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Department of Environmental Quality
NC MS4 Compliance
Strategy
NC MS4 Sustainability Strategy (MS6)
Background Information
DEQ/DEMLR/Stormwater Program
Mike Randall,
(919) 807-6374
E-mail: [email protected]
Robert Patterson
(919) 807-6369
E-mail: [email protected]
1612 Mail Service Center
Raleigh NC 27699-1612
The Next Generation of Compliance
Background Information
Department of Environmental Quality
Currently one part time position dedicated to administer the MS4 program
• 101 small MS4 local governments • Over 40 have populations < 10,000
• 2 non traditional Schools in Mecklenburg County• NCDOT (TS4)• 6 Large MS4s• 2 Universities• 4 Military bases• 28 MS4 waived or requested waivers - populations < 10,000• 20 potential MS4 from the 2010 Census - populations < 10,000
Federal and State regulations allow the state to approve request to waive or rescind MS4 permits if they demonstrate that they have effective SW programs in place.
Department of Environmental Quality
DEQ’s Overall MS4/TS4 Compliance Strategy
Enforcer
ResourcePartner
• Enforcer the EPA/DEQ FY17 SECTION
106 WORKPLAN – Inspections and
audits
• A partner and a resource DEQ will
continue to support outreach activities,
such as, summits, workshops, training
• A partner and a resource DEQ will
continue to be committed to seeking
cooperative and sustainable solutions
through Round Table discussions,
Lunch and Learns, and meetings.
Department of Environmental Quality
The Next Generation of Compliance
Annual Reports
MS4s are required to prepare and submit annual reports
Audits and Inspections
CWA SECTION 106 WORKPLAN for Phase I and II MS4s requires NC DEQ –DEMLR conducts on-site audit, MS4 inspection, or off-
site desk audit once/5 years.
Department of Environmental Quality
NC DEMLR is requesting EPA eliminating the NC MS4/TS4 annual reporting and MS4/TS4 inspections and audits where there is a formal and transparent sustainability strategy.
The New Generation of MS4 Compliance
You can’t fatten a pig weighing it.
Department of Environmental Quality
Request Recognizes
• Posting Gap Analysis, Root
Cause Analysis and Action
Plans ensures transparency
and provides better oversight
• Partnerships lead to
cooperative solutions.
• Cooperative solutions lead to
ownership.
The New Generation of MS4 Compliance
Department of Environmental Quality
Request recognizes ownership leads to improved stormwater programs that:
• Minimizes liability
• Strengthens stormwater programs through adaptive management and peer-to-peer
interaction
• Allows the local government demonstrate and model success in maintaining NPDES
MS4 regulatory compliance while continually improving upon practicable measures to
help achieve local, state, and federal stormwater management goals
• Promotes public engagement and collaboration
• Promotes results-based adaptive management that benefits the community and
watersheds served by the stormwater program, the regulated entity, regulatory
agencies, and broader program stakeholders.
• Allows the Local Government to identify and implement program strategies and
measures to meet the community’s existing stormwater management requirements
and needs while anticipating and preparing for the future.
The New Generation of MS4 Compliance
Department of Environmental Quality
The Next Generation of Compliance
NC MS4 Compliance
Strategy
NC MS4 Sustainability Strategy (MS6)
Background Information
Cooperative Solution
DEQ Stormwater Permitting
SWANC and APWA
NCDOT
Phase I and Phase II
Local Governments
Environmental Groups
League of Municipalities
Private Sector
Department of Environmental Quality
• MS6 was a cooperative solution to address the environmental, social and economic impacts of the MS4 program
• MS6 IS NOT mandatory• MS6 IS A MANAGEMENT
STRATEGY that provides local governments the tools to develop sustainable programs
The Next Generation of Compliance
Department of Environmental Quality
MS4s Partners MS4s Partners Engineering Firms
Burlington* Greenville AMEC*
Winston-Salem (Phase I)* Lewisville WK Dickson
Greensboro (Phase I)* Durham (Phase I) DRMP
Raleigh (Phase I)* Wilmington Timmons Group
Holly Spring* Fayetteville (Phase I) Kimley Horn
High Point Morrisville Hazen and Sawyer
Asheville Cary
Monroe Garner
Kernersville Charlotte (Phase I)
Guilford County Mecklenburg County
* Core Partners. Other Partners included Several COGs, DEQ, NCDOT, League of Municipalities, APWA, SWANC, and
several Environmental Groups
The Next Generation of Compliance
Department of Environmental Quality
Six elements for sustainable MS4
programs
Organizational Commitment
Environmental Management
Systems (EMS)
- Ordinances, Policies, Plans, and
SOPs
Asset Management
Finding cooperative solutions through collaboration and
partnerships
Gap Analysis and Root Cause Analysis
(Identify gaps and root causes)
Action Plans with Deadlines to
address gaps and root causes
• E-camp audits (Airforce)
• Environmental Compliance Evaluations (ECEs – Marine Bases)
• ISO14000 Gap Analysis
• Corporate Environmental Management Systems (EMS) and Asset Management
• APWA PW certification
• The Baldrige Performance Excellence Program and other Business Plan Models
• Practices implemented by NC local governments.
