Community specific priorities for the Community specific priorities for the WMP goals and SWPPI actionsWMP goals and SWPPI actions

• Community specific history pertinent to Community specific history pertinent to the WMP and/or SWPPIthe WMP and/or SWPPI

• Costs associated with SWPPI Costs associated with SWPPI implementationimplementation

Page 7: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Content and GuidanceContent and Guidance

• Major Sections (Text Portion)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

Page 8: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Contents and GuidanceContents and Guidance

• Major SWPPI Sections (Tables)Major SWPPI Sections (Tables)– Methods for Assessing and Measuring

Progress in the subwatershed(s)– Permittee Specific Actions to Address Goals

Page 9: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Permittee Contact Permittee Contact InformationInformation

• Permit number and Certificate of Permit number and Certificate of Coverage numberCoverage number

• Permittees name, addressPermittees name, address• Contact person for questionsContact person for questions

– Including name, title, and phone number

• Date SWPPI submittedDate SWPPI submitted• Signature of person with authority to Signature of person with authority to

make financial and other commitmentsmake financial and other commitments

Page 10: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Purpose of SWPPIPurpose of SWPPI

• Boilerplate Language used for Boilerplate Language used for clarificationclarification

• Identifies if there will be a single Identifies if there will be a single document also incorporating the IDEP document also incorporating the IDEP and PEPand PEP

• Summary of contents of SWPPISummary of contents of SWPPI

Page 11: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Annual Reporting Annual Reporting RequirementsRequirements

• Information must be submitted annually Information must be submitted annually on the anniversary date of the COC. on the anniversary date of the COC. Includes: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)

Page 12: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Requirement for Biennial Requirement for Biennial RevisionsRevisions

• SWPPI and WMP SWPPI and WMP shallshall be reviewed be reviewed every 2 years (May 2003)every 2 years (May 2003)

• Revisions to the WMP and SWPPI can be Revisions to the WMP and SWPPI can be submitted together on the date submitted together on the date specified for WMP revisionspecified for WMP revision

• Any proposed changes shall be Any proposed changes shall be submitted to MDEQ for approval by the submitted to MDEQ for approval by the specified date. If no changes are specified date. If no changes are needed, a letter stating this is adequateneeded, a letter stating this is adequate

Page 13: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Retention of RecordsRetention of Records

• Permit RequirementPermit Requirement• SWPPI and its associated records must SWPPI and its associated records must

be retained by permittee for 3 years be retained by permittee for 3 years after permit terminationafter permit termination

• Do not submit to MDEQ-Do not submit to MDEQ-but must be but must be made available to us upon requestmade available to us upon request

• Information includes analysis Information includes analysis performed, calibration of instruments, performed, calibration of instruments, recordings from continuous monitors, & recordings from continuous monitors, & analysis performed analysis performed

Page 14: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Permittee Goals & PrioritiesPermittee Goals & Priorities

• This Section can contain: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

Page 15: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Permittee Housekeeping/ Permittee Housekeeping/ Pollution PreventionPollution Prevention

• Purpose to reduce the discharge of Purpose to reduce the discharge of pollutants to maximum extent practicable pollutants to maximum extent practicable on on permittees own propertiespermittees own properties and and activitiesactivities- municipal operations- municipal operations

• 5 specific areas need to be considered5 specific areas need to be considered– Maintenance of stormwater control structures– Pollutants from roads, parking lots, etc.– Disposal of O&M wastes– WQ impacts from flood management projects– Pollution from fertilizers and pesticides

Page 16: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

BMPs for New and BMPs for New and RedevelopmentRedevelopment

• Evaluation and implementation of Evaluation and implementation of structural and nonstructural controls for structural and nonstructural controls for new and significant redevelopmentnew and significant redevelopment

• Goal is to protect designated uses from Goal is to protect designated uses from the effects of urbanizationthe effects of urbanization

• Can be included in Table of activities in Can be included in Table of activities in SWPPI templateSWPPI template

Page 17: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Methods for Assessing Methods for Assessing ProgressProgress

• Methods to be used to measure Methods to be used to measure progress toward achieving goals and progress toward achieving goals and reducing stormwater pollutantsreducing stormwater pollutants

