PC422c_Arleen_Fisher2012_Stormwater_Management_Program_(PDF)
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SPOKANE COUNTY
STORMWATER MANAGEMENT PROGRAM (SWMP) Eastern Washington Phase II Municipal Stormwater Permit
Compliance
Permit Cycle - February 16, 2007 to July 31, 2014
Eastern Washington Phase II Municipal Stormwater Permit Areas (orange areas)
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FORWARD
Spokane County is required to develop and implement a Stormwater
Management Program in order to meet its requirements under the Eastern
Washington Phase II Municipal Stormwater Permit. The Stormwater Management Program (SWMP) for Spokane County
described in the following document is designed to be a “Public Working
Document”.
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TABLE OF CONTENTS
Section Page No.
1.0 INTRODUCTION
1.1 History 1
1.2 Purpose 2
1.3 Authorization 2
1.4 Area of Coverage 3
1.5 Period of Performance 3
1.6 Public Process 4
1.7 Stormwater Management Program Permit Requirements 4
1.8 Spokane County - Stormwater Management Program, Sections 4
2.0 LEGAL AUTHORITY
2.1 Introduction 5
2.2 Existing Legal Authority 5
2.3 Additional Required Legal Authority 7
2.4 Priorities and Measurable Goals 7
2.5 Staffing and Funding 7
3.0 STORMWATER BASELINE DATA AND MAPS
3.1 Introduction 8
3.2 Stormwater System Map 9
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3.3 Priorities and Measurable Goals 10
3.4 Staffing and Funding 11 4.0 PUBLIC EDUCATION AND OUTREACH
4.1 Introduction 12
4.2 Public Education and Outreach Program Elements 12
4.2.1 Objectives for Public Education and Outreach 12
4.2.2 Public Education and Outreach Activities 13
4.3 Priorities and Measurable Goals 14
4.4 Staffing and Funding 14
5.0 PUBLIC INVOLVEMENT AND PARTICIPATION
5.1 Introduction 15
5.2 Public Involvement and Participation Program Elements 15
5.2.1 Objectives for Public Involvement and Participation 15
5.2.2 Public Involvement and Participation Activities 16
5.3 Priorities and Measurable Goals 16
5.4 Staffing and Funding 16
6.0 ILLICIT DISCHARGE DETECTION AND ELIMINATION
6.1 Introduction 17
6.2 Illicit Discharge Data and Mapping 18
6.3 Non-Stormwater Discharges 18
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6.4 Visual Inspection Program Elements 18
6.5 Spill Prevention and Response Program Elements 19
6.6 Public Reporting Program Elements 19
6.7 Hazardous Waste Disposal Program Elements 19
6.8 High Priority Water Body Assessment 20
6.9 Priorities and Measurable Goals 20
6.10 Staffing and Funding 22
7.0 CONSTRUCTION SITE STORMWATER RUNOFF CONTROL
7.1 Introduction 23
7.2 NPDES Construction Stormwater Permit - Ecology 23
7.3 Spokane Regional Stormwater Manual 24
7.4 Erosion and Sediment Control Plan General Requirements 24
7.5 Developer Notification Program Elements 25
7.6 Construction Site BMP Elements 25
7.7 Contractor Education and Training Program Elements 25
7.8 Employee Education and Training Program Elements 26
7.9 Priorities and Measurable Goals 26
7.10 Staffing and Funding 27
8.0 POST-CONSTRUCTION STORMWATER MANAGEMENT
FOR NEW DEVELOPMENT AND REDEVELOPMENT 8.1 Introduction 28
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8.2 Post-Construction General Requirements 28
8.3 Post-Construction Notification Program Elements 29
8.4 Post-Construction Site Inspection Program Elements 29
8.5 County Staff Education and Training Program Elements 29
8.6 Priorities and Measurable Goals 29
8.7 Staffing and Funding 30
9.0 POLLUTION PREVENTION AND GOOD HOUSEKEEPING FOR MUNICIPAL OPERATIONS
9.1 Introduction 32
9.2 Municipal Stormwater Facilities and Programs 32
9.2.1 Regional Stormwater Facilities 33
9.2.2 Roadway Stormwater Facilities 33
9.2.3 Stormwater Facilities at Parks and Other County Owned Properties 34
9.2.3.1 Parks and Open Spaces 34
9.2.3.2 Vehicle Fleets, Heavy Equipment Storage Areas, Maintenance Areas 35
9.2.3.3 Municipal Buildings 35
9.2.3.4 Material Storage 36
9.2.3.5 Industrial Activities and Other Public Facilities 36
9.3 Construction Projects 36
9.4 Spokane County Employee Education and Training 36
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9.4.1 Objectives for Spokane County Employee Education and Training 37
9.4.2 Employee Education and Training Activities 37
9.5 Priorities and Measurable Goals 37
9.6 Staffing and Funding 39
10.0 SWMP IMPLEMENTATION RESPONSIBILITIES
10.1 Introduction 40
10.2 Implementation Responsibilities 40
10.3 Implementation in New Areas 41
11.0 MEASURABLE GOALS
11.1 Year 1 Goals 42
11.2 Year 2 Goals 43
11.3 Year 3 Goals 44
11.4 Year 4 Goals 46
11.5 Year 5 Goals 47
11.6 Year 6 Goals xx
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SECTION 1 – INTRODUCTION
1.1 History
The United States Environmental
Protection Agency (EPA) considers pollution from all diffuse sources, including urban stormwater pollution, to
be the most important source of
contamination in our nation’s waters.
