MDEQ General Comments on SWPPI Review
September 6, 2001

1. In order to facilitate MDEQ's SWPPI review, directly transferring the actions that the permittee has agreed to in the Subwatershed Management Plan (WMP) into SWPPI Table 2 would be very helpful. An example of this can be found in Table 3 of the Farmington Hills SWPPI template where the actions listed in the Upper WMP are also listed in the SWPPI.
2. In the "WMP Goals Addressed" section, only goals that directly relate to the action should be listed here. If a goal is listed as being addressed, it should have a "method of measuring progress" accompanying it, in one of the SWPPI tables.
3. Use language that demonstrates commitment to actions. For example, "XYZ Community will/shall sponsor workshops on lawn chemical use for property owners" is acceptable. "XYZ Community would like to sponsor workshops on lawn chemical use for property owners" is not acceptable.
4. Include schedules: start date, frequency, ongoing, end date (if appropriate).
5. Include details/specifics on action items.
6. MDEQ will review and comment on any completed draft SWPPIs before December.
7. MDEQ's final review will occur by subwatershed.

For Communities in Multiple Subwatersheds

1. If goals and actions of different WMPs are redundant, then the permittee may select a primary subwatershed for its SWPPI that will be implemented throughout the community. The redundancy must be justified in detail in the table and can be included in the SWPPI text. For the first iteration, the permittee must demonstrate that they have done a comparison of all the goals and actions they committed to in each of the subwatersheds listed in their COC.
2. If one of the multiple subwatersheds comprises a very small portion of the community then this is a reasonable justification for focusing on the primary watershed.
3. The concern to carefully consider is if there are goals or actions not being addressed by selecting to work from just one WMP.
4. Farmington Hills is an example. They have a COC for the Upper, the Main 1-2, and Middle 1. The WMP goals and Farmington Hills' actions listed in the Upper and the Main 1-2 are nearly identical. The goals and actions are stated differently, but are similar, in the Middle 1 WMP. The Middle 1 comprises only a small portion of Farminton Hills. For their SWPPI Farmington Hills can select the Upper WMP as its primary subwatershed, but they must explain the rationale for doing this. They must also describe how they are still agreeing with and addressing the goals and actions listed in the Middle 1 WMP. This detail shall be provided in a table.
5. If the goals and actions stated in different WMPs are sufficiently different then they must all be included in the SWPPI.

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The Rouge River National Wet Weather Demonstration Project is funded, in part, by the United States Environmental Protection Agency (EPA) Grants #XP995743-01, -02, -03, -04, -05, -06, -08 and C-264000-01.