2018 NPDES Permit Outreach Section Survey of Jurisdictions
For more information, contact Tiffany O’Dell, Pierce County (253) 798-2468; [email protected]
During Summer 2016, Stormwater Outreach for Regional Municipalities (STORM) led an effort to survey
jurisdictions in Western Washington about the outreach section of the Phase I and II municipal
stormwater permits. The following are the results of the survey. Results include multiple choice answers
and additional comments submitted by jurisdictions.
1. 72 out of 92 Western Washington municipal permittees responded to the survey
2. It is important that jurisdictions continue to use the Puget Sound Starts Here campaign to raise
awareness about stormwater runoff and the simple steps residents can take to prevent pollution. Public
awareness is an important issue that will make residents more open to behavior change. Implementing
awareness programs on a regional basis is more effective, because it provides a consistent and effective
message to residents about the problem. The awareness section of the permit should be clarified to
make it clear that promoting the Puget Sound Starts Here campaign meets the intent of this section.
Overall Totals: 4/4/7/18 (25%) /43 (59%)
Comments were generally positive towards using the Puget Sound Starts Here campaign as meeting the
awareness and education component of the permit. Most critiques of the premise of the question
revolved around the difference between western Washington and the Puget Sound region; not all
jurisdictions meet both criteria and the messaging may not be applicable to jurisdictions along the
Columbia River or Willapa Bay. Other respondents questioned the messaging of PSSH directly. A few
were concerned that there wasn’t a way to measure the effectiveness of the campaign. These folks
didn’t dispute the value of a regional approach to education and outreach, but rather if PSSH was an
effective precursor for behavior change. One respondent questioned if PSSH was meaningful for diverse
audiences compared to more direct messaging like, “Dump no waste, drains to streams”. The gist of
several comments was that the regional messaging behind PSSH should be revisited.
Total Responses
Overall Responses
Disagree
Somewhat disagree
Neutral
Somewhat Agree
Agree
2018 NPDES Permit Outreach Section Survey of Jurisdictions
For more information, contact Tiffany O’Dell, Pierce County (253) 798-2468; [email protected]
3. Ecology should require a regional or statewide spill hotline and encourage jurisdictions to work
regionally to promote it.
4/10 (14%) /15 (21%) /23 (32%) /24 (33%)
Attitudes expressed in comments were divergent, many respondents had differing ideas about how a
new regional or statewide spill hotline would look. Some wondered about the existing ERTS system, and
thought it worked fine, while still more would like to see a reworking of ERTS – to either combine spills
IDDE for a unified stormwater hotline, or increased funding and staffing. The largest criticism of the idea,
a regional/statewide hotline to be promulgated, wouldn’t be as responsive or effective as local lines
since they are more responsive and geographically knowledgeable. A few respondents supported the
idea of a single number to call for folks by noting that people often don’t know which jurisdiction to call,
they may not know where they are, and that it should be as easy as possible for citizens – something a
single number does. A handful objected to being required to support it, preferred it to be optional, and
were concerned about how such an effort would be funded given ongoing funding concerns at the state
level.
Responses
Overall Responses
Disagree
Somewhat disagree
Neutral
Somewhat agree
Agree
2018 NPDES Permit Outreach Section Survey of Jurisdictions
For more information, contact Tiffany O’Dell, Pierce County (253) 798-2468; [email protected]
4. Jurisdictions should be allowed to choose those behavior change programs which are most relevant
and will have the most impact in their jurisdiction in order to focus time and resources. They should not
be required to implement every behavior change program prescribed in the permit. For example,
jurisdictions should have the ability to choose to focus outreach on those topics related to a TMDL or
identified water quality program in their jurisdiction. Phase 1s have been required to implement
programs not relevant in their jurisdictions, which has been detrimental to the quality and reach of all of
their outreach programs.
0/1/3/8 (11%) / 63 (86%)
The majority of comments for question 4 were positive. Commenters remarked that they strongly
agreed with the idea of flexibility based on local needs. Many commented that jurisdictions should link
outreach programs to local water quality concerns, especially those of highest priority or concern. Some
commented that jurisdictions should provide justification, while others did not mention justification.
