Hello Water Quality Associates –
Late last year, the City of Bellevue, Redmond, and Kirkland put together a short survey to get a better
understand of how jurisdictions, big and small, are all doing with implementing the IDDE NPDES permit
requirements, especially with the twist of COVID. We had fabulous turnout in completing the survey –
thank you (65 responses)! The survey results are showing some really great different program
implementation information we each can takeaway. Information such as how we each primarily receive
our water quality concerns calls, who within our jurisdiction responds to the calls, who cleans up the
spills that do occur (responsible party vs. jurisdiction staff), how we are all handling enforcing code
compliance (that is a touch one!), and how we train our staff.
Quick summary, we are all doing a really great job and learning from each other is a great way to grow.
No need to reinvent the wheel with so much expertise out there! Please see the results attached.
Again, thank you for participating.
Ryean-Marie Tuomisto
City of Kirkland
[email protected]
Tanya MacFarlane
City of Bellevue
[email protected]
Scott McQuary
City of Redmond
[email protected]
Implementing IDDE NPDES Permit Requirements Jurisdiction Survey Results
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Survey Question Results are organized into two sections—the survey questions with survey responses
and a summary of jurisdictions results. The two sections organize the survey results into four categories
based on the jurisdictions population.
Results collected and analyzed by Ryean-Marie Tuomisto.
Survey Question Responses
Q1: What is the population of your jurisdiction?
(65 responses)
29% (19)
< 20,000
31% (20)
20,000 – 60,000
15% (10)
60,000 – 100,000
25% (16)
> 100,000
29%
31%
15%
25%
What is the population of your jurisdiction?
(65 responses)
<20,000
20,000 – 60,000
60,000 – 100,000
> 100,000
Implementing IDDE NPDES Permit Requirements Jurisdiction Survey Results
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Q2: How many full-time employee(s) work in your jurisdiction's IDDE program
(staff investigating IDDE incidents)?
(64 answered)
< 20,000
o 58%
Less than 1 FTE
o 21%
1 FTE
o 21%
2-3 FTE
20,000 – 60,000
o 40%
Less than 1 FTE
o 35%
1 FTE
o 25%
2-3 FTE
60,000 – 100,000
o 60%
Less than 1 FTE
o 20%
1 FTE
o 20%
2-3 FTE
> 100,000
o 13%
Less than 1 FTE
o 20%
1 FTE
o 67%
2-3 FTE
58%
40%
60%
13%
21%
35%
20%
21%
25%
20%
67%
< 20,000
20,000 – 60,000
60,000 – 100,000
> 100,000
How many full-time employee(s) work in your
jurisdiction's IDDE program
(staff investigating IDDE incidents)? (64 answered)
2-3 FTE
1 FTE
Less than 1 FTE
Implementing IDDE NPDES Permit Requirements Jurisdiction Survey Results
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Q3: Where do you receive most of your water quality calls from? Rank from highest volume of calls to
lowest volume of calls.
(64 answered)
< 20,000
o Internal staff (not emergency services)
o Customer/residents
o Ecology ERTS notifications
o Emergency Services (fire/police)
o Other jurisdictions (not Ecology)
20,000 – 60,000
o Customer/residents
o Internal staff (not emergency services)
o Ecology ERTS notifications
o Emergency Services (fire/police)
o Other jurisdictions (not Ecology)
60,000 – 100,000
o Customer/residents
o Internal staff (not emergency services)
o Ecology ERTS notifications
o Emergency Services (fire/police)
o Other jurisdictions (not Ecology)
> 100,000
o Customer/residents
o Ecology ERTS notification
o Internal staff (not emergency services)
o Emergency Services (fire/police)
o Other jurisdictions (not Ecology)
Implementing IDDE NPDES Permit Requirements Jurisdiction Survey Results
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Q4: Please share any additional comments about where you receive most of your water quality calls
from.
Implementing IDDE NPDES Permit Requirements Jurisdiction Survey Results
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Q5: Who primarily performs non-dangerous/non-hazmat spill clean-up in your public storm system?
