2024 WW Ad Hoc Process
2nd 2024 Plenary Group Meeting
January 27, 2022
2024 WW Ad Hoc Purpose
To report Topic Group outcomes and review the
next steps in the reissuance process, including
instruction for providing final white papers to
Ecology.
S4/S4
S4F Adaptive Management
Melissa Ivancevich
• Administrative burden is challenging
• “Credible site-specific information” too vague
• CSWGP/ISWGP discharge reporting
• Adaptive Management Report process
• Workflow/timeline process for S4F
• S4F and TMDLs or other enforceable water quality cleanup plans
S4F Ad Hoc committee Overall Themes
S5.C2/S5.C4
Outfall Reporting Standards
Angela Gallardo
S5.C6.d/S5.C1.d
Stormwater Management Action Plan (SMAP)
Janet Geer
Three-step process to generate content for report
1. Initial discussion – everyone’s ideas on the table
2. Create 18 “key idea” statements – not trying for consensus
3. Two Anonymous surveys on statements and of level of
agreement
Allowed presenting ideas while showing level of consensus
SMAP Ad Hoc Committee
Have options for meeting planning requirement
NPDES planning GMA planning – big range of
views
“Limit NPDES planning scope to SSC program”
Don’t require implementation of everything in a
plan
Should be able to include past, current, future
work in plans
Guidance documents should not contain binding
requirements
S5.C8 & S5.C.9/S5.C5 & S5.C8
Source Control Illicit Discharge Detection Elimination
Rod Swanson
The group met once in early November and discussed the ways
that source control and illicit discharge programs differ and
compliment each other.
There were numerous recommendations presented to the group.
Individual recommendations, along with two primary
recommendations are included in the white paper.
Source Control/IDDE
Source Control/IDDE Primary Recommendations
Clearly allow the use of Source Control Programs as the primary tool for
Illicit Discharge Screening in areas where it is appropriate.
Remove conveyance systems in areas zoned as single-family residences,
rural residential, agricultural, and forest from the annual 12 percent of
the MS4 performance standard because there very few detectable illicit
discharges and resources would be better used elsewhere.
12 percent of the rural and residential MS4 is a huge number of
conveyance systems for some permittees.
S5.C5/S5.C6
Stormwater Management Manual
Mieke Hoppin
#1: Current Best Management Practice Options: Design, Constructability, Maintainability
BMP design standards in the SWMM may be outdated and may not rely on constructability and
maintainability.
3rd Party SWMM Assessment to review design standards and consider BMPs in terms of constructability
and maintainability.
#2: Additional BMP Guidance Needed
There are some subjects not addressed in the SWMM directly such as artificial turf, and temporary
sediment tanks.
Create guidance to clarify certain items – this could be guidance or how to documents outside the SWMM.
Make any guidance ECY provides to jurisdictions available to all in Interpretation Documents. Ask
jurisdictions which items make sense as guidance.
#3: Minimum Requirement #8 – Wetland Protection
Unclear about ramifications to receiving waterbodies when MR#7 takes precedence over MR#8. Should
proximity to wetland affect this standard? Small project effects on wetlands.
Have Ecology/consultant conduct comprehensive analyses of several wetlands of varying sizes to see how
small projects affect wetlands over time.
Stormwater Management Manual for Western Washington
#4: Terms and Definitions
Terms and definitions conflict with Permit terms and conflict amongst Permits (like Industrial Permit).
Ecology to complete a comprehensive search of all terms used in the Permit and ensure meaning is
consistent to SWMM. Ensure consistency in terminology throughout SWMM. Provide definitions when
needed.
#5: Climate Impacts
Should Ecology consider future climate impacts in design?
Ecology should continue to support defensible methods for predicting future rainfall increases and what
those impacts may mean for the constructed and natural systems. Create schedule to update WWHM
rainfall files regularly and monitor how these changes have effected BMP design over time.
#6: The LID List Approach
Hierarchy does not consider facility function, constructability and maintenance. Approach often results
in higher cost BMPs that are not easy to maintain in the long run.
Reconsider the hierarchy with the factors of constructability and maintainability. Conduct real world
analyses of performance of MR#5 BMP over time.
Stormwater Management Manual for Western Washington
#7: SWMM BMPs and Facilities Covered Under other NPDES Permits
• Allow for greater flexibility for projects located on sites that fall under separate NPDES permits.
