Successful stormwater management often involves committed actions from across multiple community departments like water, public works, and roads. Recent approaches to stormwater management involve developing multi-departmental teams focused on specific activities that collectively accomplish a set of established objectives. Conceivable objectives to consider when developing an MS4 program include retaining natural features of drainage systems, improving stormwater quality, reaping community and societal benefits, and finding ways to sustainably finance a program in the long term.
The requirements for the contents of a written stormwater management program (SWMP) vary from MS4 permit to MS4 permit. But, in general, the SWMP is intended to be a living document that reflects the most current practices and procedures you are implementing for each element of your municipal stormwater program. SWMPs should also describe programmatic objectives and measurable goals to evaluate progress, as required by your MS4 permit.
Governmental coordination
Coordination among the municipal agencies and departments that control stormwater-related issues is fundamental to the success of a stormwater management program. You should consider designating a "lead agency" within the community to facilitate the coordination of the various departments’ stormwater pollution control activities. This approach creates administrative and financial efficiencies, leading to more opportunities for positive environmental outcomes.
After establishing productive coordination among internal departments, look for opportunities to coordinate and collaborate with external entities. For example, several small MS4s could partner together to meet shared goals. Contact other stormwater programs in neighboring communities to set the stage for such opportunities. It can also be advantageous to involve your state environmental regulatory agency or EPA when exploring opportunities to coordinate stormwater management efforts with neighboring communities.
Stormwater Management Program Objectives
Programs often seek to retain natural features of drainage systems by reducing onsite stormwater quantity, which also improves stormwater quality. This approach views stormwater as a resource that can be used to:
- Recharge groundwater supplies.
- Supply fresh water to surface waters.
- Increase recreational opportunities, including hunting, swimming, fishing, and boating.
- In some cases, augment drinking water supplies.
Other important objectives might focus on community and societal benefits—such as changing detrimental behaviors, increasing public knowledge, and supporting the funding of stormwater programs—or finding ways to sustainably finance the program and think about stormwater management in a more proactive way through long-term planning.
Legal authority and comprehensive planning
Communities can use the legal authority of new and existing programs and ordinances, zoning rules, and the site plan review process to ensure that new development and redevelopment plans address water quality concerns. Communities must demonstrate they can operate under the legal authority to implement and enforce most parts of their stormwater management programs, as described in EPA’s NPDES regulations at 40 CFR 122.26(d)(2)(i) and 40 CFR 122.34(b)(3)(i)(B), (b)(4)(i)(A), and (b)(5)(i)(B).
Consider developing a comprehensive stormwater plan that incorporates both location-specific and watershed-wide goals for stormwater management (see Watershed-Based Modeling for more information). Conduct both long- and short-term planning to prevent or mitigate the impacts of cumulative loadings throughout the watershed. Assessing the impacts of cumulative loadings using indicators, trend data, and other means is essential (see Stormwater Monitoring).
Addressing stormwater impacts from new development and redevelopment is a required element of all municipal stormwater permits. Urbanization can modify the natural water cycle by increasing runoff and associated pollutant loadings. Because development almost always increases impervious surface area, new development will, in most cases, lead to increased discharges of pollutants from MS4s. Stormwater discharges can also physically alter natural waterways. Reviewing and considering existing ordinances, policies, and programs related to development is a good way to assess how you could incorporate stormwater management into things the community is already doing and identify new actions to complete.
Many jurisdictions have ongoing programs and activities that relate to stormwater quality. Review existing programs, state and local codes, and local ordinances to determine if requirements should be revised or strengthened. For example, you might find that codes and ordinances need to be updated to comply with permit requirements. When no program or ordinance exists to address a specific stormwater issue, one should be developed. Examples include programs that address flooding, combined sewer overflows, infiltration and inflow (a contributor to sanitary sewer overflows), illicit discharges, and erosion and sediment control. Consider how to link, expand, or otherwise augment these programs to further enhance stormwater quality and achieve other measurable environmental benefits as efficiently as possible with the resources available.
The site plan review process can help you ensure that new development or redevelopment projects implement appropriate stormwater codes and ordinances. The site plan review process is typically the final stage of municipal review that occurs before development. This is a critical window of opportunity to integrate stormwater planning, as site plan review is often the only regulatory process of this type that a land developer must go through if the land use is compatible with current zoning requirements. Your municipality can implement water-related codes and ordinances (e.g., erosion and sediment controls) for stormwater management during site planning and verify implementation through the review process.