Runoff pollution occurs every time rain or snowmelt flows across the ground and picks up contaminants.
This Stormwater Management Program
(SWMP) focuses on runoff pollution
from developed areas, which occurs when stormwater carries away a wide
variety of contaminants as it runs across
rooftops, roads, parking lots, baseball
diamonds, construction sites, golf
courses, lawns, and other surfaces. A majority of Spokane County’s
population lives in urbanized areas
where the water resources are highly
vulnerable to degradation from urban
runoff.
Urban stormwater continues to impair the nation’s waterways, 29 years after passage in
1972 of the law now known as the Clean Water Act. The main reason urban stormwater
remains such an important contributor to water pollution is the fact that in most areas,
stormwater receives no treatment before entering waterbodies.
Over the past three decades, national and local water pollution control efforts have focused primarily on certain process water discharges from facilities such as factories and sewage treatment plants, with less emphasis on diffuse sources. While these efforts have
led to many water quality improvements, new efforts are now needed to address the
remaining sources of water pollution, including urban runoff pollution.
Figure 1. Spangle Creek - circa 1930's
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On December 8, 1999, EPA promulgated a rule requiring smaller municipalities, those
with populations of fewer than 100,000 people located in urbanized areas (where
population density is greater than 1,000 persons per square mile), to develop a Stormwater Management Program that addresses stormwater pollution runoff that enters
surface waters. In Washington, EPA’s smaller municipality rule is directed to local
jurisdictions through the National Pollution Discharge Elimination System (NPDES) –
Phase II Permits that are under the direction of the Department of Ecology.
Spokane County (County) was issued coverage under the Eastern Washington Phase II Municipal Stormwater Permit (Permit), under Permit No. WAR04-6506, effective February 16, 2007. The Permit states, “All Counties shall develop and implement a
Stormwater Management Program (SWMP) during the term of this permit.” The Permit
primarily addresses stormwater discharges to surface waters. Stormwater that is directed
to underground injection control (UIC) wells is regulated under the State of Washington’s, Underground Injection Control Program, and therefore is not addressed within the SWMP.
The following Stormwater Management Program is designed to meet Spokane County’s
Permit obligations.
1.2 Purpose
The purpose of this SWMP is to describe the programs, practices and responsibilities
adopted by the County to manage the municipal separate storm sewer system (MS4) in
implementing the requirements of the Permit.
The SWMP describes the activities that will be performed to comply with the Permit
conditions, provides measurable goals for key activities, and outlines staffing and funding
responsibilities for the County. The SWMP will apply to the 5-year duration of the
current Permit cycle (expiring February 15, 2012) and forms the foundation for a long-
term program to reduce pollutants discharged to waters of the state within Spokane County. The Washington State Legislature extended the expiration date of Permit to July
31, 2014.
Annual updates to the SWMP will be provided to encourage public involvement, hear
public comment, to address necessary revisions in program elements and to provide for necessary revisions as conditions change within the Permit.
1.3 Authorization
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This SWMP was prepared by the Spokane County, Engineering and Roads - Stormwater
Utility.
