3.04 3.4
RESOLUTIONS\Stonnwater Management Plan—Adopt—1-25-16
RESOLUTION ADOPTING TOWN OF QUEENSBURY MS4
STORMWATER MANAGEMENT PROGRAM PLAN
RESOLUTION NO.: ,2016
INTRODUCED BY:
WHO MOVED ITS ADOPTION
SECONDED BY:
WHEREAS, the Town of Queensbury is a regulated municipality under the New York State
Department of Environmental Conservation Municipal Separate Storm Sewer System Program (MS4
Program), which regulations help to protect and improve the quality of public water bodies in more
densely populated areas of the State, specifically focusing on stormwater runoff, and
WHEREAS, to comply with New York State requirements, by Resolution No. 67,2009, the
Town Board added Chapter 146, titled"Storm Sewer System Discharges, Activities and Connections"
to the Town Code after conducting a SEQRA review and declaring a Negative Declaration with regard
to the effects of Chapter 146, and
WHEREAS, for the purpose of implementing Chapter 146, by Resolution No.: 191,2011, the
Town Board accepted and authorized an MS4 Stormwater Management Services Agreement from the
Warren County Soil and Water Conservation District (District), with such Agreement providing for,
among other things, that the District assume the role of Queensbury's Stormwater Management
Officer, to implement and enforce MS4 Program requirements within the Town and by Resolution
No.: 234,2014, the Town Board authorized renewal of such Agreement, and
WHEREAS, the District has presented the Town Board with an MS4 Stormwater
Management Program Plan (Plan) dated November 2015, which Plan outlines activities and measures
that would be undertaken to address stormwater education, outreach and other implementation
required under Chapter 146 of the Town Code and New York State law and regulations, and
WHEREAS, the Town Board wishes to adopt such Plan to further its goal of protecting and
improving water quality of lakes and streams within its MS4 area,
NOW, THEREFORE, BE IT
RESOLVED, that adoption of the proposed Plan is consistent with the Negative Declaration
issued for the addition of Chapter 146 to the Queensbury Town Code, and the proposed Plan will not
result in any significant adverse environmental impacts, and the Town Board hereby affirms the
SEQRA Negative Declaration issued for the addition of Town Code Chapter 146, and
BE IT FURTHER,
RESOLVED, that the Queensbury Town Board hereby adopts the November 2015 MS4
Stormwater Management Program Plan (Plan) prepared by the Warren County Soil & Water
Conservation District (District) in substantially the form presented at this meeting, and authorizes and
directs the Warren County Soil and Water Conservation District (District), as the Town's Stormwater
Management Officer, to take all actions necessary for the Town to implement such Plan, and
BE IT FURTHER,
RESOLVED, that the Town Board further authorizes and directs the Town Supervisor, Town
Counsel and/or Director of Planning, Zoning and Code Compliance to take such other and further
action as may be necessary to effectuate all terms of this Resolution.
Duly adopted this 25th day of January, 2016, by the following vote:
AYES
NOES
ABSENT :
Town of Queensbury
MS4 Stormwater Management
Program Plan — Draft for Review
State Pollution Discharge Elimination System ID#: NYR20A112
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This Plan is a requirement under NYSDEC General Permit for
Stormwater Discharges, Permit # G-0-15-002
November 2015
•Introduction
The Town of Queensbury (Town) is categorized as a traditional Municipal Separate Storm Sewer System
(MS4), under Part IV.A. of the New York State Department of Environmental Conservation General Permit for
MS4 Stormwater Discharges (G-0-10-002). Under this mandate, the Town must have a working Program Plan
which outlines their activities to address stormwater education, outreach, and implementation under the state
requirements. The MS4 area designated by the NYS DEC is the full boundary of the Town.
This Stormwater Management Program Plan (SWMPP) documents the efforts currently undertaken and
planned by the Town under this program. These requirements correspond to the Town infrastructure and
properties (roads, bridges, drainage infrastructure and facilities), but also include public information and
outreach on stormwater issues and construction/post-construction stormwater runoff. The ultimate purpose
of this plan is to protect and improve water quality of the lakes and streams in the MS4 area.
The SWMPP Plan is based on the Federal Stormwater Phase II rule, issued in 1999, which requires MS4
owners and operators, in U.S. Census-defined urbanized areas as well as in additionally designated areas, to
develop a Stormwater Management Program. As of March 10, 2003, these new regulations and requirements
came into effect. There are six program elements designed to reduce the discharge of pollutants to the
maximum extent practicable. The program elements, titled Minimum Control Measures (MCMs), include:
1. Public Education and Outreach
2. Public Involvement/ Participation
3. Illicit Discharge Detection and Elimination
4. Construction Site Runoff Control
5. Post-Construction Stormwater Management
6. Pollution Prevention / Good Housekeeping for Municipal Operations. •
This document describes each MCM and the Best Management Practices (BMPs) that have been implemented
to maintain compliance with the NYSDEC GP-0-10-002. Responsibilities to achieve and sustain compliance
are clearly defined for each BMP. The Town has contracted with the Warren County Soil and Water
•
Conservation District (SWCD) to provide administration of this MS4 stormwater program and to undertake a
variety or stormwater management tasics to acnieve ruii compliance witn tnese regulations. i ne primary
entity responsible for the Town's MS4 program is the Warren County SWCD District Manager, who has been
designated as the Town's MS4 Stormwater Management Officer.
This Plan will be updated as needed to address the latest technologies and information to maintain
compliance with the NYSDEC GP-0-10-002, as well as to account for progress made.