In some cases, you might have opportunities to integrate stormwater considerations earlier in the planning process. This is particularly true if your community has engaged in comprehensive land use planning, which typically involves setting land use goals and objectives for various parts of a municipality within a planning document (typically called a land use plan, master plan, or comprehensive zoning plan) or within a planning map.
In many instances, land has already been zoned for a certain category of land use—possibly long ago. Where a planned land use differs from the existing zoning, a developer might request a change to the zoning category. This process is referred to as rezoning, and it is one of the most important decision-making functions of local government officials. Rezoning presents opportunities for all parties, as a municipality can require land developers to make public facility improvements and other infrastructure improvements (such as implementing stormwater controls) in exchange for the desired rezoning.
Specific planned land use designations are usually identified through zoning categories on a parcel-specific basis. These categories may be limited to only one possible land use or may provide for a range of land use opportunities that depend on a series of policy-based criteria. A common example of land use decisions is that a developer who provides low- or moderately priced housing units as part of their development might be allowed to create a higher residential density than would otherwise be allowed. Just as these types of land use decisions must be made early in the development process, so should provisions for stormwater quality management planning.
Funding and staffing
To develop and implement an effective stormwater management program, you will need adequate resources for personnel and equipment. Therefore, you should identify the resources that the municipality is committing to implement each program component. MS4 permits typically require the permittee to report the funding and staffing used to implement the program and to maintain both to avoid hampering program implementation. You should clearly establish program staffing position descriptions, develop program cost estimates (budget), and identify funding sources for administrative and field personnel to implement the program. Try to accurately project your funding needs and sources to allow the longest possible lead time for arranging program financing. If you propose phased implementation, provide a schedule indicating changes in staffing and equipment. See the Funding section of this resource for detailed discussions of various aspects of program funding.
Public education and participation
Within your MS4 permit you are required to provide public education and opportunities for public participation in all aspects of your program, and you must define your goals for each. Generally, you should involve the public as early as possible when considering major technical and policy issues during the development and implementation phases of your program. Include program element milestones for public participation, particularly in the program development phase. In some cases, public involvement may simply amount to receiving information about your program; in other cases, it could involve requesting volunteers to help with activities such as stream cleanups or storm drain stenciling. Requesting and incorporating public comments on critical stormwater program documents (SWMP, ordinances, watershed plans, total maximum daily load plans, etc.) is also a great way to encourage public participation.
Try to minimize conflict and confusion by including a schedule for initial public contact, education, and milestones for involvement throughout the development and implementation phases. Public education programs should target specific audiences, including those regulated or affected by the program, such as developers, building contractors, and industrial operators, and those that can help implement the program, such as volunteers and citizens.
Selection of best management practices
Phase II MS4 programs are required to propose a stormwater management program that addresses activities and schedules for implementing each of the minimum measures identified in 40 CFR 122.34. You should emphasize program components that fit with the characteristics of the community (e.g., population density, land use and age of communities, soil type, and topography), the MS4, and the receiving waters. You can set implementation priorities to target pollutant sources from specific land uses or to target problems resulting from land use activities in a particular area.
You should describe the proposed structural and source control measures to reduce pollutants from commercial and residential areas. Common examples of potentially major sources of pollutants include commercial and retail parking lots, gasoline/service stations, and establishments with drive-through windows and other high-intensity vehicular uses. You will want to select controls that best address the interaction between pollutant sources and physical attributes—such as existing and planned land uses, soil types, and topography—from your MS4 into your receiving waters.
Structural controls
Structural controls include permeable pavements, infiltration practices, detention and retention basins, vegetated swales, screens and filters, channel stabilization, and land conservation. Clean Water Act Section 404 permits might be required for certain types of structural controls (e.g., projects that discharge dredged or fill materials to waters of the United States, including wetlands). Also, some projects might require state permits that address water quality and quantity issues.
MS4 permits require the use of state or federal guidelines and performance standards for identifying and implementing specific structural controls for a construction site and post-construction minimum measures. Your program should describe the criteria you will use to establish that a particular structural control is warranted and the circumstances that will require the control. Discuss new structural controls and proposed retrofits separately because the opportunities for selecting controls are often quite different depending on various restrictions.
