Stormwater Management Program - City of Bellingham

2015

City of Bellingham

Public Works Department

Storm and Surface Water Utility

Bellingham, WA

April 24, 2015, 2015

City of Bellingham Stormwater Management Program

Attachment A to the NPDES Phase II Permit Annual Report

City of Bellingham 2015 Stormwater Management Plan

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FORWARD This document serves as an attachment to the City of Bellingham's annual report submittal to the Department of Ecology to meet the requirements of the Western Washington Phase II Municipal Stormwater Permit (WAR04-5550) under the National Pollutant Discharge Elimination System. This Stormwater Management Plan (SWMP) is prepared to demonstrate the City’s understanding of and commitment to fully meeting the regulatory requirements of this permit. The SWMP is a dynamic document that will be updated on an annual basis and will be integral to our permit compliance. It should be noted that this year our annual capital programing has been added to the document. This portion of the report is not a requirement of the current NPDES permit. The inclusion of this information is not to create a duty on the City to continue this program as a part of our required NPDES program. The information is to provide the citizens of Bellingham a more comprehensive view of stormwater programs that are funded through our rates and fees.


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TABLE OF CONTENTS

1.0 INTRODUCTION .......................................................................................................................... 1

1.1 Document Organization ....................................................................................................................... 1

2.0 STORMWATER MANAGEMENT PROGRAM DEVELOPMENT (S5.A and S5.B) .................................. 2

2.1 Permit Requirements ............................................................................................................................ 2

2.2 Notable Accomplishments .................................................................................................................... 2

2.3 City Organizational Responsibilities for the Stormwater Management Program ............................. 4

2.4 Plans for Program Activities in 2015 .................................................................................................... 6

3.0 PUBLIC EDUCATION AND OUTREACH (S5.C.1) .............................................................................. 6

3.1 Permit Requirements ............................................................................................................................ 6

3.2 Program Overview ................................................................................................................................ 6

3.3 Accomplishments in 2014 ..................................................................................................................... 7

3.4 Plans for Program Activities in 2015 .................................................................................................. 10

4.0 PUBLIC INVOLVEMENT AND PARTICIPATION (S5.C.2)................................................................. 13

4.1 Permit Requirements .......................................................................................................................... 13

4.2 Program Overview .............................................................................................................................. 13

4.3 Accomplishments in 2014 ................................................................................................................... 13


5.0 ILLICIT DISCHARGE DETECTION AND ELIMINATION (S5.C.3) ....................................................... 14



5.3 Accomplishments for 2014 ................................................................................................................. 17


6.0 CONTROLLING RUNOFF FROM NEW DEVELOPMENT, REDEVELOPMENT AND CONSTRUCTION SITES (S5.C.4) ....................................................................................................................................... 18





7.0 POLLUTION PREVENTION AND OPERATION AND MAINTENANCE FOR MUNICIPAL OPERATIONS (S5.C.5) 22


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8.0 MONITORING (S8.C.1.b and S8.C.2)........................................................................................... 25




9.0 CAPITAL PROJECTS and RETROFITTING (Not Required by NPDES) ............................................... 27


9.2 Fish Passage Improvements ............................................................................................................... 28

9.3 Retrofitting .......................................................................................................................................... 29

9.4 Six Year Capital Program .................................................................................................................... 29

List of Tables

Table 1: City Organizational Responsibilities for the NPDES program ......................................... 5

Table 2: Education and Outreach Activities Undertaken In 2014 ...............................................11

Table 3: Public Involvement Opportunities Undertaken in 2014 ................................................13


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1.0 INTRODUCTION

Stormwater runoff from streets, parking lots, construction sites, industrial properties, and residential areas

is now recognized as one of the leading sources of pollution to our streams, lakes, wetlands, and Puget

Sound. Of heightened concern for the City of Bellingham is the quality of water in Lake Whatcom, the

source of drinking water for over 100,000 city and county residents. To address stormwater pollution, the

City of Bellingham (City) established a Storm and Surface Water Utility in 1990 and since the onset of the

utility has been developing and refining its Stormwater Management Program (SWMP). While the City has

been actively managing stormwater for decades, the City was officially designated in 2007 by the

Environmental Protection Agency and the Washington State Department of Ecology as one of thousands of

municipalities in the United States requiring a special stormwater permit: the Western Washington Phase II

Municipal Stormwater Permit (Permit) under the National Pollutant Discharge Elimination System (NPDES).

The City has expanded its stormwater program to meet the terms and conditions of this permit, including

revised requirements of the current 5-year permit extending through 2018.

The Phase II Permit allows municipalities to discharge stormwater from municipal systems into “waters of

the state” such as streams, lakes and Puget Sound, as long as there are programs in place to reduce

pollutants in stormwater to the “maximum extent practicable”. Stormwater runoff from the City of

Bellingham discharges to five urban streams, Lake Whatcom, Lake Padden, Bellingham Bay, and Chuckanut

Bay. Improving habitat and water quality in these streams and lakes was identified as one of the top

priorities in the City's Legacies and Strategic Commitments to its citizens and is a component of many other

City programs such as the Lake Whatcom Management Program, Bellingham Water Quality Improvement

Plans, Habitat Restoration Plans and the downtown renovation and waterfront restoration programs.

Requirements under the NPDES Phase II Permit provide the City additional opportunities to accomplish

cleaning up the City's streams and furthering protection of Lake Whatcom.

1.1 Document Organization

This document is organized by program components in the order found in Condition S5C of the Phase II

Permit. To facilitate cross-reference with the permit language, each permit item is presented along

with the associated permit section indicator in parentheses as follows:

Section 2.0 addresses the Stormwater Management Program Development (S5.A & S5.B)

Section 3.0 addresses the Public Education and Outreach Component (S5.C.1)

Section 4.0 addresses the Public Involvement and Participation Component (S5.C.2)

Section 5.0 addresses Illicit Discharge Detection and Elimination (S5.C.3)

Section 6.0 addresses Controlling Runoff from New Development, Redevelopment and Construction Sites (S5.C.4)

Section 7.0 addresses Pollution Prevention and Operation and Maintenance for Municipal Operations (S5.C.5)

Section 8.0 addresses Monitoring (S8)


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2.0 STORMWATER MANAGEMENT PROGRAM DEVELOPMENT (S5.A and S5.B)

2.1 Permit Requirements

Sections S5.A and S5.B of the Phase II Permit as reissued by Ecology on August, 2012 require the City to:

Develop and implement a Stormwater Management Program and submit annual compliance reports

Manage an ongoing program for gathering, tracking, maintaining and using information to evaluate the SWMP development, implementation and permit compliance and set priorities

Track the cost of the development and implementation of the SWMP

Track the number of inspections, official enforcement actions and types of public education

Coordinate with other NPDES permittees and partners in the region on stormwater related policies, programs, and projects

Coordinate internally among City Departments

2.2 Notable Accomplishments

The City of Bellingham has been proactively managing the quality of stormwater for 25 years using a

variety of approaches designed to control runoff, treat runoff, reduce pollutant sources, and employ

adaptive management. Over the course of the first Phase II permit term (2007-2012), the reissuance

year (2012-2013), and the beginning of the second Phase II permit (2013-2018), the City continued to

build a strong stormwater program adding depth to existing programs and increasing staff as needed.

Through education and the use of incentive programs, the City has engaged a variety of audiences in

stormwater issues; from classroom children and rain garden planting volunteers, to focus groups

targeting restoration options and survey respondents documenting behavioral changes. Stormwater

control and treatment has been accomplished through implementing Best Management Practices

(BMPs) and development standards, designing and building capital projects for new treatment facilities

and retrofitting older public facilities. The City has worked with businesses on pollutant source control

as well as individual homeowners to reduce runoff and pollution from their properties. All of these

strategies work in unison to form a multifaceted program that addresses stormwater quality and meets

the six Phase II permit elements: education and outreach, public involvement, illicit discharge detection

and elimination, runoff control from new development and redevelopment, good housekeeping in all

facets of municipal operations, and water quality monitoring. The City's stormwater code has been

revised four times (1990, 1995, 2006, and 2009) to reflect new information on the water quality in Lake

Whatcom as well as to comply with the NPDES permit requirements.

The City works very closely with other local jurisdictions to coordinate stormwater efforts citywide and

in the Lake Whatcom Watershed. The City has partnered with other Phase II permittees in Whatcom

and Skagit County to support Stormwater University, operated by RE Sources for Sustainable

Communities, to provide workshops and educational materials targeted at businesses, industries, and

municipal staff. Other examples include the recent joint purchase of a high-efficiency street sweeper

that is being shared by four NPDES Phase II permit holders in Whatcom County and a study undertaken

in conjunction with the Port of Bellingham to screen the stormwater quality from outfalls entering

directly into Bellingham Bay.

http://www.cob.org/services/environment/stormwater/images/new-sweeper.jpg


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The Lake Whatcom Management Program is a joint effort of the City of Bellingham, Whatcom County,

and Lake Whatcom Water and Sewer District (formerly Water District 10) to protect Lake Whatcom as a

source of drinking water. The main focus of efforts is on reducing the pollutant load and the amount of

stormwater entering the lake. While there are many constituents typically associated with urban

stormwater, including suspended solids, metals, and nutrients, phosphorus has become the foremost

pollutant of concern to Lake Whatcom’s health. For the past several years, the City has focused on

evaluating the effectiveness of these efforts, documenting increased removal rates for both phosphorus

and fecal coliform levels. In addition, the City is active in the land preservation program which aims to

reduce water quality impacts by preserving land within the Lake Whatcom Watershed that might

otherwise be made available for development.

The City's Storm and Surface Water Utility is constantly evaluating, retrofitting, and improving

Bellingham's stormwater system and has completed many projects to date. The City operates 5

regional detention facilities and continues to be a leader in integrating low impact development (LID)

techniques into infrastructure. Currently, the City is investing heavily in retrofitting stormwater

facilities in the Lake Whatcom Watershed and in our downtown area. Noteworthy retrofit projects

begun or completed during the 2014 period include the installation of 36 bioretention cells within the

Central Business District and improvements along the shoulder of Northshore Drive. The Central

Business District improvements, known as the Downtown Improvement Gardens (DIG), prevent

urbanized pollution from reaching Whatcom Creek from a previously untreated 90-acre basin. The

Northshore Drive Water Quality Improvements targeted phosphorus loading from 36 developed acres

draining to Lake Whatcom. The improvements at Bloedel-Donovan Park targeted phosphorus and fecal

coliform loading from a heavily used, and heavily maintained, public park located near the outlet of the

Lake into Whatcom Creek.

Additional highlights from the 2013-2014 period include 176 infiltration, dispersion, and/or re-

vegetation projects on private properties in the watershed as part of the Homeowner Incentive

Program. The City applied for grant and loan funding for 8 projects in 2014. Draft funding lists

published by the Department of Ecology indicate that all 8 projects qualify for grant and loan funding

totaling approximately 4.0 million dollars. Projects proposed and accepted for funding include:

o Lake Whatcom Watershed Phosphorus Treatment Retrofits

East Oregon St. Dispersion and Infiltration Facility

East North St. Infiltration and Treatment Facility

Britton Rd. Distributed Treatment Facilities

o High-Use Road Corridor Treatment Retrofits, Squalicum Creek Watershed

Meridian St. Water Quality Improvements

Sunset Drive Water Quality Improvements

o Public Works Operations Facility Water Quality Project

o Water Quality for Storm Main Replacements

o Vactor Truck Purchase


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2.3 City Organizational Responsibilities for the Stormwater Management Program

The City of Bellingham's Storm and Surface Water Utility (SSWU) Section in the Natural Resources

Division of the Public Works Department holds the primary responsibility for developing and

implementing the stormwater program and tracking Phase II Permit requirements. Within the Public

Works Department, the Engineering and Operations divisions also hold integral roles in implementing

the components of the stormwater program. The program is also supported by Planning & Community

Development, Fire, Police, and Parks and Recreation (Table 1). Internal coordination between these city

divisions occurs regularly as issues arise (e.g. handoff between construction inspectors and the private

facility inspector, incident response and follow-up actions to stormwater violations) and more formally

through stormwater committee meetings, safety meetings, and Operations and Engineering

coordination meetings.