Several commented that implementing programs that are irrelevant siphons resources away from locally
relevant programs and wastes public funds. Smaller jurisdictions tended to comment that Ecology or
STORM programs should continue to provide quality program examples that could be easily adopted. A
few commented that this was more likely a problem limited to Phase 1s, as the permit is currently
written, because Phase 2s have flexibility to implement programs of their choice. Two commenters
warned that such flexibility should be implemented, however guards should be in place to ensure
additional flexibility does not allow jurisdictions to opt-out of implementing outreach programs.
Responses
Overall Responses
Disagree
Somewhat disagree
Neutral
Somewhat agree
Agree
2018 NPDES Permit Outreach Section Survey of Jurisdictions
For more information, contact Tiffany O’Dell, Pierce County (253) 798-2468; [email protected]
5. The goal of the outreach section of the permit should be to effect long-term, sustainable behavior
change related to water quality issues. The 2013 permits made it difficult for jurisdictions to implement
effective, long-term behavior change programs. In almost all cases, behavior change programs require
years of consistent investment to reach audience saturation, and as such jurisdictions should be
required to invest in the same programs over time to be effective. Rather than prescribing a long list of
programs, the focus should be on high quality, effective programs.
2/3/6/15 (21%) /49 (67%)
Several jurisdictions commented that this has been less of a problem for Phase 2s, because they have
more flexibility in their permit to choose to implement the same program year-after-year, and as such
are able to invest more in quality programming. For Phase 1s, this has been a serious struggle –
resources are pulled away from high-quality programs to “check-the-box” for implementation of
required programs. Several jurisdictions commented that they have had success partnering with other
jurisdictions or regional groups to implement stronger programs than they would have been able to
implement individually. Several also clarified that this is a generalization – some problems only require
short-term programs, while others require long-term investment. Many commented that it should be up
to the jurisdiction to determine when a program has run its course either by achieving its goals, or
becoming ineffective. In this case, jurisdictions should have the option of changing their programs.
Responses
Overall Responses
Disagree
Somewhat disagree
Neutral
Somewhat agree
Agree
2018 NPDES Permit Outreach Section Survey of Jurisdictions
For more information, contact Tiffany O’Dell, Pierce County (253) 798-2468; [email protected]
6. Because permittees differ significantly in population size, it would be beneficial to all if the number of
behavior change programs required were based on population, not permit type. For example,
jurisdictions with a population of 40,000 or fewer should have 1 program, jurisdictions sized between
40-80,000 should have 2 programs, jurisdictions 80-120,000 should have 3 programs, jurisdictions 120-
200,000 should have 3 programs, jurisdictions 200-400,000 should have 4 programs, jurisdictions with
more than 400,000 should have 5 programs. Allowing jurisdictions to make program investments
proportional to the population of that jurisdiction will result in more resources invested in fewer, high
quality programs, instead of spreading funding over many low-quality programs.
5/11 (15%) / 11 (15%) / 20 (27%) /28 (38%)
While many jurisdictions agreed that the number of programs required is problematic, many
commented that correlating the number of required programs to population is not the right approach.
Some commented that there are jurisdictions where water quality concerns are significant despite small
population size. They argued that burden of program implementation should be higher based on the
number of water quality concerns, not population size. Several commented that even at the proposed
levels this approach could spread resources too thin, proposing only one program focus per jurisdiction.
Many commented that the approach of jurisdictions doing multiple programs leads to hastily
implemented programs instead of deeper, higher quality programs. A few commented that regional or
watershed approaches allow for jurisdictions of all sizes to implement high quality programming. A few
commented that partnerships should be incentivized.
Responses
Overall Responses
Disagree
Somewhat disagree
Neutral
Somewhat agree
Agree
2018 NPDES Permit Outreach Section Survey of Jurisdictions
For more information, contact Tiffany O’Dell, Pierce County (253) 798-2468; [email protected]
7. The permit should continue to include the requirement for jurisdictions to provide opportunities for
stewardship activities. Jurisdictions like receiving credit for good work such as this, and it provides an
excellent opportunity to form partnerships with non-profit organizations working locally.
