Education and Outreach Topic Group White Paper
Co-leads: Katherine Straus, STORM Coordinator and Susan McCleary, City of Olympia
The Education and Outreach White Paper identifies issues, concerns and recommendations for the
Education and Outreach section of the NPDES permit gathered from permittees and partner
organizations during the 2024 Permit Reissuance Ad Hoc Process. The report is organized by topic and
permit section. It does not address every comment received, but rather highlights trends and common
issues.
Process
The E&O Topic group convened twice between November and December. Comments were gathered via
an online survey and during a virtual “Listening Session”. Permittees and partner organizations were
given the opportunity to review all comments and provide additional input. The feedback gathered
during the virtual meeting and the comments from the survey results were aggregated and then distilled
into common themes. Due to the large participation numbers, the goal of the group was not to reach
consensus, but to gather all feedback, identify trends, and then present those findings to Ecology.
Approximately 50 individuals attended the December 9th “Listening Session,” where attendees were
divided into breakout rooms to discuss the E&O sections of the permit. Feedback was collected in a
shared google document, provided as Appendix II. The online survey received 30 responses (27
individual municipal stormwater permittees and 3 partner agencies). Consolidated survey results and
Google Slide comments, organized by topic and permit section, are provided as Appendix I.
The following information is a summary of key themes and common issues. To view all comments please
see Appendix I.
Long term sustainability
Section S.5.C.2.
Smaller and less-resourced jurisdictions feel that they don’t currently have the staff capacity
or expertise to meet many of the E&O requirements as currently written. They expressed a
common concern about future additions in the next permit cycle and their ability to meet
additional requirements.
Section S.5.C.2.a.ii: Behavior Change
There is consensus among Phase I and Phase II permittees that the Permit language needs
to encourage long-term efforts that are refined over time to increase effectiveness, rather
than jumping from program to program between permit cycles.
Local WQ Data
Section S.5.C.2.
There was general confusion around what is meant by and what qualifies as “local water
quality data.” Permittees recommend updating this language to “local and/or regional water
quality data.” More information on the intent behind “local” water quality data could be
included in the guidance documents.
Regional Collaboration
Section S.5.C.2.
There was general consensus among permittees that they appreciate the option to meet
E&O permit requirements through regional collaboration, however they would benefit from
more information in the guidance documents on what qualifies as regional collaboration.
Section S.5.C.2.a.ii: Behavior Change
There is consensus that being able to meet this requirement as part of a regional effort is
important and jurisdictions want this to stay in the permit.
Stewardship
Section S.5.C.2.
There was a general feeling of conflict between how stewardship was described in this
section vs. how it is described in Section S.5.C.2.a.iii, specifically the use of the word
“partner” vs. “promote.” Permittees would like to see more consistent language used
between the two sections.
Section S.5.C.2.a.iii: Stewardship
Permittees felt that the next permit would benefit from including language around offering
opportunities through virtual engagement, as volunteers are reluctant to attend events and
COVID protocols can be difficult to enforce.
There was consensus that permittees need more examples of different kinds of activities
that would qualify as “stewardship.” This would be best communicated as additional
information in the guidance documents.
There is confusion among jurisdictions about the purpose of stewardship- whether it is to
maintain the MS4 or to engage the community in local watershed stewardship. The
guidance documents could help clarify this with more information on what is intended by
the statement “areas serviced by the MS4.”
Permittees would also benefit from more information in the guidance documents on
appropriate ways to meet the stewardship requirement through regional collaboration.
Staff Capacity
Section S.5.C.2.a.ii: Behavior Change
Developing and implementing a behavior change program is staff and resource intensive,
and most small and/or less-resourced jurisdictions don't currently have the staff capacity or
expertise to meet this requirement.
Staff and managers need more educational resources to help them better understand the
staff and financial inputs needed to implement an effective behavior change program
Measurement and Evaluation
Section S.5.C.2.a.ii: Behavior Change
Permittees need more guidance on what program evaluation looks like and what it should
include. Guidance for this section should also include more information about what it means to
“affect” behavior change. For example, there was concern that if a behavior chance program
was not successful a jurisdiction might be found to be out of compliance.