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Table 1: City Organizational Responsibilities for the NPDES program

City Department Description of NPDES Stormwater Responsibilities

Public Works/ Natural Resources Division/Storm & Surface Water Utility Section

Administers and develops the program and coordinates with other divisions within the City and other NPDES jurisdictions

Education and Outreach

Public Involvement

Illicit Discharge Detection and Elimination program including local source control & dry weather monitoring

Stormwater incident response

Private facility inspections

Municipal staff training

Pollution prevention practices

Integrated Pest Management Plan

Annual Reporting

Planning & Community Development

Permit Center provides first contact for new or redevelopment stormwater permits and distributes NOI

Public Works Engineering - Development Section

Site Plan Review for stormwater permits

Public Works Engineering

Capital projects -stormwater facilities and retrofits Construction stormwater inspections pre, during and post -construction

Public Works Advisory Committee Annual review of stormwater program

Public Works - Operations - Surface and Stormwater Division

Maintenance of public stormwater facilities; stormwater incident response

Fire Department First responder to stormwater incident if called

Police Department First responder to stormwater incident if called; code enforcement for stormwater violations

Parks and Recreation Integrated Pest Management Plan

Public Works - Laboratory Water quality sample analysis for illicit discharge characterization Urban Streams Monitoring Program


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2.4 Plans for Program Activities in 2015

The City plans to continue work on stormwater issues at a level commensurate with 2014 efforts,

building on systems and procedures developed throughout the first permit cycle.

3.0 PUBLIC EDUCATION AND OUTREACH (S5.C.1)


Section S5.C.1 of the Permit requires the City to address the following public education and outreach elements:

Develop a program that targets specific audiences including general public, businesses, homeowners, landscapers, property managers, engineers, contractors, developers, and City employees including review staff and land use planners

Develop a program that aims to reduce or eliminate behaviors and practices that cause or contribute to adverse stormwater impacts

Measure improvements in the target audience’s understanding of the problem and what they can do to solve it. Use this information to improve the education program

Track and maintain records of public education and outreach activities

3.2 Program Overview

The City of Bellingham has developed and implemented a comprehensive stormwater education and

outreach program with the goal of increasing awareness of stormwater pollution issues. The program

strives to provide tools, assistance, and incentives to reduce or eliminate behaviors and practices that

cause or contribute to adverse stormwater impacts. City staff emphasize the importance of

environmental education and technical assistance in daily interactions with the Bellingham community.

Through both broad-based educational efforts aimed at

the general public and targeted resources for specific

businesses, contractors, stormwater facility owners, or

municipal staff, the City has compiled a library of

resources ready for scheduled presentations or available

on hand as educational opportunities arise. Pollution

prevention factsheets and brochures are routinely

distributed to specific audiences and many of the

resources are available on the City’s website.

Examples of targeted handouts include pet waste fliers,

car wash videos and car wash kits offered to charity

groups, the "We Keep It Clean Using the 4Cs" poster for

the auto industry, and good cleaning practices for the

food and restaurant industry. Specific educational

efforts that reach the youth in our community include an

The Homeowner Incentive

Program (HIP) 2014 efforts

resulted in 24 projects to

reduce stormwater runoff in

the Lake Whatcom Watershed

and demonstration projects

underway at two local

elementary schools.


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interactive stormwater grade school education program tailored for 5th graders and the "Only Rain in

the Drain" storm drain marking program in partnership with RE Sources for Sustainable Communities.

City educators are active in STORM, the Stormwater

Outreach for Regional Municipalities group, participating in

meetings, roundtable discussions, and giving presentations.

The City’s education team also works with local partners to

provide workshops on LID techniques, rain garden and

stormwater facility /detention pond maintenance. Local

stewards and restoration groups are also a priority for City

educators as they support groups such as NSEA, the People

for Lake Padden, the Chuckanut Bay focus groups and Lake

Whatcom Stewards.

Through the Homeowner Incentive Program (HIP), the City

conducts low impact development outreach by providing

technical and financial assistance to City residents living in

the Lake Whatcom Watershed. Educational services

provided through HIP include site assessments, project

design and permitting assistance.. HIP-eligible projects

protect water quality by reducing sources of phosphorus,

improving stormwater treatment, encouraging infiltration,

or a combination of best management practices for

phosphorus control. Project examples include native planting areas, phosphorus-limiting rain gardens,

infiltration trenches and permeable paving.

Through experiences, lessons learned, and public feedback the City continues to improve the education

program. In particular, the use of customer surveys, both pre and post-education contact, have helped

measure improvements in the target audience’s understanding of the problem and document

behavioral changes.

3.3 Accomplishments in 2014

The City of Bellingham undertook many educational activities that brought stormwater information to a

variety of audiences. Highlights include the Homeowner Incentive Program, the pet waste home

scooping project, the Spills Happen campaign and the school programs. In addition, the City has

partnered with RE Sources, Whatcom County, and Washington State Extension to carry out joint public

education and outreach activities. Table 2 summarizes education and outreach activities undertaken

by the City of Bellingham and partners during 2014 and the following paragraphs highlight a few of the

efforts.


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Homeowner Incentive Program

There were 69 completed HIP projects and194

total on-site consultations ranging from initial

site assessments to construction assistance to

final inspection. A total of 176 phosphorus-

limiting BMPs were installed in 2014. A HIP

demonstration project at Silver Beach

Elementary School included a planting project

engaging approximately 80 students from the

school. . Education presentations regarding the

HIP were delivered to various homeowners associations, the Silver Beach Neighborhood Association,

professional peer groups at other municipalities, and one large community event. This event, titled the

"Lake Whatcom Solutions Workshop" was attended by representatives of over 80 properties in the

Lake Whatcom Watershed, was intended to provide a one-stop-shopping opportunity for homeowners.

The workshop provided overview-level education, detailed and personalized service, and access to

landscape design professionals at no cost.

Pet Waste Management

City staff promoted messages of proper pet waste disposal on

residential properties through a grant from Puget Sound Partnership.

Using social marketing strategies, staff developed a program to

incentivize dog owners to scoop at home at least once a week and

dispose of dog waste in the trash. Using audience research from pre-

program surveys and focus groups, City staff focused on reducing the

barriers to scooping at night and in inclement weather, and reinforcing

the message that the trash is the best place to dispose of dog waste.

Displays and activities at local pet events, including the Dog Days of

Summer and the Paws & Claws Expo were adapted to fit our "We Scoop

at Home" program messages.

School Programs

City educators offer a water education program, "Sharing

our Watersheds", centered on watersheds, the Lake

Whatcom Watershed, the drinking water and wastewater

treatment processes, water conservation and stormwater

pollution prevention. The curriculum is designed for 5th

grade students and was conducted at 18 local schools in

2014 reaching 920 students. The program involves tours of

treatment facilities as well as in-class education sessions.


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Student groups watch the video "Lost in Puget Sound" and prepare small group presentations about

local stormwater pollutants such as oil and gas, fertilizer, pesticides, pet waste, phosphorus, sediment,

litter, and soap. At a follow-up visit, students present their stormwater pollution information to City

educators. When finished, they receive a Drain Ranger certificate to remind them of their pledge to

keep our waterways clean.

Spills Happen Campaign

As part of the Department of Ecology

"Stormwater University" grant, the City

extensively promoted the "Spills Happen: Only

Rain Down the Drain" campaign and the City's

stormwater hotline using a colorful and engaging

graphic originally produced for Kitsap County.

Ads were placed in various media channels,

including bus ads, print and online newspaper

ads, movie theaters, and a utility bill insert. Two 30-second movie trailers, originally produced by the

STORM consortium, were played at the movie theater. Stickers and magnets with the graphic were

made and distributed to the public and businesses at public events and neighborhood meetings and

through Local Source Control business visits.

Neighborhood Association Meetings

City staff presented at two neighborhood association

meetings for the Fairhaven and Puget neighborhoods.

The presentation provided details on the work of the

City stormwater division, water quality monitoring data,

practices residents can implement to protect water

quality, and forthcoming capital projects that will treat

stormwater in the area. City staff have offered to give

this presentation and meet with all the neighborhood

associations. Additional presentations are being

conducted in 2015.

Business Sector Education

City staff conducted 110 site visits to local businesses

providing technical assistance on pollution prevention

practices. Business owners receive one-on-one

education on good housekeeping practices specific to

activities they are conducting such as proper storage

and disposal of automotive chemicals, cleaning

2014 General Educational Materials

Facts and Figures

300 phosphorus brochures

delivered to retailers 300 HIP booklets distributed 980 School aged children learned

about watersheds and took the Drain Ranger Pledge

1,000 pet waste fliers inserted into

Whatcom Humane Society mailings

120 dog owners pledged to scoop the poop at home at least weekly, bag it and put it in the trash.

http://www.seattlechannel.org/videos/video.asp?ID=5917


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products, wood finish and paint, cooking grease, and other hazardous materials. In addition, owners

are assisted with locating and maintaining their storm drains and the impacts of illicit discharges, how

to report them, and how to prevent them by using BMPs. In 2014, the food industry, restaurants, and

property managers were the primary target sectors. Other visits were made to concrete contractors,

laboratories, long term care facilities, pressure washers, and grocery stores.


The City plans to continue work on stormwater education and outreach at a level commensurate with

2014 efforts building on systems and procedures developed throughout the first permit cycle.

The City is partnering with Whatcom County to complete a detailed assessment of the pilot phase of

HIP. This assessment will serve as the basis for formative research needed to create targeted outreach

for the next version of the residential program. This research will include interviews, surveys, and focus

groups and will be integrated into 2015 (and beyond) offerings for residential incentive programs in the

Watershed.


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Table 2: Education and Outreach Activities Undertaken In 2014

Education/ Outreach Activity Description Targeted Audiences

Spills Happen Campaign

Two months of promotional advertising for the City's Stormwater Hotline and the "Only Rain Down the Drain" campaign. Media channels included:

Local newspaper ads

Bus ads

Movie theater trailers

Utility bill insert

Stickers and magnets for the public and businesses

General public

Homeowner Incentive Program (HIP)

One-on-one homeowner education:

194 personalized site visits

40 New HIP Project Assessments

69 HIP Final Inspection visits - including maintenance education Group Education:

HIP presentations delivered to City and County Councils, Lake Whatcom groups, other jurisdictions, and the public -195 attendees

Contractor Education:

Held meetings involving nearly 80 local contractors, material suppliers, and professionals to introduce them to HIP and support their use of the program within their marketing materials.

Homeowners in City portion of the Lake Whatcom Watershed, general public interested in Lake Whatcom Restoration Programs

BTV10 aired programs on stormwater

Lake Whatcom Challenge, Puget Sound Starts Here public service announcements

General public

Educational Events

World Water Day - 60 attendees, ~400 passive audience read trail signs

Pet waste display and activity at Paws and Claws Expo & Dog Days of Summer - 92 contacts

5th Grade School Programs - 18 elementary schools- 980 students

Whatcom Water Weeks Public Works Downtown Tour - 20 contacts

Neighborhood stream clean-ups (Hanna, Fever, Lincoln, and Cemetery) - 29 volunteers

General public, elementary school students, pet owners


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Education/ Outreach Activity Description Targeted Audiences

Online Outreach

City website has resources and links to stormwater resources www.cob.org/stormwater Videos on City website and City YouTube channel, including What's the Scoop About Healthy Streams video and Stormwater University videos

General public, business owners

Educational Materials Distributed educational materials to many audiences (sidebar on page 11) Car wash kits were loaned to 3 charities

General public, pet owners, lake residents

Surveys Home Pet Waste Pickup Behavior Baseline Survey (Applied Research Northwest)

Residents, pet owners

Local Source Control 110 businesses were visited and educated on good housekeeping practices for pollution prevention

Businesses, industries

Neighborhood Meetings Two stormwater presentations at neighborhood association meetings for the Fairhaven and Puget neighborhoods - 40 attendees

General public

Water Use Efficiency Outreach

2 rainwater demonstration projects with a total storage capacity of 3,250 gallons

3 workshops with a total of 38 participants

3 tours with a total of 55 participants

General public


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4.0 PUBLIC INVOLVEMENT AND PARTICIPATION (S5.C.2)


Section S5.C.2 of the Permit requires the City to address the following public involvement and participation elements:

Provide ongoing opportunities for public involvement in the SWMP process through committees/commissions and updating the SWMP

Make the SWMP and Annual Compliance Report available to the public, including posting on the City’s website


The Bellingham public is invited to participate in stormwater decision-making. Opportunities include the

City’s Public Works Advisory Board, City Council meetings, Community meetings, public hearings,

neighborhood association meetings, focus groups, community surveys, and webpage communications.