There are several key personnel involved in the Town's Stormwater Management Program;
Key:
SMO = Town Stormwater Management Officer P&R = Parks and Recreation
SWCD = Warren County Soil and Water Conservation District WD = Water and Wastewater Department
HD = Town Highway Department TPB = Town Planning Board
CEO = Town Code Enforcement Officer PVC = Pine View Cemetery
B&G = Town Building and Grounds Crew
TD = Town Information Technology Department
Non-stormwater discharges are defined in the MS4 General Permit(GP-0-10-002) Part I.A.2 and •
include:
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• Water line flushing • Water from crawl space and basement sump pumps
• • Landscape irrigation • Footer drains
• Diverted stream flows • Lawn and landscape watering runoff provided that all
• Rising ground water pesticides and fertilizers have been applied in
• Uncontaminated groundwater infiltration accordance with the manufacturer's product label
• Uncontaminated groundwater • Water from individual residential car washing
• Discharges from potable water sources • De-chlorinated swimming pool discharges
• Foundation drains • Residual street wash water
• Air conditioning condensate • Discharges or flows from fire fighting activities
• Irrigation water • De-chlorinated water reservoir discharges
• Springs • Any SPDES permitted discharge
• Flows from riparian habitats and wetlands
Pollutants of Concern:
On a regional level:
• Silt/Sediment • Dissolved oxygen/ oxygen demand • Phosphorus • Pathogens
On a localized level:
• Floatables • Oil and Grease • Pet Waste
• Waterbodies of Concern:
NYS DEC 2010 Section 303(d) Impaired Waterbodies List
(1)Tribs to Lake George, East Shore
(2) Wood Creek/Champlain Canal and Tribs
• Halfway Brook begins in the Town of Queensbury and runs through the most commercially
developed area of the Town. It then crosses county lines into the Town of Fort Ann, where it
discharges into the Champlain Canal.
Within the Town there are also a number of small lakes with stormwater pollutant concerns. These include;
Glen Lake, Lake Sunnyside
Geographic area of Concern:
• Residential areas along the shores of Lake George and other waterbodies
• Heavily commercialized areas in the southern portion of the Town
Target Audiences:
• Residential • Businesses • Contractors/Developers • General Public
• Minimum Control Measure 1: Public Education and Outreach on Stormwater
Impacts
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The Public Education and Outreach MCM consists of BMPs that focus on the development of educational
•
materials designed to inform the public about the impacts that stormwater discharges have on local water
bodies. The educational materials contain specific actions as to how the public, as individuals or collectively
as a group, can participate in reducing pollutants and their impact on the environment. The Public Education
and Outreach program and BMPs, in combination, are expected to reach all of the constituents within the
Town's permitted boundary.The target pollutant sources are construction site runoff, illicit discharges and
local/regional Pollutants of Concern (POCs).
An MS4 must, at a minimum:
a. Identify POCs, waterbodies of concern, geographic areas of concern, target audiences;
b. Develop and implement an ongoing public education and outreach program designed to describe to the
general public and target audiences:
i. the impacts of stormwater discharges on waterbed/es;
ii. POCs and their sources;
iii. steps contributors of these pollutants can take to reduce pollutants in stormwater runoff;and
iv. steps contributors of non-stormwater discharges can take to reduce pollutants(non-stormwater
discharges are listed below);
c. Develop, record, periodically assess, and modify as needed, measurable goals;and
d. Select appropriate education and outreach activities and measurable goals to ensure the reduction of all
POCs in stormwater discharges to the MEP.
The table below depicts the BMPs that the Town currently performs or plans to perform for MCM 1, the
responsible parties and any applicable deadlines.
MCM 1 - PUBLIC EDUCATION AND OUTREACH BMPS RESPONSIBLE TIMELINE
PARTY
1. Participate in educational events for the general public and waterbody SWCD Annually
specific audiences related to water quality and stormwater runoff
issues.
Measurable Goal:Participate in two educational events
2. Work with the media to get articles in the Glens Falls Post Star and the SMO, SWCD, Annually
Chronicle newspapers about stormwater projects, roadside clean-ups TPB
and other important water quality issues.
Measureable Goal:Achieve at least five articles in the newspapers
related to stormwater management issues and projects
3. 'Place"clean up after your pet"signs and pet waste bag distribution HB, P&R Annually
stations in Town parks.
Measurable Goal:
Evaluate properties yearly and install signage and waste stations as
necessary.
4. Utilize and disperse existing brochures and other literature developed SMO, SWCD, Continuously •
by the Lake Champlain-Lake George Regional Planning Board, the DEC Town Clerk
and the EPA regarding stormwater runoff.
3
•
Measurable Goal. Keep at least 10 copies of all printed literature
• available for the public at all times. Update
literature as new brochures become available.
5. Distribute Provide stormwater educational flyer in tax billsinformation SMO, Town Annually
to general public. Clerk
Measurable Goal:Educate homeowners on stormwater runoff and
water conservation through s—adirect mailing or
electronic postings or notifications.
6. Maintain updated electronic files of stormwater outreach brochures on SMO,TD As needed
the Town and SWCD websites.
Measurable Goal:Educate the public through the use of the Town and
SWCD websites.
Minimum Control Measure 2: Public Involvement and Participation
The Public Involvement and Participation MCM consists of activities that are focused on getting members of the
local community involved in the MS4's municipal stormwater management program. Compliance with State and
local public notice requirements will be maintained whenever public participation is sought or required. The BMPs
include a number of practices designed to seek public input on the SWMPP and Annual Report accomplishments
in addition to describing specific activities that encourage public participation. The target audiences for the public
involvement program are key individuals and groups that may have an interest in the particular BMPs as well as
the general public located within the permitted boundary.
An MS4 must, at a minimum:
• a. Comply with the State Open Meetings Law and local public notice requirements, such as Open Meetings Law,
when implementing a public involvement/participation program;
b. Develop and implement a public involvement/participation program that:
• Identifies key individuals and groups, public and private, who are interested in or affected by the
SWMP;
• Identifies types of input the permittee will seek from the key individuals and groups, pub lic
and private, to support development and implementation of the SWMP and how the input
will be used;and
• Describes the public involvement/participation activities the permittee will undertake to
provide program access to those who want it and to gather the needed input. The activities
included, but are not limited to a water quality hotline(report spills, dumping, construction
sites of concern, etc.), stewardship activities like stream cleanups, storm drain marking,
and volunteer water quality monitoring.
c. Local stormwater public contact
• Identify a local point of contact for public concerns regarding stormwater management and compliance
with this general SPDES permit. The name or title of this contact and the telephone number must be
published in public outreach and public participation materials and kept updated with the Department on the
MCC form;
• d. Annual report presentation. Below are the requirements for the annual report presentation:
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i. Prior to submitting the final annual report to the Department, by June 1 of each reporting year(see Part
VC.), present the draft annual report in a format that is open to the public, where the public can ask
questions about and make comments on the report. This can be done:
o At a meeting that is open to the public, where the public attendees are able to ask questions about
and make comments on the report. This may be a regular meeting of an existing board, such as
planning, zoning or the town board. It may also be a separate meeting, specifically for stormwater. If
multiple permittees are working together, they may have a group meeting(refer to Part V.C.2), or on
the Internet by:
o Making the annual report available to the public on a webpage;
o Providing the public the opportunity to provide comments on the Internet or otherwise;and
o Making available the opportunity for the public to request an open meeting to ask questions about
and make comments on the report. If a public meeting is requested by 2 or more persons, the
permittee must hold such a meeting. However, the permittee need only hold a public meeting once to
satisfy this requirement.