• Should include both instream Should include both instream measurements as well as more measurements as well as more subjective measurementssubjective measurements

• Can be included as a component of a Can be included as a component of a table in the SWPPI templatetable in the SWPPI template

Page 18: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Methods for Assessing Methods for Assessing Progress on the Progress on the

Subwatershed-Wide GoalsSubwatershed-Wide Goals• Table 1 in the SWPPI templateTable 1 in the SWPPI template

– Could also be in narrative form

• Necessary (and desirable) because: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

Page 19: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Methods for Assessing Methods for Assessing Progress on the Progress on the

Subwatershed-Wide GoalsSubwatershed-Wide Goals• Can be accomplished by: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 Assistance & advice with Table 1 will be provided by the SWAGs and MDEQprovided by the SWAGs and MDEQ

Page 20: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Methods for Assessing Methods for Assessing Progress on the Progress on the

Subwatershed-Wide GoalsSubwatershed-Wide GoalsContents of Table 1:Contents of Table 1:• Subwatershed goal title, and number or Subwatershed goal title, and number or

abbreviation for later referenceabbreviation for later reference• Indication of applicability of goal to Indication of applicability of goal to

permitteepermittee• Method for evaluating progressMethod for evaluating progress

– with location(s), if appropriate• Target for evaluating progressTarget for evaluating progress

– with schedule• Party responsible for evaluating progressParty responsible for evaluating progress

Page 21: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Methods for Assessing Methods for Assessing Progress on the Progress on the

Subwatershed-Wide GoalsSubwatershed-Wide Goals• Mostly accomplished by on-going, long-Mostly accomplished by on-going, long-

term, subwatershed-wide monitoring term, subwatershed-wide monitoring programsprograms– RPO/subwatershed monitoring program– USGS flow monitoring– MDEQ-GLEAS biological monitoring

• May want to augment with additional May want to augment with additional samplingsampling

Page 22: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Methods for Assessing Methods for Assessing Progress - Subwatershed-Progress - Subwatershed-

Wide GoalsWide Goals• TargetsTargets are important. They provide: 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 Targets should be tied to beneficial uses, where appropriateuses, where appropriate

Page 23: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Methods for Assessing Methods for Assessing Progress - Subwatershed-Progress - Subwatershed-

Wide GoalsWide Goals

• Example #1:Example #1: Goal = Minimize upland Goal = Minimize upland soil erosionsoil erosion

• Method of Measuring Progress:Method of Measuring Progress: Training Training of community staffof community staff

• Target:Target: Have all staff trained, by 2002 Have all staff trained, by 2002• Responsible PartyResponsible Party (for data collection): (for data collection):

CommunityCommunity

Page 24: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Methods for Assessing Methods for Assessing Progress - Subwatershed-Progress - Subwatershed-

Wide GoalsWide Goals• Example #2:Example #2: Goal = Protect & restore Goal = Protect & restore

natural featuresnatural features• Methods of Measuring Progress:Methods of Measuring Progress: fish & fish &

benthos monitoringbenthos monitoring• Targets:Targets: improve fish & benthos scores improve fish & benthos scores

from “poor” to “good” at Eight Mile from “poor” to “good” at Eight Mile Road, by 2010; maintain “good” scores Road, by 2010; maintain “good” scores at Grand River Ave.at Grand River Ave.

• Responsible PartyResponsible Party (for data collection): (for data collection): MDEQ-GLEASMDEQ-GLEAS

Page 25: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Reporting on Reporting on Permittee-Specific ActionsPermittee-Specific Actions

• Focus is on community-specific SWPPI Focus is on community-specific SWPPI actionsactions

• Table 2 in the SWPPI templateTable 2 in the SWPPI template– Could also be in narrative form

Page 26: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Reporting on Reporting on Permittee-Specific ActionsPermittee-Specific Actions

Recommended contents of Table 2: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

Page 27: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Reporting on Reporting on Permittee-Specific ActionsPermittee-Specific Actions

Actions committed to by permitteeActions committed to by permittee• Briefly summarize the actionBriefly summarize the action• Direct from the WMPDirect from the WMP

