Take action: stormwater permits

Action checklist municipal stormwater

• Contact your city, town or stormwater utility about stormwater planning and management; ask to be involved. Public involvement is required!

• Ask your city how the stormwater management plan will reduce the discharge of pollutants “to the maximum extent practicable.” How does it prevent contribution to existing stormwater pollution problems (or fit into approved TMDLs)? How does it protect high quality waters? Do the plans include implementation commitments, timetables and budgets? Are they measurable and enforceable? Do they include monitoring and opportunities for revisions to the controls before the next permit cycle?

• Large and medium city (Phase I): ask about permit renewal. Review stormwater management plan and monitoring; what has been accomplished during the permit period? Does it need to be revised and strengthened?

• Small city/town/district/hospital (Phase II): ask how each of the six minimum measures are being addressed.

• Find out what public education or involvement is planned or going on. Can your group help? Does the city want to pay your group to help? (See this Lesson's Local Story)

• Ask your stormwater authority (town, city, county, utility) how they will address post-construction stormwater impacts. How will they coordinate with the construction stormwater permits?

• Talk with the city and state planning departments about stormwater requirements. Have they been communicating with the stormwater authority regarding land use planning, zoning and requirements for stormwater management?

Action checklist industrial stormwater

Ask about the “industrial” sites in your watershed that are exposed to stormwater, especially salvage lots or landfills.

• Do these sites have wastewater NPDES permits? If so are the stormwater requirements included in their wastewater NPDES permit?

• Is the site covered under a general permit?

• Has the site applied to be “excluded” from requirements because they claim to not be “exposed” to stormwater? Has the state inspected that claim?

• Has the facility developed a stormwater management plan? Has it been filed with the state? Is it available onsite? Get a copy and review it.

• Does the permit, the Notice of Intent or the stormwater management plan account for waters that are polluted already, waters with TMDLs or high quality waters? Causing or contributing to problems justifies individual permits, numeric effluent limits and/or permit denial.

Action checklist construction stormwater

• Contact your state water quality agency about construction stormwater permits. They may refer you to a county authority.

• Find out what individual and general construction stormwater permits are active in your watershed, or pick a site and ask questions about the specific permit and stormwater management plan.

• Are the requirements in the state general permit sufficient to protect the uses in your watershed? Do the permittees have to provide enough site specific information and develop a stormwater management plan before they begin construction?

• Are the stormwater management plans submitted to the county or state? How can the public review them?

• Does the general permit take into account the receiving water’s characteristics? Is an individual permit needed to address existing pollution or sensitive uses? Can you make the case for numeric effluent limits due to existing pollution or sensitive uses?

• Keep an eye on active sites to see whether the management practices are put in place and whether they are working. Is there a negative downstream impact that can be attributed to the site? Is the facility monitoring the effectiveness of the controls in place? Can you monitor the receiving water body?