Based on feedback, the group recommends changing the wording in this section from “measure
understanding” to “measure adoption.”
Timeline
Section S.5.C.2.a.ii: Behavior Change
Permittees feel that the timeline is too condensed in the beginning. When developing a new
program, more time is needed up front for issue research (selecting behavior and audience),
developing a social marketing strategy and piloting the program.
More clarity is needed around what "implementation" means. This could include suggestions for
ongoing evaluation or whether the pilot phase and/or phased implementation are included in
"implementation?
CBSM vs. Social marketing
Section S.5.C.2.a.ii: Behavior Change
There is consensus among permittees that they would like to see the term “Community Based
Social Marketing” removed from the permit in favor of “Social Marketing.” Community Based
Social Marketing is a specific type of social marketing championed and taught by a single
individual, while social marketing is the general name used for the field of practice.
Target Audience and/or BMP List
Section S.5.C.2.
There is consensus among permittees that the term “priority audience” should be used
throughout the permit instead of “target audience.” “Priority audience” is the more
professionally accepted term within the education and outreach field.
Section S.5.C.2.a.i: General Awareness
Suggestions for new audiences to include within this section were: unhoused individuals,
internal audiences (staff), stormwater facility owners, and real estate professionals.
Include 6PPD as a general awareness topic. Target audiences include the general public,
businesses including tire storage, sales and recycling operations, and municipal government
officials.
Provide an additional option for audiences and behaviors that are specific to a jurisdiction (for
example, wineries).
Section S.5.C.2.a.ii: Behavior Change
Suggestions for new audiences to include in this section were: commuters, college students or
young adults, and audiences identified through SMAP efforts.
Suggestions for new BMP’s to include in this section pressure washing and Adopt a Drain.
Permit language/formatting
Section S.5.C.2.
There was disagreement among permittees regarding how forceful permit language should be
around providing messages in languages other than English. While some appreciated the
flexibility that the word “shall,” allows, others felt that the language should be changed to
“must,” to help staff better communicate with management about the need to do this work.
Regardless of the language used, permittees agreed that translation is not sufficient. Instead,
the focus needs to be on transcreation i.e., not simply providing audiences with translations of
English outreach materials, but providing them with translated AND culturally relevant outreach
materials.
Section S.5.C.2.a.ii: Behavior Change
Consider creating a visual guidance tool for the timeline, like a table or flowchart, including
social marketing steps, to help permittees better understand how to stay on track to meet
requirements over the course of the permit cycle.
Overburdened Communities
Section S.5.C.2.a.i: General Awareness
Permittees request more guidance on what audiences qualify as “overburdened” and how to
identify them.
The following is a summary of items described above that would be helpful to include in future
guidance documents:
What is meant by “local” water quality data.
What qualifies as regional collaboration.
More examples of different kinds of activities that would qualify as “stewardship.”
Clarification on the stewardship requirement and what is intended by the statement “areas
serviced by the MS4.”
More information on what program evaluation entails. Guidance for this section should also
include more information about what it means to “affect” behavior change.
A visual guidance document for the behavior change timeline.
What audiences qualify as “overburdened” and how to identify them.
Appendix I
Consolidated Comments from E&O Ad Hoc Survey and Google Slide
Meeting Notes
E&O Intro Section: S5.C.2
Local WA to regional
What kind of local water quality info is appropriate? Proposed solution: Direction on
appropriate water quality info. (Phase II)
Instead of "local water quality" it should say "local and/or regional water quality" or better
define what is meant by "local". Proposed solution: "Local" implies within our jurisdiction. But
water quality information may be part of a study covering a large area, like the impacts of road
runoff. (Phase II)
"Create" stewardship opportunities, "local" water quality data. Change “create” to “promote”
and change local water quality data to regional water quality data. Justification: We are a small
jurisdiction and do not have a large capacity to create stewardship opportunities. Further in the
permit it says create or promote opportunities in your community, which is better language.