(65 answered)
< 20,000
o 47%
Jurisdiction maintenance staff and equipment
o 5%
Jurisdiction hires a clean-up contractor
o 11%
Responsible party cleans spill up (including hiring a contractor)
o 37%
Combination of maintenance staff & responsible party
20,000 – 60,000
o 60%
Jurisdiction maintenance staff and equipment
o 5%
Jurisdiction hires a clean-up contractor
o 5%
Responsible party cleans spill up (including hiring a contractor)
o 30%
Combination of maintenance staff & responsible party
60,000 – 100,000
o 40%
Jurisdiction maintenance staff and equipment
o 60%
Combination of maintenance staff & responsible party
> 100,000
o 50%
Jurisdiction maintenance staff and equipment
o 6%
Responsible party cleans spill up (including hiring a contractor)
o 44%
Combination of maintenance staff & responsible party
47%
60%
40%
50%
60%
37%
30%
60%
44%
< 20,000
20,000 – 60,000
60,000 – 100,000
> 100,000
Who primarily performs non-dangerous/non-hazmat spill
clean-up in your public storm system?
(65 answered)
Maintenance &
Responsible Party
Hire Contractor
Maintenance Staff
Implementing IDDE NPDES Permit Requirements Jurisdiction Survey Results
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Q6: Who primarily performs non-dangerous/non-hazmat spill clean-up on your public
street/sidewalk?
(65 answered)
< 20,000
o 53%
Jurisdiction maintenance staff and equipment
o 10%
Responsible party cleans spill up (including hiring a contractor)
o 37%
Combination of maintenance staff & responsible party
20,000 – 60,000
o 90%
Jurisdiction maintenance staff and equipment
o 5%
Responsible party cleans spill up (including hiring a contractor)
o 5%
Combination of maintenance staff & responsible party
60,000 – 100,000
o 60%
Jurisdiction maintenance staff and equipment
o 40%
Combination of maintenance staff & responsible party
> 100,000
o 50%
Jurisdiction maintenance staff and equipment
o 19%
Responsible party cleans spill up (including hiring a contractor)
o 31%
Combination of maintenance staff & responsible party
58%
40%
60%
13%
21%
35%
20%
21%
25%
20%
67%
< 20,000
20,000 – 60,000
60,000 – 100,000
> 100,000
Who primarily performs non-dangerous/non-hazmat
spill clean-up on your public street/sidewalk?
(65 answered)
Maintenance &
Responsible Party
Maintenance Staff
Implementing IDDE NPDES Permit Requirements Jurisdiction Survey Results
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Q7: Do you pursue fines to responsible parties of illicit discharges?
(65 answered)
< 20,000
o 10%
Yes
o 32%
o 53%
We have authority to but it’s difficult to implement
o 5%
Sometimes
20,000 – 60,000
o 10%
Yes
o 10%
o 45%
We have authority to but it’s difficult to implement
o 35%
Sometimes
60,000 – 100,000
o 30%
Yes
o 20%
o 50%
We have authority to but it’s difficult to implement
> 100,000
o 6%
Yes
o 25%
o 38%
We have authority to but it’s difficult to implement
o 31%
Sometimes
10%
30%
32%
10%
20%
25%
53%
45%
50%
38%
35%
31%
< 20,000
20,000 – 60,000
60,000 – 100,000
> 100,000
Do you pursue fines to responsible parties of illicit
discharges? (65 answered)
Sometimes
Authority but
difficult to do
YES
Implementing IDDE NPDES Permit Requirements Jurisdiction Survey Results
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Q8: Do you pursue cost recovery for the cost of city resources to respond to illicit discharges?
