Subwatershed Management Plan Guidance

• Guidance for preparing a Management Plan
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• Discussion Materials:   Watershed Management Planning
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Guidance for preparing a Management Plan
(Prepared by the Rouge Program Office, November 14, 1997)

Introduction
The first step in applying for coverage under the new MDEQ General Storm Water Permit is determining the hydrologic boundaries of the subwatershed, and the public agencies and communities that will participate in the preparation of a joint subwatershed storm water management plan. The individual agencies and communities who agree to participate in the development of a management plan can seek coverage under the terms of the permit for either the portion of their jurisdiction that lies within the identified subwatershed or for their entire jurisdictional boundary.

Some communities may chose to seek coverage for their entire political jurisdictional boundary since the adoption of ordinances, construction of facilities, education programs, illicit discharge inspections or other actions anticipated under the permit are easier to implement on a community wide basis (particularly if the entire community is within the Rouge River watershed). Other communities with only a small portion of their total area within the Rouge River watershed may choose to only seek coverage for that portion within the Rouge River watershed.

The subwatershed management plan must be completed and submitted to MDEQ for review within three years from the date coverage under the permit is authorized. MDEQ has also indicated that they may temporarily waive the requirement for a subwatershed storm water management plan if there are insufficient number of communities or agencies that apply within a single subwatershed to justify a joint planning effort. A plan would be required when a sufficient number of communities and agencies in the subwatershed subsequently seek coverage under the general permit.

Subwatershed Boundaries
Who Selects Subwatershed Boundaries?

• Cooperating communities and public agencies seeking coverage under permit.

Who Approves Boundaries?

• MDEQ has final approval on boundaries of subwatershed.

Other Consideration

• Hydrologic Boundaries - With possible minor exceptions the subwatershed should represent actual hydrologic boundaries.
• Data Resources - The information compiled by the RPO over the last four years on flow and to a certain extent on water quality is based upon specific hydrologic units. The creation of watershed boundaries that do not substantially conform to existing data , may limit the availability and use of existing information.

Responsibility for Plan

Who is responsible for preparation of plan?

• Public agencies and communities applying for coverage under the general permit that own, operate or control storm water conveyances or facilities within subwatershed are responsible for preparing the plan.

Opportunity to participate

• All public agencies and communities within a subwatershed that are eligible for coverage must be given opportunity to participate.

Review of plan

• In addition to public review and opportunity to comment, the MDEQ must be given and opportunity to review and comment on plan. MDEQ does not approve or disapprove subwatershed management plans.
• MDEQ does approve Pollution Prevention Initiatives submitted by individual communities and public agencies and those initiatives must be consistent with the subwatershed management plan.

Plan Elements

Assess nature and status of watershed ecosystem

• The collective knowledge of the participants and the information already compiled by the Wayne County Rouge Program Office, USGS, MDEQ and other sources may provide sufficient information on which to assess the nature and status of the watershed (additional information needs may be identified and cited in this analysis).
• Two draft subwatershed reports have been prepared and each contains a baseline assessment that can be used as guidance.

Define short and long-term goals for the system

• The two draft subwatershed reports contain goals and objectives established by the communities and public agencies who participated in the planning process (an outline of those goals were presented this morning and are contained in your notebooks).

Determine objectives and actions needed to achieve selected goals

• Again the draft subwatershed plans contain specific objectives, and in some cases action plans, that are directly related to the priority goals. These draft plans can be used as guidance; although, each subwatershed will have goals and objectives tailored to the priorities of the participating agencies and their citizens.
• The actions selected and identified in the subwatershed plan become the basis for preparation of individual Pollution Prevention Initiatives.

Assess benefits and costs of each action

• MDEQ has indicated that a detailed benefit/cost analysis is not required.
• An assessment of the benefits derived from the proposed actions compared to costs is required.
• If certain actions are rejected because of high cost compared to benefits, that information should also be included in this element.

Implement desired actions (schedule)

• The implementation schedule for the entire subwatershed shows how individual projects or actions by participants will be integrated to achieve both short term objectives and long term goals.
• The short term objectives should have specific dates for initiation of programs and activities that relate directly to the Pollution Prevention Initiatives required to be submitted by each participating agency or community.
• All agencies and communities within a subwatershed do not have to commit to do the same thing in the same time frame; the schedule needs to show how activities will be integrated to achieve common objectives.

