Eastern Washington
Stormwater Effectiveness Studies
Technical Evaluation Report (TER)
BMP Inspection and Maintenance Responsibilities for
Privately Owned Facilities
Study Classification:
ï‚£ Structural BMP
 Operational BMP
 Education & Outreach
Study Objective(s):
ï‚£ Evaluate Effectiveness
 Compare Effectiveness
October 2021
Prepared For:
Yakima County Public Services
128 N. 2nd St. 4th Floor Courthouse
Yakima, WA 98901
(509)720-5018
Prepared By:
Osborn Consulting, Inc.
101 South Stevens Street
Spokane, WA 99201
(509) 867-3654
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QAPP and TER Publication Information
The Quality Assurance Project Plan (QAPP) and Technical Evaluation Report (TER) will be
available to the public on the Yakima County Public Service webpage:
http://www.yakimacounty.us/1732/Stormwater-Management.
For questions regarding the project, please contact David Haws by email
[email protected] or phone (509) 574-2277.
TER Authors and Contact Information
Aimee S. Navickis-Brasch, PhD, PE
Osborn Consulting, Inc.
Senior Project Manager & Stormwater Engineer
101 South Stevens Street
Spokane, WA 99201
[email protected]
509-867-3654 Ext. 301
Taylor Hoffman-Ballard, PE
Osborn Consulting, Inc.
Project Engineer
101 South Stevens Street
Spokane, WA 99201
[email protected]
509-867-3654 Ext. 302
Kevin Flanagan, EIT
Osborn Consulting, Inc.
Project Engineer
101 South Stevens Street
Spokane, WA 99201
509-867-3654 Ext. 307
Kali Ledeboer
Osborn Consulting, Inc.
Engineering Intern
101 South Stevens Street
Spokane, WA 99201
Francisco Jimenez
Osborn Consulting, Inc.
Engineering Intern
101 South Stevens Street
Spokane, WA 99201
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Document History
This study was conducted following the QAPP which can be accessed at the link on the previous
page. The study started in December 2020 and the last data was collected in July 2021. The
findings of the study were presented and submitted to the Technical Advisory Group (TAG) in
August 2021 for review and comment. No comments were received at the time of this document.
The final TER was submitted to Ecology in October 2021.
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Distribution List
This section includes the distribution list for each party who will receive an Ecology-approved
copy of the Proposal.
Name, Title
Organization
Contact Information:
Email, Telephone
Jack Wells,
Natural Resources Specialist
Yakima County
[email protected]
509.574.2350
Brittany Whitfield,
Senior Engineer
City of Pasco
[email protected]
509.544.3080 Ext. 6418
Chuck Geissel,
Public Works Technician III
Walla Walla County
[email protected]
509.524.2729
Randy Meloy, PE
Surface Water Engineer
City of Yakima
[email protected]
509.576.6606
Erin Barnett
Code Enforcement Officer
City of Selah
[email protected]
509.698.7331
Raul Sanchez
Wastewater & Storm Supervisor
City of Sunnyside
[email protected]
509.836.6566
David Dominguez
Civil Engineer
City of Union Gap
[email protected]
509.249.9211
Andrea Jedel
Municipal Stormwater Permit
Manager
Department of Ecology
[email protected]
509.575.2807
Brandi Lubliner
Water Quality Project Manager
Department of Ecology
[email protected]
360.407.7140
Doug Howie,
Water Quality Project Manager
Department of Ecology
[email protected]
360.407.6444
Aimee Navickis-Brasch, PhD, PE
Engineering Manager
Osborn Consulting, Inc.
[email protected]
509.867.3654 Ext. 301
Taylor Hoffman-Ballard, PE
Stormwater Engineer
Osborn Consulting, Inc.
[email protected]
509.867.3654 Ext. 302
Kevin Flanagan, EIT
Project Engineer
Osborn Consulting, Inc.