1.4 Area of Coverage
The area of coverage is defined in paragraph S1 of the municipal permit:
“For all Counties required to obtain coverage under this permit, the geographic area
of coverage is the urbanized areas and the urban growth areas associated with Cities within the urbanized areas that are under the jurisdictional control of the County. The
geographic area of coverage also includes any urban growth areas that are contiguous
to urbanized areas that are under the jurisdictional control of the County.”
The focus is on the discharge of municipal stormwater runoff into the waters of the U.S. and waters of the state as described within the Permit. Consistent with this focus, the
activities described in the SWMP will be conducted within the urban growth areas of
Spokane County. See Appendix A for a detailed Spokane County map of the initial
Permit boundary covered by this permit, as well as the current Stormwater Service Area
(SWSA) boundary.
The City of Spokane and the City of Spokane Valley are also subject to the Permit issued
by Ecology and are developing their own processes of compliance with that permit.
Spokane County will be coordinating with these jurisdictions and other agencies on
various elements of the SWMP, particularly on the Public Education tasks.
1.5 Period of Performance
This SWMP applies to the 5-year effective period of the municipal permit, valid from
February 16, 2007 to February 15, 2012. The SWMP refers to Permit Years specifying when various activities are scheduled to occur. Permit Years are defined as follows:
Permit Year 1 - February 16, 2007 to February 15, 2008
Permit Year 2 - February 16, 2008 to February 15, 2009
Permit Year 3 - February 16, 2009 to February 15, 2010 Permit Year 4 - February 16, 2010 to February 15, 2011
Permit Year 5 - February 16, 2011 to February 15, 2012
Permit Year 6 - February 17, 2012 to February 15, 2013
In addition, the Permit also requires annual reports that are subject to the following “reporting periods”:
Annual Report, Year 1 - February 16, 2007 to December 31, 2008
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Annual Report, Year 2 - January 1, 2008 to December 31, 2009
Annual Report, Year 3 - January 1, 2009 to December 31, 2010
Annual Report, Year 4 - January 1, 2010 to December 31, 2011 Annual Report, Year 5 - January 1, 2011 to December 31, 2012 Annual Report, Year 6 – January 1, 2012 to December 31, 2013
1.6 Public Process
The SWMP is continually available for public comment on the Spokane County webpage (www.spokanecounty.org/stormwater). Prior to each year's deadline for the annual
report, the SWMP will be evaluated and updated in response to public comments
received.
1.7 Stormwater Management Program Permit Requirements There are six (6) basic elements described within the Permit that make up the heart of the
SWMP. Those elements are as follows:
1) Public Education and Outreach;
2) Public Involvement and Participation;
3) Illicit Discharge Detection and Elimination;
4) Construction Site Stormwater Runoff Control; 5) Post-Construction Stormwater Management for New Development and
Redevelopment;
6) Pollution Prevention and Good Housekeeping for Municipal Operations.
1.8 Spokane County - Stormwater Management Program, Sections
The SWMP components are described within the following Sections of this document:
• Section 2.0 - Legal Authority
• Section 3.0 - Baseline Data and Maps
• Section 4.0 - Public Education and Outreach
• Section 5.0 - Public Involvement and Participation
• Section 6.0 - Illicit Discharge Detection and Elimination
• Section 7.0 - Construction Site Stormwater Runoff Control
• Section 8.0 - Post Construction Stormwater Management for New Development and Redevelopment
• Section 9.0 - Pollution Prevention and Good Housekeeping for Municipal
Operations
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• Section 10 – Stormwater Management Program Implementation Responsibilities
• Section 11 - Years 1, 2, 3, 4 and 5 Measurable Goals
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SECTION 2 – LEGAL AUTHORITY
2.1 Introduction
This section addresses the Eastern
Washington Phase II Municipal Permit
(Permit) requirements dealing with legal
authority of the County to implement the various aspects of the proposed Stormwater Management Program
(SWMP). The objective is to provide
documentation that the County either
currently has adequate legal authority to conduct all necessary activities, or has a plan for obtaining that authority.
2.2 Existing Legal Authority
The Spokane County, Stormwater Utility was formed in 1992 to prepare and implement basin stormwater management plans. The Utility is funded through stormwater service
charges based on impervious coverage on developed parcels.