Goal(s) addressed by each actionGoal(s) addressed by each action• Must have at least one action for each goalMust have at least one action for each goal• Try only to list goals that are Try only to list goals that are directlydirectly affected affected

by an actionby an action

Page 28: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Reporting on Reporting on Permittee-Specific ActionsPermittee-Specific Actions

Coverage of “permit-required” activitiesCoverage of “permit-required” activities• Actions in SWPPI template section 6.2.a-e, and Actions in SWPPI template section 6.2.a-e, and

6.3 (or Permit section B.2.a.2)6.3 (or Permit section B.2.a.2)• ““Housekeeping” activitiesHousekeeping” activities

Method of implementation and scheduleMethod of implementation and schedule• Steps for implementing actionSteps for implementing action• Be as specific and quantitative as possibleBe as specific and quantitative as possible

Page 29: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Reporting on Reporting on Permittee-Specific ActionsPermittee-Specific Actions

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

Page 30: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Reporting on Reporting on Permittee-Specific ActionsPermittee-Specific Actions

• Example #1:Example #1: Action = golf Action = golf course/recreation area managementcourse/recreation area management

• Goal addressedGoal addressed: 3U (protect & restore river : 3U (protect & restore river ecosystem for fish & wildlife)ecosystem for fish & wildlife)

• Permit-required activities:Permit-required activities: 6.2.e 6.2.e• Implementation:Implementation: Require Require

training/certification for those applying training/certification for those applying pesticides, fungicides, fertilizers on city pesticides, fungicides, fertilizers on city propertyproperty

• Report progressReport progress: # certified applicators, in : # certified applicators, in annual reportannual report

Page 31: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Reporting on Reporting on Permittee-Specific ActionsPermittee-Specific Actions

• Example #2:Example #2: Action = Encourage low- Action = Encourage low-impact development practicesimpact development practices

• Goals Addressed:Goals Addressed: L1-1 (flow variability); L1-1 (flow variability); L1-2 (nutrient loading); L1-2 (nutrient loading); and othersand others

• Permit-required activities:Permit-required activities: 2.b; 2.e; 3 2.b; 2.e; 3• Implementation:Implementation: Develop standards for Develop standards for

new developments; begin 2new developments; begin 2ndnd quarter, quarter, 20022002

• Progress report:Progress report: Document BMPs and Document BMPs and practice standards, in annual reportpractice standards, in annual report

Page 32: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Methods for Assessing Methods for Assessing ProgressProgress

SummarySummary• Two kinds of progress assessment:Two kinds of progress assessment:

– subwatershed-wide goals• mostly on-going monitoring programs

– permittee-specific actions• mostly reporting on action progress

• Easily summarized in tablesEasily summarized in tables• Asking for detail and forethought, to Asking for detail and forethought, to

minimize ambiguity in defining progress minimize ambiguity in defining progress in years to comein years to come

Page 33: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Inkster SWPPIInkster SWPPI

• Inkster is a one sub-watershed exampleInkster is a one sub-watershed example• This SWPPI follows the generic MDEQ This SWPPI follows the generic MDEQ

SWPPI TemplateSWPPI Template• The IDEP and PEP are combined into the The IDEP and PEP are combined into the

SWPPI (reference Section 2)SWPPI (reference Section 2)• The SWPPI and the WMP will be The SWPPI and the WMP will be

reviewed and revised at the same time reviewed and revised at the same time (reference Section 3)(reference Section 3)

Page 34: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Inkster SWPPIInkster SWPPI

• Section 5 has been utilized by the City Section 5 has been utilized by the City to present their specific programs and to present their specific programs and their unique situationstheir 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

Page 35: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Lower 2 Subwatershed GoalsLower 2 Subwatershed Goals

1.1. Improve water quality in the Rouge River and Improve water quality in the Rouge River and restore impaired usesrestore impaired uses

2.2. Remove sources of pollution that threaten public Remove sources of pollution that threaten public healthhealth

3.3. Educate the public regarding their impact of the Educate the public regarding their impact of the River and the River’s existing and future River and the River’s existing and future potential as a community asset and recreational potential as a community asset and recreational sourcesource

4.4. Improve the water quality of the river to Improve the water quality of the river to increase recreational opportunities and remove increase recreational opportunities and remove fish consumption advisoriesfish consumption advisories