The City also solicits public comment through press releases specific to projects and code updates, and

leisure guide advertisements. Status reports on the Stormwater Management Program were presented

at the monthly Public Works Committee meetings. In addition, the current SWMP and Annual

Compliance Report were made available to the public by posting downloadable versions on the City’s

website and a copy is available for public review at City Hall.


Public involvement opportunities to comment on the stormwater program in 2014 are summarized in

Table 3. In addition, the Department of Ecology has granted the City of Bellingham funding to help

improve the water quality in Whatcom Creek by installing 36 rain gardens in strategic locations in

downtown Bellingham to help treat and infiltrate stormwater from over 90 urban acres. The Downtown

Improvement Garden Program (DIG) will work with downtown businesses to “adopt” rain gardens,

often replacing existing parallel parking spots, aiming to improve local water quality while beautifying

downtown neighborhoods.

Table 3: Public Involvement Opportunities Undertaken in 2014

Public Involvement Opportunity Description of Opportunity

City Council Meetings City Council holds weekly meetings that are open to the public

Public Works Advisory Board Annual review of Stormwater Management Program

Website posting of SWMP and Annual Report

Downloadable versions of the current stormwater management documents are available to the public on the City website

Downtown Improvement

Gardens (DIG) Program

encourages businesses to

become stewards of rain

gardens


Page 14


The City plans to offer public involvement opportunities similar to those offered in 2014.

5.0 ILLICIT DISCHARGE DETECTION AND ELIMINATION (S5.C.3)


Section S5.C.3 of the Permit requires the City to address and/or maintain the following illicit discharge detection and elimination (IDDE) elements:

Develop an ongoing program to detect and remove illicit discharges, connections, and improper disposal, including any spills into the municipal separate storm sewers owned or operated by the City

Develop a map of the municipal storm sewer system

Implement an ordinance that prohibits illicit discharges, and create a program to detect and address illicit discharges

Publicize a hotline or other local telephone number for public reporting of spills and other illicit discharges

Train staff on proper IDDE response procedures

Track all spills, illicit discharges and connections reported to the City and response actions taken, including enforcement actions


The City has developed and implemented an ongoing program to detect and remove illicit discharges

and connections into the City’s MS4. A comprehensive GIS mapping system of its Municipal Separate

Storm Sewer System (MS4) has been in place for many years. The map contains all known municipal

storm sewer outfalls and receiving waters, and structural stormwater BMP’s owned or operated by the

City. All known private stormwater facilities are mapped as well. The City tracks and locates all outfalls,

retains development records, and continually updates the map as new facilities come online. Records

are also refined as new information becomes available. All City staff and the public as well have access

to the stormwater system attributes through the CityIQ Online Map Viewer which allows searches for

Bellingham-area information. While many features are available in the GIS system, the City also has a

Comprehensive Stormwater Management Plan that developed a customized application of the Western

Washington Hydrology Model version 3 (WWHM3) to evaluate the hydrology and hydraulics of the

City's stormwater system components.

Through Bellingham Municipal Code 15.42.020.U and 15.42.020.C, the City prohibits non-stormwater

illegal discharges, and/or dumping into the City's MS4. The enforcement of all stormwater code

provisions including illicit discharges is provided for in BMC 15.42 subsections 070-110. Illicit discharges

were prohibited in the 1995 adopted code however the language was refined in the 2009 ordinance to

fully reflect the NPDES permit language. The City is active in the enforcement of illicit discharges and

continues to respond to more incidences.


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Over the course of the first permit, the City implemented procedural changes to IDDE program

components as new staff came on board and interdepartmental coordination was established. City

staff utilize many methods to discover and trace illicit discharges and IDDE problems including visual

observation and chemical analysis, internal pipe scanning, stormwater outfall monitoring/dry weather

monitoring, and source control inspections. The city also uses customer information to identify and

resolve stormwater issues.

A stormwater hotline number (360-778-7979) is posted on the City's website and also publicized on the

newer storm drain markers throughout the City. The SSWU staff is ready to record and respond to all

calls regarding illicit discharges or illegal spills that are received on the hotline. All valid inquiries are

followed up as necessary to resolve the issue. Follow-up actions are tracked and feedback is given to

the initiators as well as Ecology as necessary. The City has also both received and sent information thru

the Ecology ERTS system and responds similarly providing closure information back to Ecology. Ecology

staff in Bellevue and Bellingham have been very helpful in aiding our processes.

SSWU staff respond to most stormwater incident call-outs to assess

the situation and plan follow-up actions to resolve them. For

incidences that reach the MS4, SSWU staff work with the Storm

Operations crew and a vactor truck is used if needed. Fire and Police

are often the first responder; however, if it is not a hazardous

materials situation, they are trained to call SSWU responders and the

Storm Operations crew. All SSWU vehicles, Storm Operations crew

vehicles, and many other departmental vehicles have spill kits for

containment and cleanup of small spills. The Storm Operations crew

receives training on spill response and through stormwater

committee meetings and safety meetings any additional questions or

concerns are addressed. The COB Emergency Response Plan for

Public Works Operations: Water, Wastewater, Stormwater Chapter 8

Water Quality Contamination, and Checklists 10 and 11 Hazardous Materials Spill to Streets or Storm

Water System cover procedures for spill response.

In addition to responding to illicit discharge incidents, the City is proactive in tracing the source of illicit

discharges. The City of Bellingham has been utilizing system scanning since 2003 to both discover illicit

discharges and trace the sources as well as to detect maintenance issues. The crew has been trained to

look for signs of non-stormwater discharges from private piping entering our system. Signs of staining,

foam, discolored discharges are all indications that would be a part of the condition report of the piping

system. This information is provided to the supervisor but is also logged into system reports for future

referral. Since 2006, the City has reviewed over 80% of our total of 28 square miles of stormwater

network. The initial effort captured older infrastructure in the Central Business District and known

problem areas. Crews have since proceeded by ¼ sections starting in the northwest moving east and

then south. This system review has resulted in locating many problems including misconnections and

suspicious flows.


Page 16

The City also identifies illicit connections through its dry weather outfall inspection program which was

initiated in 2004. Information from the dry weather studies has been useful in identifying stormwater

problems ranging from sewer/stormwater service line cross connections, leaking water valves, pet

waste mismanagement, pest waste, and yard waste mismanagement. When samples from flowing

outfalls indicated a problem, GIS information was used to track the pathways up the stormwater

system. Even though there were some years were no illicit discharges were pinpointed, evidence of

non-point source pollution or remote-source illicit discharges was typically documented. For these

years, the studies were helpful in directing septic failure investigations and guiding the pet waste

education efforts.

The priority of field assessment on City streams was

based on the level of water quality impairment and 303d

listing parameters. Outfall inspections were conducted

during dry weather in accordance with the Center for

Watershed Protection’s Illicit Discharge Detection and

Elimination Guidance Manual. To date, outfall

inspections have been conducted on:

Lake Whatcom and Silver Beach Creek in 2004

Whatcom Creek and Tributaries in 2004

Padden Creek and Tributaries in 2005

Squalicum Creek and Tributaries in 2006

Whatcom Creek and Tributaries in 2007, repeated to support TMDL efforts

Lake Whatcom and Silver Beach Creek in 2008 repeated to support TMDL efforts

Bellingham Bay in 2012 in conjunction with the Port of Bellingham

Whatcom Creek wet weather sampling in 2011 and 2012 to support TMDL efforts

Connelly and Fever Creeks wet weather sampling in 2014 to support TMDL efforts

The City, through our Local Source Control (LSC) Partnership with Ecology, provides technical assistance

and pollution prevention education to businesses

and industries. The City evaluates priority

businesses and industrial activities likely to have

illicit discharges and provides technical assistance

to these entities on ways to reduce sources of

pollution. Site visits with businesses include in-

depth surveys of current practices. The focus is to

examine hazardous material storage and disposal,

outdoor storage, catch basin maintenance, and

the potential for stormwater contamination.

Good housekeeping practices are commended


Page 17

and corrective actions are discussed. Follow-up letters, if necessary, are sent to establishments

highlighting the good practices and itemizing the practices that need to be corrected along with

recommendations on how to remedy them. Certain high priority environmental issues trigger an

automatic follow-up visit. During these visits the City is able to note business practice changes or

continue with education to correct persistent problems. Program staff also deal directly with these

businesses on illicit discharges either reported or imminent. Dye testing is used in cases where

questions arise about the storm / sewer network.

Over the period of the first three contract cycles (2008-2013), the LSC program focused technical

assistance visits on high-risk sectors including boat repair, printers, photo processors, dry cleaners,

landscapers, nurseries, dentists, veterinary clinics, gas stations, painters, pharmacies, auto body, auto

repair shops, wood workers, metal workers, and scrap recyclers. During the 2013-2015 biennium, the

LSC program has focused on other sectors, including jewelers, restaurants, property managers, grocery

stores, and municipal facilities and operations. The visits have resulted in significant reductions in

stormwater pollution along with reduction in hazardous waste materials sent to our sewage treatment

plant.

Over the first permit term, the City has held IDDE trainings for the following crews: Surface and Storm,

Streets, Water, Sewer, and Traffic and Fire. During 2014, all municipal field staff completed an online

IDDE training. Public Works inspectors and supervisors have also been trained on illicit discharge

identification and procedures. Follow-up training occurs at staff meetings and stormwater committee

meetings. The City has 65 Certified Erosion and Sediment Control Lead (CESCL) trained personnel on

staff.

5.3 Accomplishments for 2014

The City has taken many steps to identify and eliminate illicit discharges in 2014. Knowledge of City

infrastructure improves as the City's comprehensive map of its MS4 continues to be updated. The Spills

Happen Campaign promoted the City Stormwater Hotline and "Only Rain Down the Drain" for two

months via various media channels, including bus ads, print and online newspaper ads, a utility bill

insert, and trailers at both movie theaters in town.

In 2014, the City added an online submission

form to the City's website for stormwater

incident reports from the public, augmenting

the existing 24-hour stormwater hotline. In

2014, the City responded to 203 hotline calls,

as well as an additional 55 notifications from

online reports, direct calls, emails, and ERTS

referrals. All incidents reported were

responded to in some manner. Some inquiries

were discussed with the caller and did not

require further action while others were


Page 18

forwarded on to a different department as appropriate. Most

inquiries were addressed by SSWU staff and follow-up

responses were tracked in the stormwater incident response

database.

Wet weather sampling of outfalls was conducted in the

Connelly Creek and Fever Creek basins in 2014. The

monitoring successfully identified high fecal coliform level

hotspots which helped to direct the pet waste education in

that basin. Through effective outreach and clean-up events,

awareness of fecal coliform contamination has increased among community members and fecal

coliform levels dropped significantly in one area.

Local source control staff completed 110 technical assistance visits in 2014. The food industry,

restaurants, and property managers were the primary target sectors. Other visits were made to

concrete contractors, laboratories, long term care facilities, pressure washers, and grocery stores.

IDDE training of SSWU personnel occurred frequently at staff meetings. The Stormwater Committee

met every two months in 2014 and served as a forum for training staff from other divisions and

departments. The City developed an online IDDE training for all City field staff and it was completed by

197 City field staff from the Police, Fire, Public Works and Parks departments. SSWU Staff also

participated in:

Webinars on stormwater monitoring, stormwater BMPs, pesticides and human health, safer cleaning products, etc.

Monthly conference call presentations and quarterly in-person trainings with regional Local Source Control Specialists on topics such as L&I safety, stormwater toxicology, low impact development, database training, chemicals of emerging concern, and waste designation.

Annual Regional North American Hazardous Materials Management Association conference


The city plans to continue responding to illicit discharges at a commensurate level of effort as in 2014.

6.0 CONTROLLING RUNOFF FROM NEW DEVELOPMENT, REDEVELOPMENT AND CONSTRUCTION SITES (S5.C.4)


Section S5.C.4 of the Permit requires the City to address the following elements regarding controlling runoff from new development, redevelopment and construction sites:

Develop, implement, and enforce a program to reduce pollutants in stormwater runoff discharging to the municipal separate storm sewer system from new development, redevelopment, and construction site activities

In 2014, 110 business were

provided technical

assistance on pollution

prevention techniques


Page 19

Adopt an ordinance to address runoff from new development, redevelopment, and construction activities from both public and private sites using Appendix 1 as the standard.