ii. Provide public notice about the presentation, making public the following information when noticing the
presentation in accordance with the State Open Meetings Law or other local public notice requirements:
o The placement of the annual report on the agenda of this meeting or location on the Internet;
o The opportunity for public comment. This general SPDES permit does not require a specified time
frame for public comments, although it is recommended that permittees do provide the public an
opportunity to comment for a period after the meeting. Comments received after the final annual report
is submitted shall be reported with the following year's annual report. Permittees must take into account
those comments in the following year;
o The date and time of the meeting or the date the annual report becomes available on the
•
Internet;and the availability of the draft report for prior review prior to the public meeting or duration of
availability of annual report on the Internet.
The Department recommends that announcements be sent directly to individuals(public and private)
known to have a specific interest in the permittee's SWMP;
made to to the SWMP in response to comments should be described in the annual report;and
v. Ensure that a copy of the final report and, beginning in 2009, the SWMP plan are available for public
inspection.
e. Develop, record, periodically assess and modify as needed measurable goals;and
f Select appropriate public involvement/participation activities and measurable goals to ensure the reduction of
POCs in stormwater discharges to the MEP.
The table below depicts the BMPs that the Town currently performs or plans to perform for MCM 2, the
responsible parties and any applicable deadlines.
MCM 2- PUBLIC INVOLVMENT AND PARTICIPATION BMPS RESPONSIBLE TIMELINE
PARTY
1. Maintain and advertise a water quality hotline for the public to report SMO, HD Clerk Continually
spills, dumping, illegal pipes, etc.The HD Clerk will be responsible for
taking all calls, and will set up an answering machine for post- •
operating hours calls. Refer all substantive calls to the SMO, who will
follow up with site investigations as appropriate.
Measurable Goal:Follow Town protocols for receiving and responding
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to public calls. Respond to all reasonable calls.
• 2. Develop a program to work with various municipal and stakeholder SWCD, HD By-June
groups to undertake a storm drain marking program for key areas 2G43
within the Town. Annually
Measurable Goal:Prioritize storm drains within the Town.
Place at least 10 storm drain markers per year.
3. Engage the public in the Adopt-A-Highway program, and work to SWCD, HD Annually
expand the mileage of Town roads covered by this initiative. This
program is a beneficial means of addressing roadside litter while
helping to educate the public about environmental issues.
Measurable Goal:Keep an updated list of all participants and cleanup
sites. Expand the program by one mile per ycaror
by adding one partner per year.
4. Participate in a Lake/Stream Cleanup Day once per year. Outreach SMO, SWCD, Annually
this effort through the media, and encourage volunteer participation, HD, B&G
including the Lake George Association and other lake associations.
Measurable Goal: Obtain volunteers for the event.
Remove and properly dispose of all floatable debris.
Measure and record water quality parameters at the
cleanup site.
5. Develop a volunteer water quality monitoring program for designated SMO, SWCD, BY
outfalls along priority waterbodies. Train volunteers in proper water HD September
quality testing techniques and provide volunteers with necessary 3
supplies. COMPLETED
Measurable Goal:Develop protocols for testing at Town outfalls.
Prioritize outfalls within the Town based on
possible discharges into the storm sewer system.
Obtain various testing materials.
Obtain volunteers.
6. Implement volunteer water quality monitoring program SWCD, HD Beginning
Measurable Goal: Train all volunteers on testing techniques. Geteber
Supply volunteers with necessary equipment and 2043
supplies. Annually
Once program is established, obtain dry weather
discharge water quality data from at least 5 outfalls
per year.
7. Host at least 1 community meeting per year to discuss either regional Town Board, Annually
or town-wide stormwater issues SMO
Measurable Goal: Solicit input from the community on local and
regional stormwater issues.
8. If the opportunity becomes available, the Town will participate in a SMO, SWCD, When
Household Hazardous Waste Collection program facilitated by NYS HD possible
DEC.
Measurable Goal: Collect household hazardous waste so it is not
released into the storm drain system or waterways
9. Prepare and present the Annual Report for public review, by May 1 of SMO May 1,
every year. Present this report to the Town Board in May of every annually
year, and publicly notice this meeting as required by Open Meetings
Law. Provide DEC will public comments.
Measurable Goal:Record all public comments received on Annual
Report. Update SWMPP to incorporate applicable
public comments.
10. Host Annual Report on the Town website in an easily findable location SMO, TD Annually
for public review and use. Provide opportunity for public comment.
6
•
Measurable Goal: Provide public access to the Annual Report.
Minimum Control Measure 3: Illicit Discharge Detection & Elimination
The Illicit Discharge Detection and Elimination (IDDE) MCM consists of BMPs that focus on the detection and
elimination of illicit discharges located within the Town. The Town has adopted the NYS Department of
Environmental Conservation Model IDDE Law, giving the Town the authority to locate and remove or cause to
remove sources of the illicit discharge.
An MS4 must, at a minimum:
a. Develop, implement and enforce a program to detect and eliminate illicit discharges(as defined at 40CFR
122.26(6)(2))into the small MS4;
b. Develop and maintain a map, at a minimum within the,permittee's jurisdiction in the urbanized area and
additionally designated area, showing:
• The location of all outfalls and the names and location of all surface waters of the State that receive
discharges from those outfalls;
• By March 9, 2010, the preliminary boundaries of the permittee's storm sewersheds determined using GIS
or other tools, even if they extend outside of the urbanized area(to facilitate trackdown), and additionally
designated area within the permittee's jurisdiction;and
• When grant funds are made available or for sewer lines surveyed during an illicit discharge trackdown, the
permittee's storm sewer system in accordance with available State and EPA guidance. •
c. Field verify outfall locations;
d. Conduct an outfall reconnaissance inventory, as described in the EPA publication entitled Illicit Discharge
Detection and Elimination:A Guidance Manual for Program Development and Technical Assessment, addressing
every ouud// iN/Ln/r/Cne UfUan/Zeu aria anu auu/uuna/ly ucSiyiiaccu alma WILIlIJI t/iC SIC/IN/LLCC. JuIISUii.uWC at ICciJc
once every five years, with reasonable progress each year;
e.Map new outfalls as they are constructed or newly discovered within the urbanized area and additionally
designated area;
f. Prohibit, through a law, ordinance, or other regulatory mechanism, illicit discharges into the small MS4 and
implement appropriate enforcement procedures and actions.