Page 36: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Lower 2 Subwatershed GoalsLower 2 Subwatershed Goals

5.5. Enhance and preserve habitat, especially next to Enhance and preserve habitat, especially next to the river, for fish and wildlife compatible with the river, for fish and wildlife compatible with subwatershed land usessubwatershed land uses

6.6. Minimize the amount of soil erosion and Minimize the amount of soil erosion and sedimentationsedimentation

7.7. Reduce water volumes and velocities in the river Reduce water volumes and velocities in the river during a storm event to minimize band erosion and during a storm event to minimize band erosion and floodingflooding

Page 37: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

City of InskterIN1 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

Page 38: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

City of InksterIN10 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“

Page 39: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Inkster SWPPI Table 1Inkster SWPPI Table 1

Table 1. Goal-Specific Long Term Assessment of Progress in the Lower 2 Subwatershed

# L2 WMP Goals N/A* Methods for Evaluating Progress in

River Endpoint for Evaluation in the

Subwatershed Responsible Party for Evaluating Progress

1 Improve Water Quality in the Rouge River and restore impaired uses

A. Dry and wet weather sampling at Henry Ruff, John Daly, and Beech Daly Roads and other historic L2 sampling locations

No nuisance algae in the Lower 2 Dissolved oxygen meets warmwater fish criteria at all L2 sampling locations by 2015 Dry weather phosphorus less than 0.05 mg/l at all L2 sampling locations by 2015

A. RPO, City

2 Remove sources of pollution that threaten public health

A. Dry and wet weather sampling at Henry Ruff, John Daly, and Beech Daly Roads and other historic L2 sampling locations

Partial body contact criteria for E.Coli met in dry weather at all L2 sampling locations by 2015

A. RPO, City

3 Educate the public regarding their impact on the River and the River’s potential as a community asset

A. Involvement in activities B. Public surveys C. Tracking complaints D. Workshops/meeting attendance E. Other reporting

A.D. Increased in meeting attendance A.D. Increased activity participation B. C. Increased public knowledge of Rouge River and programs offered

A – E. City B. High School

Page 40: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Inkster SWPPI Table 2Inkster SWPPI Table 2

Table 2: Storm Water Pollution Prevention Initiative for Inkster

Action WMP Goals

Addressed

Permit Required Activities

Method of implementation Methods of Reporting (to be documented in SWPPI annual

report)

Approved Illicit Discharge Elimination Plan (IDEP) projects/programs as per current General Permit (in italicized type ) and any additional related projects/programs since the approval of the IDEP.

Locate potential illicit discharges and illicit connections (IDEP testing/study)

1,2 NA Develop Complaint System Review current water sample data Source sampling and visual observation Educate field employees Walk LRR from Henry Ruff to Beach Daly Road to identify additional outfalls by 12/2002

# identified # corrected

Eliminate illicit discharges and connections (IDEP Correction)

1,2 NA On-going removal of known /identified illicit connections. All connections will be eliminated through sewer separation project that will be fully implemented by 12/2005

# identified # corrected

Prioritize illicit discharges

1,2 NA On-going data review Priority list

Page 41: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Multiple SubwatershedsMultiple SubwatershedsSWPPI TemplateSWPPI Template

FARMINGTON HILLS*FARMINGTON HILLS*

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

Page 42: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

IssuesIssues

• Sorting out Sorting out priorities and priorities and relating to relating to overlapping overlapping subwatershed subwatershed goalsgoals

• Identifying any Identifying any exceptions to exceptions to goals/objectivesgoals/objectives

• Summarizing Summarizing measures/short term measures/short term targetstargets

• Linking actions to Linking actions to multiple goalsmultiple goals

Page 43: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Sorting Out Sorting Out Community/Agency Priorities Community/Agency Priorities

-- Overlapping Goals-- Overlapping Goals

• Template for Farmington HillsTemplate for Farmington Hills– Focuses on priorities selected for the Upper

Subwatershed– Describes the basis for the city’s priorities– Outlines the relationship to the other

subwatershed goal/objectives

Page 44: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Identifying Exceptions to Identifying Exceptions to Goals/ObjectivesGoals/Objectives