Retain existing local requirements to apply stormwater controls at smaller sites or at lower thresholds than required pursuant to S5.C.4

Develop and implement a planning process for development that includes plan review, inspection, and enforcement capability

Provide copies of the Notice of Intent for construction or industrial activities to representatives of the proposed new development and redevelopment

Provide training to staff on the new codes, standards, and standard operating procedures

Develop a process to record and maintain all inspections and enforcement actions by staff


The City has developed, implemented, and enforced a program to control runoff from new

development, redevelopment, and construction site activities. In 2006 and 2009, the City updated its

stormwater code to address construction runoff control from both public and private sites using

language consistent with the "Technical Thresholds" in Appendix 1 of the Phase II Permit. However,

since the adoption of the City's initial stormwater ordinance in 1995, a permitting, inspection, and

enforcement program has been in place that is more restrictive than the Appendix 1 thresholds. The

City requires some form of erosion control on all projects that exceed 120 square feet of impervious

surfaces or disturb more than 500 square feet of soil. These local requirements have been retained as

the City continues to regulate stormwater from smaller sites or at lower thresholds than required

pursuant to S5.C.4. Sites that trigger the Appendix 1 thresholds receive more detailed reporting,

increased inspection frequencies, and additional compliance items as necessary to meet the Phase II

Permit requirements.

The City previously followed the planning process and BMP selection and design criteria outlined in the

2005 Stormwater Management Manual for Western Washington. The new 2012 Manual was adopted

by the City automatically at the time it was adopted by Ecology. Our permitting process includes site

plan review, inspection, and enforcement capability. Copies of the Notice of Intent for construction or

industrial activities are provided to project proponents. City databases are used to record permit

activity and maintain a record of all inspections and enforcement actions taken by staff.

The use of Low Impact Development techniques is promoted and encouraged through the stormwater

permit review process, educational outreach programs, and financial incentives. The City adopted

financial incentives for the use of LID techniques in the form of reduced stormwater development fees

in 2006 for any prospective project. In addition, residents in the Lake Whatcom Watershed taking part

in the Ecology Grant funded Homeowner Incentive Program (HIP) receive a free stormwater permit,

design assistance, and material reimbursement for completing an LID project.


Page 20

All permitted development sites are inspected by

qualified Public Works Department Inspectors for proper

erosion and sediment controls and appropriate

enforcement actions are taken as necessary to ensure

compliance. The City's inspection program includes site

visits prior to the onset of construction, during

construction and post-construction. Verbal warnings are

often given during inspections and corrections are made

when the inspector is present. When necessary

stormwater permit correction notices are issued listing

the items that do not comply with City codes along with required corrective actions. Stop work orders

are issued in cases where non-compliance persists and they remain in effect until additional inspections

show compliance. All permitted developments sites are inspected upon completion and prior to final

approval or occupancy to ensure proper installation of permanent stormwater controls and to verify

that a maintenance plan is in place. The City uses an escalating enforcement strategy of corrective

warnings, monetary ticketing, and if necessary the case is transferred to the City's legal staff.

The City's Private Stormwater Facility Inspection Program has two major components. The first priority

is the scheduling and inspecting of private facilities that trigger the NPDES annual inspection

requirement to ensure maintenance standards are met on post-construction private facilities.

Secondarily, the City inspects and provides technical assistance to owners of smaller or older private

facilities within the City’s jurisdiction. Private facilities built after 2007 that trigger the Appendix 1

thresholds are inspected annually unless inspection

records support a different frequency. Inspection

reports document conditions and itemize specific

maintenance corrective actions. Notification letters

are sent to the property owners along with the

inspection report and a timeline for action.

Typically, maintenance is required prior to the next

annual inspection however there are circumstances

that call for more frequent follow-up inspection and

the City continues to work with owners until

maintenance issues have been resolved.

Site plan reviewers, inspectors, city engineers and SSWU staff have had stormwater code training, DOE

manual training, and have attended permit overview workshops. Permit Center staff are trained

quarterly on the new codes, standards, and standard operating procedures. The City has 65 Certified

Erosion and Sediment Control Lead (CESCL) trained personnel on staff.


The Public Works Development Section reviewed 493 site plans in 2014. These plans were distributed

as follows into the four permit levels:


Page 21

248 level 1 permits for projects containing more than 300 square feet and less than or equal to

1,000 square feet of new or replaced impervious surface or containing more than 500 square feet

and less than or equal to 5,000 square feet or clearing or grading.

185 level 2 permits for projects containing more than 1,000 square feet and less than or equal to

5,000 square feet of new or replaced impervious surface or containing more than 5,000 square feet

and less than or equal to 30,000 square feet or clearing or grading.

46 level 3 permits for projects containing more than 5,000 square feet and less than or equal to one

acre of new or replaced impervious surface or containing more than 30,000 square feet of clearing

or grading.

14 level 4 permits for projects containing more than one acre of impervious surface.

The City continued to regulate stormwater from smaller sites or at lower thresholds than required

pursuant to S5.C.4 using local ordinances that were in place prior to the NPDES Phase II Permit.

City Stormwater Inspectors made 13,968 stormwater inspections during 2014. Verbal warnings and

corrective actions were delivered during many site visits. Stormwater permit correction notices were

issued to document 290 construction activities that were not in compliance with City stormwater code.

These sites were re-inspected until corrective actions

were taken. Nineteen stop work orders were issued

and 2 cases were sent to the legal department with 1

additional case pending legal referral.

The City continued its Private Stormwater Facility

Inspection Program which provides inspection and

documentation of 64 facilities that meet the

requirements for inspection. . Inspection records and

subsequent maintenance activities have

demonstrated that a few of the required private

inspections sites can be moved to a biannual

schedule.

In addition, the City provided technical assistance to 66 facilities that did not trigger NPDES

requirements

The Public Works Department staff viewed various webcasts on design of stormwater facilities,

implementing best management practices, and pollution prevention. The Development department

holds quarterly trainings for permit center staff on code changes and to help with outreach questions.

Many staff attended DOE municipal permit overview workshops and manual training. Additional

training included:

Washington State University LID Research Program Annual Review

Policy Forum on water quality standards


Page 22

Center for watershed protection Webinar/Webcast series: Retrofit This – A Guide to Retrofitting the World? Build This – Stormwater Retrofit Construction Issues

The Art of Retrofitting

Principals of Hydrology and Hydraulics?

Participation in STORM activities and opportunities

Participation in W. Washington APWA Stormwater Managers Committee

Participation in N. Sound Stormwater Managers Committee


The city plans to continue to control runoff at a commensurate level of effort as in 2014.

7.0 POLLUTION PREVENTION AND OPERATION AND MAINTENANCE FOR MUNICIPAL OPERATIONS (S5.C.5)


Section S5.C.5 of the Permit requires the City to address the following pollution prevention and operation and maintenance elements:

Develop and implement an operations and maintenance program, with the ultimate goal of preventing or reducing pollutant runoff from municipal operations.

Adopt maintenance standards for the municipal separate stormwater system that are at least as protective as those specified in Ecology’s 2005 Stormwater Management Manual for Western Washington

Perform annual inspections of stormwater flow control and treatment facilities and catch basins

Develop Standard Operating Procedures to reduce stormwater impacts associated with runoff from municipal O&M activities

Train staff to implement new procedures

Prepare Stormwater Pollution Prevention Plans (SWPPPs) for all heavy equipment maintenance or storage yards identified for year-round facilities or yards, and material storage facilities owned or operated by the City


The City of Bellingham has developed and implemented an operations and maintenance program with

the goal of preventing or reducing pollutant runoff from municipal operations. One focus of the

program is training municipal staff on good housekeeping pollution prevention practices that are

applicable to daily City operations and activities. Other components include, maintaining public

stormwater facilities, updating stormwater pollution prevention plans for city facilities, and

constructing capital improvement projects that reduce pollution.

The City has a comprehensive program for maintaining city-owned or operated permanent stormwater

treatment and flow control facilities. Maintenance standards from Ecology’s 2005 Stormwater

Management Manual for Western Washington were adopted by the City and are used to evaluate


Page 23

facilities for both private and public inspections. The City maintains over 394 facilities including 5

regional detention ponds, 84 water quality swales, 104 storm filter vaults, 73 rain gardens and 128

detention/water quality ponds, vaults or pipes. Inspection and maintenance of facilities is scheduled

and tracked through a maintenance management system. Inspections occur at a minimum annually

with most facilities inspected several times throughout the year. Filters are inspected even more

frequently; typically on a 3 month circuit. Maintenance is scheduled when a facility exceeds the

applicable maintenance standards and corrective actions are executed as soon as practical. All known

catch basins and inlets owned or operated by the City of Bellingham are inspected and cleaned as

necessary to comply with the maintenance standards. In addition, City Storm Operations staff have

identified potentially vulnerable stormwater facilities that are monitored during and after major storm

events.

Stormwater Pollution Prevention Plans (SWPPPs) have been developed for the Public Works Operations

Complex and the Parks & Recreation Operations Center. SSWU staff perform internal site inspections of

operations facilities to ensure that proper good housekeeping practices are being followed and provide

training for municipal employees.

The City’s street sweeper program aims to clean all City

streets on a 2 to 3 month circuit. More frequent street

sweeping

occurs in the

downtown

Central

Business

District where

streets are

serviced twice

a week and in the Lake Whatcom Watershed where streets

are cleaned twice a month. In addition, the City led a joint

venture to purchase a street sweeper for Whatcom County

NPDES partners to proactively prevent pollutants from

entering TMDL water bodies. This state of the art high efficiency street sweeper has a higher rate of

fine particulate capture and is used around the city and particularly in the Lake Whatcom Watershed to

improve removal of particulate phosphorus from roadways. It is also currently being used by the Port

of Bellingham and is available to both Whatcom County and the City of Ferndale.

Capital improvement projects have been a major component of the City’s effort to reduce stormwater

impacts associated with runoff from streets and parking lots. Over the past decade, numerous

stormwater quality retrofit projects have been completed citywide and many more are scheduled with

funding secured. Projects have used LID techniques, conventional water quality facilities, and in-line

treatment options. Currently, the City is investing heavily in retrofitting stormwater facilities in the Lake

Whatcom Watershed and in our downtown area. Noteworthy projects include the Broadway Park sand

Through stormwater

facility retrofits and source

control activities, the City

has markedly decreased

fecal coliform levels in our

creeks


Page 24

filter that receives stormwater from the Sunset Drive and I-5 junction and distributes it to planter areas

for infiltration and a water quality vault installed in Maritime Heritage Park that treats 40 acres of the

downtown area.

For the Lake Whatcom Watershed in particular, a key component to the City’s stormwater treatment

strategy is implementing controls that reduce the amount of phosphorus entering the Lake. A notable

accomplishment in this regard is that all public stormwater facilities in the City's portion of the Lake

Whatcom Watershed are now utilizing phosphorus-specific filtration media, improving phosphorus

removal efficiency to 50-60%. The City has 46 main treatment systems in the Lake Whatcom Watershed

and other smaller ones associated with our HIP program. Of particular note is the Lake Whatcom water

quality system at Bloedel Donovan Park which won the 2004 National award for Environmental

Excellence from the American Public Works Association. In 2014, the City expanded that project to

treat phosphorus loading from approximately 6 acres of the park not draining to the previous

improvements. This project employed shoreline restoration, passive treatment, and infiltration to

reduce phosphorus loading to the Lake. This park is the City's primary, and most visible, public property

along the Lake. This project will help with outreach to shoreline homeowners and serve as a

demonstration project for private projects along the shoreline.

The City has 65 Certified Erosion and Sediment Control Lead (CESCL) trained personnel on staff.

Training of municipal staff is ongoing through interdepartmental meetings and monthly Stormwater

Committee meetings and occurs as well during facility inspections from SSWU staff.


The City of Bellingham inspected and maintained all publicly-owned stormwater facilities in 2014 and

responded promptly to reported maintenance issues. While each facility was inspected at least once,

the majority of the facilities were visited or serviced 3 to 4 times. Crews also inspected and maintained

4,029 catchbasins of the 11,052 known publicly-owned catchbasins in the City.