This mechanism must be equivalent to the State's model IDDE local law "NYSDEC Model Local Law to Prohibit
Illicit Discharges, Activities and Connections to Separate Storm Sewer Systems' The mechanism must be certified
by the attorney representing the small MS4 as being equivalent to the State's model Rot discharge local law.
Laws adopted during the GP-02-02 permit cycle must also be attorney certified as effectively assuring
implementation of the State's model IDDE law;
g. Develop and implement a program to detect and address non-stormwater discharges, including illegal
dumping, to the small MS4. The program must include:procedures for identifying priority areas of concern
(geographic, audiences, or otherwise)for IDDE program;description of priority areas of concern, available •
equipment, staff, funding, etc.;procedures for identifying and locating illicit discharges(trackdown);procedures
for eliminating illicit discharges;and procedures for documenting actions;
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h. Inform public employees, businesses, and the general public of the hazards associated with illegal discharges
• and improper disposal of waste;
i. Address the categories of non-stormwater discharges or flows(listed in Section 1..A.2 of GP 0-10-002)as
necessary;
j. Develop, record,periodically assess, and modify as needed, measurable goals;and
k. Select appropriate IDDE BMPs and measurable goals to ensure the reduction of all POCs in stormwater
discharges to the MEP.
The table below depicts the BMPs that the Town currently performs or plans to perform for MCM 3, the
responsible parties and any applicable deadlines.
MCM 3 —ILLICIT DISCHARGE DETECTION & ELIMINATION BMPS RESPONSIBLE TIMELINE
PARTY
1. As the MS4 program boundary has expanded, undertake a new SMO, SWCD, By June
mapping of the stormwater outfalls within the outermost boundaries HD 283
of the Town. Include the names and DEC classification of any streams Annually
which receive stormwater discharge from a Town outfall.
Measurable Goal: Complete 75% of mapping in 2012
Finish remaining 25% of mapping in 2013 Review
• and map as additional outfalls are located or as necessary.
2. Develop, approve and implement a new town-wide law eliminating the Town Board, Law
use of phosphorus in fertilizers. Town Attorney adopted
Measurable Goal:A new law in place and outreached to public Sept 2011
3. Map all outfalls within the designated area as they are constructed or SWCD, HD As-needed
newly discovered within the urbanized area. Annually
Measurable Goat.. Review and -Updated GIS maps of all Town
outfalls.
4. Map the drainage areas which contribute to the stormwater outfalls SMO, SWCD, By January
(their sewersheds) in ArcGIS, and create hard copy maps of those HD 2815
areas. Annually
Measurable Goal: Updated GIS maps of Town sewershed.
5. Establish an IDDE Program within the Town. SMO, SWCD, By January
Measurable Goal:Identify roles in Program for each applicable HD, Town 2014
employee. Identify warning procedures for disconnection of illicit Attorney
discharges coming from private property. COMPLETED
Identify enforcement procedures for private party non-compliance.
Identify disconnection procedures for illicit discharges
coming from private property.
Establish procedures to disconnect any public illicit
discharge connections. _
6. I Enforce all provisions of the Town IDDE law regarding illicit discharges CEO, SMO, As needed
into Town drainage infrastructure, Town Attorney
Measurable Goal:Enforced IDDE laws by issuing citations.
• 7. Inventory high risk areas for possible illicit connections. Highest SMO, SWCD, By May
priority outfalls for inspection will be industrial areas, heavy HD 2014
commercial areas, areas of new development, and older areas of COMPLETED
development.
8
Measurable Goal:Produce map of high risk areas for illicit discharge. •
Produce outfall inspection schedule based upon inventory.
8. Conduct routine visual inspections of 25% of Town outfalls once per SWCD $egin
year, in dry periods. Record outcomes, including surrounding September
generating sites, and record type of potential illicit discharges. 2012
Measurable Goal:Record basic visual water quality information. Annually
9. Obtain water quality data from Town stormwater outfalls. SWCD, $egin
Measurable Goal: Obtain dry weather discharge water quality data volunteers G€teber
from at least 8 outfalls per year. 20}3
Annually
10. Inspect Town sub-surface storm sewer infrastructure (sewer cam.) for HD, WD, SMO By March
possible illicit discharges. 20 S
Measurable Goal: Utilize sewer camera for 3 days per As needed
infrastructure for possible illicit discharges. As necessary up on
evaluation of water quality testing data indicates
11. Replace any Combined Sewer Overflows (CSOs) that are found during SMO, HD, Town As needed
routine Town maintenance and construction activities. WD
Measurable Goal:Remove as many CSOs as practicable.
12. Confirm illicit discharges either found in routine Tovvn activities or SMO, SWCD, As needed
reported by the public. Eliminate discharges as necessary. HD, WD
Measurable Goal:Illicit discharges confirmed and eliminated.
13. Train all Town personnel (including labor, equipment operator and SMO, SWCD, By
field staff) regarding the IDDE provisions, including how to identify an P&R, PVC, B&G, September
illegal discharge and how to undertake the recommended follow-up WD 2$1-3
actions. Update training as necessary. As needed
Measurable Goal:All Town staff trained by September 2013. Provide •
IDDE training to staff within a 3 year time period or as requested.
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The Construction Site Runoff MCM consists of BMPs that focus on the reduction of pollutants to the MS4 from
construction activities that result in a land disturbance of greater than or equal to one acre. Reduction of
stormwater discharges from construction activities disturbing less than one acre will be considered if it is part of a
larger common plan of development or sale that would disturb one acre or more.
An MS4 must, at a minimum:
a. Develop, implement, and enforce a program that:
i. Provides equivalent protection to the NYS SPDES General Permit for Stormwater Discharges from
Construction Activities(either GP-02-01, GP-0-08-001 or GP 0-10-001), unless more stringent requirements
are contained within this general SPDES permit(GP-0-10-002);
ii. Addresses stormwater runoff to the small MS4 from construction activities that result in a land disturbance
of greater than or equal to one acre. Control of stormwater discharges from construction activity disturbing
less than one acre must be included in the program if:
o That construction activity is part of a larger common plan of development or sale that would disturb •
one acre or more;or
o If controlling such activities in a particular watershed is required by the Department.
