CHAPTER 7: EDUCATION AND OUTREACH
MATERIALS
PART OF THE SOURCE CONTROL (BUSINESS/SITE)
INSPECTION PROGRAM GUIDANCE MANUAL
Prepared for
2606 West Pioneer
Puyallup, Washington 98371
Funding Provided by
Stormwater Action Monitoring (SAM)
Prepared by
Herrera Environmental Consultants, Inc.
2200 Sixth Avenue, Suite 1100
Seattle, Washington 98121
Telephone: 206-441-9080
April 29, 2022
Note:
Some pages in this document have been purposely skipped or blank pages inserted
so that this document will print correctly when duplexed.
Table of Contents
mf cc_20-07522-000_scmanual_ch7_edoutreach_20220428.docx
CONTENTS
Education and Outreach Materials …………………………………………………………………………………………………… 3
7.1. Permit Requirements ………………………………………………………………………………………………………………….. 3
7.2. Communication Plan …………………………………………………………………………………………………………………… 4
7.2.1.
Types of Materials …………………………………………………………………………………………………….. 4
7.2.2.
Delivery Methods and Timing ………………………………………………………………………………… 4
7.2.3.
Technical Assistance …………………………………………………………………………………………………. 6
7.2.4.
Multi-Lingual Communication Recommendations …………………………………………….. 7
7.3. Cross-Jurisdiction Collaboration ………………………………………………………………………………………………. 8
7.4. Source Control BMP Guidance ………………………………………………………………………………………………….. 9
7.5 Business Outreach Materials ……………………………………………………………………………………………………. 10
TABLES
Table 7.1. Source Control Inspection Program Communication Recommendations. …………………….. 5
Chapter 7: Education and Outreach Materials
April 2022
Source Control (Business/Site) Inspection Program Guidance Manual
7. EDUCATION AND OUTREACH MATERIALS
This chapter summarizes the elements of a basic communication plan related to source control
inspections, provides recommendations for cross-jurisdictional collaboration for materials,
includes links to example education and outreach materials. Supplemental resources to
support this chapter can be found in the Source Control Online Resource Library (SCORL) for
Chapter 7.
7.1. PERMIT REQUIREMENTS
The National Pollutant Discharge Elimination System (NPDES) Municipal Stormwater permit
specifies outreach to all businesses/sites included in the source control inventory and specifies
outreach delivery methods and frequency (Western Washington 2019-2024 Phase II Permit,
S5.C.8.b.iii(a)):
“All identified sites with a business address shall be provided information about
activities that may generate pollutants and the source control requirements
applicable to those activities. This information shall be provided by mail, telephone,
electronic communications, or in person. This information may be provided all at
one time or spread out over the permit term to allow for tailoring and distribution
of the information during site inspections.”
The NPDES Municipal Stormwater permit also specifies communication when a site has failed to
implement required best management practices (BMPs), usually during a routine site inspection
or complaint visit (Western Washington 2019-2024 Phase II Permit, S5.C8.b.iv.(a)).
No later than January 1, 2023, each Permittee shall implement a progressive
enforcement policy that requires sites to comply with stormwater requirements
within a reasonable time period as specified below:
(a) “If the Permittee determines, through inspections or otherwise, that a site has
failed to adequately implement required BMPs, the Permittee shall take
appropriate follow-up action(s), which may include phone calls, reminder
letters, emails, or follow-up inspections.
Chapter 7: Education and Outreach Materials
April 2022
Source Control (Business/Site) Inspection Program Guidance Manual
7.2. COMMUNICATION PLAN
Recommended elements of a communication plan include available types of education or
outreach materials, delivery methods and timing, technical assistance methods, and provisions
for multiple language needs.
7.2.1.
Types of Materials
Many outreach materials are designed utilizing graphics and photos to effectively communicate
proper implementation of source control BMPs. Printed outreach materials are produced in a
variety of sizes, colors, and types of paper including:
Size
Color Preferred or Optional?