(65 answered)
< 20,000
o 16%
Yes
37%
o 26%
We have authority to but it’s difficult to implement
o 21%
Sometimes
20,000 – 60,000
o 30%
Yes
o 10%
o 35%
We have authority to but it’s difficult to implement
o 25%
Sometimes
60,000 – 100,000
o 10%
Yes
o 10%
o 50%
We have authority to but it’s difficult to implement
o 30%
Sometimes
> 100,000
o 12.5% Yes
o 12.5% No
o 44%
We have authority to but it’s difficult to implement
o 31%
Sometimes
16%
30%
10%
13%
37%
10%
13%
26%
35%
50%
44%
21%
25%
30%
31%
< 20,000
20,000 – 60,000
60,000 – 100,000
> 100,000
Do you pursue cost recovery for the cost of city resources
to respond to illicit discharges? (65 answered)
Sometimes
Authority but
difficult to do
YES
Implementing IDDE NPDES Permit Requirements Jurisdiction Survey Results
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Q9: Who responds to illicit discharges from permitted construction sites to the public storm system?
(65 answered)
< 20,000
o 53%
Inspectors (including ROW, Development, Building, CIP, but not including IDDE)
o 26%
IDDE inspector
o 21%
Jurisdiction maintenance staff and equipment
20,000 – 60,000
o 70%
Inspectors (including ROW, Development, Building, CIP, but not including IDDE)
o 30%
IDDE inspector
60,000 – 100,000
o 80%
Inspectors (including ROW, Development, Building, CIP, but not including IDDE)
o 20%
IDDE inspector
> 100,000
o 69%
Inspectors (including ROW, Development, Building, CIP, but not including IDDE)
o 31%
IDDE inspector
53%
70%
80%
69%
26%
30%
20%
31%
21%
< 20,000
20,000 – 60,000
60,000 – 100,000
> 100,000
Who responds to illicit discharges from permitted
construction sites to the public storm system?
(65 answered)
Maintenance
IDDE Inspector
Other Inspectors
Implementing IDDE NPDES Permit Requirements Jurisdiction Survey Results
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Q10: Who reports IDDEs to the Department of Ecology?
(64 answered)
< 20,000
o 73%
IDDE Program Staff
o 16%
Maintenance Staff
o 11%
Both IDDE Program Staff and Maintenance Staff
20,000 – 60,000
o 55%
IDDE Program Staff
o 5%
Maintenance Staff
o 40%
Both IDDE Program Staff and Maintenance Staff
60,000 – 100,000
o 30%
IDDE Program Staff
o 10%
Maintenance Staff
o 60%
Both IDDE Program Staff and Maintenance Staff
> 100,000
o 53%
IDDE Program Staff
o 47%
Both IDDE Program Staff and Maintenance Staff
73%
55%
30%
53%
16%
10%
11%
40%
60%
47%
< 20,000
20,000 – 60,000
60,000 – 100,000
> 100,000
Who reports IDDEs to the Department of Ecology?
(64 answered)
Both
Maintenance
Staff
IDDE Staff
Implementing IDDE NPDES Permit Requirements Jurisdiction Survey Results
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Q11: Who provides internal IDDE training to field employees?
(65 answered)
< 20,000
o 74%
Internal staff
o 21%
Hired out to consultant/contractor
o 5%
Other
20,000 – 60,000
o 60%
Internal staff
o 20%
Hired out to consultant/contractor
o 20%
Other
60,000 – 100,000
o 80%
Internal staff
o 20%
Other
> 100,000
o 88%
Internal staff
o 6%
Hired out to consultant/contractor
o 6%
Other
74%
60%
80%
88%
21%
20%
< 20,000
20,000 – 60,000
60,000 – 100,000
> 100,000
Who provides internal IDDE training to field employees?
(65 answered)
Other
Consultant/
Contractor
Internal
Staff
Implementing IDDE NPDES Permit Requirements Jurisdiction Survey Results
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Q12: How is your internal IDDE training provided? Please check all that apply
(65 answered)
< 20,000
o 42%
Video training
o 68%
Formal staff training
o 53%
Informal staff training as hired
o 21%
Online lesson/exam
o 11%
Other
20,000 – 60,000
o 45%
Video training
o 85%
Formal staff training
o 35%
Informal staff training as hired
o 30%
Online lesson/exam
o 10%
Other
60,000 – 100,000
o 50%
Video training
o 70%
Formal staff training
o 40%
Informal staff training as hired
o 20%
Online lesson/exam
o 30%
Other
> 100,000
o 44%
Video training
o 75%
Formal staff training
o 31%
Informal staff training as hired
o 31%
Online lesson/exam
o 25%
Other
42%
45%
50%
44%
68%
85%
70%
75%
53%
35%
40%
31%
21%
30%
20%
31%
30%
25%
< 20,000
20,000 – 60,000
60,000 – 100,000
> 100,000
How is your internal IDDE training provided?