The Next Generation of Compliance
Department of Environmental Quality
Six elements for sustainable MS4
programs
Organizational Commitment
Environmental Management
Systems (EMS)
- Ordinances, Policies, Plans, and
SOPs
Asset Management
Finding cooperative solutions through collaboration and
partnerships
Gap Analysis and Root Cause Analysis
(Identify gaps and root causes)
Action Plans with Deadlines to
address gaps and root causes
1. Resolution affirming the Local Government’s Support Regarding the MS4 Sustainable Strategy –Sample in packet
2. Primary community contact information
3. Link to program website
Start accepting July 1, 2017
Email w/ PDF to [email protected]
The Next Generation of Compliance
Department of Environmental Quality
Six elements for sustainable MS4
programs
Organizational Commitment
Environmental Management
Systems (EMS)
- Ordinances, Policies, Plans, and
SOPs
Asset Management
Finding cooperative solutions through collaboration and
partnerships
Gap Analysis and Root Cause Analysis
(Identify gaps and root causes)
Action Plans with Deadlines to
address gaps and root causes
The Next Generation of Compliance
• Compendium of useful documents, checklist, and sample gap analysis, list of root causes, etc.
• Available July 1, 2017
• Maintained by the State w/ local governments and stormwater professionals providing updates.
Department of Environmental Quality
Six elements for sustainable MS4
programs
Organizational Commitment
Environmental Management
Systems (EMS)
- Ordinances, Policies, Plans, and
SOPs
Asset Management
Finding cooperative solutions through collaboration and
partnerships
Gap Analysis and Root Cause Analysis
(Identify gaps and root causes)
Action Plans with Deadlines to
address gaps and root causes
The Next Generation of Compliance
• Stormwater Inspection and maintenance (SWIM)
• Like an IRA for Stormwater Management Controls that want to retire
• Public Private Partnerships (P3) ???
Department of Environmental Quality
Six elements for sustainable MS4
programs
Organizational Commitment
Environmental Management
Systems (EMS)
- Ordinances, Policies, Plans, and
SOPs
Asset Management
Finding cooperative solutions through collaboration and
partnerships
Gap Analysis and Root Cause Analysis
(Identify gaps and root causes)
Action Plans with Deadlines to
address gaps and root causes
• Partnerships lead to
cooperative solutions
• Cooperative solutions
lead to ownership
• Ownership leads to
improved stormwater
programs
The Next Generation of Compliance
Department of Environmental Quality
Six elements for sustainable MS4
programs
Organizational Commitment
Environmental Management
Systems (EMS)
- Ordinances, Policies, Plans, and
SOPs
Asset Management
Finding cooperative solutions through collaboration and
partnerships
Gap Analysis and Root Cause Analysis
(Identify gaps and root causes)
Action Plans with Deadlines to
address gaps and root causes
• Checklist • Background Information (EPA
Federal Regulations)
• Permit Requirements
• Questions related to sustainability
• Redundancies
• Gap Analysis identifies • Positive Findings, Deficiencies or
Gaps in the Stormwater
• Recommendations and opportunities to improve the program
• Identifies Root Causes
• Start using July 1, 2017
The Next Generation of Compliance
Department of Environmental Quality
Six elements for sustainable MS4
programs
Organizational Commitment
Environmental Management
Systems (EMS)
- Ordinances, Policies, Plans, and
SOPs
Asset Management
Finding cooperative solutions through collaboration and
partnerships
Gap Analysis and Root Cause Analysis
(Identify gaps and root causes)
Action Plans with Deadlines to
address gaps and root causes
• Local Government develops and implements an action plan
• Specific actions that address both the deficiencies and the root causes
• Identify specific time frames and deadlines when the actions are to be completed
The Next Generation of Compliance
Department of Environmental Quality
Local Government’ Role
• Adopt a resolution or other mechanism affirming support of the NC MS4 Sustainable
Strategy (MS6)
• Identify and implement program strategies and measures to meet the community’s
existing stormwater management requirements and needs while anticipating and
preparing for the future.