Recommended Type of Paper
Letter sized sheet
Optional
Standard printer paper
Postcard
Color preferred
Sturdy glossy thick paper
Fact card
Color preferred
Cardstock
Booklet/brochure/pamphlet
Color preferred
Standard printer paper or cardstock
Wall/bulletin board poster
Color preferred
Laminated poster
Electronic materials are also commonly used. Choosing between print or electronic materials
should be based on the target audience for the outreach message. Regardless of whether
materials are printed or electronic, design (e.g., colors, layout, font size, etc.) should be based on
accessibility standards. For creation of new outreach materials, it is also recommended to utilize
the jurisdiction or agency’s local style guide to maintain consistency for public communications.
7.2.2.
Delivery Methods and Timing
Jurisdictions are required to distribute information to meet NPDES Municipal Stormwater permit
requirements regarding activities that may generate pollutants and the source control
requirements applicable to those activities. Each delivery method (i.e., mail, telephone, electronic
communications, or in person) identified in the NPDES Municipal Stormwater permit presents
advantages or disadvantages that vary based on the scenario or audience. For example, the
following applies to mailing versus hand-delivery of printed materials:
Advantages
Disadvantages
If conducting a windshield survey during source control inventory
development or if hand delivering information to a targeted business sector
(e.g., auto shops) then the correct address, e-mail, business phone number,
and preferred communication method could be confirmed.
Traditional mail can be ineffective
if delivered to corporate
headquarters rather than the local
owner/site manager.
Costs of various delivery methods and staff resources required to implement should also be
compared when selecting the preferred approach.
Chapter 7: Education and Outreach Materials
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Source Control (Business/Site) Inspection Program Guidance Manual
Most programs conduct site inspections without appointments but if an appointment is
necessary for a site inspection, a phone call or in person request to the business/site is the most
effective option.
During the site inspection, verbal communication combined with written materials (including
diagrams or photographs) can be highly effective when communicating BMP deficiencies (see
Chapter 5: Conducting Business/Site Inspections).
Enforcement letters specifying required actions will likely need to be delivered by registered
mail, whereas other communications (e.g., confirmation that a business/site has achieved
compliance, follow-up coordination regarding action items, sharing technical assistance, etc.)
following the initial site inspection can be delivered by e-mail with supplemental content
provided through weblinks. Methods of delivery will vary depending on what is allowable within
each jurisdiction.
Ongoing outreach, outside of site inspections and follow up inspections, can be expensive and
time intensive. Some jurisdictions have developed content to post to their jurisdiction’s website
to educate and provide technical assistance related to source control BMPs. Methods to drive
the target audience to the relevant content on the jurisdiction’s website should be considered in
the communication plan.
Table 7.1 summarizes various stages in the site inspection process and recommended options
for communication and timing.
Table 7.1. Source Control Inspection Program Communication
Recommendations.
Messaging Purpose
Options to Deliver Messaging
When to Deliver Messaging
Notify businesses/sites on the
source control inventory about
the source control inspection
program
● Mail or e-mail
● Hand deliver/in person
● Jurisdiction website
● Social media
● Article in local media, trade publications,
or local chamber of commerce publication
Prior to source control
inspection program
implementation
PERMIT REQUIRED: General
and site-specific BMP
information to all
businesses/sites on the source
control inventory
● Mail or e-mail
● Hand deliver/in person
● Jurisdiction website
● Social media
● Workshops
PERMIT REQUIRED: Prior to
the end of the Western
Washington Phase II Permit
term (July 31, 2024)
Notify businesses/sites of site
inspections
● Mail or e-mail
● Hand deliver/in person
2 to 3 weeks prior to site
inspection
Request appointment for site
inspection (if needed)
● Phone call
● Mail or e-mail
● Hand deliver/in person
1 to 2 weeks prior to site
inspection
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Source Control (Business/Site) Inspection Program Guidance Manual
Table 7.1 (continued).
Source Control Inspection Program Communication
Recommendations.