Evaluate actions against goals (methods)

• The plan needs to contain a method for keeping track of how actions are progressing to meet the goals and objectives (some evaluations will require testing such as whether or not bacteria counts exceed a specific standard).
• Other acceptable evaluation techniques might include such things as number of inspections of septic tanks, number of communities passing certain types of ordinances, frequency of street sweeping or catch basin cleaning, number of grassy swales or other BMPs.
• The type of evaluation used will depend upon how the specific objective is set and the practical limitations of measuring results in water quality improvement over the short term.

Re-evaluate goals and objectives (process)

• The initial goals and objectives of the management plan need to be evaluated prior to the expiration of the first general permit coverage period.
• The management plan should identify the process that will be used to solicit input to reevaluate the goals and objectives based upon the effectiveness of programs conducted under the permit and comments received from participating public entities and other stakeholders.

Public Participation Process

What are the requirements?

• A Watershed Planning Public Participation Process that is submitted to the MDEQ for approval must have the consensus support of the public entities seeking coverage under the permit (the plan can have noted exceptions identified by communities or agencies and recorded in an appendix to the plan)
• Exceptions to consensus among the public agencies cooperating in the drafting of the management plan must be noted in an appendix to the plan and an explanation provided.

What should the public participation process contain?

• A person, group or agency responsible for coordinating the development of the Watershed Management Plan.
• A mechanism(s) for Public Participation in the group responsible for Watershed Management Plan development and finalization.

• public agency representatives (public works department, drain commissioner office, planning and development department, road commission, etc.);
• citizen representatives (citizen members of local planning commissions, park boards, neighborhood rganizations, businesses organization, environmental/conservation organization, etc.);
• elected officials; and,
• community resource volunteers (teacher from college, university or local schools, retired professional, etc.)

• Mechanism(s) for Public Input (fact and perception finding) prior to finalization of management plan.
• Previous public survey findings, new public surveys, interviews, focus groups, public meetings, workshops.

Formal Approval Process

Who needs to approve plan at local level?

• Management plans need to be formally adopted or approved by the responsible public body or public official with statutory or delegated authority to accept responsibilities and obligations under the NPDES permit.
• Actions by public bodies to approve the management plan would be subject to the Michigan Open Meetings Act requirements.

Note: This guidance for preparation of management plans is meant to supplement information contained in the General Permit No. MIG610000, permit application, and Guidelines for the Voluntary Storm Water Discharge NPDES Permit prepared by MDEQ which officially describe the complete legal requirements.

Discussion Materials:
Watershed Management Planning

Purpose
Develop a consensus between communities and other stakeholders within subwatersheds to implement management techniques to address existing problems and future threats to water quality and ecosystem health through a cooperative planning and an iterative decision making process that is based upon sound scientific principles and data analyses.

Core Features

• One common plan for each subwatershed
• Participation by all permittees within subwatershed
• One person, group or agency responsible for subwatershed plan coordination
• One integrated public participation plan for subwatershed (MDEQ approval required)
• Completion of plan within 18 months of receiving Certificate of Coverage (unless extended by MDEQ)
• Method for responding to MDEQ comments (No MDEQ plan approval)
• Process for revising and updating plan at end of permit term

Process

• Agree on operating procedures (who writes, reviews, approves and how are disagreements to be resolved)
• Assess and characterize water related natural resources (primarily utilizing existing information sources)
• Develop goals and identify objectives based upon existing conditions and vulnerability of aquatic resources and community needs
• Identify priority issues and opportunities
• Review management options and develop action plans (i.e., long term plans for subwatershed)
• Agree upon methods to assess progress and process to revise plans

Minimum Plan Requirements

• Describe nature and status of watershed ecosystem to extent required to achieve purpose of plan
• Define short-term goals in context of long-term goals that must include protection of designated uses defined by Michigan=s Water Quality Standards
• Identify actions needed to achieve short-term and long-term goals
• Describe the benefits expected and estimated costs of the actions proposed
• Describe commitments by permittee or others to implement specific actions by dates (schedule) to achieve short-term goals (incorporated in detail as part of permittee's Pollution Prevention Initiative)
• Establish target dates for actions by permittee or others to implement actions to achieve long term goals (subject to reassessment as part of iterative decision making process following evaluation)
• Establish methods for evaluating progress (monitoring chemical or biological parameters, recording completion of action items, etc.)
• Establish date for deciding whether or not management plan needs to be revised (at least 180 days prior to permit expiration)

  * Note: This outline was prepared for the workshop discussion and is not meant to cover all elements necessary for the development of a watershed management plan.

Steps and Alternative Approaches to Plan Preparation

1. Identify Permittees within Watershed Boundary
   Example: Upper Rouge Watershed

Permittees:

Communities need to define

Primary - Farmington, Farmington Hills, Livonia, Redford Township, and West Bloomfield Township.