A Stormwater Committee was convened as a

forum for interdepartmental discussions on

municipal stormwater issues. Each bimonthly

meeting contained a training component for

City staff on stormwater protocol and pollution

prevention practices. The City purchased two

new municipal stormwater pollution prevention

employee training kits. SSWU staff previewed

them and scheduled training of additional

municipal staff through the stormwater

committee forum. Other municipal activities

undertaken in 2014 include continuation of the

street sweeping program, source control inspections on City-owned facilities and the revision of the


Page 25

stormwater pollution prevention plans for the Public Works Operations Complex and the Parks &

Recreation Operations Center.

Retrofit projects begun or completed during the 2014 period include the installation of 36 bioretention

cells within the Central Business District and improvements along the shoulder of Northshore Drive. The

Central Business District improvements, known as the Downtown Improvement Gardens (DIG), prevent

urbanized pollution from reaching Whatcom Creek, a 303(d) listed waterbody, from a previously

untreated 90-acre basin. The Northshore Drive Water Quality Improvements targeted phosphorus

loading from 36 developed acres draining to Lake Whatcom. The improvements at Bloedel-Donovan

Park targeted phosphorus and fecal coliform loading from a heavily used, and heavily maintained,

public park located near the outlet of the Lake into Whatcom Creek. Stormwater retrofits are also

funded to treat stormwater from an outfall into Padden Creek near its mouth.


The city plans to continue to implement pollution prevention and maintenance for municipal operations

at a commensurate level of effort as in 2014.

8.0 MONITORING (S8.C.1.b and S8.C.2)


The City of Bellingham has conducted water quality

monitoring for over 20 years through our Urban

Streams Monitoring Program. This program was

initiated in 1990 with the purpose of collecting data

and maintaining a record of stream conditions at up to

19 separate stream sites on the 5 major creeks within

Bellingham. In addition, the City sponsors an in-depth

water quality program focused on the Lake Whatcom

Watershed. The program began over 50 years ago due

primarily to our requirements as a purveyor of water

to test the quality of incoming water to our water

treatment system but has continued to grow and expand in scope as additional parameters and studies

have been deemed necessary. In recent years, the City has focused not only on the Lake quality but

also on the nature of the water entering the Lake through creeks and large storm drains. Western

Washington University (WWU) over this time period has been commissioned by the City to provide

ambient Lake monitoring and stormwater input monitoring from the various creeks.

A third facet of the City’s program involves stormwater monitoring. For over 15 years, the City has

tested inflows to creeks primarily in the Lake Whatcom Watershed following storm events. Monitoring

started with the inclusion of the Park Place stormwater wet pond in the WWU Lake Monitoring study.

Our stormwater monitoring program has expanded to test a variety of BMP’s for effectiveness in

removing standard pollutants and phosphorus. To date we have performed testing on rain gardens,


Page 26

wet ponds, sand filters, and media filtration. Three different types of systems have been analyzed to

date with the following results:

Phosphorus specific filtration media - 50-85% phosphorus removal efficiency based on water quality sampling

Rain gardens – 81% fecal coliform removal based on quarterly sampling

Sand filters – 50% phosphorus removal and 80 to 99.9% fecal coliform removal based on quarterly sampling

Analysis of systems in Lake Whatcom is being used to typify phosphorus removal rates for TMDL

compliance. This program is of regional significance because it provides credible information on new

stormwater treatment and infiltration techniques that is specific to Western Washington. The new

media in the facility, including phosphorus-removing filter cartridges, has been given conditional

approval from the Department of Ecology as a phosphorus-limiting best management practice (BMP).

Bellingham has also engaged in short term monitoring as a part of our illicit discharge program. In all

of our system review done for illicit discharge detection the City has utilized a hydrolab or equivalent

to determine water quality issues. During field investigations, the flowing outfalls have been tested for

basic water quality parameters including turbidity, pH, conductivity, dissolved oxygen and

temperature. In addition, testing for fecal coliform and total phosphorus was included as applicable.


The City’s Urban Stream Monitoring program and Lake Whatcom Monitoring programs continued. In

2014, wet weather monitoring of Fever and Connelly Creeks was completed. The City continued

evaluating specialized filter medias for installation in vaults around Lake Whatcom. In addition to the

removal of suspended solids, the new medias are formulated to remove dissolved phosphorus from

stormwater. All city-operated Lake Whatcom watershed media systems have been fitted with these

new phosphorus-absorbing materials. Preliminary information points to a removal rate of 50 to 60

percent using the media.

In addition to the filter medias used in our cartridge based systems, Bellingham has been implementing

use of the recent Department of Transportation/Ecology Media Filter Drain Best Management Practice

(BMP) within the LW Watershed. This BMP uses a mixture of gypsum, perlite, dolomite and aggregate

to treat water for phosphorus and other pollutants. This BMP has undergone testing and is rated to

remove about 85% of total phosphorus. This BMP has been used for our Northshore and Bloedel

Donovan stormwater retrofit projects to date. Field testing of this BMP will be accomplished to further

verify it's viability.


The city plans to continue its monitoring at a commensurate level of effort as in 2014. Chuckanut Creek

and Bear Creek are potential candidates for dry weather monitoring in the coming year.


Page 27

9.0 CAPITAL PROJECTS and RETROFITTING (Not Required by NPDES)


The City of Bellingham has an active Capital

Program associated with the Storm and Surface

Water Utility (SSWU). This program has been

used in multiple ways to enhance our

stormwater system A part of the SSWU funding

has been used for the replacement of capital

assets to maintain the infrastructure. A larger

function of the capital program has been

retrofitting stormwater systems and areas for

water quality and environmental benefit.

Since the 1980's Bellingham has been active in providing system retrofits and managing stormwater. The

retrofits were first primarily related to the prevention of flooding. In 1992 Bellingham received a grant

from Ecology and constructed our first water quality facility retrofit for the protection of Lake Whatcom.

Since Lake Whatcom is the drinking water source for about 120,000 people it has remained high on our

needs list. For this basin alone the City has constructed 25 facilities to reduce phosphorus and other

pollutants. This is in addition to another 5 facilities that are managed and maintained by the City.

Retrofitting is also of importance to areas outside of Lake Whatcom. In addition to required water quality

improvements related to transportation improvements the City has endeavored to include water quality

retrofits even whenever possible. Not only transportation projects but water and sewer replacements

are looked at for the addition of SSWU funding to improve our water quality infrastructure.

The City now has 394 public facilities that we own and maintain. These are a result of both our code

requirements and our retrofitting program. These facilities include 5 regional detention ponds; 128

detention/water quality ponds, vaults or pipes; 84 water quality swales; 104 storm filters; 73 rain gardens

and miles of ditches being maintained to provide a water quality function.


Page 28

9.2 Fish Passage Improvements

This is a component of the SSWU capital program and is a funding mechanism for the improvement of

culverts that are impediments to fish. An attempt has been made to identify fish passage issues within

Bellingham and to provide a level of funding to deal with those issues over time. Projects occur based

on both a prioritization ranking and on existing system condition.

Current fish passage projects include Baker Creek at McLeod Rd., Landon Creek at E. Bakerview Rd. and

Willow Spring near Squalicum Parkway. SSWU funding is also being used for two large creek modification

projects.

Padden Creek is being modified between 17th

and 22nd Streets to daylight a portion of the

creek that has been in a tunnel for the last

120 years. This project will allow fish

populations to utilize habitat areas that have

been substantially cut off since the tunnel

construction.

Squalicum Creek is being modified to remove

barriers created by the construction of

Interstate 5 in the 1950's. This project

creates a new channel, provides enhanced

riparian habitat and encompasses

modification to the flood plain. The floodplain enhancements include a solution to the flooding of existing

structures as well.


Page 29

9.3 Retrofitting

Bellingham's stormwater capital program has included a substantial number of retrofits over the years.

SSWU policy has been that street projects that create new stormwater impacts and trigger code

compliance are responsible for those mitigations.

SSWU funding has been used to augment those mitigations or to provide funding in total to retrofit

project areas that are not responsible for mitigation. Primary examples of that are street projects that

are overlaying existing roadways with new asphalt or replacing

existing curb/gutter systems.

If the improvements do not trigger any code requirements, we look

at retrofitting purely as an opportunity to improve our systems. In

such cases decisions are based on average daily traffic for the street,

the degree of opportunity and available funding.

Where street projects are only responsible to mitigate for new

impervious surfaces, retrofitting is incorporated to aid providing total

mitigation for the street or project area. This is to avoid having

streets that are only partially mitigated that may present problems

in the future if comprehensive retrofitting is desired or required.

9.4 Six Year Capital Program

The SSWU creates a list of projects that are proposed for funding every biennial budget cycle. In addition,

capital project planning looks out an additional 4 years to projects that may be proposed for funding in

the future. Below is the capital plan for 2015-2020.

Please note that there several areas of annual programmed expenditures that are ongoing.

For instance:

The annual overlay expenditures are related to the provision of changes to pipes, catch basins and other

minor work associated with the overlay of streets.

The annual fish passage program is providing a set amount of funding that is earmarked for projects over

time.

The annual replacement budget is set by our total stormwater assets and to be able to provide

replacement on a 50 to 100 year cycle.

Page 30

Note: Amounts in parenthesis indicate grant or loan

Six Year Capital Projects

Project Name 2015

Request 2016

Request 2017

Estimate 2018

Estimate 2019

Estimate 2020

Estimate

Lake Whatcom Stormwater Projects Paid by Watershed Fund

Stormwater WS-Northshore Facility A-1 (AHHS)

300,000

Stormwater WS Oregon Infiltration Dispersion Facility

100,000

Stormwater WS Anderson Creek Restoration

100,000 500,000

Stormwater WS-Park Place Alum Facility

100,000

Stormwater WS Silver Beach Easements & Imps.

300,000 500,000

Stormwater WS Mill Wheel Pond Purchase/Imp.

700,000

Stormwater Capital Projects Paid by SSWU

Annual Storm Main Replacement Projects

100,000 1,000,000 1,000,000 1,000,000 1,000,000 1,000,000

Annual Overlay Storm Improvements

50,000 50,000 50,000 50,000 50,000 50,000

Annual Fish Passage (culvert) System Replacement Program

200,000 200,000 200,000 200,000 200,000 200,000

Britton Road Lake Whatcom SSWU Improvements

150,000 150,000

Little Squalicum Creek Estuary Habitat Enhancement

(1,200,000)

Lake Whatcom SSWU Improvements

250,000 250,000 250,000 250,000

Whatcom Creek Estuary/Roeder-Holly

(2,000,000)

Squalicum Creek Flood Berm 800,000

Squalicum Creek Flood Berm (800,000)

Padden Creek Daylighting 800,000

Padden Creek at Harris WWQ

(349,875)

Padden Creek at Harris WWQ

466,500

Squalicum Creek Re-Route/WQ Ph.1

483,485

Annual Water Quality System Retrofits

500,000 500,000 500,000 500,000 500,000 500,000

Storm System Replacements - Columbia Neighborhood

(1,047,000)

Storm System Replacements - Columbia Neighborhood

1,047,000

Willow Springs Fish Passage Improvements

75,000 100,000

Company Name Signer Name System NameCity of Bellingham William M. Reilly WQWebPortal

Washington Department of Ecology Submission Cover Letter

WQWebSubmittal - Submittal Submission Id: 1495082 - 4/24/2015 1:54:42 PM

Report Received Dated: 4/24/2015 1:54:43 PM

Document Name of Description Document File NameWAR045550_5_03312015125031 2014 Outreach Monthly Work

Pla_5_03312015125031.xl

WAR045550_2_03312015040216 PacificHighway_2_03312015040216.pdf

WAR045550_20_03312015040504 2014 BERTS data_20_03312015040504.xlsx

WAR045550_1_04242015012333 2015 City of Bellingham SWMP F_1_04242015012333.do

Submitted Copy of Record for City of Bellingham

Copy of Record CityofBellingham Friday April 24 2015

WAR045550_4b_04242015012333 2015 Internal Processes Statem_4b_04242015012333.d

WAR045550_56_03312015043018 2014 Monitoring Data Synopsis_56_03312015043018.do

Attachments:

Attestation Agreed to at Signing:

I certify I personally signed and submitted to the Department of Ecology an Electronic Signature Agreement. I understand that use of my electronic signature account/password to submit this information is equal to my written signature. I have read and followed all the rules of use in my Electronic Signature Agreement. I believe no one but me has had access to my password and other account information.

