Michigan General Storm Water Permit
MDEQ Permits for General Storm Drainage Systems
in Phase I and Phase II Communities
In accordance with rules issued by USEPA, municipalities and other
public bodies that operate a separate storm water drainage system
within the U.S. Census defined urbanized area will be required to
apply for a permit by March 10, 2003 to maintain authorization to
discharge storm water. Municipalities in Michigan will have two
permit options for permit coverage of separate storm water drainage
systems. For
additional details on these options, click here.
The two permit options MDEQ is offering for discharges from separate
storm water system are summarized below.
- Jurisdictional storm water general permit (Permit No. MIS040000).
(The reader should check the MDEQ
web site for the latest information on the status of this
permit). This traditional general permit contains prescriptive
storm water control measures that will be required within the
jurisdiction of the permittee. These include requirements for
public education and public involvement, illicit discharge elimination,
construction and post construction storm water controls, and good
housekeeping and pollution prevention practices for municipal
operations
- Watershed-based storm water general permit (Permit No. MIG610000).
This is the watershed based General Storm Water Permit being implemented
in the Rouge River Watershed. To
view the application for this permit and the permit itself, click
here. This permit is final and currently available across
the State. Although the watershed based General Storm Water Permit
addresses the same basic requirements as the traditional general
permit described above, the watershed based permit provides much
greater flexibility in how these basic requirements (public education
and public involvement, illicit discharge elimination, construction
and post construction storm water controls, and good housekeeping
and pollution prevention practices for municipal operations) are
selected and implemented. The watershed based General Storm Water
Permit also requires cooperative interaction with other public
bodies outside the permittees jurisdiction. This cooperative approach
is designed to accomplish storm water quality improvements watershed-wide,
and provides an added benefit of cost sharing for some storm water
controls. Watershed-wide controls means that many public bodies
that discharge storm water to the same river or lake develop controls
together, and implement them as part of a coordinated strategy.
NOTE: THE FOLLOWING INFORMATION IS ONLY APPLICABLE TO THE
WATERSHED BASED GENERAL STORM WATER PERMIT (PERMIT NO. MIG610000)
WHICH IS BEING USED IN THE ROUGE RIVER WATERSHED. FOR INFORMATION
ON THE JURISDICTIONAL GENERAL STORM WATER PERMIT, PLEASE VISIT THE
MDEQ
WEB PAGE.
Background On the Watershed Based Michigan General
Storm Water Permit
See the Overview Description of Storm Water
Management in the Rouge Watershed for a discussion of the process
that led to the development of the watershed based Michigan General
Storm Water Permit.
Applying for a Michigan Watershed Based General
Storm Water Permit
Please click on the following for information on Applying
for a watershed based Michigan General Storm Water Permit. Click
on the following to view example applications for MDEQ Watershed
Based General Storm Water Permits from Wayne
County and Canton.
Watershed Based Michigan General Storm Water
Permit
The innovative, watershed based General Waste Water Discharge Permit
for Storm Water Discharges from Separate Storm Water Drainage Systems
(Permit Number MIG610000) was issued on July 31, 1997. This General
Permit was "voluntary". It was voluntary since there was no legal
requirement for most storm sewers to have a permit at that point
in time. However, those granted coverage under the voluntary general
permit would be just as bound by its conditions as any other NPDES
discharger. The permit was viewed as an opportunity to demonstrate
that a flexible, locally-driven program will be effective in dealing
with wet weather issues. It was the conclusion by MDEQ that if this
overall approach could be proven effective, it is expected that
the jurisdictions with coverage under this permit would continue
the locally driven program in lieu of the coming USEPA Phase II
program.
The watershed based General Storm Water Permit incorporates the
following elements:
- As stated above, coverage is voluntary until the permits under
the USEPA's
Phase II storm water program are required. It is important
to note that USEPA endorsed Michigan's proposal to use the Voluntary
Watershed Based General Storm Water Permit in lieu of permits
that would otherwise be required by the Phase II regulations.;
- Only public agencies who own, operate, or control storm water
are provided the opportunity for coverage;
- Subwatershed size is established by the potential permittees
during the application process;
- Application and permit process have limited required actions,
the focus is to establish desired outcomes.
The watershed based General Storm Water Permit requires permittee
to develop certain items that are to be submitted with the permit
application and certain other items will be submitted during the
life of the permit. To view the complete
application and accompanying information developed by MDEQ, click
here.