• Table 1 in Farmington Hills SWPPITable 1 in Farmington Hills SWPPI

Long Term Goals Exceptions* Reasons

Listed 22 Goals of the Upper, Main 1&2 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

Page 45: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Identifying Exceptions to Identifying Exceptions to Goals/ObjectivesGoals/Objectives

• Table 1Table 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

Page 46: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Progress Measures and Progress Measures and Short-Term TargetsShort-Term Targets

• Progress measures described -- with Progress measures described -- with focus on those developed in Upper focus on those developed in Upper Subwatershed Management PlanSubwatershed Management Plan

• Table 2 Table 2 – Goal/Progress Measure– Responsible Party– Short Term Target– Schedule

Page 47: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Progress Measures and Progress Measures and Short-Term TargetsShort-Term Targets

• Table 2Table 2

Goals/Progress

Measures (17)

Entity Responsibl

e

Target

Schedule

Example:

Enhance River Ecosystem

D.O. Levels

RPO or Upper SWAG

Reduce # WQ

Violations

Re-sample previous sites by 2003

Page 48: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Linking Actions to Multiple Linking Actions to Multiple Subwatershed GoalsSubwatershed Goals

• Table 3Table 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

Page 49: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Linking Actions to Multiple Linking Actions to Multiple Subwatershed GoalsSubwatershed Goals

Actions (46)

Goals

RequirementsMethods/Schedule

Methods of Reporting

Table 3

Example:

Staff Training Erosion Control

5U, 4M, 3MD,7M

6(3)

Send staff to training, complete 12-31-02

Number of staff trained each year

Page 50: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Sources of InformationSources of Information

• The three subwatershed plans identify The three subwatershed plans identify goals in priority ordergoals in priority order

• Proposed actions were taken from list Proposed actions were taken from list compiled in the Upper Management Plancompiled in the Upper Management Plan

• Measures proposed were taken from those Measures proposed were taken from those developed in the Upper Management Plandeveloped in the Upper Management Plan

• Short-term targets were developed based Short-term targets were developed based upon the short term objectives in Upper upon the short term objectives in Upper Management PlanManagement Plan

Page 51: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

SummarySummary• The goals of all three subwatershed - The goals of all three subwatershed -

Upper, Main 1-2, and Middle 1 - are Upper, Main 1-2, and Middle 1 - are considered in the SWPPIconsidered in the SWPPI

• At least one action is included in the At least one action is included in the SWPPI for each of the subwatershed SWPPI for each of the subwatershed goals goals

• Actions and measures are linked to Actions and measures are linked to goals and permit requirements are citedgoals and permit requirements are cited

• Methods of reporting progress are Methods of reporting progress are identified along with short-term targetsidentified along with short-term targets

Page 52: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Rural Township Rural Township SWPPI ExampleSWPPI Example

Page 53: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Rural Township:Rural Township:unique attributesunique attributes

• Rural community, limited Rural community, limited jurisdiction/authorityjurisdiction/authority

• Land use primarily low-Land use primarily low-density residential, small density residential, small agriculture, open spaceagriculture, open space

• Permit coverage for entire Permit coverage for entire communitycommunity

• Covers two major Covers two major watersheds: Rouge and watersheds: Rouge and Huron RiversHuron Rivers

• Headwaters of both river Headwaters of both river systemssystems

• Three associated Three associated watershed management watershed management plans: Ford Lake, Flemming plans: Ford Lake, Flemming Creek, Lower 1 RougeCreek, Lower 1 Rouge

Page 54: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Goa

l and

Objectives

Fleming Creek Management Plan

Goals and Objectives

Ford Lake Environmental Quality Improvement Plan

Long Term Goal s

Lower One Rouge River Subwatershed Management Plan

Goal (FC1)

Protect water quality and natural features in the Fleming Creek Watershed.

Goal 1 (FL1)

Attain water quality in Ford Lake that meets full body contact standards at all times of the year.

Goal 1 (L1R1)

Reduce flow variability

Objective A (FCA)

Protect surface water quality by protecting the floodplain, banks, steep slopes, and functional wetlands.

Goal 2 (FL2)

Manage fisheries to provide fish species that are safe for human consumption and that are closer to their natural range of diversity and levels of population.