On January 17, 2006, the Board of County Commissioners adopted the Comprehensive Stormwater Management Plan (CSWMP) along with individual stormwater plans for Glenrose, North Spokane and West Plains and their associated Capital Improvement
Plans. Each of the individual basin plans emphasizes protecting natural drainage features
as the most cost effective means of handling stormwater over the long term.
In addition, Spokane County has implemented flood controls through Title 3, Buildings and Structures, Chapter 3.20, Flood Damage Protection, a comprehensive flood control
ordinance that manages development within floodplain zones in compliance with the
National Flood Insurance Program (NFIP).
Spokane County has adopted engineering design standards and BMPs that are described within the Spokane Regional Stormwater Manual (SRSM). The SRSM was approved by
the Board of Commissioners on April 15, 2008 and officially became law on June 1,
2008. The SRSM replaces the Spokane County - Guidelines for Stormwater
Management”.
Figure 2. Chester Creek August 2004
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In addition to the new requirements within the SRSM, the following chapters of the
existing Spokane County Code address stormwater requirements: 1) Chapter 9.14,
Roads, Approach and Drainage in New Construction; 2), Chapter 12.400 Subdivisions; 3) Chapter 14.802.060, Parking Lot Location and Design.
Spokane County Code, Title 8, Health and Sanitation Code, Chapter 8.03, Sanitary Sewer
Code, includes various sections that address illicit discharges within Spokane County.
The primary relevant sections include: 8.03.1570 POTW; 8.03.1710 Private Storm Sewer; 8.03.1730 Prohibited Discharge Standards or Prohibited Discharges; 8.03.1750
Public Sewer; 8.03.1830 Sewer; 8.03.1990 Stormwater; 8.03.2010 Storm Sewer or Storm
Drain; 8.03.3200 Prohibited Uses of Sanitary Sewer; 8.03.3220 Use of Storm Sewers--
Combined Sewers--Natural Outlets; 8.03.3260 Obstructing Sewer Prohibited; 8.03.3300
Unauthorized Connection to Public Sewers; 8.03.3240 Prohibited Uses--Public Sewers; 8.03.4040 Prohibited Discharge Standards--General Prohibitions; 8.03.4060 Prohibited
Discharge Standards--Specific Prohibitions.
Spokane County Code, Title 8, Health and Sanitation Code, Chapter 8.26, Litter and
Discriminate Dumping, includes various sections that are relevant to protecting the integrity of stormwater and other surface waters, such as Section 8.26.020, Litter in
General, which addresses the disposing of litter upon any public place or private
property, or within any waters in Spokane County. This Chapter also addresses notice of
violation, enforcement and penalty.
Spokane County Code, Chapter 8.60.030 Oil Sellers--Educational Responsibilities,
requires sellers of lubricating oil to do the following: 1) post educational materials that
describe the importance of used oil recycling and how and where used oil may be
recycled; and 2) provide for the sale of reusable used oil containers.
In 2008, County staff evaluated current regulations relating to illicit discharge detection
and elimination. The results of the investigation concluded that County Code, although
covering many aspects of the illicit discharge detection and elimination components of
the Permit, fell short of meeting all requirements. As a result, draft amendments to
Spokane County Code, Chapter 9.14, Roads, Approach and Drainage in New Construction, were developed and approved (Resolution No. 09-0672) through the public
review and process referenced in Section 1.6. The new illicit discharge regulations bring
the County into compliance with the requirements of the Permit by addressing the
following:
• Prohibit illicit discharges to the municipal separate storm sewer system;
• Control spills, dumping or disposal of materials other than stormwater to the storm
sewer system;
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• Require compliance with conditions in ordinances related to stormwater discharges;
• Carry out inspection and monitoring procedures necessary to determine compliance with the prohibition on illicit discharges to the storm sewer system;
• Provide regulations guiding inspection, enforcement and penalty.
2.3 Additional Required Legal Authority
If the review of current regulations and ordinances identifies deficiencies in the ability to
implement SWMP programs, a plan for addressing those deficiencies will be developed.
2.4 Priorities and Measurable Goals
Existing legal authority will be documented first, followed by development of a plan to address any deficiencies in current ordinances, etc. Measurable goals are defined below.