The first step in implementing control structures in your community is to evaluate existing structural controls as well as municipally owned sites and rights-of-way where new controls can be installed. These are commonly referred to as hard assets and would be catalogued within your Asset Management Program (AMP). An asset inventory will allow you to develop a better picture of the capacity to reduce pollutants of current and potential stormwater controls and will facilitate both long- and short-term stormwater master planning.
You could also follow a set of pre-established priorities for selecting, siting, and installing structural controls and implementing source control measures during the development process. EPA and the Center for Watershed Protection provided guidance in the form of a "Manual Builder" for this purpose. This tool is available on the Stormwater Manager’s Resource Center website. The process should begin at the initial planning and zoning stages and continue throughout the development and redevelopment stages.
Source controls
Like any type of pollution, stormwater pollution is most effectively controlled directly at the source. This means implementing practices and strategies to ensure that pollutants are properly stored and managed such that they can’t pollute stormwater, or never come into contact with it in the first place. At construction sites, this means properly stabilizing soils and implementing temporary best management practices to keep sediment on site. At municipal yards, it means ensuring that oils, fuels, chemicals, and construction materials are properly covered and contained from stormwater. Source controls also include information-based strategies such as pollution prevention and good housekeeping training or public education and outreach about how to prevent stormwater pollution.
Consider the following questions when developing implementation priorities:
- What are the sources of stormwater pollution in the community?
- What types of best management practices would be best at treating/eliminating those pollutant sources?
- What can be done on municipally owned land and facilities versus privately owned land and facilities?
- What is the quality of the receiving water(s)? Are there any impairments or total maximum daily loads?
Certain structural control measures might not be possible to implement in previously developed areas due to land unavailability. Examples include:
- First flush diversion systems
- Detention/infiltration basins
- Retention basins
- Extended detention basins
- Infiltration trenches
- Porous pavement
- Grass swales
- Swirl concentrators
You could also consider the following source controls, especially when land area for stormwater controls is limited or unavailable:
- Erosion controls
- Stream bank management techniques
- Street cleaning operations
- Vegetation/lawn maintenance controls
- Debris removal
- Road salt application management
- Public outreach, education, and awareness
Operation and maintenance
Maintenance plays a vital role in ensuring the proper operation of both structural and source controls. For example, reducing the frequency of inspections and cleanout of a structure may initially reduce program costs, but it can diminish the effectiveness of the stormwater control. This creates the need for additional controls and results in deteriorated water quality, which has a cost associated with it. In addition, the perception that a given stormwater control does not work (even though the reason is lack of maintenance) can be damaging as a fledgling program seeks to establish its support base.
The section of your stormwater management program that describes your management practices should also describe activities and schedules for regularly maintaining structural controls and infrastructure (e.g., removing sediment from retention ponds every five years, cleaning catch basins annually, removing litter from channels twice a year), consistent with permit requirements. You must also analyze data to optimize the effectiveness of your maintenance resources and manage costs.
Regularly scheduled maintenance might not be appropriate at many sites; instead, you can conduct periodic inspections to determine when maintenance is necessary. If you base maintenance on the inspection results, or if you schedule maintenance infrequently, you should provide an inspection schedule and identify the municipal department(s) responsible for inspection. Because maintenance issues are critical to successful program implementation, consider maintenance throughout the term of your permit.
Maintenance Tracking Tips
You can use maintenance logs to track activities and develop a matrix of tasks—such as inspection, repair, replacement, and cleanout—on a timeline. Gannt charts or other critical path analyses are readily available to help you organize a maintenance program and schedule.
Resources
The additional resources below provide guidance on how to articulate and establish objectives for your stormwater management program, as well as how to successfully administer and manage it.