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iii. Includes a law, ordinance or other regulatory mechanism to require a SWPPP for each applicable land
• disturbing activity that includes erosion and sediment controls that meet the State's most up-to-date technical
standards:
o This mechanism must be equivalent to one of the versions of the "NYSDEC Sample Local Laws for
Stormwater Management and Erosion and Sediment Control and
o Equivalence must be documented using the NYSDEC Gap Analysis Workbook or be certified by the
attorney representing the small MS4 as being equivalent to one of the versions of the sample laws if
one of the sample laws is not adopted or if a modified version of the sample law is adopted.
iv. Contains requirements for construction site operators to implement erosion and sediment control
management practices;
v. Allows for sanctions to ensure compliance to the extent allowable by State or local law;
vi. Contains requirements for construction site operators to control waste such as discarded building
materials, concrete truck washout, chemicals, litter, and sanitary waste at the construction site that may
cause adverse impacts to water quality;
Describes procedures for SWPPP review that incorporate consideration of potential water quality impacts
and review of individual pre-construction SWPPPs to ensure consistency with State and local sediment and
erosion control requirements;
o Ensure that the individuals performing the reviews are adequately trained and understand the State
and local sediment and erosion control requirements;
o All SWPPPs must be reviewed for sites where the disturbance is one acre or greater;and
o After review of SWPPPs, the permittee must utilize the "SWPPP Acceptance Form"created by the
Department and required by the SPDES General Permit for Stormwater Discharges from Construction
• Activity(GP-0-10-002) when notifying construction site owner/operators that their plans have been
accepted and approved by the permittee.
viii. Describes procedures for receipt and follow up on complaints or other information submitted by the
public regarding construction site storm water runoff;
ix. Describes procedures for site inspections and enforcement of erosion and sediment control measures
including steps to identify priority sites for inspection and enforcement based on the nature of the
construction activity, topography, and the characteristics of soils and receiving water;
o The permittee must ensure that the individual(s)performing the inspections are adequately trained
and understand the State and Local sediment and erosion control requirements. An adequately
trained inspector is a P.E., a CPESC, a LA or others who have received inspector training by a NYS
DEC sponsored or approved training;and
o All sites where the disturbance is one acre or greater must be inspected by staff from the operator
of the MS4.
x. Educates construction site owner/operators, design engineers, municipal staff and other individuals to
whom these regulations apply about the municipality's construction stormwater requirements, when
construction stormwater requirements apply, to whom they apply, the procedures for submission of SWPPPs,
construction site inspections, and other procedures associated with control of construction stormwater;
xi. By May 15, 2010, ensures that construction site operators have received erosion and sediment control
training before they do work within the permittee's jurisdiction. Small home site construction(construction
where the Erosion and Sediment Control Plan is developed in accordance with Appendix E of the "New York
Standards and Specifications for Erosion and Sediment Control')is exempt from the requirements below:
o Training may be provided by the Department or other qualified entities(such as Soil and Water
• Conservation Districts);
o The permittee is not expected to perform such training, but they may cosponsor training for
construction site operators in their area;
10
•
o The permittee may ask for a certificate of completion or other such proof of training;and
o The permittee may provide notice of upcoming sediment and erosion control training by posting in
the building department or distribute with building permit application.
xii. Establishes and maintains an inventory of active construction sites, including the location of the site,
owner/operator contact information;
xiii. Develop, record, periodically assess and modify as needed measurable goals;and
xiv. Select appropriate construction stormwater BMPs and measurable goals to ensure the reduction of all
POCs in stormwater discharges to the MEP.
The table below depicts the BMPs that the Town currently performs or plans to perform for MCM 4, the
responsible parties and any applicable deadlines.
MCM 4—CONSTRUCTION SITE STORMWATER RUNOFF CONTROL RESPONSIBLE TIMELINE
BMPS PARTY
1. For any land development projects performed within the Town that Town Engineer, As needed
anticipates exceeding one acre of land disturbance, the owner shall Town Planning
prepare an appropriate Stormwater Management Pollution Prevention Board
Plan (SWPPP). This SWPPP must conform to all requirements and
guidelines of the NYS SPDES General Permit requirements. All SWPPPs
will be reviewed by the contracted Town Engineer and Town Planning
Board.
Measurable Goal:All development projects follow the appropriate
SWMPP guidelines.
2. Encourage developers/contractors include the feasibility of Low Impact Town Engineer, As needed
Development/Better Site Design/Green Infrastructure principles in the Town Planning
development of SWPPP. Board
Measurable Goal:Encourage the use of Low Impact Development/
Green Infrastructure practices in construction BMPs.
informed and knowledgeable of the SWPPP, and that each contractor
sign a "Contractor's Certification Statement"acknowledging such.
Measurable Goal:Ensure only knowledgeable contractors are working
within the Town boundary.
4. Ensure that all subcontractors on such development have obtained the CEO As needed
4-hour contractor Erosion and Sediment Control Training, and are in
possession of ID cards noting such training has been obtained.
Measurable Goal:All contractor's working within the Town boundaries
have been properly trained.
5. Keep updated records of all construction projects in the Town. CEO As needed
Measurable Goal: Updated knowledge of construction activities. _
6. Perform weekly inspections of all construction sites by a Professional CEO As needed
Engineer or a Certified Professional in Erosion and Sediment Control.
Utilize the NYS DEC Region 5 inspection checklist for these
inspections. Keep all inspection records on file in the Town offices.
Measurable Goal:Assess and approve of all construction stormwater
BMPs at construction sites.
7. Any public complaints regarding erosion and sediment control or CEO As needed
stormwater runoff concerns from such development shall be directed "
to the Town CEO for review. The CEO will review the issue and
ensure that all provisions of the approved SWPPP are in compliance.
Measurable Goal:Solicit public involvement in the SWPPP process.
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8. The Town will issue Notices of Violation and Stop Work Orders to any CEO As needed
• construction site that does not follow the proper stormwater runoff
management procedures.
Measurable Goal:Stop all work that is not in compliance with DEC and
Town mandates.
9. Keep apprised of all new provisions of the SPDES General Stormwater SMO As needed
Permit, and outreach this information to the appropriate parties at the
Town.
Measurable Goal:Stay in compliance with updated DEC regulations.
Minimum Measure 5: Post-Construction Stormwater Management
The Post-Construction Stormwater Management MCM consists of BMPs that focus on the prevention or
minimization of water quality impacts from both new and re-development projects that disturb one acre or more.