[email protected]
509.867.3654 Ext. 307
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1.0
Table of Contents
QAPP AND TER PUBLICATION INFORMATION ……………………………………………………………………………… I
TER AUTHORS AND CONTACT INFORMATION …………………………………………………………………………….. I
DOCUMENT HISTORY ………………………………………………………………………………………………………………………..II
SIGNATURE PAGE …………………………………………………………………………………………………………………………………… III
DISTRIBUTION LIST …………………………………………………………………………………………………………………………………. III
1.0
TABLE OF CONTENTS …………………………………………………………………………………………………………………. IV
2.0
EXECUTIVE SUMMARY …………………………………………………………………………………………………………………… 1
3.0
BACKGROUND ……………………………………………………………………………………………………………………………… 3
3.1
INTRODUCTION TO THE OPERATION & MAINTENANCE PROGRAM ……………………………………………………. 3
3.2
PROBLEM DESCRIPTION …………………………………………………………………………………………………………………. 4
3.3
PROJECT GOALS AND OBJECTIVES …………………………………………………………………………………………………… 4
3.4
PROJECT OVERVIEW ………………………………………………………………………………………………………………………. 5
3.5
TARGET POPULATION ……………………………………………………………………………………………………………………. 7
4.0
DATA COLLECTION PROCEDURES ………………………………………………………………………………………………….. 8
4.1
TYPES OF DATA COLLECTED ………………………………………………………………………………………………………….. 8
4.2
SAMPLE COLLECTION PROCESS ………………………………………………………………………………………………………. 8
5.0
DATA QUALITY ASSESSMENT ……………………………………………………………………………………………………….. 10
5.1
DATA VERIFICATION …………………………………………………………………………………………………………………… 10
5.2
DATA USABILITY ASSESSMENT ……………………………………………………………………………………………………… 10
6.0
RESULTS & DISCUSSION …………………………………………………………………………………………………………….. 12
6.1
OBJECTIVE #1: IDENTIFY STRATEGIES MORE COMMONLY IMPLEMENTED AND MORE EFFECTIVE …………… 12
6.2
OBJECTIVE #2: IDENTIFY WHICH ELEMENTS OF STRATEGIES ARE MORE EFFECTIVE ……………………………… 14
6.3
OBJECTIVE #3: DEVELOP RECOMMENDATIONS BASED ON STUDY RESULTS ………………………………………… 20
7.0
CONCLUSIONS AND FUTURE ACTION RECOMMENDATIONS …………………………………………………………… 22
8.0
REFERENCES ……………………………………………………………………………………………………………………………… 24
9.0
APPENDICES ………………………………………………………………………………………………………………………………. 26
APPENDIX A. PARTICIPANT SUMMARY ………………………………………………………………………………………………….. 27
APPENDIX B. SURVEY DATA SUMMARY …………………………………………………………………………………………………. 30
APPENDIX C. INTERVIEW DATA SUMMARY ……………………………………………………………………………………………. 76
APPENDIX D. DATA QUALITY……………………………………………………………………………………………………………….. 83
APPENDIX E. SUMMARY OF QAPP REVISIONS ………………………………………………………………………………………… 92
APPENDIX F. FACT SHEET FOR RECOMMENDED MANUAL ……………………………………………………………………….. 94
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2.0
Executive Summary
Under the National Pollutant Discharge Elimination System (NPDES) and State Waste
Discharge General Permit for discharges from Municipal Separate Storm Sewer Systems
(MS4s), municipalities and other jurisdictions designated by Washington State Department of
Ecology (Ecology) in Eastern Washington (EWA) that manage discharges from their MS4s are
regulated by the EWA Phase II Municipal Stormwater Permit program. One of the ways that
Permittees are required to manage stormwater is to limit the amount of pollutants that discharge
from the MS4s by implementing operational and structural Best Management Practices (BMPs)
for publicly owned and privately-owned drainage systems. Over time, the effectiveness of
structural BMPs can become compromised unless the BMP is properly maintained. Permittees
are required to ensure maintenance is performed as required by the NPDES permit so that
structural BMPs operate and provide the intended runoff treatment and flow control functions.