| Article Description | Categories | categories_hfilter |
|---|---|---|
Stormwater Manager’s Resource CenterAuthor: Sustainable Communities online | Developed/Updated on Date: 2020 Web Link: https://www.sustainable.org/environment/water/319-stormwater-managers-resource-center-smrc The Stormwater Manager’s Resource Center (SMRC) is designed specifically for stormwater practitioners, local government officials, and others who need technical assistance on stormwater management issues. It is created and maintained by the Center for Watershed Protection. | Program Goals and Management: Developing a Program, Public Education and Outreach, Public Participation | developing-a-program public-education-and-outreach public-participation |
Quick Resource Guide to the MS4 ProgramAuthor: Southwestern Pennsylvania Commission Water Resource Center | Developed/Updated on Date: June 2016 This guide was written for municipalities that own and operate an MS4. The guide begins with the history and background of MS4s and regulations. Then it provides an overview of the six minimum control measures (MCMs) of the National Pollutant Discharge Elimination System MS4 permit and their associated best management practices (BMPs). Examples provided of BMPs are not meant to be the only available solutions—there are many other BMPs. | Good Housekeeping in Municipal Operations, Illicit Discharge Detection and Elimination, Management of Construction Site Runoff, Management of Post-Construction Site Runoff, Program Goals and Management: Developing a Program, Program Goals and Management: Vision and Goals, Public Education and Outreach, Public Participation | good-housekeeping-in-municipal-operations illicit-discharge-detection-and-elimination management-of-construction-site-runoff management-of-post-construction-site-runoff developing-a-program vision-and-goals public-education-and-outreach public-participation |
New Jersey Stormwater Best Management Practices ManualAuthor: New Jersey Department of Environmental Protection Division of Watershed Management | Developed/Updated on Date: April 2004, Last Revised November 2018 Web Link: https://www.njstormwater.org/bmp_manual2.htm The New Jersey Stormwater Best Management Practices Manual (BMP manual) was developed to provide guidance to address the standards in the Stormwater Management Rules, N.J.A.C. 7:8 and provides examples of ways to meet the standards. The methods referenced in the BMP manual are one way of achieving the standards. | Management of Post-Construction Site Runoff, Operations: Green Infrastructure, Program Goals and Management: Developing a Program, Program Goals and Management: Vision and Goals | management-of-post-construction-site-runoff green-infrastructure developing-a-program vision-and-goals |
Minnesota Stormwater ManualAuthor: Minnesota Pollution Control Agency | Developed/Updated on Date: October 2019 Web Link: https://stormwater.pca.state.mn.us/index.php/Main_Page Throughout the production of the Manual, one singular goal was kept in mind—to produce a useful product that helps the everyday user better manage stormwater. The purpose, goal, vision, and tenets were developed by the original Stormwater Design Team. Although stormwater management to control the pollution of receiving waters has been around in earnest for over 30 years in Minnesota, the advent of many new programs means that guidance is needed more than ever. Such programs as the NPDES (National Pollutant Discharge Elimination System) Phase I and II program, the TMDL (Total Maximum Daily Load) program, and strong runoff control programs at the local and watershed levels have all contributed to the need for this information to be compiled in a comprehensive, technically sound document. The directive the Manual Sub-Committee received from the SSC was to produce a document that could be used as a single source to guide stormwater managers through the maze of regulations, best management practices (BMPs) designs, models/techniques, and terminology that constitute good stormwater management. It does not address the requirements of other non-stormwater-related regulatory programs that can have an effect on stormwater. Related to this was the charge to produce a manual that does not duplicate the many good sources of information already available. Because Minnesota is fortunate enough to have had many additional tools created over the years, the Manual will often forego detailed explanation of a particular element and send the user directly to another resource via electronic linkage or cited reference. These linked resources provide information that Minnesota stormwater managers can put to use in conjunction with this Minnesota Stormwater Manual. The Manual is intended to be flexible, easily updated, and responsive to the needs of the Minnesota stormwater community. | Good Housekeeping in Municipal Operations, Illicit Discharge Detection and Elimination, Management of Construction Site Runoff, Management of Post-Construction Site Runoff, Program Goals and Management: Developing a Program, Public Education and Outreach, Public Participation | good-housekeeping-in-municipal-operations illicit-discharge-detection-and-elimination management-of-construction-site-runoff management-of-post-construction-site-runoff developing-a-program public-education-and-outreach public-participation |