Goal 2 (L1R2)

Reduce nutrient loading

Objectiv

e B

(FCB)

Protect drinking water by preserving groundwater recharge areas.

Goal 3 (FL3)

Restore the integrity of the Ford Lake ecosystem to a level that maintains wildlife species closer to their natural ranges of habitat and variation, and provides enjoyment for residents.

Goal 3 (L1R3)

Reduce soil erosion and sedimentation

Objective C (FCC)

Minimize flooding and avoid costs of replacing natural flood control systems by preserving wetlands, the creek banks and the 100-year floodplain.

Objective A (FLA)

Monitor toxic waste inputs and monitor clean up operations.

Goal 4 (L1R4)

Protect and mitigate the loss of natural features

Objective D (FCD)

Control storm water runoff by preserving the storm water management functions of the landscape such as pervious soils and areas of trees and shrubs. Objective B (FLB)

Raise awareness and enjoyment of water resources in the subwatershed.

Goal 5 (L1R5)

Increase opportunities for passive and active recreation

Objective E (FCE)

Minimize soil erosion and develop and implement effective methods to prevent sediments and pollutants from entering the creek.

Objective C (FLC)

Preserve open space within the subwatershed.

Goal 6 (L1R6)

Increase water quality, water quantity, and biological monitoring in the subwatershed

Objectiv

e F

(FCF)

Maintain the presence of wildlife by preserving wildlife habitat and continuous undisturbed corridors, particularly along the creek. Objective D (FLD)

Reduce garbage in Ford Lake and Huron River.

Goal 7 (L1R7)

Increase public understanding of their role in protecting water quality

Objective G (FCG)

Retain additional runoff on site, utilizing infiltration where soil conditions permit. Use retained water on site where practical.

Objective E (FLE)

Reduce quantity of nutrients, especially phosphorus, entering the water in order to reduce algae blooms to non-nuisance levels.

Goal 8 (L1R8)

Integrate storm water management in planning process

Objective F (FLF)

Preserve shoreline and control erosion from banks.

Goal 9 (L1R9)

Establish financial and institutional arrangements for the fulfillment of the management plan

Objective G (FLG)

Help ensure enforcement of rules to control sedimentation from construction activities.

Goal 10 (L1R10)

Enforce action plans and increase accountability for storm water management

Rural Rural Township:Township:

Table 1:Table 1:

addressing multiplewatershed management plan goals and objectives (28)

Page 55: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Rural Township:Rural Township:Section 5Section 5:: community-specificcommunity-specific

goals and prioritiesgoals and priorities

• Protect existing wetlandsProtect existing wetlands• Control the increase of impervious Control the increase of impervious

surfacessurfaces• Manage and direct growth while Manage and direct growth while

protecting the environmentprotecting the environment• Prevent excessive phosphorus Prevent excessive phosphorus

loadsloads• Protect downstream recreational Protect downstream recreational

uses by controlling sources of uses by controlling sources of bacteriabacteria

• Encourage the control of soil Encourage the control of soil erosion and sedimentationerosion and sedimentation

Page 56: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Rural Township:Rural Township:Table 2:Table 2: how to measure how to measure

progress?progress?• Headwaters currently show good Headwaters currently show good

water quality and habitatwater quality and habitat• Progress = minimize degradation Progress = minimize degradation

of water quality and habitatof water quality and habitat• Targets based on subwatershed Targets based on subwatershed

goalsgoals• Work with watershed groups to Work with watershed groups to

use data downstream to use data downstream to determine upstream changesdetermine upstream changes

• Use biology (macroinvertebrates, Use biology (macroinvertebrates, amphibians, fish) as indicators of amphibians, fish) as indicators of long-term stream health and long-term stream health and water quality changeswater quality changes

Page 57: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Rural Township:Rural Township:Table 2:Table 2: how to measure how to measure

progress?progress?

