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MS4 Permitting ProcessMS4 Permitting Process
William CrealWilliam Creal
Water BureauWater Bureau
Permits Section ChiefPermits Section Chief
MS4 Permitting ProcessMS4 Permitting Process
Two permit optionsTwo permit options
Process to dateProcess to date
Process forwardProcess forward
Implementation committeeImplementation committee
Watershed PermitWatershed Permit– Public education and Post Public education and Post
construction = watershed construction = watershed boundaryboundary
– Remaining requirements = Remaining requirements = MS4 owned/operated within MS4 owned/operated within watershedwatershed
Coverage AreaCoverage Area
Jurisdictional PermitJurisdictional Permit– MS4 owned/operated within urbanized areaMS4 owned/operated within urbanized area
Coverage AreaCoverage Area
Discharge point information on applicationDischarge point information on application– Discharge point = discharges to surface waters of Discharge point = discharges to surface waters of
state and to other MS4sstate and to other MS4s
Categorical coverageCategorical coverage
Authorized DischargesAuthorized Discharges
Discharges after application, but not Discharges after application, but not categorical coveragecategorical coverageLess than 1,500 this permit cycleLess than 1,500 this permit cycleMore than 1,500 next permit cycleMore than 1,500 next permit cycle
Discharge Point LocationDischarge Point Location
Constructed/installed Constructed/installed after submittalafter submittalJP = lat/long also for JP = lat/long also for discharges after discharges after application and application and labeling for new labeling for new constructed/installedconstructed/installed
Discharge Point LocationDischarge Point Location
WP = submit revised planWP = submit revised plan
JP = public notice, citizen advisory committee, JP = public notice, citizen advisory committee, watershed organizationswatershed organizations
Public ParticipationPublic Participation
Update needed unless demonstrateUpdate needed unless demonstrate– Evaluating effectivenessEvaluating effectiveness– Triggers for revision Triggers for revision
Watershed Management PlanWatershed Management Plan
SWPPI regulatory documentSWPPI regulatory document
Approved upon submittal if it meets GP Approved upon submittal if it meets GP requirementsrequirements
MDEQ reopener if SWPPI is deficientMDEQ reopener if SWPPI is deficient– Revise SWPPI within 90 days unless negotiate Revise SWPPI within 90 days unless negotiate
timeline ORtimeline OR– COC ModificationCOC Modification
Implement upon submittalImplement upon submittal
Approval/ReopenerApproval/Reopener
Allowed for many SWPPI requirementsAllowed for many SWPPI requirements
Needs MDEQ approvalNeeds MDEQ approval
Innovative watershed alternatives are Innovative watershed alternatives are encouragedencouraged
Work with WB staff prior to SWPPI submittal Work with WB staff prior to SWPPI submittal
Alternative ApproachesAlternative Approaches
Watershed or regional PEP (WP Watershed or regional PEP (WP only)only)
Watershed effectiveness (WP only)Watershed effectiveness (WP only)
Topics similar to last permit Topics similar to last permit – added septic system, native added septic system, native
landscapinglandscaping
JP = Additional topics JP = Additional topics – P-free fertilizer & P-free fertilizer &
restaurant educationrestaurant education
Public EducationPublic Education
Stormwater related, Stormwater related, approved TMDLsapproved TMDLs
Actions to make Actions to make progress in meeting progress in meeting water quality standardswater quality standards
Total Maximum Daily Loads Total Maximum Daily Loads (TMDL)(TMDL)
E.Coli/Total E.Coli/Total Phosphorus Phosphorus monitoring:monitoring:– Outfall monitoring at Outfall monitoring at
50% major discharge 50% major discharge pointspoints
– Elective monitoring Elective monitoring option (WP only)option (WP only)
Total Maximum Daily Loads Total Maximum Daily Loads (TMDL)(TMDL)
Regulatory mechanism prohibiting Regulatory mechanism prohibiting illicit discharges to MS4illicit discharges to MS4Staff trainingStaff training
Illicit Discharge EliminationIllicit Discharge Elimination
Program to eliminate discharges:Program to eliminate discharges:– Storm sewer mapStorm sewer map
Illicit Discharge EliminationIllicit Discharge Elimination
– Dry weather screening at discharge pointDry weather screening at discharge point– OR collaborative approach at waters of OR collaborative approach at waters of the state (WP only)the state (WP only)
Regulatory mechanism Regulatory mechanism – New development and New development and
redevelopment >1 acre.redevelopment >1 acre.