Secondary *- Commerce Township, Northville Township, and Novi.

*These communities have a small portion of their geographic area located in the Upper Rouge Subwatershed, therefore their participation and emphasis may lie in another subwatershed (i.e., Novi may choose to be more active in the Middle 1 Subwatershed.)

Other Public Agencies

Primary - Wayne County (Department of Environment (Drains, Public Works, Watershed); Wayne County Department of Public Service (Roads, Parks); Oakland County Drain Commissioner; Oakland County Road Commission and MDOT.

Secondary- Schoolcraft Community College and other public schools with separate storm water discharges.

2. Who Is Going to Take the Lead? (Each Subwatershed group must decide among the permittees who will provide administrative support for the subwatershed plan development.)

1. Alternative 1. - Community or Agency
   Permittees agree that one community or agency will provide leadership to coordinate the preparation of the subwatershed management plan and apply for grant funding from the Rouge Project for the development of the plan. The required grant match will be provided by all permittees for the Rouge Project grant to one permittee to generate plan.
2. Alternative 2. - Subwatershed Group
   Permittees agree that subwatershed group will coordinate preparation of the plan, approve single or multiple grant applications and divide work among participants, and elect a chair to speak for the group. Group may decide to hire single consultant to facilitate meetings, collect and evaluate information and prepare written drafts of plan for review by group, or assign responsibilities to various members who in turn use staff or consultants to complete needed work.

3. Agreement on Operating Procedures
   1. How will the group operate: with chair, facilitator or both?
   2. Who will prepare, review and approve written plan?
      1. How will differences between group be decided ?
      2. Voting or consensus
   3. Recording exceptions to votes/consensus
   4. How will resources be provided to collect and analyze information, write plan, conduct public participation, etc.?

    

4. Public Participation Plan (At a minimum the public must be given meaningful opportunity to review and comment on management plan prior to submission to MDEQ for approval)

1. Alternative 1.
   Plan drafting committee formed with representatives of various stakeholder interests: permittees, public at large, business community, neighborhood organizations, locally based environmental organizations, other public agencies, etc. Draft plan presented to public at series of hearings or workshops for public comment.
2. Alternative 2.
   Once draft plan is developed by Subwatershed group, work shops, hearings or other forums to solicit public comment are scheduled by group or individual permittees.

5. Information Sources and Technical Assistance

1. MDEQ, EPA & MDNR - General Information on watershed management, storm water management, ecological restoration, etc. Specific information on Rouge River including, Rouge River Remedial Action Plan and Rouge River Watershed Fisheries Assessment. See MDEQ Guidance for General Storm Water Permit for specific documents that are available or call Cathy Bean at the MDEQ Surface Water Quality Division District Office at 734.953.1441 or Roy Schrameck at 734.953.1431.

2. Rouge Program Office - Technical reports on a variety of topics related to storm water management and pilot projects; examples of public information materials; water quality data; summaries of demographic, land use and related information by subwatersheds; GIS maps with various coverages by subwatershed; and draft subwatershed reports. See Rouge Project Catalog of Publications for list of specific materials that are available or call Sharon Cummings at the RPO at 313.964.8876.

6. Timing of Steps

   1. Subwatershed Group, Lead and Organization
      Agree on participants, lead and organizational issues while application for coverage is being prepared and MDEQ approval pending (before Feb.1, 1999).

   2. Grant Application for Rouge Project Funding
      Prepare grant application when participants, lead and organization is finalized and Certificate of Coverage is imminent (before Feb. 1, 1999).

   3. Preparation and Submittal of Coordinated Public Participation Plan
      Submit coordinated public participation plan (within 90 days of receiving COC)

   4. Prepare Plan, Conduct Public Participation, Submit Plan
      Prepare subwatershed management plan with public participation, submit draft plan for MDEQ review (within 18 months of receiving COC or later date specified in COC).

   5. Respond to MDEQ Comments (no time limit specified, up to 90 days for MDEQ review)

   6. Prepare and Submit Pollution Prevention Initiative
      Each permittee must submit to MDEQ for approval a Pollution Prevention Initiative with a specific schedule for actions consistent with subwatershed plan (within 18 months after receiving COC or later date specified in COC)

   7. Implement Approved Storm Water Pollution Prevention Initiative (immediately after approval)

   8. Determine if Plan needs to be Revised and Revise
      Determine whether plan needs revisions (within 180 days before permit expires). Revise plan if needed (submit any needed revisions with request for continuation of permit coverage prior to expiration).

Please address all comments and suggestions about the contents of this Web page to rougeweb@co.wayne.mi.us.

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.