Protect and mitigate the loss of natural features (L1R4, FC1, FCA, FCB, FCC, FCD, FCF, FL2, FL3, FLC)

A. Evaluate frog and toad population trends in Rouge.

B. Biological monitoring (fish, macroinvertebrates) in Huron and Rouge.

• Track and report frog and toad populations to detect trends in decline or increase over time and relate to land use

, . changes habitat protection in Rouge • , 51 “ ” For fisheries maintain GLEAS scores of excellent at

, “ ” ., Fellows Creek good at Sheldon and Van Born Rds and attain scores o “ ” ., 2015. f at least good at Denton Rd by

. Maintain sensitive fish communities • , For macroinvertebrates increase monitoring sites to

2005 51 improve database by and attain GLEAS scores of “ ” . 2015 . at least fair at Sheldon Rd by in Rouge

.A FOTR

.B / ,MDEQ GLEAS / HRWC FOTR

Volunteers

Related WMP Goals/objectives

Methods for evaluating progressSubwatershed target Responsible Party

Example:

Page 58: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Rural Township:Rural Township:Table 3:Table 3: Action TableAction Table

Continue to enforce Wetlands Ordinance

L1R1,2,3,4,8,10; FC1,FCA, FCB, FCC, FCD, FCF, FCG; FL2, FL3, FLC, FLE, FLF

6.3 Continue regular meetings of the Superior Township Wetland Board to review wetland permit applications; Board meets quarterly.

Provide copies of wetland board meeting minutes.

Complete Wetland Assessment for Township

L1R 4, 5, 8; FC1,FCA, FCB, FCC, FCD, FCF, FCG; FL2, FL3, FLC, FLE, FLF

6.3 Work with Rouge Program Office and wetland consultant to complete the Rapid Wetland Assessment that was done for the Rouge River watershed portion of the Township for the Huron portion of the Township; complete assessment by 4th quarter, 2003.

Provide copy of completed wetland assessment, associated report or maps.

ActionGoal(s) addressed

Permit Required Activities

Method of implementation and schedule Methods of reporting

Examples:

* Chose to combine the IDEP and PEP into the SWPPI for one comprehensive plan.

Page 59: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Rural Township:Rural Township:Table 3:Table 3: emphasis of our action emphasis of our action

itemsitems

1. Public education 1. Public education and stewardshipand stewardship– Watershed Newsletter– Wetland education– Septic system

maintenance– Educating developers– Educating staff, board

and commission members– working with local creek

groups and land trusts

Page 60: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Rural Township:Rural Township: Table 3:Table 3: emphasis of our action emphasis of our action

itemsitems2. Partnerships and inter-agency 2. Partnerships and inter-agency

communicationcommunication– 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

Page 61: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Rural Township:Rural Township: Table 3:Table 3: emphasis of our action emphasis of our action

itemsitems3. Institutionalizing storm water 3. Institutionalizing storm water

protection:protection:– Natural features inventory

and assessments– Wetland ordinance and

Wetland Board– Growth Management Plan– Low-impact development

through Planning Commission

– Additional part-time staff

Page 62: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Rural Township:Rural Township: Table 3:Table 3: emphasis of our action emphasis of our action

itemsitems4. Looking at community 4. Looking at community

facilitiesfacilities– Participate in Drain

Commissioner’s Community Partners for Clean Streams

– Construction of wetland detention system in Township park adjacent to creek, to address flooding, aesthetics and water quality problems

Page 63: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Rural Township SummaryRural Township Summary

• Important to identify Important to identify community priorities based on community priorities based on various management plans, various management plans, across two different across two different watershedswatersheds

• All 28 goals/objectives have All 28 goals/objectives have been addressed through at been addressed through at least one actionleast one action

• Advantage of whole community Advantage of whole community coverage under one permitcoverage under one permit

• Actions focus on protectionActions focus on protection• Important to recognize and Important to recognize and

utilize partnershipsutilize partnerships

Page 64: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Canton CommunityCanton CommunitySWPPI ExampleSWPPI Example

Page 65: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Canton Community:Canton Community:Unique AttributesUnique Attributes

• Developing Developing communitycommunity

• Located in two Rouge Located in two Rouge subwatershedssubwatersheds

• Large residential Large residential populationpopulation

• Emphasis on both Emphasis on both protection and protection and restorationrestoration

• Strong public Strong public education emphasiseducation emphasis

Page 66: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Canton CommunityCanton CommunitySWPPI FocusSWPPI Focus