Completed by Measurable Goal/Milestone
End of Permit Year 1
(February 15, 2008) • Begin to assemble and summarize existing legal authority
End of Permit Year 2
(February 15, 2009) • Develop a plan for addressing deficiencies in current legal authority
• Begin developing policy and code revisions in legal
authority
End of Permit Year 3
(February 15, 2010)
• Complete implementing policy and code revisions
relating to illicit discharge (September 1, 2009)
• If necessary, revise existing codes relating to construction and post construction
End of Permit Year 4 (February 15, 2011) • Continue evaluating construction and post construction codes and procedures
End of Permit Year 5 (February 15, 2012) • Monitor previous Code revisions.
End of Permit Year 6 (February 15, 2013) • Continue implementing previous year goals and milestones
2.5 Staffing and Funding
Funding for review of legal authority will be provided by:
Engineering and Roads - Stormwater Utility.
Staffing for review of legal authority will be provided by:
Engineering and Road - Stormwater Utility.
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SECTION 3 – STORMWATER BASELINE DATA AND MAPS
3.1 Introduction
An initial task (special provision S 5. B.
of the permit) is to gather information
about the County’s storm drainage
infrastructure. Most stormwater runoff in unincorporated Spokane County is discharged into the ground, either via
natural infiltration or through drywells.
In many areas the local geology,
including the gravel soils that lie over the Spokane Valley Rathdrum Prairie (SVRP) Aquifer, allows stormwater to
infiltrate rapidly into the ground.
Unincorporated Spokane County has developed without an extensive system of storm sewers. Much of the runoff
discharged into the ground recharges the
aquifer which has an interchange of
flows with both the Spokane River and the Little Spokane River. Providing a comprehensive approach to inventorying
the County’s stormwater system requires
combining an inventory of any
municipal discharges to surface waters with an inventory of county facilities that discharge stormwater into the
ground.
This SWMP is focusing on meeting the requirements of the Permit. At the same time, Spokane County is preparing a separate program to meet the requirements of the state Underground Injection Control (UIC) program. The municipal separate storm sewer
system (MS4) in Spokane County is comprised of roads with ditches, culverts, curbs,
bridge drains, swales, detention ponds, and piping systems that direct stormwater into a
surface water body such as a DNR stream, wetland, pond, etc.
Figure 3. Example Stormwater Facilities Infrastructure Map
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A stormwater system map for the Permit area of unincorporated Spokane County has
been prepared and is being continually updated. A stormwater system map is valuable to
the various departments within the County, the public, regulatory agencies and others by documenting the stormwater system and in determining where potential stormwater
quality problems may exist or originate. The initial stormwater system map is based on
field work conducted regularly within the Stormwater Service Area since the Stormwater
Utilities inception in 1992. The existing computerized inventory information is
periodically evaluated and updated annually based field surveys.
3.2 Stormwater System Maps
Maps of the existing regional storm drainage system have been prepared to document
locations and contributing areas of major outfalls. The maps will also include underground injection wells and Spokane County detention and retention ponds located
within the Permit boundary. As information is gathered and developed, GIS data will be
reviewed and updated annually.
The base maps prepared in since the beginning of the Permit were developed from existing stormwater data layers developed over many years of the Stormwater Utility’s
past work activities. Data layers include facilities such as: catch basins, swales, roadside
ditches, drywells, inlets, etc. The maps show the locations of major regional stormwater
drainage and collection systems, stormwater control facilities and other relevant
information.
The SWU hired a field crew in 2008 to find and document MS4 outfalls located within
the Permit jurisdictional area. That data was processed and finalized in 2009.
In 2009, 2010 and 2011 additional outfall inventory analysis and field investigations were conducted. This work further located and defined outfalls to the MS4. The data
collected expanded the existing GIS outfall database.
The following maps were developed and/or updated by the Stormwater Utility:
(a) Permit jurisdictional area map;
(b) Permit areas in relation to the Stormwater Service Area;
(c) Permit area in relation to the Spokane Valley-Rathdrum Prairie Aquifer;
(d) Stormwater conveyance and collection infrastructure systems (outfalls, UIC
wells, detention and retention ponds, etc.); (e) Natural Drainage areas and contours (streams, rivers, lakes, ponds, etc.);
(f) Regional watersheds;
(g) County rights-of-way within the Permit boundary;
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(h) Sites where NPDES Construction Permits have been issued by Ecology;
(i) Public road systems within the Permit area.