This includes projects less than one acre that are part of a larger common plan of development or sale that
discharge into the MS4.
An MS4 must, at a minimum:
a. Develop, implement, and enforce a program that:
i, Provides equivalent protection to the NYS SPDES General Permit for Stormwater Discharges from
Construction Activities(either GP-02-01, GP-0-08-001 or GPO-10-002), unless more stringent requirements
• are contained within this general SPDES permit(GP-0-10-002);
ii. Addresses stormwater runoff from new development and redevelopment projects to the small MS4 from
projects that result in a land disturbance of greater than or equal to one acre. Control of stormwater
discharges from projects of less than one acre must be included in the program if:
o That project is part of a larger common plan of development or sale;or
o If controlling such activities in a particular watershed is required by the NYS DEC.
iii. Includes a law, ordinance or other regulatory mechanism to require post-construction runoff controls from
new development and re-development projects to the extent allowable under State or Local law that meet
the State's most up-to-date technical standards:
o The mechanism must be equivalent to one of the versions of the"NYSDEC Sample Local Laws for
Stormwater Management and Erosion and Sediment Control";and
o Equivalence must be documented using the NYSDEC Gap Analysis Workbook or certified by the
attorney representing the small MS4 as being equivalent to one of the sample laws if one of those
sample laws is not adopted or if a modified version of one of the sample laws is adopted.
iv. Includes a combination of structural management practices(including, but not limited to practices from the
NYS Stormwater Management Design Manual or equivalent)and/or non-structural management practices
(including, but not limited to comprehensive plans, open space preservation programs, Low Impact
Development(LID), Better Site Design(BSD)and other Green Infrastructure practices, land use regulations)
appropriate for the permittee that will reduce the discharge of pollutants to the MEP. Permittees are
encouraged to implement Green Infrastructure practices at a site level and to review, and revise where
appropriate, local codes and laws that include provisions that preclude construction that minimizes or
reduces pollutant loadings;
• o If a stormwater management practice is designed and installed in accordance with the New York
State Stormwater Management Design Manual or has been demonstrated to be equivalent and is
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properly operated and maintained, then MEP mall be assumed to be met for post-construction „
stormwater discharged by the practice.
v. Describes procedures for SWPPP review that incorporate consideration of potential water quality impacts
and review of individual pre-construction SWPPPs to ensure consistency with local post-construction
stormwater requirements;
o Ensure that the individuals performing SWPP reviews are adequately trained, or under the
supervision of a qualified professional who understand the State and Local post construction
stormwater requirements;
o All SWPPPs must be reviewed for sites where the disturbance is one acre or greater;and
o After review of SWPPPs, the permittee must utilize the "SWPPP Acceptance Form"created by the
Department and required by the SPDES General Permit for Stormwater Discharges from Construction
Activity(GP-0-08-001) when notifying construction site owner/operators that their plans have been
accepted and approved by the permittee.
vi. By May 1, 2009 establish and maintain an inventory of post-construction stormwater management practices
within the permittees jurisdiction. At a minimum, include practices discharging to the small MS4 that have
been installed since March 10, 2003, all practices owned by the small MS4, and those practices found to
cause or contribute to water quality standard violations;
o The inventory shall include at a minimum:location of practice(street address or coordinates); type of
practice; maintenance needed per the NYS Stormwater Management Design Manual, SWPPP, or other
provided documentation;and dates and type of maintenance performed;and
vii. Ensures adequate long-term operation and maintenance of management practices identified in Part
VII.5.a.vi by trained staff, including inspection to ensure that practices are performing properly.
o The inspection shall include inspection items identified in the maintenance requirements(NYS •
Stormwater Management Design Manual, SWPPP, or other maintenance information)for the practice.
Permittees are not required to collect stormwater samples and perform specific chemical analysis.
0
b. Develop, implement, and provide adequate resources for a program to inspect development and re-
,1...,..
c. Develop, record, periodically assess and modify as needed measurable goals;and
d. Select appropriate post-construction stormwater BMPs and measurable goals to ensure the reduction of all
POCs in stormwater discharges to the MEP.
The table below depicts the BMPs that the Town currently performs or plans to perform for MCM 5, the
responsible parties and any applicable deadlines.
MCM 5— POST- CONSTRUCTION SITE STORMWATER RUNOFF RESPONSIBLE TIMELINE
CONTROL BMPS PARTY
1. Develop a Post-Construction Plan for the Town that includes protocols CEO,Town By-March
for the inventory, inspection and maintenance of Post-Construction Engineer, Town 2013
stormwater activities on private and municipal construction projects. Planning Board Continuously
Measurable Goal:Ensure all development projects follow the
appropriate SWPPP guidelines.
2. Encourage that developers include the feasibility of Low Impact Town Planning Begw4ng
Development/Better Site Design/Green Infrastructure principles in the Board, Town January •
development of SWPPP Operation and Maintenance manual. Engineer 2G1-3
Measurable Goal:Encourage the use of Low Impact Development/ Continuously
Green Infrastructure practices in post-construction
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BMPs.
• 3. Maintain an updated inventory of all post-construction stormwater CEO As needed
management practices.
Measurable Goal:Stay informed of all post-construction stormwater
management practices within the town boundary.
Maintain list of types of post-construction
stormwater management practices used.
4. Prioritize all post-construction stormwater management practices and CEO BY-May
develop an inspection schedule for each project based upon the 2012
Operation and Maintenance manual developed during the SWPPP Annually
process. Update as necessary.
High priority projects, as deemed by the Town, shall have their post-
construction stormwater practices inspected a minimum of 2 times
per year.
Medium priority projects, as deemed by the Town, shall have their
post-construction stormwater practices inspected a minimum of once
per year.
Low priority projects, as deemed by the Town, shall have their post-
construction stormwater practices inspected a minimum of every
other year.
Measurable Goal:All post-construction stormwater practices inspected
on a rotating basis based upon the necessity for
inspection.
5. Inform the owner of any un-maintained post-construction stormwater CEO As needed
practices and if necessary, issue warnings/citations to ensure that all
post-construction management practices are properly maintained.
• Measurable Goal:Ensure that all post-construction management
practices are properly maintained.
6. Maintain or cause to maintain all post-construction management HD As needed
practices that the Town has contracted to manage.
Measurable Goal:All post-construction management practices are
maintained and remain working to the best ability.