Please check all that apply (65 answered)
Other
Online
Informal Staff
Formal Staff
Video Training
Implementing IDDE NPDES Permit Requirements Jurisdiction Survey Results
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Q13: Do you have after-hours staff to respond to spills?
(65 answered)
< 20,000
o 95%
Yes
o 5%
20,000 – 60,000
o 90%
Yes
o 10%
60,000 – 100,000
o 100%
Yes
> 100,000
o 88%
Yes
o 12%
95%
90%
100%
88%
10%
12%
< 20,000
20,000 – 60,000
60,000 – 100,000
> 100,000
Do you have after-hours staff to respond to spills
(65 answered)
YES
Implementing IDDE NPDES Permit Requirements Jurisdiction Survey Results
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Survey Jurisdictional Summaries
< 20,000
o IDDE Program has less than 1 FTE
o Receives most WQ calls from internal staff (not emergency services) & customers
o Both jurisdiction maintenance staff and equipment and a combinations of jurisdiction
maintenance staff and responsible party cleanup spills in MS4
o Jurisdiction maintenance staff and equipment primarily cleanup spill on streets & sidewalks,
sometimes responsible party if identified
o Have authority to pursue fines but don’t because it’s difficult to implement
o Both do not pursue cost recovery and have authority but don’t pursue.
o Inspectors (including ROW, Development, Building, CIP, but not including IDDE) respond to spills
related to construction sites
o IDDE Program Staff report spills to Ecology
o Internal staff provide internal IDDE training to field employees through formal staff training and
informal staff training as hired
o Majority have after-hours staff respond to spills.
20,000 – 60,000
o IDDE Program has ≤1 FTE
o Receive most WQ calls from internal staff (not emergency services), customers & ERTS
o Jurisdiction maintenance staff and equipment primarily cleanup spills in MS4
o Jurisdiction maintenance staff and equipment primarily cleanup spill on streets & sidewalks
o Have authority to pursue fines but don’t because it’s difficult to implement, sometimes do
pursue
o Both yes, pursue cost recovery and have authority to pursue cost recovery but don’t because it’s
difficult to implement
o Inspectors (including ROW, Development, Building, CIP, but not including IDDE) respond to spills
related to construction sites
o IDDE Program Staff and Maintenance Staff report spills to Ecology
o Internal staff provide internal IDDE training to field employees through formal staff training
o Majority have after-hours staff respond to spills.
Implementing IDDE NPDES Permit Requirements Jurisdiction Survey Results
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Survey Jurisdictional Summaries (continued)
60,000 – 100,000
o IDDE Program has less than 1 FTE
o Receives most WQ calls from internal staff (not emergency services), customers, & ERTS
o Combinations of jurisdiction maintenance staff and equipment and responsible parties primarily
cleanup spills in MS4
o Jurisdiction maintenance staff and equipment primarily cleanup spill on streets & sidewalks,
sometimes responsible party if identified
o Have authority to pursue fines but don’t because it’s difficult to implement
o Have authority to pursue cost recovery but don’t because it’s difficult to implement
o Inspectors (including ROW, Development, Building, CIP, but not including IDDE) respond to spills
related to construction sites
o Both IDDE Program Staff and Maintenance Staff report spills to Ecology
o Internal staff provide internal IDDE training to field employees through formal staff training and
video training
o Have after-hours staff respond to spills.
> 100,000
o IDDE Program has 2-3 FTE
o Receives most WQ calls from internal staff (not emergency services), customers & ERTS
o Both jurisdiction maintenance staff and equipment and combination of maintenance staff and
responsible parties primarily cleanup spills in MS4
o Jurisdiction maintenance staff and equipment primarily cleanup spill on streets & sidewalks,
sometimes responsible party if identified