Difficulties can arise for Permittees when they try to identify and correct operational and
maintenance problems with structural BMPs on private property. While this problem is clearly
documented in related literature, few studies were located that describe strategies related to
inspection, maintenance, and enforcement of structural BMPs on private property. Of the studies
located, none reported on the effectiveness of those strategies.
The goal of the study was to identify and evaluate commonly used inspection, maintenance, and
enforcement strategies of privately owned stormwater BMPs. The strategies identified focused
on who inspects and/or maintains privately owned BMPs: the permittee, BMP owner, a 3rd
party, or different combinations of these groups. These strategies were evaluated based on survey
and interview responses from 26 Permittees in Washington, Oregon, Idaho, and Montana. All 26
permittees responded to an online survey and interviews were conducted with 9 of the permittees
to gain clarification and additional insight on their responses.
Responses from the permittees were analyzed to meet the specific study objectives. The analysis
included coding responses into common themes for open ended questions and basic statistics was
used to analyze responses from multiple choice questions. The effectiveness of a given strategy
was evaluated based on the self-reported effectiveness of the jurisdictions program and by
comparing elements of the strategy to elements identified through a literature search that appear
to support a successful program. A summary of the results, organized by objective are as
follows:
Study Objective #1: Identify strategies more commonly implemented and more effective.
A total of ten strategies were identified for inspection and maintenance of BMPs on private
property. The most commonly implemented strategy was to assign inspection responsibilities to
the Jurisdiction and to assign maintenance responsibilities to the property owner (referred to as
strategy A-B in this document). A determination of which strategy was more effective could not
be determined because of insufficient data to compare: strategy A-B was selected by twelve
participants however only one to three participating jurisdictions selected the other nine
strategies identified.
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Study Objective #2: Identify which elements of strategies are more effective.
Elements are the components that make up a jurisdictions program for O&M on private property.
Jurisdictions that self-reported their program as effective had more elements that align with what
is reported in the literature as elements that make up a successful program compared to
jurisdictions that self-reported their program as somewhat effective or not effective. However
self-reported effective programs have less than half the elements found in the literature. Aside
from a few elements, no elements were found to be used by all strategies all the time, and none
of the benefits of strategies reported by jurisdictions aligned with the elements obtained in the
literature. Moreover, data collected during the survey and interviews indicated that the
jurisdictions had a diverse array of priorities and issues related to inspection, maintenance, and
enforcement of BMPs on private property. This suggests that the importance of elements
identified by the literature vary highly for individual jurisdictions.
Study Objective #3: Develop recommendations based on study results.
The findings related to Objective #1 and #2 indicated that the programs and priorities of each
participant vary and are unique to that jurisdiction. Providing a resource with options would
allow jurisdictions to select solutions that meet their unique priorities. As a result, the future
action recommendations for this study include the development of a guidance manual. The
manual would include a variety of methods to develop and/or improve a jurisdiction’s inspection,
maintenance, and enforcement programs for BMPs on private property. Jurisdictions statewide
could use the manual and select the methods that best fit their strategy and priorities. Moreover,
the manual would include case studies, examples, and templates that jurisdictions could apply to
their own programs.
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3.0
Background
3.1
Introduction to the Operation & Maintenance Program
The focus of this study was to evaluate procedures developed by other jurisdictions to meet
inspection, maintenance, and enforcement (O&M) permit requirements for structural best
management practices (BMPs) on privately-owned property. According to the 2007, 2014, and
2019 versions of the EWA Phase II Municipal Stormwater Permit (Washington State Department
of Ecology, 2019), permittees are required to implement procedures for site inspection and
enforcement of post-construction control measures. Specifically, permittees must implement
mechanisms that allow access for permittees to inspect stormwater BMPs on private properties
that discharge to the MS4. In lieu of requiring continued access, the mechanisms may require
private property owners to provide annual certification by a qualified third party that adequate
maintenance has been performed and the facilities are operating as designed to protect water
quality…