lessons learned from past ms4 audits 1/3/20161 lessons learned from past ms4 audits
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Lessons Learned from Past MS4 Audits
04/21/23 1
Lessons Learned from Past MS4 Audits
Lessons Learned from Past MS4 Audits
Overview of MS4 audits in California
• About 40 audits conducted of over 120 MS4s
• Primarily Phase I MS4s, but also included several Phase II MS4s
• Audits began in August 2001
• Copies of audit reports are available at:
http://www.epa.gov/region09/water/npdes/ms4audits.html
Lessons Learned from Past MS4 Audits
Municipal Stormwater Program Findings
• Strong Public Education Programs• Refining approach to construction/new
development• Beginning to evaluate program effectiveness• Developing innovative reporting techniques• Measurable goals are often lacking• Maintenance programs are generally well-
established• Programs need to address pollutants of concern
Lessons Learned from Past MS4 Audits Many MS4s have strong public education programs
Lessons Learned from Past MS4 Audits
MS4s are refining their approach to construction/new development
• Developing more specific standards• Conducting more inspections• Providing technical guidance• Training and education
Lessons Learned from Past MS4 Audits
MS4s are Beginning to Evaluate Program Effectiveness
• Provides guidance and program focus
• Helps target resources
• Ensures continued program support
• Facilitates the iterative approach
• Difficulty in conducting water quality monitoring of wet weather events
Lessons Learned from Past MS4 Audits
MS4s are developing innovative reporting techniques
• Web-based reporting tools
• Standard annual reports (Phase II)
• Using more graphical examples
Lessons Learned from Past MS4 Audits
Example: Tracking inspections at NOI facilities
Lessons Learned from Past MS4 Audits
Example: Photos showing structural controls (Fairfax County, VA)
Lessons Learned from Past MS4 Audits
Example: Evaluating construction inspections via GIS (King Co., WA)Example: Evaluating construction inspections via GIS (King Co., WA)
Lessons Learned from Past MS4 Audits Example: King Co., WA table for tracking maintenance activities
Lessons Learned from Past MS4 Audits
MS4 Assessment Report
Includes:
• Audit Approach
• Special projects
• Analysis of findings
• Lessons learned
• Recommendations
Lessons Learned from Past MS4 Audits
Common program deficiencies
Lessons Learned from Past MS4 Audits
Lessons Learned
• MS4 Permit Language Greatly Affects SWMP Development and ComplianceMore specific permit language often resulted
in more specific SWMPsE.g., Los Angeles, San Diego
Lessons Learned from Past MS4 Audits
Lessons Learned
• Need for Clear Guidance and Direction from the Water BoardsEven detailed permits need additional
guidanceBoards are working with MS4s to issue
guidance (e.g., new development requirements)
Lessons Learned from Past MS4 Audits
Lessons Learned
• Communication Provides Many BenefitsAudit process builds stronger relationship
between MS4 and StateDirect and immediate feedback on the MS4’s
program
Lessons Learned from Past MS4 Audits
Lessons Learned
• A Well-Written SWMP Plan is Critical for ComplianceSome permits did not specifically require a
SWMP, or a single generic SWMP was developed for all co-permittees
An MS4-specific plan is needed to describe implementation procedures, BMPs, schedules, responsibilities, and goals
Lessons Learned from Past MS4 Audits
Lessons Learned
• Measurable Goals Should Be Outcome-BasedGoals should be based on the desired
outcomes of the stormwater programGoals should be developed on the basis of
the pollutant of concern, sources of the pollutant, behaviors associated with the sources, and the indicator most appropriate to demonstrate a change in those behaviors
Lessons Learned from Past MS4 Audits
Lessons Learned
• Annual Reports are not Effective Indicators of Program ComplianceEspecially where MS4 permits lack specificity
in annual reporting requirementsMS4 reluctant to voluntarily report non-
compliance
Lessons Learned from Past MS4 Audits
Summary
• All Phase I MS4 permit programs in California have been audited
• Audits have resulted in increased compliance and attention to MS4 program
• MS4 permit reissuance building on audit results
• Questions?• John Kosco, [email protected]