There are so many partners to utilize that are well experienced in stewardship opportunities and
volunteer management. (Phase II)
Under minimum performance measures, language includes using "local water quality." This is
problematic for smaller jurisdictions who may not have access to local data. We suggest
changing from "local" water quality to "regional" water quality. (Phase I)
We appreciate the language in this section which is broad enough for interpretation by smaller
jurisdictions. Adding language that is too specific and prescriptive makes it difficult for small
jurisdictions to comply. (Phase I)
"Local" water quality data limits jurisdictions to the data that they collect, which may not be
much/give a full picture. Change to local and/or regional water quality. Justification: Gives a
fuller picture of water quality/water quality issues to better inform outreach programs. We pay
into SAM and, as a result, are limited in the amount of local data available. (Phase II)
It would be more appropriate to convey this as something along the lines of “relevant or
“applicable water quality data related to pollutants conveyed from MS4 discharges.”
No resources for mgmt commitment to identify WQ issues – challenging to do this level of work,
challenge is only one staff – doing door to door engagement
Findings from SMAP-related analyses can also be a local source to help inform local E&O-related
priorities.
Instead of “local” water quality data, use “Regional” as some jurisdictions don’t have hyper-
localized data to pull from. Maintain regional language. “Local water quality” is very ambiguous,
what are the data requirements? Define what qualifies. How does one incorporate local data?
Suggest changing language from “local” water data to allow/include “regional” water quality
data. Not everyone has access to data.
“The program design shall be based on local water quality information.” Needs to be more
elaborate or explicit as this language doesn’t give enough guidance; however, having some
flexibility is positive. Proposed solution: Provide guidance on how jurisdictions could use local
water quality and/or illicit discharge information to help prioritize efforts.
Changing water quality language seems to be a reoccurring theme; may be more appropriate to
convey this as something along the lines of “relevant” or “applicable water quality data related
to pollutants conveyed from MS4 discharges.”
What is the local water quality basis that Ecology is looking for? And how must that be
considered when jurisdictions work on a regionally collaborative basis? Is the local WQ
established by the jurisdiction? Ecology? A third party? What if not all jurisdictions have done
the same types of WQ analysis across the regional group? What determines the priority of one
water quality issue in comparison to another? (Phase I)
Regional Collaboration
We are subject to secondary permit (S6.E). However, I agree that allowing for regional approach
and collaboration is a positive – stormwater and BMPs make sense in watersheds that cross city
and county boundaries. (Secondary Permit)
I would love to define regional collaboration, and to encourage that more in our region. (Phase
II)
There is a lack of recognition of the global impact of climate change on our work, communities
and the role of stormwater or investment – what is the overall community engagement goal of
Ecology’s work? How can we use the power of these dedicated folks to address environmental
outcomes we hope to see? Are we missing the big issue by focusing on local details, not having
an overall shared goal? E.g., strategic messaging focus: climate change – human environmental
health- economic health -role of stormwater WQ and infrastructure. We could have a reqt for
other skill sets: social scientists, urban planners, economists to pull the big picture together –
and allow individual stormwater managers to feel successful and that they are contributing.
placing education on stormwater managers risks may not be the best approach for ed – we need
to call out that skill set – rather than assuming anyone can be an educator. We risk traumatizing
or turning off students, esp. those from underserved communities.
Don’t recommend making the above suggestion in the white paper. This would require small
jurisdictions to have to contract out for specialized skill sets without resources to do so.
Kudos to Ecology to see the effectiveness of regional collaboration. Water quality issues are not
confined within the boundaries of a jurisdiction. And residents and businesses rely on
information from sources across the region, not just from those within the confines of the
jurisdiction. Significant impact is made through well-done regional collaboration. Regional
collaboration is amazingly effective.…