Information to be submitted with the Watershed
Based General Storm Water Permit Application
As shown on the permit application, there are a number of items
that must be submitted. The items that require significant effort
are delineated below.
- General Information. The applicant shall 1) identify
its legal name and mailing address, 2) identify the proposed watershed
boundaries, 3) identify the location of known point source discharges
of storm water for which coverage is requested and their receiving
waters, and 4) provide a map of drainage area indicating the hydrologic
boundary and approximate square miles of area covered. Requirements
3) and 4) would be satisfied by providing a map of the separate
storm water drainage system.
Information to be submitted during the life
of the Watershed Based General Storm Water Permit
The following items must be developed and submitted during the
term of the watershed based General Storm Water Permit.
- Illicit Discharge Elimination Plan (IDEP). An illicit
discharge is the introduction of polluting materials into a pipe that
drains to surface water or the dumping of polluting material that
can impact surface water. This is a broader definition than the "classical" definition
of sanitary plumbing fixtures connected to a storm sewer. The Rouge
Project found there were a number of illicit discharges that were
adversely impacting water quality. Examples found in the Rouge River
watershed include toilets connected to storm sewers, laundry waste
discharging to a drain, swimming pool backwash water discharging to
a storm sewer or situations where polluting material can move over
land to a storm sewer.
The IDEP has the goal of eliminating raw sewage discharges and includes addressing
failing septic systems and improper connections of sanitary sewers to storm drains
and open waterways. The IDEP is due at the time of permit application. At a minimum,
the Illicit Discharge Elimination Plan must include the following:
- a description of a program to find, prioritize, and eliminate
illicit discharges and illicit connections identified during dry
weather screening activities;
- a description of a program to minimize infiltration of seepage
from sanitary sewers and septic systems into the applicant's separate
storm water drainage system.
- Public Education Plan (PEP). The PEP is designed
to inform residents and businesses what actions they should take to
protect the river. The PEP is due at the time of permit application.
The Public Education Plan shall promote, publicize, and facilitate
watershed education for the purpose of encouraging the public to reduce
the discharge of pollutants in storm water to the maximum extent practicable.
The Public Education Plan may involve combining with or coordinating
existing programs for public stewardship of water resources. Pollution
prevention shall be encouraged. The plan shall be designed to accomplish
the following as appropriate based on the potential impact on the
watershed:
- encouragement of public reporting of the presence of illicit
discharges or improper disposal of materials into the applicant's
separate storm water drainage system;
- education of the public on the availability, location and requirements
of facilities for disposal or drop-off of household hazardous
wastes, travel trailer sanitary wastes, chemicals, grass clippings,
leaf litter, animal wastes, and motor vehicle fluids;
- education of the public regarding acceptable application and
disposal of pesticides and fertilizers;
- education of the public concerning preferred cleaning materials
and procedures for residential car washing;
- education of the public concerning the ultimate discharge point
and potential impacts from pollutants from the separate storm
water drainage system serving their place of residence;
- education of the public about their responsibility and stewardship
in their watershed; and
- education of the public concerning management of riparian lands
to protect water quality.
- Watershed Management Plan prepared in cooperation
with others, to resolve water quality concerns. The Watershed
Management Plan is typically due two years after the certificate
of coverage is issued to the applicant. The planning is iterative
in
nature.
The completed plan is not subject to MDEQ approval. The first
revision of the Watershed Management Plan is due prior to permit
expiration. This is intended to support the concept of planning
being an iterative process. The MDEQ states the following: "We
expect frequent revisions to the Plan. And we hope that, due to
the frequency of revisions, stakeholders will be willing to support
Plans that are less than fully satisfactory to them, i.e. their
concerns can be fully addressed in the next iteration."
As a minimum, the Watershed Management Plans shall contain:
- an assessment of the nature and status of the watershed
ecosystem to the extent necessary to achieve the purpose of
the watershed management plan,
- definition of the short-term goals for the watershed,
- definition of the long-term goals for the watershed, which
shall include protection of designated uses of the receiving
waters as defined in Michigan's Water Quality Standards,
- determination of the actions needed to achieve the short-term
goals for the watershed,
- determination of the actions needed to achieve the long-term
goals for the watershed,
- assessment of both the benefits and costs of the actions
identified above (a "cost/benefit analysis" is not required),
- commitments, identified by specific permittee or others
as appropriate, to implement actions by specified dates necessary
to achieve the short-term goals,
- commitments, identified by specific permittee or others
as appropriate, to implement actions by specified dates necessary
to initiate achievement of the long-term goals, and
- methods for evaluation of progress, which may include chemical
or biological indicators.