I further certify: I had the opportunity to review the content or meaning of the submittal before signing it; and to the best of my knowledge and belief, the information submitted is true, accurate, and complete. I intend to submit this information as part of the implementation, oversight, and enforcement of a federal environmental program. I am aware there are significant penalties for submitting false information, including possible fines and imprisonment.

For Ecology Use Only --- Dev

F1luEAgrVuDR8XZfU6D6k68Xq9rRIO5fqMiZy30/dJFIWgyVggcthf4aU0AyNM6+UXdXZKG1kPyQJxw1rhUBfv8f/tBcKPHT/IBaTjHCHXw=

Water Quality Program

Permit Submittal Electronic Certification

Permit Number:

Permittee:

Site Address:

Version:

WAR045550

MS4 Annual Report Phase II Western

BELLINGHAM CITY

210 LOTTIE STBellingham, WA 98225

Submittal Name:

1 Due Date: 3/31/2015

Questionnaire

Number Permit Section Question Answer

1 S5.A.2 Attach updated annual Stormwater Management Program Plan (SWMP Plan). (S5.A.2)

2015 City of Bellingham SWMP F_1_04242015012333.docx

2 S9.D.5 Attach a copy of any annexations, incorporations or boundary changes resulting in an increase or decrease in the Permittee’s geographic area of permit coverage during the reporting period per S9.D.5.

PacificHighway_2_03312015040216.pdf

3 S5.A.3 Implemented an ongoing program to gather, track, and maintain information per S5.A.3, including costs or estimated costs of implementing the SWMP.

Yes

4 S5.A.5.b Coordinated among departments within the jurisdiction to eliminate barriers to permit compliance. (S5.A.5.b)

Yes

4b S5.A.5.b Attach a written description of internal coordination mechanisms. (Required to be submitted no later than March 31, 2015, S5.A.5.b)

2015 Internal Processes Statem_4b_04242015012333.docx

5 S5.C.1.a.i and ii Attach description of public education and outreach efforts conducted per S5.C.1.a.i and ii.

2014 Outreach Monthly Work Pla_5_03312015125031.xlsx

6 S5.C.1.b Created stewardship opportunities (or partnered with others) to encourage resident participation in activities such as those described in S5.C.1.b.

Yes

7 S5.C.1.b Used results of measuring the understanding and adoption of targeted behaviors among at least one audience in at least one subject area to direct education and outreach resources and evaluate changes in adoption of targeted behaviors. (Required no later than February 2, 2016, S5.C.1.b)

Not Applicable

7b S5.C.1.b Attach description of how this requirement was met.

8 S5.C.2.a Describe the opportunities created for the public to participate in the decision making processes involving the development, implementation and updates of the Permittee’s SWMP. (S5.C.2.a)

Input on SWMP's is requested at the end of each annual reporting process. The input received is to be considered in the formulation of the next SWMP. In addition, the SSWU has been meeting with neighborhood associations to explain our stormwater programs and solicit comments from these associations.

9 S5.C.2.b Posted the updated SWMP Plan and latest annual report on your website no later than May 31. (S5.C.2.b)

Yes

9b S5.C.2.b List the website address. http://www.cob.org/services/planning/environmental/stormwater-program.aspx

10 S5.C.3.a.i - vi Maintained a map of the MS4 including the requirements listed in S5.C.3.a.i.-vi.

Yes

11 S5.C.3.b.v Implemented a compliance strategy, including informal compliance actions as well as enforcement provisions of the regulatory mechanism described in S5.C.3.b. (S5.C.3.b.v)

Yes

12 S5.C.3.b.vi Updated, if necessary, the regulatory mechanism to effectively prohibit illicit discharges into the MS4 per S5.C.3.b.vi. (Required no later than February 2, 2018)

Not Applicable

12b Cite the Prohibited Discharges code reference

13 S5.C.3.c.i Implemented procedures for conducting illicit discharge investigations in accordance with S5.C.3.c.i.

Yes

13b S5.C.3.c.i Cite methodology Multiple. Outfall monitoring, internal camera investigation, employee training, citizen information, stream monitoring, source tracking.

14 S5.C.3.c.i Percentage of MS4 coverage area screened in reporting year per S5.C.3.c.i. (Required to screen 40% of MS4 no later than December 31, 2017 (except no later than June 30, 2018 for the City of Aberdeen) and 12% on average each year thereafter. (S5.C.3)

15

15 S5.C.3.c.ii List the hotline telephone number for public reporting of spills and other illicit discharges. (S5.C.3.c.ii)

360-778-7979

15b S5.C.3.c.ii Number of hotline calls received. 203

16 S5.C.3.c.iii Implemented an ongoing illicit discharge training program for all municipal field staff per S5.C.3.c.iii.

Yes

17 S5.C.3.c.iv Informed public employees, businesses, and the general public of hazards associated with illicit discharges and improper disposal of waste. (S5.C.3.c.iv)

Yes

17b S5.C.3.c.iv Describe the information sharing actions. (S5.C.3.c.iv)

Bellingham is participating in an Ecology Source Control Program. This entails employees performing site visits for specific businesses and providing information on proper disposal techniques and requirements. Implemented a public information campaign for the use of the Stormwater Hotline. Provided information and have a program for the return of pharmaceutical products including a public information blitz (bus ads, paper and radio ads, utility bill inserts, etc). Regularly conduct program on animal waste, purchase and provide dog bags for stations throughout Bellingham with accompanying information. Informational meetings with each neighborhood in the City are conducted.

18 S5.C.3.d Implemented an ongoing program to characterize, trace, and eliminate illicit discharges into the MS4 per S5.C.3.d.

Yes

19 S5.C.3.d.iv Number of illicit discharges, including illicit connections, eliminated during the reporting year. (S5.C.3.d.iv)

41

20 S5.C.3.d.iv Attach a summary of actions taken to characterize, trace and eliminate each illicit discharge found by or reported to the permittee. For each illicit discharge, include a description of actions according to required timeline per S5.C.3.d.iv

2014 BERTS data_20_03312015040504.xlsx

21 S5.C.3.e Municipal illicit discharge detection staff are trained to conduct illicit discharge detection and elimination activities as described in S5.C.3.e.

Yes

22 S5.C.4.a Implemented an ordinance or other enforceable mechanism to address runoff from new development, redevelopment and construction sites per the requirements of S5.C.4.a.

Yes

24 S5.C.4.a.i Number of exceptions granted to the minimum requirements in Appendix 1. (S5.C.4.a.i., and Section 6 of Appendix 1)

0

25 S5.C.4.a.i Number of variances granted to the minimum requirements in Appendix 1. (S5.C.4.a.i., and Section 6 of Appendix 1)

0

26 S5.C.4.b.i Reviewed Stormwater Site Plans for all proposed development activities that meet the thresholds adopted pursuant to S5.C.4.a.i. (S5.C.4.b.i)

Yes

26b S5.C.4.b.i Number of site plans reviewed during the reporting period.

493

27 S5.C.4.b.ii Inspected, prior to clearing and construction, permitted development sites that have a high potential for sediment transport as determined through plan review based on definitions and requirements in Appendix 7 Determining Construction Site Sediment Damage Potential, or alternatively, inspected all construction sites meeting the minimum thresholds adopted pursuant to S5.C.4.a.i. (S5.C.4.b.ii)

Yes

27b S5.C.4.b.ii Number of construction sites inspected per S5.C.4.b.ii.

493

28 S5.C.4.b.iii Inspected permitted development sites during construction to verify proper installation and maintenance of required erosion and sediment controls. (S5.C.4.b.iii)

Yes

28b S5.C.4.b.iii Number of construction sites inspected per S5.C.4.b.iii.

13968

29 S5.C.4.b.ii, iii and Number of enforcement actions taken during the reporting period (based on construction phase inspections at new development and redevelopment projects). (S5.C.4.b.ii, iii and v)

22

30 S5.C.4.b.iv Inspected all permitted development sites that meet the thresholds in S5.C.4.a.i upon completion of construction and prior to final approval or occupancy to ensure proper installation of permanent stormwater facilities. (S5.C.4.b.iv)

Yes

31 S5.C.4.b.ii-iv Achieved at least 80% of scheduled construction-related inspections. (S5.C.4.b.ii-iv)

Yes

32 S5.C.4.b.iv Verified a maintenance plan is completed and responsibility for maintenance is assigned for projects. (S5.C.4.b.iv)

No

33 S5.C.4.c Implemented provisions to verify adequate long-term operation and maintenance (O&M) of stormwater treatment and flow control BMPs/facilities that are permitted and constructed pursuant to S5.C.4. a and b. (S5.C.4.c)

No

35 S5.C.4.c.iii Annually inspected stormwater treatment and flow control BMPs/facilities per S5.C.4.c.iii.

Yes

35b S5.C.4.c.iii If using reduced inspection frequency for the first time during this permit cycle, attach documentation per S5.C.4.c.iii

Reduced inspection report available but system is not allowing entry. Call Bill Reilly at 360-778-7955 for more information

36 S5.C.4.c.iv Inspected new residential stormwater treatment and flow control BMPs/facilities and catch basins every 6 months per S5.C.4.c.iv to identify maintenance needs and enforce compliance with maintenance standards.

Yes

37 S5.C.4.c.v Achieved at least 80% of scheduled inspections to verify adequate long-term O&M. (S5.C4.c.v)

Yes

38 S4.C.4.c.vi Verified that maintenance was performed per the schedule in S5.C.4.c.vi when an inspection identified an exceedance of the maintenance standard.

Yes

38b S5.C.4.c.vi Attach documentation of any maintenance delays. (S5.C.4.c.vi)

Not Applicable

39 S5.C.4.d Provided copies of the Notice of Intent for Construction Activity and Notice of Intent for Industrial Activity to representatives of proposed new development and redevelopment. (S5.C.4.d)

Yes

40 S5.C.4.e All staff responsible for implementing the program to control stormwater runoff from new development, redevelopment, and construction sites, including permitting, plan review, construction site inspections, and enforcement are trained to conduct these activities. (S5.C.4.e)

Yes

42 S5.C.4.g Participated and cooperated with the watershed-scale stormwater planning process led by a Phase I county. (S5.C.4.g)

Not Applicable

43 S5.C.5.a Implemented maintenance standards as protective, or more protective, of facility function as those specified in Chapter 4 of Volume V of the 2005 Stormwater Management Manual for Western Washington.

Yes

44 S5.C.5.a Applied a maintenance standard that is not specified in the Stormwater Management Manual for Western Washington.

No

44b S5.C.5.a Please note what kinds of facilities are covered by this alternative maintenance standard. (S5.C.5.a)

45 S5.C.5.a.ii Performed timely maintenance per S5.C.5.a.ii. Yes

46 S5.C.5.b Annually inspected all municipally owned or operated permanent stormwater treatment and flow control BMPs/facilities. (S5.C.5.b)

Yes

46b S5.C.5.b Number of known municipally owned or operated stormwater treatment and flow control BMPs/facilities. (S5.C.5.b)

394

46c S5.C.5.b Number of facilities inspected during the reporting period. (S5.C.5.b)

394

46d S5.C.5.b Number of facilities for which maintenance was performed during the reporting period. (S5.C.5.b)

345

47 S5.C.5.b If using reduced inspection frequency for the first time during this permit cycle, attach documentation per S5.C.5.b.

Not Applicable

48 S5.C.5.c Conducted spot checks and inspections (if necessary) of potentially damaged stormwater facilities after major storms as per S5.C.5.c.

Yes

49 S5.C.5.d Inspected all municipally owned or operated catch basins and inlets as per S5.C.5.d, or used an alternative approach. (Required once no later than August 1, 2017 and every two years thereafter, except once no later than June 30, 2018 and every two years thereafter for the City of Aberdeen)

Not Applicable

49b S5.C.5.d Number of known catch basins. 11052

49c S5.C.5.d Number of catch basins inspected during the reporting period.

2450

49d S5.C.5.d Number of catch basins cleaned during the reporting period.