Requirements include: Requirements include: – Water quality criteria, channel Water quality criteria, channel
protection criteria, O & M, protection criteria, O & M, enforcement mechanisms.enforcement mechanisms.
Post Construction Runoff ControlPost Construction Runoff Control
Standards met by:Standards met by:– Incorporate standards given in permitIncorporate standards given in permit– Grandfather existing mechanism includes Grandfather existing mechanism includes
WQ & channel criteriaWQ & channel criteria– Procedures in placeProcedures in place– Submit an alternative approach or outcome Submit an alternative approach or outcome
based approach based approach
Standards slightly different between permitsStandards slightly different between permits
Post Construction Runoff ControlPost Construction Runoff Control
Part 91 and Part 91 and Permit by RulePermit by RuleProcedures to:Procedures to:– Notify agencies of sediment Notify agencies of sediment
& other wastes& other wastes– Ensure for erosion controls Ensure for erosion controls
in preliminary site plansin preliminary site plans– Receipt and considerations Receipt and considerations
of complaintsof complaints
Construction Stormwater Runoff Construction Stormwater Runoff ControlControl
Employee / contractor trainingEmployee / contractor training
Structural stormwater control effectivenessStructural stormwater control effectiveness
Roads, parking lots & bridgesRoads, parking lots & bridges
Fleet maintenance & storage yardsFleet maintenance & storage yards
Managing vegetated propertyManaging vegetated property
Pollution Prevention/ Good Pollution Prevention/ Good HousekeepingHousekeeping
Existing employees: 1 Existing employees: 1 session permit cyclesession permit cycle
New employees: 1 session New employees: 1 session first year of employmentfirst year of employment
Contractors: trained before Contractors: trained before work performed/can work performed/can include in bid include in bid specificationsspecifications
Employee/Contractor TrainingEmployee/Contractor Training
Inspect structural controls owned/operatedInspect structural controls owned/operated– Swales, infiltration, detention basins, catch Swales, infiltration, detention basins, catch
basinsbasins
Structural Stormwater Structural Stormwater Control EffectivenessControl Effectiveness
Structural Stormwater Structural Stormwater Control EffectivenessControl Effectiveness
• Inspect structural controls owned/operatedInspect structural controls owned/operated– Swales, infiltration, detention basins, catch Swales, infiltration, detention basins, catch
basinsbasins
• Summary list of municipal properties and Summary list of municipal properties and structural controlsstructural controls– Location information by first progress reportLocation information by first progress report
– Information retained by permitteeInformation retained by permittee
O & M waste O & M waste disposed of disposed of according to state according to state lawlaw
New controls meet New controls meet post construction post construction standardsstandards
Structural Stormwater Control Structural Stormwater Control EffectivenessEffectiveness
Reduce TSS to MEPReduce TSS to MEP– First p-report current control level First p-report current control level
& estimate load reduction& estimate load reduction– Second p-report evaluate Second p-report evaluate
effectiveness effectiveness & identify methods to improve& identify methods to improve
– JP has a 25% reduction goal. JP has a 25% reduction goal. Progress report develop methods Progress report develop methods to attain 25% reduction goalto attain 25% reduction goal
Roadways, Parking Lots and Roadways, Parking Lots and BridgesBridges
Good housekeeping practices salt and sand Good housekeeping practices salt and sand storage; gravel parking lots/roadsstorage; gravel parking lots/roadsBans use of coal tar emulsions to seal Bans use of coal tar emulsions to seal asphalt (Austin, TX 2006)asphalt (Austin, TX 2006)
Roadways, Parking Lots and Roadways, Parking Lots and BridgesBridges
Stormwater Pollution Stormwater Pollution Prevention Plan (SWPPP) Prevention Plan (SWPPP) at each facility.at each facility.– Certified stormwater Certified stormwater
operatoroperator
Or integrate into SWPPI Or integrate into SWPPI and overseen by and overseen by stormwater program stormwater program manager (WP only)manager (WP only)
Fleet Maintenance/Storage Yards Fleet Maintenance/Storage Yards
Elements include: site Elements include: site map, list of significant map, list of significant materials, schedules, materials, schedules, description of good description of good housekeeping housekeeping practices, etc.practices, etc.