• Ecology develop a comprehensive guidance document regarding BMP selection on sites that have
existing site specific BMPs installed to treat specific contaminants of concern and how
new/redevelopment can utilize those BMPs. Incorporate appropriate language in various Permits to
require greater coordination amongst the various Permits.
#8: SWMM Usability and Plain Talk
• Make Source Control BMPs available as individual handouts. Transcreate all source control BMPs for
the most common communities in Western Washington and plain talk all for usability.
• Create more companion documents such as Tip Sheets, Activity Sheets, Calculators to make SWMM
an easier to use document.
#9: SWMM Equivalency Process
• Does not appear to be a formalized process for ECY equivalency review – as such – review is up to
the individual ECY reviewer.
• Have independent council review the Permit to see if the SWMM equivalency process is legally
required. If it is not, remove the process. If it is, have independent council create a review
procedure document to clearly show process and ensure equitable review.
Stormwater Management Manual for Western Washington
#10: Requirement to Inspect Residential Developments Every 6 Months
Remove this requirement as all other inspections are based upon 1 year time frames and this is a
burden to track.
#11: Clarification of Current Items within the SWMM
Certain terms and concepts are not well defined.
Ecology develops a series of interpretation documents that go along with the SWMM to show ECY
intent. Include examples to help guide jurisdictions in their interpretations.
#12: Errata
Fix errata as noted.
S5.C7/TBD
Structural Stormwater Controls (SSC)
Blair Scott
Structural Stormwater Controls Themes
Theme
Drastic changes are not wanted in this next permit cycle without
appropriate scientific justification
Posed questions/suggestions for possible relatively minor
adjustments to the SSC point system for the PAC to discuss (e.g.
accounting for SSC projects related to rarely traveled rural roads
vs more highly traveled urban arterials in the point multipliers?)
Suggestions for the PAC to consider related comments from other Ad
hoc subcommittees:
– Regional SW retrofit fund idea?
Annual reporting associated with SSC requirement
Enhanced maintenance credits
S5.C10/S5.C7
Operations & Maintenance
Royce Young
Operations and Maintenance
Issue #1 – Street Sweeping
Ecology needs to do a comprehensive cost benefit analysis prior to adding this as a
requirement. That analysis could look at all permits requirements and rank the relative
benefits of all Permit Requirements
If added, can another requirement be removed to help with cost and staffing needs
Increase the funding for Capacity grants to help with purchasing sweepers and Staff
Issue #2 – Catch Basin Inspection/Maintenance
Inspect and cleaning all catch basins twice per permit cycle
Prioritization of receiving waters to determine high priority catch basins (land use, road use, is
discharge treated, does it infiltrate
Ecology should address concerns on guidance for the circuit base approach and on submitting
less frequent CB inspections (how does this work)
Request a definition of catch basins and inlets, permit mentions both
Permit needs a footnote referencing the required deadline of August 1st every 2 years that
was carried over from the 2013-2018 permit (update it to calendar years, this will help with
scheduling and budget
Operations and Maintenance
Issue #3 – Required 6 month maintenance timeline for Catch Basins
Some jurisdictions have limit resources (no vacuum truck) or limited maintenance crew and
have difficulty meeting this criteria.
Extend timeline to 1 year and allow a 5% tolerance in compliance metric
Add option to describe contractor failure to complete contractually obligated work as a
circumstance beyond permittees control
Issue #4 – Maintenance for Stormwater Treatment and Flow Control
BMPs/Facilities
Should there be a tolerance in the maintenance requirements for WQ/FC Facilities
Permittees suggest 95% instead of 100%
S5.C11/S5.C2
Education and Outreach
Katherine Straus
Section S5.C.3.a.iii – Stewardship
COVID Concerns
Stewardship Definition
MS4 Boundary
This section could include language around offering
opportunities through virtual engagement as
volunteers are reluctant to attend events and COVID
protocols can be difficult to enforce
Include more examples of different kinds of
activities that would qualify as “stewardship” in
guidance documents
Change “advertise” to “promote” to align
with Section S5.C.2
Guidance should include clarification on the statement
“areas serviced by the MS4.” What is the purpose of
stewardship? To maintain the MS4 or to engage the
community in local watershed stewardship?