2450

50 S5.C.5.d.i-ii Attach documentation of alternative catch basin cleaning approach, if used. (S5.C.5.d.i or ii)

Not Applicable

51 S5.C.5.f Implemented practices, policies and procedures to reduce stormwater impacts associated with runoff from all lands owned or maintained by the Permittee, and road maintenance activities under the functional control of the Permittee. (S5.C.5.f)

Yes

52 S5.C.5.g Implemented an ongoing training program for Permittee employees whose primary construction, operations or maintenance job functions may impact stormwater quality. (S5.C.5.g.)

Yes

53 S5.C.5.h Implemented a Stormwater Pollution Prevention Plan for all heavy equipment maintenance or storage yards, and material storage facilities owned or operated by the Permittee in areas subject to this Permit that are not required to have coverage under an NPDES permit that covers stormwater discharges associated with the activity. (S5.C.5.h)

Yes

54 S7.A Complied with the Total Maximum Daily Load (TMDL)-specific requirements identified in Appendix 2. (S7.A)

Not Applicable

55 S7.A For TMDLs listed in Appendix 2: Attach a summary of relevant SWMP and Appendix 2 activities to address the applicable TMDL parameter(s). (S7.A)

Not Applicable

56 S8.A Attach a description of any stormwater monitoring or stormwater-related studies as described in S8.A.

2014 Monitoring Data Synopsis_56_03312015043018.docx

57 S8.B.1 Participated in cost-sharing for the regional stormwater monitoring program (RSMP) for status and trends monitoring. (S8.B.1)

Yes

58 S8.C.1 Participated in cost-sharing for the regional stormwater monitoring program (RSMP) for effectiveness studies. (S8.C.1) (Required to begin no later than August 15, 2014)

Yes

59 S8.D.1 Contributed to the RSMP for source identification and diagnostic monitoring information repository in accordance with S8.D.1. (Required to begin no later than August 15, 2014)

Yes

I certify under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

William M.

Signature Date

4/24/2015 1:54:41 PM

60 G3 Notified Ecology in accordance with G3 of any discharge into or from the Permittees MS4 which could constitute a threat to human health, welfare or the environment. (G3)

Yes

61 G3 Number of G3 notifications provided to Ecology.

0

62 G3.A Took appropriate action to correct or minimize the threat to human health, welfare, and/or the environment per G3.A.

Yes

63 S4.F.1 Notified Ecology within 30 days of becoming aware that a discharge from the Permittee’s MS4 caused or contributed to a known or likely violation of water quality standards in the receiving water. (S4.F.1)

Yes

64 S4.F.3.a If requested, submitted an Adaptive Management Response report in accordance with S4.F.3.a.

Not Applicable

65 S4.F.3.d Attach a summary of the status of implementation of any actions taken pursuant to S4.F.3 and the status of any monitoring, assessment, or evaluation efforts conducted during the reporting period. (S4.F.3.d)

Not Applicable

66 G20 Notified Ecology of the failure to comply with the permit terms and conditions within 30 days of becoming aware of the non-compliance. (G20)

Not Applicable

67 G20 Number of non-compliance notifications (G20) provided in reporting year.

0

67b G20 List the permit conditions described in non-compliance notification(s).

Not Applicable

City of Bellingham City Limits and UGA Area

PACIFIC HWY

MITC

HELL

WAY

ALDR

ICH RD

NORTHWEST AVE

LARRABEE R D

JUNE RD

SUMAC LN

BEAUMONT DR

TROUT LAKE DR

FUCHSIA DR

ALDR

ICH RD

JUNE RD§̈¦I-5

Pacific Highway Annexation Area

City of Bellingham

2014 Stormwater Monitoring

Synopsis

1. 2014 Annual Stream Monitoring (report in process).

Monthly evaluation of stream health for Chuckanut, Padden, Whatcom and Squalicum Creeks.

Copy to Ecology each year

2. Monitoring associated with Lake Whatcom Watershed for streams, selected storm systems and

facilities.

This monitoring is provided to Ecology, on request, for aid in the formulation of the Lake

Whatcom TMDL. Sources include Western Washington University, Brown and Caldwell contract,

USGS and City of Bellingham

3. Miscellaneous monitoring of stormwater systems associated with potential illicit discharges.

Various locations. Data available upon request.

4. Monitoring reports associated with various grants. Information provided to Ecology per

individual grant projects. Includes benthic macro-invertebrate testing.

5. Stream flow data available for Chuckanut, Padden, Whatcom and Squalicum Creeks. Lake data

available for Lake Whatcom and Lake Padden.

ID Incident Date Incident Street NumberIncident Street Incident Illicit Discharge Notification Method Property Type Response ERTS Number Resolved

C Street sewer cross connects TRUE found by system review Public Property 4 side sewers rerouted TRUE

Holly/Broadway sewer cross connTRUE found by system review Public Property 1 side sewer disconnected

Roosevelt School cross connect TRUE found by system review Public Property dyetest,1 side sewer rehabilitiation

191 12/31/2+D18+B2:B98800 Lakeway leaky trash compactor TRUE found it myself Commercial ERTS filed 648641 TRUE

188 12/22/2014 405 E Holly St Pressure Washing TRUE Saw ourselves Commercial Written warning TRUE

189 12/22/2014 310 E Magnolia St Pressure Washing TRUE Saw ourselves ROW Refer to Rick Nolan TRUE

173 11/18/2014 1715 F St water line break TRUE Hotline Residential ERTS filed;#Crew Dispatched 652974 TRUE

180 11/7/2014 1421 N State Washing Gear TRUE Hotline Commercial Written warning TRUE

169 11/5/2014 1300 Commercial Water main break TRUE ERTS ROW Crew Dispatched 652725 TRUE

166 10/30/2014 341 Telegraph Rd Exposed Soils TRUE ERTS Residential Construction NPDES 652609 TRUE

163 10/23/2014 4000 Irongate st Spill TRUE Hotline Industrial Old discharge, Source Control Visit TRUE

159 10/17/2014 E Holly & N Garden Spill TRUE ERTS ROW Crew Dispatched TRUE

160 10/17/2014 3707 Taylor Spill TRUE Complaint ROW Ensured containment TRUE

158 10/16/2014 714 Lakeway Dr carpet wash water TRUE Hotline Commercial Written warning TRUE

162 10/15/2014 1224 Cornwall Spill;#Exposed Soils;#Track Out;#Soil delivery caused an illicit dischargeTRUE Dave Roberts called Mark Howard's direct line.Commercial Written warning TRUE

149 9/10/2014 4219 Alice Spill;#Paint Wash Water DischargeTRUE Hotline Residential Verbal warning;#Written warning;#ERTS filed;#Crew Dispatched;#Field investigation by Eli651472 TRUE

142 8/27/2014 1200 Lincoln Pressure Washing TRUE City Staff Residential Verbal warning;#Written warning TRUE

141 8/22/2014 State & Magnolia Spill TRUE BPD dispatch Public Property Verbal warning TRUE

139 8/11/2014 N State & Magnolia foamy, greasy water in storm TRUE City Staff Public Property Written warning TRUE

135 8/6/2014 2111 F St Pet Waste TRUE Hotline Residential Other;#sampled CB FALSE

131 8/4/2014 Western turbidity in Padden Creek TRUE Hotline Other ERTS filed TRUE

129 7/22/2014 W Orchard Drive Spill TRUE Hotline Other;#not issue TRUE

127 7/15/2014 1345 King St Pressure Washing TRUE City Staff Commercial Written warning TRUE

123 7/5/2014 804 Dupont Pressure Washing TRUE Hotline Commercial Written warning TRUE

117 6/12/2014 2416 Yew Street Spill TRUE City Staff Commercial Verbal warning;#Crew Dispatched TRUE

112 5/9/2014 800 Lakeway Dr Leaky trash compactor TRUE Hotline Commercial Written warning 648641 TRUE

110 5/1/2014 140 Samish Way grease interceptor backup TRUE City Staff Commercial ERTS filed;#Crew Dispatched;## 648463 648463 TRUE

109 4/30/2014 1001 Sunset Dr Sewer overflow TRUE ERTS Commercial Sewage cleaned up 648426 TRUE

107 4/28/2014 2010 Broadway St Car Washing TRUE Complaint Commercial Verbal warning TRUE

108 4/28/2014 1100 Railroad Ave Spill TRUE City Staff Public Property Other;#visited site TRUE

101 3/4/2014 3910 Bennett Spill TRUE ERTS ROW WRS called 647354 TRUE

95 1/29/2014 907 21st oil leak TRUE City Staff Residential Cleaned up area,Educated on car leakage TRUE

87 12/1/2013 10 Chuckanut Dr Spill TRUE Hotline Residential Education TRUE

85 11/19/2013 2405 E ST ground water & sewage in crawl space pumped to streetTRUE Hotline Residential Other;#referral to WCHD TRUE

78 10/8/2013 1345 King St. Spill TRUE Hotline Commercial Crew Dispatched 644460 TRUE

38 4/4/2013 Lindbergh Ave Spill;#Hazard Exposed to Rain TRUE Hotline ERTS filed TRUE

39 4/4/2013 Bayside & Linden Car Washing;#source not found TRUE Hotline Public Property Crew Dispatched TRUE

190 12/30/2014 630 Cornwall Ave BNSF Materials in wetland FALSE ReSources Email Commercial Written warning 653752 FALSE

187 12/22/2014 1975 Alpine Way Sand blasting residue near storm drainFALSE City Staff Commercial Verbal warning TRUE

186 12/18/2014 601 N Garden ST Clearing/Grading;#Drainage issueFALSE Hotline FALSE

185 12/17/2014 2814 Meridian Foam coming out of grate in parking lotFALSE Complaint Commercial TRUE

184 12/15/2014 2237 James Street Christmas tree cutting FALSE City Staff Commercial Verbal warning TRUE

183 12/11/2014 502 Chuckanut dr N Stormwater culvert blocked FALSE Hotline PW crew will be sent out TRUE

181 12/9/2014 2929 Roeder Ave Flooding FALSE Hotline Commercial TRUE

182 12/9/2014 Academy & Northshore Dr clogged culvert FALSE Hotline ROW Other TRUE

179 12/3/2014 1217 N Forest Pet Waste;#Hazard Exposed to RainFALSE Online ROW education TRUE

177 12/2/2014 2604 Meridian Gasoline spill (small amount) FALSE Call to Health DepartmentCommercial Gave a spill kit to manager TRUE

178 12/2/2014 Laurel ST between High and N Garden st ICEY ROAD FALSE Hotline ROW TRUE

176 11/28/2014 4258 Northwest Ave Sewage dumping FALSE Complaint Residential Verbal warning FALSE

174 11/24/2014 A st & Irving St, big yellow house exposed wood chips FALSE Hotline Residential TRUE

175 11/20/2014 1806 Cornwall Ave Dumping wash water FALSE City Staff Commercial Written warning TRUE

172 11/17/2014 Alabama & Northshore Car Washing FALSE Hotline Residential FALSE

170 11/13/2014 18th between Rainier and Fairhaven AveSpill FALSE Hotline ROW Other FALSE

171 11/12/2014 200 block S Garden ST Water issue on S Garden st FALSE Online ROW TRUE

168 11/8/2014 Chuckanut Creek at eastern Arroyo trailheadfoam in creek FALSE Hotline Water Body none TRUE

167 11/3/2014 Franklin and Whatcom St Car leak FALSE ERTS ROW 652666 TRUE

165 10/24/2014 Railroad Trail Toledo Pet Waste FALSE Hotline Public Property cleaned up area TRUE

164 10/23/2014 Pet Waste FALSE Hotline ROW Other TRUE

161 10/20/2014 2915 Coolidge Spill FALSE Hotline Residential Crew Dispatched TRUE

157 10/14/2014 312 and 314 Sea Pines Rd vegetation plan request FALSE written request Residential education TRUE

156 10/13/2014 1704 N State St hosing down urine FALSE Hotline Commercial education TRUE

155 9/24/2014 775 Telegraph Rd Hazard Exposed to Rain FALSE Online ROW Not an issue TRUE

154 9/23/2014 1522 Valhalla St Leaking vehicle FALSE Hotline Residential TRUE

153 9/22/2014 1400 Iowa St Car Washing FALSE City Staff Commercial Not an issue TRUE