7. Attend trainings on Low Impact Development, Better Site Deign and CEO, Town As available
other Green Infrastructure principles. Planning Board,
Measurable Goal: Train Town staff and Board in low impact Town Engineer
development principles.
Minimum Measure 6: Pollution Prevention and Good Housekeeping for
Municipal Operations
The Pollution Prevention and Good Housekeeping MCM consists of BMPs that focus on training and on the
prevention or reduction of pollutant runoff from municipal operations.
An MS4 must, at a minimum:
•a. Develop and implement a pollution prevention/good housekeeping program for municipal operations and
facilities that:
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i. Addresses municipal operations and facilities that contribute or potentially contribute POCs to the small
MS4s. The operations and facilities may include, but are not limited to:street and bridge maintenance;
winter road maintenance;stormwater system maintenance; vehicle and fleet maintenance;park and open
space maintenance;municipal building maintenance;solid waste management;new construction and land
disturbances;right-of-way maintenance;marine operations;hydrologic habitat modification; or other;
ii. At a minimum frequency of once every three years, perform a self assessment of all municipal operations
addressed by the SWMP to:
o Determine the sources of pollutants potentially generated by the permittee's operations and facilities;
and
o Identify the municipal operations and facilities that will be addressed by the pollution prevention and
good housekeeping program, if it is not done already.
iii. Determines management practices,policies,procedures, etc. that will be developed and implemented to
reduce or prevent the discharge of(potential)pollutants. Refer to management practices identified in the
"NYS Pollution Prevention and Good Housekeeping Assistance Document"and other guidance materials
available from the EPA, State, or other organizations;
iv. Prioritizes pollution prevention and good housekeeping efforts based on geographic area,potential to
improve water quality, facilities or operations most in need of modification or improvement, and permittee's
capabilities;
v. Addresses pollution prevention and good housekeeping priorities;
vi. Includes an employee pollution prevention and good housekeeping training program and ensures that
staff receive and utilize training;
vii. Requires third party entities performing contracted services, including but not limited to street sweeping,
snow removal, lawn/grounds care, etc., to meet permit requirements as the requirements apply to the
40
activity performed;and
Requires municipal operations and facilities that would otherwise be subject to the NYS Multisector
General Permit(MSGP, GP-0-06-002)for industrial stormwater discharges to prepare and implement
provisions in the SWMP that comply with Parts III.A, C, D,J, K and L of the MSGP. The permittee must
reports must be attached to an MS4s annual report. For those operations or facilities that are not required
to gain coverage under the MSGP, implementation of the above noted provisions of the SWMP will ensure
that MEP is met for discharges.
b. Consider and incorporate cost effective runoff reduction techniques and green infrastructure in the routine
upgrade of the existing stormwater conveyance systems and municipal properties to the MEP. Some examples
include replacement of dosed drainage with grass swales. replacement of existing islands in parking lots with rain
gardens, or curb cuts to route the flow through below grade infiltration areas or other low cost improvements
that provide runoff treatment or reduction.
c. Develop(for newly authorized MS4s), record, periodically assess and modify as needed measurable goals;and
d. Select and implement appropriate pollution prevention and good housekeeping BMPs and measurable goals to
ensure the reduction of all POCs in stormwater discharges to the MEP.
e. Adopt techniques to reduce the use of fertilizers,pesticides, and herbicides, as well as potential impact to •
surface water.
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•
The table below depicts the BMPs that the Town currently performs or plans to perform for MCM 6, the
• responsible parties and any applicable deadlines.
MCM 6— POLLUTION PREVENTION/GOOD HOUSEKEEPING FOR RESPONSIBLE TIMELINE
MUNICPAL OPERATIONS BMPS PARTY
1. Roadway and Bridge Maintenance. Roadways and bridges will HD Continuously
continue to be maintained in compliance with the Environmental
Manual prepared by the New York State Department of
Transportation. Measures will be taken to reduce stormwater runoff
from the roads where possible, including hydroseeding, installing
roadside buffers, removing all construction debris, ect.
Measurable Goal:Decrease stormwater runoff from Town roads.
2. Parking Lot and Street Cleaning. All parking lots within the Town HD, WD Annually
boundaries will be inventoried and prioritized for cleaning.
Measurable Goal:Sweep all Town parking lots at least once per year.
3. Parking Lot and Street Cleaning. Street cleanings will be HD Annually
scheduled in the spring and fall of every year.
Measurable Goal: Sweep all Town roadways at least once per year.
Increase frequency of leaning ycarlyReview
program yearly to reduce potential impacts to waterbodies.:
4. Parking Lot and Street Cleaning. Roadside leaf collection will be HD Annually
• scheduled and performed in the fastest manner possible to decrease
leaf buildup in storm sewers.
Measurable Goal: Collect all//leaf litter within one mefltk:month.
Encourage on site composting to reduce waste disposal.
Increase amount of leaf litter collected each year.
5. Parking Lot and Street Cleaning. Draft ordinance to require all SMO, Town By January
leaf litter be bagged and placed on the curb within a certain time Board, Town 2011
frame. Attorney COMPLETED
Measurable Goal:Adopt the ordinance. Eliminate all loose leaf piles
dumped on Town roads.
6. Road Salt Application and Storage. Continue to follow NYSDOT HD Continuously
Guidelines for Snow &Ice Control for use of deicing salt. Salt will
continue to be stored in buildings constructed for that purpose.
Measurable Goal:Eliminate salt storage seepage.
7. Road Salt Application and Storage. Inspections of the Town HD Annually
road salt storage facilities will be completed at least once per year
and any issues will be addressed within one week of discovery.
Measurable Goal:Expedite salt storage facility repairs.
Eliminate salt storage facility seepage.
8. Road Salt Application and Storage. Evaluate the possibility of HD By-Geteber
using alternative deicing materials on Town roads. 2012
Measurable Goal: Decrease the amount of traditional salt mixtures Annually
used on Town roads.
9. Road Salt Application and Storage. Keep annual records on the HD Annually
amount of salt applied to Town roads.
• Measurable Goal:Maintain completed records of salt usage.
Decrease amount of salt usage where possible.
10. Road Salt Application and Storage. Collect water samples at HD, WD Begin
outfalls near recent salt application sites on five different occasions Neverrlber
16
throughout the winter months. Test for and record the chloride and 2042 •
conductivity measurements. Annually
Measurable Goal::Evaluate salt usage based on water quality
impacts.
