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

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

2. 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

3. 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

7. 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

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

9. 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

10. 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

11. 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)

12. 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

14. 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

15. Permittee Housekeeping/ Pollution Prevention • Purpose to reduce the discharge of pollutants to maximum extent practicable on permittees own propertiesand activities- municipal operations • 5 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

16. 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

17. 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

18. 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 optimizeallocation of resources • Need to justify efforts to officials & public • Want to apply lessons learned to other locations

19. 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

20. 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

21. 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

22. 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

23. 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

24. 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

25. Reporting on Permittee-Specific Actions • Focus is on community-specific SWPPI actions • Table 2 in the SWPPI template • Could also be in narrative form

26. 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

27. 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

28. 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

29. Reporting on Permittee-Specific Actions Reporting or measuring progress • Be as specific and quantitative as possible • Usually reported in Annual Report

30. 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

31. 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

32. 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

33. 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)

34. 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

35. 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 River’s 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 Lower 2 Subwatershed Goals

36. 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 Lower 2 Subwatershed Goals

37. 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

38. 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“

39. Inkster SWPPI Table 1

40. Inkster SWPPI Table 2

41. 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

42. 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 Issues

43. Sorting Out Community/Agency Priorities -- Overlapping Goals • Template 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

44. Identifying Exceptions to Goals/Objectives • Table 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

45. 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

46. 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

47. 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

48. 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

49. 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)

50. 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