Fleet Maintenance/ Storage Yards Fleet Maintenance/ Storage Yards
Process to train Process to train employees/contractorsemployees/contractors
P-free fertilizerP-free fertilizer
Program to minimize Program to minimize stormwater impacts stormwater impacts from managed from managed vegetated propertiesvegetated properties
Managing Vegetated PropertyManaging Vegetated Property
Coverage AreaCoverage Area– WP = watershed areaWP = watershed area– JP = MS4 areaJP = MS4 area
Discharge LocationDischarge Location– JP = labeling, lat/long of existingJP = labeling, lat/long of existing
Public ParticipationPublic Participation– WP = update planWP = update plan– JP = participate on citizen groupsJP = participate on citizen groups
Watershed PlanWatershed Plan– WP = may need updatingWP = may need updating– JP = goals/objectives, stresses, wq statusJP = goals/objectives, stresses, wq status
Jurisdictional vs. WatershedJurisdictional vs. Watershed
More flexibilityMore flexibility– WP = alternative approaches allowedWP = alternative approaches allowed– JP = no flexibilityJP = no flexibility
TMDLTMDL– WP = Elective option for E.Coli/TP TMDLWP = Elective option for E.Coli/TP TMDL– JP = Requires outfall monitoringJP = Requires outfall monitoring
PEPPEP– WP = watershed/regional PEPs and WP = watershed/regional PEPs and
evaluationevaluation
Jurisdictional vs. WatershedJurisdictional vs. Watershed
IDEPIDEP– WP = dry weather screening option at outfalls to WP = dry weather screening option at outfalls to
waters of the statewaters of the state– JP = dry weather screening at all discharge pointsJP = dry weather screening at all discharge points
RoadwaysRoadways– JP = 25% reduction goal and progress reportingJP = 25% reduction goal and progress reporting
Fleet maintenanceFleet maintenance– WP = Incorporate into SWPPI; stormwater managerWP = Incorporate into SWPPI; stormwater manager– JP = SWPPP and certified stormwater operatorJP = SWPPP and certified stormwater operator
Jurisdictional vs. WatershedJurisdictional vs. Watershed
What’s the relative emphasis on What’s the relative emphasis on outcome: water quality vs. institutional outcome: water quality vs. institutional simplicity?simplicity?Are you a township, city, school, Are you a township, city, school, county?county?Do you have an approved TMDL?Do you have an approved TMDL?Do you have a number of maintenance/ Do you have a number of maintenance/ storage yards?storage yards?
Jurisdictional vs. WatershedJurisdictional vs. WatershedFood for ThoughtFood for Thought
What is your current permit?What is your current permit?Do you have numerous discharge Do you have numerous discharge points vs. outfalls to the waters of the points vs. outfalls to the waters of the state?state?Are you interested in an alternative Are you interested in an alternative approach?approach?Working collaborative on public Working collaborative on public education?education?
Jurisdictional vs. WatershedJurisdictional vs. WatershedFood for ThoughtFood for Thought
Submit an alternative approach on any Submit an alternative approach on any of the itemsof the itemsOne PEPOne PEPWatershed evaluationWatershed evaluationElective monitoring option for TMDLElective monitoring option for TMDLElective IDEP optionElective IDEP optionMunicipal education topicsMunicipal education topicsPost construction runoff controlPost construction runoff control
Watershed Group DecisionsWatershed Group Decisions
QuestionsQuestions
Contact Mark Fife at 517-241-8993 or Contact Mark Fife at 517-241-8993 or [email protected]@michigan.gov for permit or application for permit or application questions.questions.Contact the appropriate district staff for Contact the appropriate district staff for program implementation/compliance program implementation/compliance questions.questions.For additional information go to For additional information go to http://www.michigan.gov/deqhttp://www.michigan.gov/deq and click on and click on water, then surface water, then storm water, water, then surface water, then storm water, then Municipal Program/ MS4 Permit then Municipal Program/ MS4 Permit Guidance Guidance