• Integrated IDEP and PEP Integrated IDEP and PEP into SWPPIinto SWPPI

• Storm water management Storm water management in new developmentsin new developments

• Public educationPublic education• Recreational opportunitiesRecreational opportunities• Detention pond retrofitsDetention pond retrofits• PartnershipsPartnerships

Page 67: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Storm Water ManagementStorm Water Management

• Additional StaffAdditional Staff– Public Works Foreman

• Storm Water Storm Water ManagementManagement– Storm water ordinance– Street sweeping– Catch basin cleaning– Minor detention pond

maintenance

Page 68: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Public EducationPublic Education

• Homeowners’ Homeowners’ association workshopsassociation workshops

• River DayRiver Day• Household Hazardous Household Hazardous

Waste Collection DayWaste Collection Day• Liberty FestLiberty Fest• Neighborhood clean upNeighborhood clean up

Page 69: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Public EducationPublic Education

• FOCUS newsletterFOCUS newsletter• WebsiteWebsite• Cable televisionCable television• Tip cardsTip cards• School demonstrationsSchool demonstrations

Page 70: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Recreational OpportunitiesRecreational Opportunities

• Community pathway Community pathway systemsystem

• Park enhancementsPark enhancements

Page 71: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Detention Pond RetrofitsDetention Pond Retrofits

• Demonstration grant for 4 Demonstration grant for 4 pondsponds

• Community pond retrofit Community pond retrofit combined with educational combined with educational signagesignage

• Residential ponds/work with Residential ponds/work with homeowners’ associationshomeowners’ associations

• Utilize storm water fundsUtilize storm water funds

Page 72: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Building PartnershipsBuilding Partnerships

• Subwatershed PartnershipsSubwatershed Partnerships– Continue participation in subwatershed groups to

share information and challenges– Identify activities that can be utilized across

community boundaries• Wayne CountyWayne County

– Soil erosion inspection and compliance– Septic system inspection and compliance– Illicit discharge inspection– Public education assistance

Page 73: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

Canton Community Summary:Canton Community Summary:why is this important?why is this important?

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

Page 74: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

SWPPI Submittal ProcessSWPPI Submittal Process

1.1. Develop draft SWPPI in conjunction Develop draft SWPPI in conjunction with any other “responsible parties” with any other “responsible parties” (internal – not submitted to MDEQ)(internal – not submitted to MDEQ)

2.2. Obtain commitment/sign-off from other Obtain commitment/sign-off from other “responsible parties” (internal – not “responsible parties” (internal – not submitted to MDEQ)submitted to MDEQ)

Page 75: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

SWPPI Submittal Process SWPPI Submittal Process (cont. . .)(cont. . .)

3.3. Review with Council/Board as appropriate and Review with Council/Board as appropriate and obtain a resolution adopting the SWPPI, if obtain a resolution adopting the SWPPI, if necessary (The MDEQ strongly recommends the necessary (The MDEQ strongly recommends the adoption of a resolution)adoption of a resolution)

4.4. Transmit SWPPI to MDEQ with a signature block in Transmit SWPPI to MDEQ with a signature block in the SWPPI signed by an appropriate Permittee the SWPPI signed by an appropriate Permittee RepresentativeRepresentative (Person with the authority to make (Person with the authority to make financial and other commitments necessary to financial and other commitments necessary to reduce the discharge of pollutants to the reduce the discharge of pollutants to the maximum extent practicable and to be consistent maximum extent practicable and to be consistent with the watershed management plan)with the watershed management plan)

Page 76: How to Develop a SWPPI (Storm Water Pollution Prevention Initiative) June 8, 2001

SWPPI Review ChecklistSWPPI Review Checklist

• Draft checklist to be used by MDEQ to Draft checklist to be used by MDEQ to review SWPPIs (copy in your packet)review SWPPIs (copy in your packet)

• Generally follows permit requirementsGenerally follows permit requirements• Ensure there is at least one action for each Ensure there is at least one action for each

applicable goal for applicable goal for allall subwatershed listed subwatershed listed in COCin COC

• Check to ensure all IDEP and PEP approved Check to ensure all IDEP and PEP approved activities have been transferred, if activities have been transferred, if applicableapplicable

• Check for any disagreements with WMPCheck for any disagreements with WMP