152 9/17/2014 Flynn & Lakeside Abandoned car on POW with a residual oil pool from hydraulic problemFALSE Hotline ROW Other;#Resolved by car owner TRUE

151 9/15/2014 1522 Valhalla St Leaky Vehicle FALSE Hotline Residential TRUE

150 9/11/2014 2402 F St Car Washing FALSE Complaint Residential Verbal warning TRUE

147 9/7/2014 1311 Clearbrook Clearing/Grading;#Work in or near Critical Area;#Cemetary CreekFALSE Online Residential As of 9/8/2014 9:00 - sent to planning department - See notes TRUE

144 9/3/2014 2900 Donovan Ave Sewage and laundry freshener odor from ditch on 2900 Donovan AveFALSE Hotline Residential Site visit for cross connection TRUE

145 9/3/2014 1244 Birch falls CatchBasin inlet sock FALSE Hotline Residential TRUE

146 9/3/2014 1422 N Forest St Leaking UST FALSE ERTS Commercial none 651279 TRUE

143 8/23/2014 1333 Cornwall Ave Pressure Washing FALSE Complaint Commercial TRUE

140 8/13/2014 St. Clair stron sulfur smell at St. Clair pondFALSE City Staff Industrial Other;#called pipeline to alert them to smell TRUE

138 8/12/2014 116 Grand Track Out FALSE Complaint Commercial Referred to Rick Nolan TRUE

136 8/7/2014 8TH & Wilson Leaking Hydrant FALSE Hotline ROW Water Crew TRUE

137 8/6/2014 E Oregon carpet cleaning FALSE Complaint Residential Verbal warning TRUE

134 8/5/2014 4107 Strider Loop suspected illicit discharge FALSE Hotline Industrial Other;#education TRUE

132 8/4/2014 1616 Valhalla Car Washing FALSE Hotline Residential letter to resident FYI TRUE

133 8/4/2014 Humbolt and Meador Bubbles in Whatcom creek at Hombolt and Meador AveFALSE Hotline ROW Other;#Nothing was found. TRUE

130 7/28/2014 Yew Street water main break FALSE Hotline Public Property Crew Dispatched TRUE

128 7/21/2014 3033 Lynn St Car Washing FALSE Complaint Residential Written warning TRUE

125 7/15/2014 Merlin Ct Track Out;#track out of asphalt sealantFALSE Complaint Residential none TRUE

126 7/15/2014 2320 Michigan Spill FALSE ERTS Residential follow up with Rod 650101 TRUE

124 7/14/2014 Midway & Irongate gross ditch FALSE Online Industrial Monitoring TRUE

122 6/20/2014 1240 Undine car leak FALSE ERTS Residential education 649637 TRUE

121 6/18/2014 1601 & 1603 Valhalla Car Washing FALSE Hotline Residential education TRUE

120 6/17/2014 1536 Lowell Ave Pressure Washing FALSE Hotline Residential Education TRUE

119 6/16/2014 12524 Wilson Pesticide FALSE City Staff Industrial Written warning TRUE

118 6/13/2014 22nd & Fairhaven Pkwy fish ladderCar Washing FALSE Hotline Water Body TRUE

116 6/10/2014 908 Puget St Excess drainage FALSE Hotline Residential Meet on site TRUE

115 6/4/2014 2100 Electric Pesticide FALSE Complaint Residential Written warning TRUE

113 5/29/2014 811 Iowa St Concrete cutting, dust FALSE Hotline Commercial Verbal warning TRUE

114 5/29/2014 various Spill FALSE City Staff Industrial Other;#noted TRUE

111 5/5/2014 2330 Park St Pressure Washing FALSE Complaint Residential no evidence found, no response TRUE

105 4/3/2014 3110 Taylor St Iron fixing bacteria flush FALSE Complaint Residential Looked for source - not found TRUE

104 3/19/2014 1811 W North St Pet Waste FALSE Hotline Residential Written warning TRUE

102 3/14/2014 WWU Spill FALSE Hotline Public Property none TRUE

103 3/13/2014 2172 Division St petroleum product in ditch FALSE City Staff Industrial none needed TRUE

106 3/6/2014 2700 Xenia Pesticide FALSE City Staff Residential Written warning TRUE

99 3/3/2014 2639 Franklin clogged drain FALSE Hotline ditch Crew Dispatched TRUE

100 3/3/2014 2725 Superior backing up of Fever Creek FALSE Hotline Residential Crew Dispatched TRUE

97 2/13/2014 Cornwall Ave Spill;#Hazard Exposed to Rain FALSE 360-738-6169 Industrial Other;#called Ecology - sent email 646939 TRUE

98 2/10/2014 Easton and 10th Fire at Metal Shop FALSE ERTS Commercial Crew Dispatched 646734 TRUE

96 1/29/2014 2310 E. Sunset Work Without Permit;#Exposed Soils;#Track OutFALSE City Staff Residential Written warning;#Warning sent to contractor, Property Mgmt, and Property OwnerTRUE

94 1/23/2014 222 E Stuart Soap in storm main FALSE City crew Public Property TRUE

79 10/29/2013 135 S 44TH ST Hazard Exposed to Rain FALSE Hotline Residential Written warning TRUE

74 9/27/2013 Highland Dr leaky vehicles FALSE Hotline ROW Verbal warning TRUE

64 7/26/2013 Bill Mcdonald Spill FALSE Hotline ROW Crew Dispatched TRUE

58 7/5/2013 1000 Girard St Hotline call re:brown drinking waterFALSE Hotline Residential Other;#called Terry Fahlstrom & Torhil Ramsey TRUE

57 6/27/2013 2100 Broadway Pressure Washing FALSE Hotline Commercial Verbal warning TRUE

53 5/21/2013 2908 Cottonwood Spill FALSE Hotline ROW education TRUE

54 5/17/2013 1400 Welling sink hole in yard FALSE Hotline Residential Other TRUE

46 4/15/2013 1200 Lincoln St 1200 Lincoln St Pesticide FALSE Hotline Residential Education TRUE

26 2/5/2013 2301 Elm St Pet Waste FALSE Hotline TRUE

12 11/19/2012 2215 Cornwall Hazard Exposed to Rain FALSE Hotline Commercial Verbal warning TRUE

28 2/12/2013 2231 Valencia St Spill Hotline ERTS filed TRUE

25 2/4/2013 2301 Elm St Pet Waste Hotline Commercial TRUE

15 12/4/2012 2212-2218 Xenia St. Spill Hotline Water Body ERTS filed TRUE

14 11/28/2012 2234 Valencia St Illicit Discharge;#Blowing leaves into creek Hotline Residential Written warning TRUE

10 10/22/2012 4210 Springland Lane dead deer #NAME? Hotline Public Property TRUE

37

2014 Outreach Work Plan

January February March April May June July August September October November December

Lake Whatcom

Lake Whatcom

Management Program

LWMP Annual

Report

LWMP Annual

Report

Joint Councils

meeting

end 2010-2014

work plan

..Educ. Team

..Lake-friendly

Landscaping

work window

closed , edit P-fert

ordinance for

retailers

work window

closed , implement

new P-fert outreach

for retailers

work window

closed, spring

planting,

gardening season

work window

closed, spring

planting,

gardening season

work window

closed, spring

planting, gardening

season

work window

open

work window

open

work window

open

work window

open

work window

closed, fall

planting

work window

closed, fall

planting, assess P-

fert outreach for

retailers

work window

closed

Residential Retrofits

(Homeowner Incentive

Program)

2014 outreach

strategy assessment

2014 outreach

strategy assessment.

- posctards, ads,

press release for

workshop.

- phone survey of

HIP participants.

Solutions

workshop

survey of

workshop

attendees

"last chance"

letter

edit rain garden

sign for Silver

Beach

install rain

garden sign for

Silver Beach

Grant contract

ENDS 12/31/14

ROW Retrofits letter public meeting preconstruction

signs

during

construction signs

post construction

signs

Aquatic Invasive Species signage, postcards,

and press release for

info session

Info session

postcards, ads,

and press release

for incentive

course and

inspection

Incentive course

and inspections

open

Nonmotorized

signage

Stormwater

Residential Develop BMP

flyer and

presentation for

RE Sources

neighborhood

outreach

print Only Rain

Down the Drain

flyer, neighborhood

meeting

check in with RE

Sources a/b

Stormwater

Stewards

Stormwater

neighborhood

meetings

Stormwater

neighborhood

meetings

Stormwater

neighborhood

meetings

..Animal Waste order incentives,

design mailer,

finalize budget

Event: Paws and

Claws (July 28),

mailer #1,

quarterly grant

report (July 15)

Event: Dog Days

of Summer (Aug

24)

redefine audience

& prep for

implementation

media ad

campaign (bus

ads, PSAs),

mailer, partner

web sites,

contact vets

place-based

outreach at vets,

stores & parks

Meet with ARN

to plan

evaluation

implementation

..Vehicle Leaks and

Maintenance

STORM Vehicle

Leaks Campaign

Don't Drip and

Drive planning

Don't Drip and

Drive prep

Don't Drip and

Drive events

Don't Drip and

Drive events



..Vehicle Washing check in with

watershed-

friendly locations

letters out to

potential sites &

fundraisers

lend car wash kits lend car wash kits lend car wash

kits

lend car wash

kits

lend car wash kits

..Landscaping

Commercial web updates

between LSC &

SWU..Stormwater University website updates PPTs up on web letters to

partners, videos

posted online

Stormwater U

Grant ends 6/30 -

Report Due

distribute SWU

DVDs, get videos

on BTV & online

send final

deliverables to

Ecology

distribute DVDs

at STORM

quarterly NPDES & General

Stormwater Outreach

STORM Quarterly

Meeting

NPDES Annual

Report

STORM Quarterly

Meeting, Event:

PSSH Month, utility

bill insert?

Event: Whatcom

Water Fest

STORM

Quarterly

Meeting

utility bill insert? STORM Quarterly

Meeting

Restoration

Squalicum Creek Reroute Coordinate public

meetings

Public openhouse

for Squalicum

Corrdidor projects

Presntations to

Birchwood

Association &

Web updates Establish Phase

III Ed/outreach

deliverables

Web updates

Padden Estuary Begin developing

Interp. Signage

Noise variance

postcard and

signage (work

with Heather and

Craig)Little Squalicum Estuary Grant results

Juvenile Chinook Study

Nearshore Connectivity

Study

Council

presentation in

JanuaryHabitat Restoration

Technical Analysis

Establish

Ed/outreach

deliverables

Other Develop

outreach for

State of the BayWater Conservation

General Water Demand

Outreach (events,

displays, advertising - bus

ads)

water demand

outreach

water demand

outreach

water demand

outreach

water demand

outreach

water demand

outreach

outdoor

watering/peak

demand outreach

outdoor

watering/peak

demand

outreach

outdoor

watering/peak

demand

outreach

water demand

outreach

water demand

outreach

water demand

outreach

water demand

outreach



Workshops & Events W4W planning,

workshop planning,

Ops demonstration

project prep

W4W planning &

prep, publicity,

workshop planning,

Ops demonstration

project prep

Event: Walk for

Water, workshop

planning, Ops

demonstration

project prep

assist with

demonstration

projects,

advertising

advertising - bus

ads, assist with

demonstration

projects

assist with

demonstration

projects

assist with

demonstration

projects

EVENT: Water

Weeks, assist with

demonstration

projects,

advertising

Materials Development &

Installations

install Ops demo

garden

install Ops demo

garden

install Ops demo

garden

Public Works

School Program 1 school 1 school 2 schools 2 schools 2 schools 2 schools,

compile teacher

& student

evaluations,

schedule next

assess past year revamp

curriculum

redesign journals,

confirm and

complete

schedule

2 schools 2 schools 1 school, order

shower timers

Natural Resources outreach team

mission statement,

Public Works Week

Event: treatment

plant

tours?/downtown

EVENT: Water

Weeks -

downtown tour

(Fri. Sept. 5)

develop program

branding

Green Team

Quarterly

meeting, Earth

Day clean-up

Quarterly

meeting

Quarterly

meeting

Other

Regional Water Outreach

Coord. (WWIN/ECO Net)

Quarterly

meeting

Quarterly

meeting

Steering

Committee

EVENT: Water

Weeks

Steering

Committee,

Quarterly

meeting

Steering

Committee

Documents

Stormwater Management Program - City of Bellingham