- Storm Water Pollution Prevention Initiative (SWPPI).
The SWPPI is a subset of the Watershed Management Plan and is
typically due 2.5 years after the certificate of coverage is issued
to the applicant. The following are the SWPPI requirements as
stated in the permit:
The permittee shall submit an approvable Storm Water Pollution
Prevention Initiative and implementation schedule to the MDEQ
District Supervisor of the Surface Water Quality Division by the
date specified in the certificate of coverage. The Program shall
be designed and implemented to reduce the discharge of pollutants
to the maximum extent practicable, shall be consistent with the
Watershed Management Plan, and shall include those actions expected
to be implemented over the term of the permit. The Program shall
be implemented upon approval of the MDEQ. The Program shall include,
as a minimum:
- The actions required of the permittee in the Watershed Management
Plan in accordance with the dates specified, taking into account
any specific disagreements to the Watershed Management Plan
which were provided by the permittee and included in the appendix
to the Plan. (Note: if the Watershed Management Plan requirement
has been deferred until a later time, as indicated on the
certificate of coverage, the Storm Water Pollution Prevention
Initiative shall initially be developed without consideration
of the Watershed Management Plan.)
- Evaluation and implementation of pollution prevention and
good housekeeping activities, as appropriate. The permittee
shall consider the following activities for inclusion in the
Storm Water Pollution Prevention Initiative:
- maintenance activities, maintenance schedules, and inspection
procedures for storm water structural controls to reduce
pollutants (including floatables) in discharges from the
permittee's separate storm water drainage system,
- controls for reducing or eliminating the discharges
of pollutants from streets, roads, highways and parking
lots,
- procedures for the proper disposal of operation and
maintenance waste from the separate storm water drainage
system (dredge spoil, accumulated sediments, floatables,
and other debris),
- ways to ensure that new flood management projects assess
the impacts on the water quality of the receiving waters
and, whenever possible, examine existing projects for
incorporation of additional water quality protection devices
or practices, and
- implementation of controls to reduce the discharge of
pollutants related to application of pesticides, herbicides,
and fertilizers applied in the permittee's jurisdiction.
- Evaluation and implementation of site appropriate, cost-effective
structural and nonstructural best management practices (BMPs)
to minimize the water quality impacts from areas of new development
and significant redevelopment. The goal is to protect the
designated uses in the receiving waters from the effects commonly
associated with urbanization.
- The methods of assessing progress in storm water pollution
preventionand a schedule for submittal of annual reports to
the MDEQ District Supervisor on implementation status and
pollution prevention progress. At a minimum, the annual progress
reports shall include:
- documentation of actions taken to eliminate illicit
discharges (for significant illicit discharges, the pollutant(s)
of concern, the estimated volume and load discharged,
and location of the discharge into the permittee's separate
storm sewer system and into the receiving water shall
be provided),
- schedules for elimination of illicit connections identified
but not eliminated,
- documentation of the public education effort and evaluation
of its effectiveness,
- documentation of other actions taken to reduce the discharge
of pollutants in storm water.
- Designated contact person: On or before 60 days after the
effective date of the certificate of coverage, the permittee
shall designate a storm water program manager to serve as
the contact person for the MDEQ regarding activities carried
out to comply with this permit. The permittee may replace
the program manager at any time and shall notify the MDEQ
District Supervisor within ten days after the replacement.
- Retention of records. The latest approved version of the
Storm Water Pollution Prevention Initiative shall be retained
until at least three years after coverage under this permit
terminates. All records and information resulting from the
assessment of Storm Water Pollution Prevention Initiative
effectiveness , including all records of analyses performed
and calibration and maintenance of instrumentation and recordings
from continuous monitoring instrumentation, shall be retained
for a minimum of three years or longer if requested by the
MDEQ or the USEPA Regional Administrator.
