Department of Environmental Quality NC MS4 Compliance Strategy NC MS4 Sustainability Strategy (MS6) Background Information DEQ/DEMLR/Stormwater Program Mike Randall, (919) 807-6374 E-mail: [email protected]Robert Patterson (919) 807-6369 E-mail: [email protected]1612 Mail Service Center Raleigh NC 27699-1612 The Next Generation of Compliance
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The Next Generation of Compliance - North Carolina Mineral and Land... · MS4 regulatory compliance while continually improving upon practicable measures to help achieve local, state,
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Currently one part time position dedicated to administer the MS4 program
• 101 small MS4 local governments • Over 40 have populations < 10,000
• 2 non traditional Schools in Mecklenburg County• NCDOT (TS4)• 6 Large MS4s• 2 Universities• 4 Military bases• 28 MS4 waived or requested waivers - populations < 10,000• 20 potential MS4 from the 2010 Census - populations < 10,000
Federal and State regulations allow the state to approve request to waive or rescind MS4 permits if they demonstrate that they have effective SW programs in place.
Department of Environmental Quality
DEQ’s Overall MS4/TS4 Compliance Strategy
Enforcer
ResourcePartner
• Enforcer the EPA/DEQ FY17 SECTION
106 WORKPLAN – Inspections and
audits
• A partner and a resource DEQ will
continue to support outreach activities,
such as, summits, workshops, training
• A partner and a resource DEQ will
continue to be committed to seeking
cooperative and sustainable solutions
through Round Table discussions,
Lunch and Learns, and meetings.
Department of Environmental Quality
The Next Generation of Compliance
Annual Reports
MS4s are required to prepare and submit annual reports
Audits and Inspections
CWA SECTION 106 WORKPLAN for Phase I and II MS4s requires NC DEQ –DEMLR conducts on-site audit, MS4 inspection, or off-
site desk audit once/5 years.
Department of Environmental Quality
NC DEMLR is requesting EPA eliminating the NC MS4/TS4 annual reporting and MS4/TS4 inspections and audits where there is a formal and transparent sustainability strategy.
The New Generation of MS4 Compliance
You can’t fatten a pig weighing it.
Department of Environmental Quality
Request Recognizes
• Posting Gap Analysis, Root
Cause Analysis and Action
Plans ensures transparency
and provides better oversight
• Partnerships lead to
cooperative solutions.
• Cooperative solutions lead to
ownership.
The New Generation of MS4 Compliance
Department of Environmental Quality
Request recognizes ownership leads to improved stormwater programs that:
• Minimizes liability
• Strengthens stormwater programs through adaptive management and peer-to-peer
interaction
• Allows the local government demonstrate and model success in maintaining NPDES
MS4 regulatory compliance while continually improving upon practicable measures to
help achieve local, state, and federal stormwater management goals
• Promotes public engagement and collaboration
• Promotes results-based adaptive management that benefits the community and
watersheds served by the stormwater program, the regulated entity, regulatory
agencies, and broader program stakeholders.
• Allows the Local Government to identify and implement program strategies and
measures to meet the community’s existing stormwater management requirements
and needs while anticipating and preparing for the future.
The New Generation of MS4 Compliance
Department of Environmental Quality
The Next Generation of Compliance
NC MS4 Compliance
Strategy
NC MS4 Sustainability Strategy (MS6)
Background Information
Cooperative Solution
DEQ Stormwater Permitting
SWANC and APWA
NCDOT
Phase I and Phase II
Local Governments
Environmental Groups
League of Municipalities
Private Sector
Department of Environmental Quality
• MS6 was a cooperative solution to address the environmental, social and economic impacts of the MS4 program
• MS6 IS NOT mandatory• MS6 IS A MANAGEMENT
STRATEGY that provides local governments the tools to develop sustainable programs
The Next Generation of Compliance
Department of Environmental Quality
MS4s Partners MS4s Partners Engineering Firms
Burlington* Greenville AMEC*
Winston-Salem (Phase I)* Lewisville WK Dickson
Greensboro (Phase I)* Durham (Phase I) DRMP
Raleigh (Phase I)* Wilmington Timmons Group
Holly Spring* Fayetteville (Phase I) Kimley Horn
High Point Morrisville Hazen and Sawyer
Asheville Cary
Monroe Garner
Kernersville Charlotte (Phase I)
Guilford County Mecklenburg County
* Core Partners. Other Partners included Several COGs, DEQ, NCDOT, League of Municipalities, APWA, SWANC, and
several Environmental Groups
The Next Generation of Compliance
Department of Environmental Quality
Six elements for sustainable MS4
programs
Organizational Commitment
Environmental Management
Systems (EMS)
- Ordinances, Policies, Plans, and
SOPs
Asset Management
Finding cooperative solutions through collaboration and
• Each module will include lesson plans, identify the subject, time period, lesson plan objectives, handouts, power point presentations, exercises, and a pre and posttest.
• Offered to stormwater professional and Federal and State agencies.
• Courses may be observed by DEQ/EPA staff for consistency
What’s Next
Course Agenda
Day 1 MS6 Program
Organizational Commitment Environmental Management Systems (EMS) Asset Management Finding Cooperative Solutions Performing Gap Analysis and Identifying Root Causes Developing and Implementing Action Plans
Day 2 Minimum Measures
Public Education and Outreach Public Involvement IDDE Construction Activities Post-construction Activities Good Housekeeping and Pollution Prevention
Day 3 Optional Training
NC Compliance Strategy Alternatives to TMDLs Other ideas ????
Department of Environmental Quality
What’s Next
State will maintain a list of stormwater professionals that have attended the MS6 Training
Who is going to provide the ongoing training ????
319 grants and/or Public Private Partnerships (P3)
Department of Environmental Quality
What’s Next
• DEQ commitment and EPA approval• Audits and Inspections
– EPA contracts audits and inspections– Gap Analysis and Root Cause Analysis performed by independent
stormwater professions will be reviewed, documented, and recorded in BIMs as State audits and/or inspections pursuant to the CWA SECTION 106 WORKPLAN EPA/DEQ MOU for Phase I and II MS4s
– EPA may require stormwater professionals meet a State/EPA requirements/standard to perform Gap Analysis and Root Cause Analysis on behave of the State
• Annual Report– Posting the results of Gap Analysis and Root Cause Analysis and
Action Plans meet the requirement to submit annual reports to the State.
Department of Environmental Quality
What’s Next
Gap Analysis Questionnaire, Root Cause list and Action Plans lend themselves to
a web-based application, inspections, audits and electronic reporting
(beginning in 2020)
319 grants and/or Public Private Partnerships (P3) ???