Messaging Purpose
Options to Deliver Messaging
When to Deliver Messaging
Summarize site inspection
deficiencies
● Mail or e-mail
● Hand deliver/in person
Immediately, during the site
inspection, and within 1 week
following the site inspection
PERMIT REQUIRED: Clarify
specific deficiency follow-up
actions
● Mail or e-mail
● Hand deliver/in person
Immediately, during the site
inspection, and within 1 week
following the site inspection
PERMIT REQUIRED:
Immediate enforcement of a
high priority issue (i.e., illicit
connection or illicit discharge)
● Registered mail AND e-mail
● Hand deliver/in person
Immediately and 1 to 2 days
following site inspection
Post-inspection summary
● Mail or e-mail
1 to 2 weeks following site
inspection
Ongoing business education
and outreach
● Mail or e-mail
● Jurisdiction website
● Social media
Ongoing throughout source
control inspection program
implementation
7.2.3.
Technical Assistance
The site inspection is an opportunity to provide additional education and technical assistance
beyond specific BMP deficiencies and actions needed. Some of the technical assistance materials
identified in Chapter 5: Conducting Business/Site Inspections that can be provided as education
and outreach materials may include:
● Storm drainage system as-built or record drawings
● Example spill plan template
● Contractor list for storm drainage system cleaning
● Contractor list for vent/hood or grease interceptor cleaning (Fats, Oils, and Grease [FOG])
● Contractor list for on-site septic system maintenance
● Information on labeling/marking storm drains
● Relevant outreach materials that can be posted in the workspace for employee education
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Source Control (Business/Site) Inspection Program Guidance Manual
7.2.4.
Multi-Lingual Communication Recommendations
When conducting site inspections, inspectors may encounter owners/site managers whose
primary language is not English. Since communication is a key aspect of the source control
inspection program, it is important that inspector’s communication, outreach materials, and
letters are clear and culturally appropriate. If communication is challenging and progress is
impeded during the site inspection and/or follow-up, and if the source control inspection
program expects to encounter this communication barrier in the future, consider:
Learning cultural appropriate norms ahead of the site inspection
Working to pronounce names correctly, as a sign of respect
Slowing down speech
Using hands and gestures when speaking
Limiting vocabulary by using simple phrases, and avoiding slang and acronyms
Enunciating clearly and using voice intonation
Providing pictures as examples
Being patient
“Fee for translator” service contract
Using translation mobile applications in the field for non-technical communication
Examples of outreach materials including BMP activity sheets and educational materials have
already been developed through similar programs (e.g., PPA, Phase I programs, ongoing source
control programs in other states, etc.) in other languages for commonly encountered scenarios,
which vary by business sector and geographic area. Available outreach materials in other
languages are included as SCORL Supplemental Resources. For situations not covered by
existing resources, materials or communications may need to be translated for a specific
owner/site manager if the BMP deficiencies are complicated or not well understood.
Chapter 7: Education and Outreach Materials
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Source Control (Business/Site) Inspection Program Guidance Manual
7.3. CROSS-JURISDICTION COLLABORATION
Jurisdictions have access to a wide range of outreach and education materials developed by
individual jurisdictions or from group projects. Several municipal stormwater groups meet
quarterly or more frequently and share resources. Some jurisdictions have collaborated by
interviewing target business sectors and publishing reports. These focus group reports may
provide valuable insights. The reports summarize interviews with owners, site managers, and
employees about preferred delivery methods of communication, material format, employee
educational materials, and messaging that resonates with their business environment.
Cross-jurisdiction collaboration groups include:
Stormwater Coordinator Groups: Western and Eastern Washington municipalities have
developed groups that meet quarterly or more frequently. Consider subscribing to their
meeting lists for notification of meeting agendas for opportunities to listen, learn, and
participate on the topics related to source control.
Central NPDES Coordinators Forum
Eastern Washington Municipal Stormwater Group
North Sound Coordinators Forum
South Sound Phase II Coordinators Group
Southwest Washington Coordinators Forum
Wenatchee Valley Stormwater Technical Advisory Committee
West Sound Stormwater Manager’s Coordination Group
Business Inspection Group (BIG): BIG is a regional business inspection group that meets
to share information and collaborate on topics surrounding source control business
inspections and the new permit requirements. Members include Phase I jurisdictions with
ongoing permit-required business source control programs and Phase II jurisdictions
sharing information as they develop their new permit-required programs.
Stormwater Outreach for Regional Municipalities (STORM): STORM…