The maps will also be useful in discovering and documenting illicit discharges and
related information.
Each year, the maps will be updated with new information. Future maps are anticipated
to include but may not be limited to the following:
(a) Public facilities within the Permit area (parks and open spaces, public
buildings, material storage; county shops, etc.);
(b) New sites where NPDES Construction Permits have been issued by Ecology.
Additional GIS coverages and maps will be identified and developed throughout the life
of the Permit.
3.3 Priorities and Measurable Goals
Activities in this category were or will be conducted as defined below.
Completed by Measurable Goal/Milestone
End of Permit Year 1
(February 15, 2008) • Begin preparing MS4 base maps
End of Permit Year 2
(February 15, 2009) • Continue developing the MS4 base maps
• Begin evaluation of existing stormwater infrastructure, facilities and properties
End of Permit Year 3 (February 15, 2010) • Update stormwater GIS data layers and maps
• Complete the analysis and development of the MS4 outfall
coverage from 2008 and 2009 field investigations
End of Permit Year 4
(February 15, 2011) • Gather data and develop infrastructure maps for all public
facilities and activities relating to the development of the
O&M Plan
• Conduct priority water body outfall field investigations and
continue updating outfall database
• Update stormwater GIS coverages and maps
End of Permit Year 5
(February 15, 2012) • Update stormwater GIS coverages and maps
• Develop public facility site maps to accompany the Stormwater O&M Plan site assessment analysis
• Develop material storage, heavy equipment storage area
and maintenance area maps for the O&M Plan SWPPP
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• Conduct priority water body outfall field investigations and continue updating outfall database
End of Permit Year 6 (February 15, 2013) • Continue implementing previous year Permit requirements
3.4 Staffing and Funding
Funding for the stormwater system infrastructure map will be provided by:
Spokane County, Engineering and Roads - Stormwater Utility
Staffing for map preparation will be provided by:
Spokane County, Engineering and Roads - Stormwater Utility
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SECTION 4 – PUBLIC EDUCATION AND OUTREACH
4.1 Introduction This section describes the public
education and outreach activities used by
the County in response to the Permit requirements for such a program (special provision S5.B.1). The rationale for the
program is to inform the general public
on the importance of stormwater quality,
and to influence behavior in a way that benefits water quality within the region. Activities were selected to take
advantage of existing programs, and to
target specific water quality problems
and audiences that are important in Spokane County.
4.2 Public Education and Outreach Program Elements
4.2.1 Objectives for Public Education and Outreach The overall objectives of the Public Education and Outreach Program are to:
(a) Inform the general public in Spokane County about important water quality
issues related to stormwater runoff; (b) Inform businesses and the general public about the need to prevent illicit discharges;
(c) Inform engineers, construction contractors, developers, development review
staff and land use planners about technical standards, the development of
stormwater site plans and erosion control plans and stormwater Best Management Practices (BMPs) for reducing adverse impacts of stormwater runoff from development sites; and
(d) Influence behavior of the general public, businesses and those involved in the
land development sector to reduce activities that have a negative impact on
stormwater runoff quality and increase activities that have a positive impact on stormwater runoff quality.
Figure 4. Soils and Geology Educational Tour 2004
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4.2.2 Public Education and Outreach Activities
Spokane County is working individually and where mutually beneficial with the Cities of Spokane and Spokane Valley to develop public education and outreach
program. Activities being considered include, but are not limited to:
(a) Community Events. County will continue to use community events related to
environmental awareness and regional water issues as opportunities for education and outreach. Booths will be staffed by volunteers from the County
and/or other local organizations (e.g., Spokane Aquifer Joint Board of water
purveyors), who will hand out informational materials and answer questions;
(b) Media Materials. County will evaluate the production or distribution of media
materials to disseminate public education and outreach information. Media materials may include: (1) a program for local public television including
general information on stormwater quality issues; and (2) public service
announcements or a commercial for targeted messages and audiences;
(c) Printed Materials. County will continue to develop, produce or distribute
printed materials (e.g., brochures, flyers, promotional items) for specific topics related to stormwater quality. Spokane County has supported the City
of Spokane's efforts in the developing a stormwater atlas as a companion
document to the SVRP Aquifer Atlas. Older printed materials will be updated
as necessary;
(d) Grants. County will continue to pursue opportunities for obtaining grants and loans through Ecology for specific projects addressing stormwater quality
issues, public education and outreach, and low impact development projects.