• Open data reporting
• Public engagement and collaboration
• Results-based adaptive management that benefits the community and watersheds
• Participate and support summits, workshops and training sessions.
• Seeking cooperative solutions through meetings, Lunch and Learns, and round-table
discussions.
• Providing feedback to DEMLR either with an e-mail, text, and/or mail and/or during
regular workshops, round table discussions, and Lunch and Learn sessions.
The Next Generation of Compliance
Department of Environmental Quality
• Participate and support summits,
workshops and training sessions.
• Seeking cooperative solutions through
meetings, Lunch and Learns, and
round-table discussions.
• Maintain an interactive map
• Maintain a questionnaire for
conducting a gap analysis and a list of
Root Causes.
• Maintain a compendium of SOPs,
model ordinances, checklist, policies,
and plans
• Develop and maintain NC MS6
training material
The Next Generation of Compliance
State’s Role
Department of Environmental Quality
What’s Next
DEQ/DEMLR/Stormwater Program
Mike Randall,
(919) 807-6374
E-mail: [email protected]
Robert Patterson
(919) 807-6369
E-mail: [email protected]
1612 Mail Service Center
Raleigh NC 27699-1612
DEQ/EPA Approval
Web based applications for
Inspections, Audits Gap Analysis, Root
Cause Analysis, Reporting
Training
Department of Environmental Quality
NC MS6 Training
• Develop a two or three-day course
• 12 or more modules
• Each module will include lesson plans, identify the subject, time period, lesson plan objectives, handouts, power point presentations, exercises, and a pre and posttest.
• Offered to stormwater professional and Federal and State agencies.
• Courses may be observed by DEQ/EPA staff for consistency
What’s Next
Course Agenda
Day 1 MS6 Program
Organizational Commitment Environmental Management Systems (EMS) Asset Management Finding Cooperative Solutions Performing Gap Analysis and Identifying Root Causes Developing and Implementing Action Plans
Day 2 Minimum Measures
Public Education and Outreach Public Involvement IDDE Construction Activities Post-construction Activities Good Housekeeping and Pollution Prevention
Day 3 Optional Training
NC Compliance Strategy Alternatives to TMDLs Other ideas ????
Department of Environmental Quality
What’s Next
State will maintain a list of stormwater professionals that have attended the MS6 Training
Who is going to provide the ongoing training ????
319 grants and/or Public Private Partnerships (P3)
Department of Environmental Quality
What’s Next
• DEQ commitment and EPA approval• Audits and Inspections
– EPA contracts audits and inspections– Gap Analysis and Root Cause Analysis performed by independent
stormwater professions will be reviewed, documented, and recorded in BIMs as State audits and/or inspections pursuant to the CWA SECTION 106 WORKPLAN EPA/DEQ MOU for Phase I and II MS4s
– EPA may require stormwater professionals meet a State/EPA requirements/standard to perform Gap Analysis and Root Cause Analysis on behave of the State
• Annual Report– Posting the results of Gap Analysis and Root Cause Analysis and
Action Plans meet the requirement to submit annual reports to the State.
Department of Environmental Quality
What’s Next
Gap Analysis Questionnaire, Root Cause list and Action Plans lend themselves to
a web-based application, inspections, audits and electronic reporting
(beginning in 2020)
319 grants and/or Public Private Partnerships (P3) ???