Measurable Goals Guidance for Phase II Small MS4sAuthor: U.S. EPA | Developed/Updated on Date: Not dated Web Link: https://www3.epa.gov/npdes/pubs/measurablegoals.pdf According to the Stormwater Phase II Rule, small MS4 owners/operators must reduce pollutants in stormwater to the maximum extent practicable (MEP) to protect water quality. The regulations specify that compliance with the MEP requirement can be attained by developing a stormwater management plan that addresses the six minimum control measures described in the stormwater regulations. These six minimum measures are described in detail in a series of fact sheets developed by EPA. One component of the stormwater management program is to select measurable goals to evaluate the effectiveness of individual control measures and the stormwater management program as a whole. This guidance is designed to assist small MS4 operators to comply with the measurable goals stormwater permitting requirements. The guidance presents an approach for MS4 operators to develop measurable goals as part of their stormwater management plan. This guidance is divided into five main parts: | Communication and Outreach: Outreach Campaigns, Good Housekeeping in Municipal Operations, Illicit Discharge Detection and Elimination, Management of Construction Site Runoff, Management of Post-Construction Site Runoff, Program Goals and Management: Developing a Program, Program Goals and Management: Vision and Goals, Public Education and Outreach, Public Participation | outreach-campaigns good-housekeeping-in-municipal-operations illicit-discharge-detection-and-elimination management-of-construction-site-runoff management-of-post-construction-site-runoff developing-a-program vision-and-goals public-education-and-outreach public-participation |
Evolution of Stormwater Permitting and Program Implementation ApproachesAuthor: U.S. EPA | Developed/Updated on Date: May 17, 2018 In December 2017, EPA Region 9, in partnership with the State of California and EPA Headquarters, convened a small group of stormwater professionals from across the country for a workshop designed to address the need for an overall evaluation of the MS4 program that focused on improving program implementation and MS4 permitting practices and approaches. The workshop—titled Improving Stormwater Permitting and Program Implementation Approaches—engaged 29 national experts from EPA, state Clean Water Act permitting agencies, local stormwater programs, national associations, consulting firms, and nonprofit organizations in facilitated discussions to identify tangible ways to enhance permit efficiency and effectiveness to help build state and local program capacity. Sessions focused on stormwater program implementation requirements in permits, including minimum control measures (MCMs), and water quality-based control requirements. A follow-on workshop in March 2018 assessed stormwater program monitoring, evaluation, tracking, and reporting provisions. This report aims to provide a synthesis of participant ideas and contributions along with other existing research to identify the most impactful opportunities for strengthening MS4 permits and program implementation. The document is organized by workshop session and includes an overview of the discussion, specific actions, case studies, summaries of known efforts related to the recommendations, and some indication of commitment by groups to make progress related to a given recommendation. | Program Goals and Management: Developing a Program, Program Goals and Management: Vision and Goals | developing-a-program vision-and-goals |
City of Waynesboro, Virginia, Virginia Stormwater Management Program Municipal Separate Storm Sewer System (MS4) Program Plan 2018Author: City of Waynesboro, VA | Developed/Updated on Date: 2018 Web Link: https://www.waynesboro.va.us/DocumentCenter/View/7176/Permit-Cycle-2-Stormwater-Program-Plan The purpose of this document is to supplement Waynesboro’s General Permit Registration Statement and to outline the City’s MS4 Program to address the “six minimum control measures.” MS4 Program compliance is managed by stormwater program staff within the Public Works Engineering Division. The City will update and as necessary provide schedules to implement its MS4 program, including its BMPs and measurable goals in order to meet any new requirements in the General Permit for discharges from an MS4. | Program Goals and Management: Developing a Program | developing-a-program |
A Strategic Approach to Planning for and Assessing the Effectiveness of Stormwater ProgramsAuthor: California Stormwater Quality Association | Developed/Updated on Date: February 2015 The primary purpose of this guidance document is to establish specific “how to” guidance with examples for managers in planning and assessing their MS4 programs. It approaches effectiveness assessment as an integral part of a comprehensive strategic planning process. It is designed for use by MS4 program managers involved in developing and implementing all aspects of stormwater programs, but it should also be useful to a variety of dischargers regulated under other stormwater permits and programs (e.g., construction and industrial), as well as other environmental managers with a need for guidance on management and assessment principles. A structured approach to planning and assessing stormwater programs can help managers ensure that their programs are properly targeted, determine whether intended results are being efficiently and cost-effectively achieved, relate implementation results to conditions in urban runoff and receiving waters, and, ultimately, help guide managers toward implementation strategies with the greatest opportunity for long-term success. | Good Housekeeping in Municipal Operations, Illicit Discharge Detection and Elimination, Management of Construction Site Runoff, Management of Post-Construction Site Runoff, Program Goals and Management: Developing a Program, Program Goals and Management: Long-Term Planning, Program Goals and Management: Vision and Goals, Public Education and Outreach, Public Participation, Water Quality Outcomes: Stormwater Monitoring | good-housekeeping-in-municipal-operations illicit-discharge-detection-and-elimination management-of-construction-site-runoff management-of-post-construction-site-runoff developing-a-program long-term-planning vision-and-goals public-education-and-outreach public-participation stormwater-monitoring |