Stats:
• 34 permittees/partner organizations responded to survey
• About 50 people attended the "Listening Session”, providing comments in real time
Process:
• Initial planning meeting: November 30th
• Listening session: December 9th
• Open survey
• Comment period on survey/“Listening Session” results
• Survey responses and “Listening Session” comments aggregated and distilled into
common themes
Education and Outreach Topic Group
Section S5.C.2- Introduction to E&O Section
Local WQ Data
Regional Collaboration
Stewardship
Permit Language
Staff Capacity
Section S5.C.2.a.i- General Awareness
Target Audience
Overburdened Communities
Change “Local water quality
data” to “Local and/or
regional”
Include more information
on intent behind “Local” in
guidance documents
Permittees appreciate the
ability to meet requirements
through regional collab
General feeling of conflict b/w
how stewardship was written
into the introduction to E&O vs.
how it was written into
stewardship section: "create" vs.
"partner
Disagreement around how
forceful the language should be
about providing messages in
languages other than English;
agreement that translation isn't
enough- needs to be culturally
relevant (transcreation)
Smaller and less resourced
jurisdictions don’t have the staff
capacity or expertise to meet
many of the E&O requirements
as currently written; concern
about what will be added in next
permit cycle
Include more information on
what qualifies as regional
collab in guidance
documents
Want more language about
promoting sense of place
and connection to local
watershed; more guidance
on how to meet requirement
through regional collab
Use the term “priority
audience” over “target
audience” throughout E&O
section
New audience suggestions: unhoused individuals, internal audiences (staff),
stormwater facility owners, real estate professionals
Provide an additional option for audiences and behaviors that are
specific to a jurisdiction (for example, wineries)
Permittees need more guidance on what audiences qualify as “overburdened” and how
to identify them
Section S5.C.2.a.ii- Behavior Change
Long term
sustainability
Sustainability for
smaller/less
resourced
jurisdictions
Measuring Behavior
Change
Timeline
CBSM vs. Social
marketing
Target Audience
and/or BMP List
Permit
language/formatting
Permit language
should encourage
long-term efforts that
are refined over time
to increase
effectiveness
Developing and
implementing a
behavior change
program is staff and
resource intensive, and
most small and/or less-
resourced jurisdictions
don't have the staff
capacity or expertise
to meet this
requirement
Being able to meet this
requirement as part of
a regional effort is
important and
jurisdictions want this
to stay in the permit
More educational
resources are needed
to help staff and
managers who need a
better understanding
of how resource and
staff intensive
behavior change
programs are
Permittees need more
guidance on what
program evaluation
looks like
Change language
from “measure
understanding” to
“measure adoption.”
Include language in
guidance documents
about what it means
to “affect” behavior
change. Are permittees
out of compliance if the
behavior change
program is not
successful?
Timeline is too
condensed in the
beginning; with a new
program, need more
time for issue research
(selecting behavior and
audience), developing
a social marketing
strategy and piloting
the strategy
Clarify language around
what "implementation"
means; clarification
could include
suggestions for ongoing
evaluation; is pilot
phase, or phased
implementation included
in "implementation?"
Remove “Community
Based Social
Marketing” from
permit in favor of
“Social marketing.”
Expand target
audience list:
– commuters
– college students or
young adults
– audiences identified
through SMAP efforts
Suggested BMP
additions:
– pressure washing
– Adopt a Drain
Consider creating a
more visual
guidance
document, like a
table or flowchart,
including social
marketing steps, to
help permittees
better understand
the timeline
Meeting Break 10-minutes
2nd 2024 Plenary Group Meeting
January 27, 2022
S9/S9
Annual Reporting
Mindi Kellar
Annual Reporting
Examples of AR Question Issues – Overall
Issues
1. Does the question provide
information that Ecology or
the permittee can use / build
on?
2. Enough time to meet
requirements. E.g., March 31st
deadline for AR.
3. Better consistency between
Phase I & II questions.
Example of Proposed Solutions
1. Eliminate questions where
possible if they do not meet the
“Ecology objectives list” – 2019
Response to comments.
2. Annual Report date moved to
5/31.
3. PI Question 13 – Align Phase I
and II requirements and AR
questions. Replace with PII
Q43.
Annual Reporting
Issues
4. Create Clarity for
Questions
Example of Proposed solutions
To Annual Report Questions:
• Pose questions in a way that avoids “No” as an answer indicating
full compliance. Revise to answer “yes” or “not required at the
time”.
• Revise question -> Number of construction site inspections (vs.
sites inspected)
To Permit Language:
S5.C.8. vi. Recordkeeping
(a) Each Permittee shall maintain records, including documentation of each site
visit, inspection reports, warning letters, notices of violations, and other enforcement
records, demonstrating an effort to bring sites into compliance. Each Permittee shall
also maintain records of sites that are not inspected because the property owner
denies entry.
Organize by businesses and/or activities…