The SWPPI must be reviewed at least 180 days prior to permit expiration
and a revised SWPPI (if appropriate) must be submitted to the
MDEQ for approval with the permittee's request to continue a discharge
authorized under the permit. The revised SWPPI shall be consistent
with revisions made to the Watershed Management Plan.
- Monitoring and Reporting. All NPDES permits have
specific requirements for the permittee to conduct necessary water
quality monitoring and to report on other items such as progress
being made, status of compliance with the permit requirements,
etc. The watershed based General Storm Water Permit has similar
such monitoring and reporting requirements including schedule
for revisions to the Watershed Management Plan.
Watershed Based General Storm Water Permit Guidance
and Example Documents
Five basic guidance documents were originally developed for use
by any community in applying for and then implementing the watershed
based General Storm Water Permit. These guidance documents explained
the individual requirements of the General Permit and provided valuable
information to the potential permittees on what should be contained
in each of the required parts of the watershed based General Storm
Water Permit including the permit application. The original have
been updated to reflect the more extensive knowledge gained by MDEQ,
the local communities and other permittees on how to more effectively
implement the watershed based General Storm Water Permit.. The first
guidance document listed below was prepared by the MDEQ whereas
the other four documents were prepared by the Rouge Project working
with the local communities. Those documents are available by clicking
on the appropriate item.
State of Michigan
Guidance: Michigan's Watershed Based MS4 Voluntary General Permit
Rouge Project Guidance:
Subwatershed
Management Plan Guidance
Public Education/Information
Plan Guidance
Illicit Discharge
Elimination Plan Guidance
Storm Water Pollution Prevention Initiative
Guidance
To help explain the philosophy behind the watershed based General
Storm Water Permit and to elaborate on the information contained
in the above referenced guidance documents, the Rouge Project conducted
three workshops in 1997 for the communities in the Watershed to
assist them in complying with the requirements of the watershed
based General Storm Water Permit. Several guidance documents were
prepared for use in those workshops. Those documents are available
by clicking on the following:
General Storm Water Permit:
Why Volunteer to be Regulated?
Community Project
Guide to Managing Grants
Improving Community Storm
Water Management: A Summary Guide of Ordinances
Example Applications for the MDEQ Watershed Based General
Storm Water Permit
As stated earlier, the three counties, most of the communities,
and other agencies within the Rouge Watershed have applied for the
watershed based General Storm Water Permit. By clicking on the following,
example applications for Wayne County and the city of Canton can
be viewed.
Example Submissions of the Completed Subwatershed Management
Plans
The seven subwatershed groups comprised of Rouge River communities
have developed watershed management plans and submitted them to
MDEQ in accordance with the requirements of the Michigan General
Storm Water Permit. The subwatershed management plans do not require
state approval; however, the individual pollution prevention initiatives
emanating from the watershed planning process require state approval
as the activities specified in the initiatives become permit requirements
upon approval. The subwatershed management plans are now being implemented.
To view any of the individual subwatershed management plan, click
on Completed Subwatershed Management
Plans.
Example Submissions of the Illicit Discharge Elimination
Program (IDEP)
A complete description of the Rouge Project's Illicit
Discharge Elimination Program (IDEP) can be viewed by clicking
on the above.
As stated earlier, the three counties, most of the communities,
and other agencies within the Rouge Watershed have applied for the
watershed based General Storm Water Permit. The permit requires
communities to develop IDEPs which must be submitted with the permit
application. By clicking on the following, example IDEPs for Bloomfield
Township and Canton can be viewed.
Example Submissions of the Public Education Program (PEP)
The Rouge Project's strategy for a comprehensive public involvement
and education program to support Rouge River restoration activities
has been a success. Since the Rouge Project's inception in 1992,
it was clear that public education and involvement programs were
a cornerstone of the restoration of the Rouge River. A complete
description of the Rouge Project's Public
Involvement and Education Program can be viewed by clicking
on the above.
As stated earlier, the three counties, most of the communities,
and other agencies within the Rouge Watershed have applied for the
watershed based General Storm Water Permit. The general permit requires
permittees to develop and implement public education programs. By
clicking on the following, example public education plans for Bloomfield
Township and Canton can be viewed.