This will be done in cooperation with other affected jurisdictions, as well as
other regional planning and management agencies;
(e) Website. County will continue to enhance, maintain and update the “stormwater” section of the existing Spokane County webpage, to provide
information to the public on stormwater permitting, Spokane County water
quality issues, BMPs, and links to other related websites;
(f) School Programs. County will continue to conduct outreach activities in
public schools in Spokane County to promote awareness of water quality issues, pollution prevention, and basic watershed principles;
(g) Involvement in Other Organizations. County will continue to be active in
other organizations in Spokane County that promote inter-agency cooperation
and have outreach and education functions;
(h) Construction Program. County will conduct education and outreach activities targeting construction industry organizations (developers, contractors,
engineers, surveyors, etc.) about technical standards, the development of
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stormwater site plans and erosion control plans and BMPs for reducing
adverse impacts from development sites. When opportunities become
available, Spokane County will work through professional engineering and land planning groups to provide education regarding compliance with the
Spokane Regional Stormwater Manual and with other Permit requirements.
(i) Illicit Discharge Program. County will provide information to businesses and
the general public about illicit discharges – what they are and how to prevent
them – and encourage proper management and disposal of toxic materials. (j) Regional Stormwater Facilities. Signage and other information will be
developed to explain the meaning of watersheds, and the value of using
natural stormwater systems to control and treat stormwater runoff. Regional
stormwater facilities will include opportunities for hands on education about
wetlands, the stormwater cycle and the value of clean water. (k) Civic Groups. County will provide stormwater pollution prevention
information to various community groups.
4.3 Priorities and Measurable Goals
Coordinate public outreach and education with various departments and jurisdictions.
4.4 Staffing and Funding
The annual budgets of the Spokane County Stormwater Utility and the Water Resources Program fund public education and outreach related to water quality. Funds can be used
for producing printed material and other education and outreach materials and for
assisting in developing long-term education and outreach strategies and methods.
Spokane County supports the utilization of funds for staff time to make presentations at public schools and before civic groups.
Attendance of Spokane County staff members at community outreach events, where part
of staff employment responsibilities, will be funded by various participating government
agencies.
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SECTION 5 – PUBLIC INVOLVEMENT AND PARTICIPATION
5.1 Introduction
In meeting the requirements of
the Permit, Spokane County
intends to integrate the
stormwater management program as much as possible into existing programs and activities.
Spokane County has, under the
State’s Growth Management Act,
adopted the Public Participation Program Guidelines (PPPG) which describes procedures to
ensure a wide range of
opportunities for public
participation in land use decisions.
The County will use the PPPG to ensure there are ongoing opportunities for public
involvement and participation in the development and update of stormwater related
codes. This section describes the public involvement and participation activities to be used to meet the municipal permit requirements for such a program (paragraph S5.B.2).
5.2 Public Involvement and Participation Program Elements
5.2.1 Objectives for Public Involvement and Participation The overall objectives of the Public Involvement and Participation Program are
to:
(a) Provide opportunities for public participation in the decision making processes related to stormwater management plans and regulations; and (b) Ensure the public has opportunities to participate in activities and discussions
that will mold and guide the local stormwater management program.
Figure 5. Price & Wall Regional Stormwater Facility Ground Breaking Ceremony, June 2008
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5.2.2 Public Involvement and Participation Activities
In 2008, Spokane County utilized the public participation guidelines in adopting the Spokane Regional Stormwater Manual (SRSM). The public involvement
guidelines include the following: communication programs and information
services; broad dissemination of proposals and alternatives; public meetings after
effective notice; provision for open discussion; opportunity for written comments;
and consideration of and response to public comments.
In 2009, Spokane County utilized the public participation guidelines in adopting
the Illicit Discharge Detection and Elimination related amendments to Spokane
County Code. The public involvement guidelines include the same elements
mentioned in the previous paragraph.
In 2011, the SWU conducted a randomly distributed public survey to gauge the
level of the public’s knowledge on stormwater related pollution sources, concerns,
issues, and to begin to gain an understanding of where future education efforts
should be focused towards.