6/4/10 (14%) / 12 (16%) / 43 (59%)
A near-consensus narrative from the comments was that the permit requirement of providing
opportunities for stewardship activities was vague and difficult for the smaller jurisdictions who lack a
specific education and outreach full-time staff person. Many offered ways to, as they saw it, improve the
permit. These included having Ecology provide a guidance document on the activities that qualified as
stewardship, incentivizing rather than requiring stewardship partnerships, or goals for what should be
accomplished. Though most respondents favored partnership for stewardship, some questioned the
need for including NGOs, or using partnerships on water quality problems compared to other activities
like restoration work. Though generally receptive, respondents expressed a preference for loosening
stewardship requirements while clarifying the options jurisdictions had to fulfill the requirement.
Responses
Overall Responses
Disagree
Somewhat disagree
Neutral
Somewhat agree
Agree
2018 NPDES Permit Outreach Section Survey of Jurisdictions
For more information, contact Tiffany O’Dell, Pierce County (253) 798-2468; [email protected]
8. A modest amount of funding for regional awareness and behavior change programs should be
required under the permit (for example $1,000 per year for Phase 2s and $5,000 per year for Phase 1s).
Jurisdictions would be required to have representation on regional or sub-regional committees to direct
how this funding is used. This funding could be used for long-term programs such as non-profit
partnerships, maintenance and improvement of online tools, program evaluation, audience research
and STORM network coordination.
13 (18%) /9 (12%) /10 (14%) /24 (33%) /19 (26%)
A seemingly consistent view was that pooling dollars for regional awareness campaigns was reasonable
likely more impactful than non-regional efforts. Conversely, that sense didn’t apply to behavior change.
More respondents held that that was best done at the level of the specific jurisdiction in order to better
meet citizen concerns, jurisdictional needs and be justifiable. Many smaller jurisdictions objected to
being tasked to serve on an additional committee. They saw it as burdensome on their resources and
disliked travelling to far-flung meetings. Others, both Phase I and II permittees, considered a fee-based
approach to be an over-reach of the permit. A handful thought this a mission for STORM, assuming it
would credit towards permit compliance and meeting attendance was not mandatory. Jurisdictions
outside the Puget Sound Region were unsure how it would benefit them.
Responses
Overall Responses
Disagree
Somewhat disagree
Neutral
Somewhat agree
Agree
2018 NPDES Permit Outreach Section Survey of Jurisdictions
For more information, contact Tiffany O’Dell, Pierce County (253) 798-2468; [email protected]
9. Phase 1s and Phase 2s should be encouraged to develop campaigns that serve a multicultural
audience, as appropriate, to build equity into programs. Demographic information and community
knowledge should be used to determine whether a multicultural approach is needed.
5/2/23 (32%) /14 (19%) /29 (40%)
The majority of comments for Question 9 were neutral or to some degree in agreement with the
statement. There is agreement among these respondents that addressing these barriers will provide
more equitable and effective programs. There is support that the approaches be based on jurisdiction
demographics, as each jurisdiction has different needs for this element. Among those that disagree or
are neutral regarding the statement, there is concern over lack of capacity amongst smaller jurisdictions
and an interest in this work being done regionally. Some also think that this should be encouraged but
not required in the permit. There is also interest in addressing urban vs. rural audiences and addressing
age diversity.
Responses
Overall Responses
Disagree
Somewhat disagree
Neutral
Somewhat agree
Agree
2018 NPDES Permit Outreach Section Survey of Jurisdictions
For more information, contact Tiffany O’Dell, Pierce County (253) 798-2468; [email protected]
10. The permit should continue to include the option for jurisdictions to implement awareness and
behavior change programs and evaluation individually or as a member of a regional group. The permit
should encourage jurisdictions to work together and share resources rather than develop programs in a
vacuum. Smaller jurisdictions often recreate the wheel or invest in programs that have previously been
deemed unsuccessful without looking outside their jurisdiction. Continuing to promote regional
collaboration will result in more effective and consistent programs with wider reach.
3/2/4/12 (16%) / 52 (71%)
The majority of comments for Questions 10 were in strong support of the statement. There is
agreement with almost all parties that there should continue to be the option of implementation…