Example Information on the Storm
Water Pollution Prevention Initiative (SWPPI)
As discussed above, a key component of the watershed based General
Storm Water Permit is the Storm Water Pollution Prevention Initiative
(SWPPI). The SWPPI identifies the specific responsibilities of the
permittee to implement the watershed management plans with specific
compliance dates included. The program is subject to MDEQ approval
and is enforceable thereafter. It includes evaluation and implementation
of pollution prevention and good housekeeping practices, the evaluation
and implementation of BMPs to minimize impacts of new development
and redevelopment, and assessment of progress and reporting.
Below are materials to assist communities and agencies in development
of the SWPPI. Some files require Adobe Acrobat Reader (files ending
in .pdf). This free software can be obtained at http://www.adobe.com/.
Other software required includes Microsoft Office 97 products:
Microsoft Word (files ending in .doc)
Microsoft Excel (files ending in .xls)
Microsoft PowerPoint (files ending in .ppt)
If you are unable to read files from Microsoft Office 97, please
contact Michael Flowers at (313) 224-8284.
PowerPoint Presentations given at SWPPI workshop.
As discussed earlier, the Rouge Project conducted a workshop on
the preparation of the SWPPI. The PowerPoint presentation used in
that workshop is presented below
Summary of SWPPI-related questions and answers from the MDEQ
and RPO
At the workshop, a number of questions were asked by the audience
on the preparation of the SWPPIs. Those questions and the answers
can be viewed by clicking on the following. (Adobe PDF files)
MDEQ SWPPI Template and Checklist
Following the aforementioned SWPPI workshop, the MDEQ issued guidance
material on the required SWPPIs. The template MDEQ developed and
the review checklist can be viewed by clicking on the following.
(Adobe PDF files)
Goal-Specific Long Term Assessment of Progress in Subwatershed
A key element of the SWPPI process is the process by which the assessment
of progress will be made in implementing the actions needed to achieve
the long term goals specified in the subwatershed management plans.
To assist communities and agencies in developing their SWPPI submissions,
the Rouge Project, working with one of the subwatersheds developed
a draft "Table 1" titled Goal-Specific Long Term Assessment of Progress
in Subwatershed. This is a recommended example table that was reviewed
by the MDEQ for use by the individual communities in developing
their individual SWPPIs. The table is based on the Subwatershed
Management Plan's chapter on monitoring. This table would be modified
to fit individual needs. (Microsoft Word files)
Community and agency specific activities committed to under
Subwatershed Management Plans -- as submitted in Common Appendix
B
Within the watershed management plans and the SWPPIs, communities
and agencies must identify specific activities that will be undertaken
to further the restoration of the Rouge River in order to achieve
the long term goals specified in the subwatershed management plans.
To assist communities and agencies in developing their SWPPI submissions,
the Rouge Project, working with one of the subwatersheds developed
draft tables that presents possible community and agency specific
activities committed to under subwatershed management plans. The
tables are grouped under a specific SWAG. By clicking on the listing
below, the particular SWAG will appear. The tables for individual
communities within that SWAG can then be clicked on for viewing.
These are example tables that were reviewed by the MDEQ for use
by the individual communities in developing their individual SWPPIs.
(Microsoft Excel files)
Examples of completed draft SWPPIs (Microsoft Word files)
General Comments on Draft SWPPIs
General comments were prepared by MDEQ
based upon their reviews of some draft SWPPIs. The comments were
prepared to assist the communities in the preparation of their final
SWPPIs.
Current Status of the SWPPIs in the Rouge Watershed
The communities and agencies are proceeding to implement that actions
delineated in their individual SWPPIs. Click
here for the most current status.
Common Appendix for Rouge Subwatershed Management
Plans Submitted in Fulfillment of the MDEQ Watershed Based General
Storm Water Permit
To assist the seven Subwatershed Advisory Groups (see Overview
Description of Storm Water Management for the Rouge River for
a complete discussion about these Groups) in the preparation of
the watershed management plans required by the watershed based General
Storm Water Permit, the Rouge Project prepared a Common
Appendix of information for use by the communities and agencies.
This technical appendix includes a number of items as follows:
- Planning and Cost Estimating Criteria for Best Management Practices;
- community action scores for water quality improvement;
- community action cost estimates; a summary of the 1999 public
involvement survey;
- the Rouge River Report Card;
- comments on year 2000 draft 303(d) list;
- a list of available maps; river flow data summaries;
- dissolved oxygen and temperature data summaries;
- E. Coli data summaries;
- biological and ecological features, and
- ecological impairments; and a glossary and list of acronyms.
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