11. Septic System Management. Minimize septic system wastewater B&G As needed
impacts to municipal stormwater systems and local water bodies by
diverting sources of surface and ground water away from septic
systems; preventing growth of woody plants on the system;
preventing hydraulic overloading; minimizing water usage and
repairing leaky fixtures.
Measurable Goal:Eliminate sources of impact to municipal septic
systems.
12. Hydrologic Habitat Modification. Stream and Wetlands SMO, HD As needed
disturbances will be kept to a minimum. All procedures established
by NYSDEC, USACOE, APA, USFW, and the NYSODT Environmental
Manual will be followed.
Measurable Goal:Decrease impacts to wetlands when possible.
13. Building Maintenance. Develop a list of the maintenance activities B&G, WD By January
required inside and outside of each municipal building; Identify which 2043
activities have an impact on stormwater; and develop mitigation COMPELETED
measures for each activity that impacts stormwater.
Measurable Goal:Develop a maintenance plan that decreases
stormwater pollution from Town building
maintenance activities.
14. Building Maintenance. Conduct building maintenance activities B&G, WD Continuously
such that they do not impact the stormwater systems and local water •
bodies whenever possible.
Measurable Goal:Implement the maintenance plan that decreases
stormwater pollution from Town maintenance
activities.
15. Building Maintenance. Review the maintenance activity lists on an B&G, WD Annually
Measurable Goals: Update and improve maintenance activities when
necessary
16. Landscaping and Lawn Care. Lawn care and landscaping areas B&G, WD, P&R, By May 2013
and practices will be inventoried and evaluated, looking for PVC Continuously
reductions in: Fertilizers, Leaf litter &tree trimmings, Litter,
Floatables, and Equipment Fluids.
Measurable Goal:Decrease landscaping and lawn care waste that
contributes to stormwater pollution.
17. Landscaping and Lawn Care. If possible, use slow release, B&G, P&R, PVC As applicable
natural or organic lawn care products, and record and document all
use.
Measurable Goal:Reduce amount of fertilizer used on Town
property.
18. 'Catch Basin and Storm Drain Cleaning. Clean out 5025% of the HD Annually
Town catch basins and storm drains per year.
I Measurable Goal: Clean a minimum of 25% of catch basins annually.
19. Catch Basin and Storm Drain Cleaning. Identify catch basins for HD Annually
in need of repair.
Measurable Goal:Perform at least 50% of the necessary repairs •
within 1 month of identification and 100% within 2 months of
identification.
20. Vehicle& Equipment Maintenance and Maintenance Facilities HD, WD By Junc 2012
17
IProcedures. Evaluate maintenance procedures for opportunities to Continuously
• reduce discharge to storm sewer systems at the facility.
Measurable Goal:Decrease amount of stormwater pollution coming
from vehicle maintenance.
21. Vehicle& Equipment Maintenance and Maintenance Facilities HD, WD, P&R, Continuously
Procedures. All used motor oil from municipal vehicles will be PVC
properly recycled.
Measurable Goal:Properly recycle all used motor oil.
22. Vehicle& Equipment Maintenance and Maintenance Facilities HD, B&G, WD, By June 2012
Procedures. Design specific areas for vehicle washing and collect all P&R, PVC Continuously
washwater in a system that discharges to the wastewater treatment
plant.
Measurable Goal:Eliminate washwater runoff to the Town storm
sewer system.
23. Incorporate Green Infrastructure concepts into new SWCD, B&G, By May 2013
landscaping techniques and maintenance activities on town P&R, PVC Continuously
property
Measurable Goal: Develop new landscaping techniques based on the
DEC Design Manual, Chapter 5, Green
Infrastructure.
Replace non-native plants with native plant species
as appropriate
24. Hazardous Waste and Materials Management. Develop a spill HD, B&G, WD, By January
response plan and train all applicable personnel on proper response P&R, PVC 2013
methods. COMPLETED
Measurable Goal:Properly clean up all hazardous waste spills.
• 25. Perform self-assessments of all operations on a rotating 3 HD, B&G, WD, Annually
year schedule. P&R, PVC
Measurable Goal:Self-assess 33% of Town operations per year.
Improve operations as needed.
26. Town Employee Training Program. Provide or cause to provide SMO, SWCD, Begin-May
stormwater management BMP training for applicable Town HD, B&G, WD, 2012
employees. The training will be prioritized first for management and P&R, PVC Annually
supervisory staff, then to equipment operators and laborers.
Measurable Goal: Train 25% of applicable Town staff per year.
Update training as needed.
Appendices
Appendix C: List of Documents for Inclusion by Individual MS4s
This list was compiled from page 96 of the New York State Department of Environmental Conservation
General Permit for Stormwater Discharges from Municipal Separate Storm Sewer Systems (GP-0-10-002). It
is not necessarily limited to all actions and documents for inclusion. It is the responsibility of the Town of
Queensbury MS4 and the assigned Stormwater Management Officer to address the following components of
the SWMP plan and any other required actions and documents for inclusion that may be required but are not
•present on this list.
18
The SWMP plan shall be made readily available to the permittee's staff, the general public and regulators, •
such as DEC and EPA staff. Portions of the SWMP plan, primarily policies and procedures, must be available
to the management and staff of a permittee that will be called upon to use them.
Actions and Documents for Inclusion in the SWMP Plan
• All applicable local laws or procedures (MCMs 3, 4&5)
• Inter-municipal agreements and other legal authorities
• Staffing and staff development programs and organization charts
o Organization charts should detail the applicable offices and/or individuals which are responsible
for implementing various components of the permit
• Program budget
• Policy, procedures, and materials for each minimum measure
o This item is largely satisfied by the body of this document; if, however, an MS4 wishes to
elaborate or expand upon elements in Sections 1-6, it should do so.
• Outfall and small MS4 system maps
• Stormwater management practice selection and measurable goals
o This item is largely satisfied by the body of this document; if, however, an MS4 wishes to
elaborate or expand upon elements in Sections 1-6, it should do so.
• Operation and maintenance schedules
• Documentation of public outreach efforts and public comments •
o This item is largely satisfied by the body of this document; if, however, an MS4 wishes to
elaborate or expand upon public outreach efforts detailed in Sections 1-6, or if it has received any
public comments pertaining to implementation of MCMs 1-6, it should do so.
• Submitted construction site SWPPPs and review letters and construction site inspection
reports or reference to location
•
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