The SWMP is available on the Spokane County webpage where public
involvement and participation is encouraged.
5.3 Priorities and Measurable Goals
Coordinate public involvement and participation with various departments and
jurisdictions to encourage compliance with the adopted guidelines.
The SWMP is available for public review and comment on the Spokane County web-site. 5.4 Staffing and Funding
Following the adopted guidelines and creating ongoing opportunities for involvement in
stormwater management activities is, and will continue to be, a part of doing business at Spokane County. Funding and staffing for the public participation work are part of the
operations of the Stormwater Utility and other County agencies such as the Water
Resources Program.
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SECTION 6 – ILLICIT DISCHARGE DETECTION AND
ELIMINATION
6.1 Introduction
This section describes the elements of
the Illicit Discharge Detection and
Elimination (IDDE) Program required
by the Permit in paragraph S5.B.3. This
element may be somewhat difficult initially for Spokane County to define
clearly since the County does not have
an extensive stormwater pipe system.
As previously discussed in Section 3.1,
most stormwater, including that conveyed by gutters or ditches in
unincorporated Spokane County, is
discharged into the ground, either via
natural infiltration or through drywells.
In many areas the geology above the SVRP aquifer allows for rapid
stormwater infiltration. Therefore,
opportunities for stormwater monitoring
are limited.
Illicit discharge program elements are focusing initially on evaluating the existing
stormwater system and potential non-stormwater discharges into the system to determine
potential illicit discharge issues and future water quality monitoring sites.
In late 2009, the County began the process of developing an IDDE Guidance Manual (GM) that will define the procedures for locating, assessing, characterizing, tracing and
ending illicit discharges, as per Section S5.B.3.c. of the Permit. The GM will also aid in
guiding field assessments on three high priority water bodies (Spokane River, Little
Spokane River and Liberty Lake). The IDDE Guidance Manual has been completed in
2010 and has been shared with other Eastern Washington Phase II Permittees.
Figure 6. Motor Oil Entering Storm Drain in Parking Lot
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6.2 Illicit Discharge Data and Mapping
The County will develop MS4 maps showing the following: all known and new
connections; all known outfalls; the names and locations of all waters of the state that
receive discharges from those outfalls; and areas served by discharges to the ground.
The illicit discharge related maps are described and included in Section 3, Stormwater
Baseline Data and Maps.
6.3 Non-Stormwater Discharges
Spokane County Code, Chapter 9.14.215, Roads, Approach, and Drainage in New
Construction, Discharge of Unauthorized Waters - Prohibited, historically prohibited the
discharge of unauthorized waters onto County property or rights-of-way. Unauthorized
waters include, but are not limited to groundwater, surface water containing sediment, discharges from swimming pools, hot tubs, detention or evaporation ponds, water
discharged from the cleaning of containers or equipment used in laying, cutting or
processing concrete and mortar, and water discharged from the cleaning of equipment or
containers holding paint solvents or similar contaminants. The Code also requires control
of pollutants on construction sites in a manner that does not cause contamination of stormwater or groundwater.
Also, Spokane County non-stormwater discharges are described in Spokane County
Code, Section 9.14.185, Erosion and Sediment Control as well as in the Spokane
Regional Stormwater Manual.
However, Chapter 9.14 falls short of meeting the illicit discharge requirements mandated
under the IDDE component of the Permit. Therefore, the County went through an
extensive public review process, and adopted code revisions to Chapter 9.14.215, that
address all IDDE Permit requirements. This code amendment (Resolution 09-0672) was formally adopted by the Spokane County Commissioners on July 21, 2009.
In addition, Spokane County Code, Title 8, Health and Sanitation Code, Chapter 8.03,
Sanitary Sewer Code, includes various sections that address illicit discharges within
Spokane County’s municipal separate storm sewer system (MS4). See Section 2.2, Existing Legal Authority, for a detailed list of primarily relevant sections.
6.4 Visual Inspection Program Elements
Municipal separate storm sewer systems (MS4s) is periodically inspected for evidence of non-stormwater discharges by visually observing open channel sections.
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Emphasis will be on those areas that, based on the results of visual inspections or other
appropriate information, indicate a reasonable potential of containing illicit discharges,
infiltration from the sanitary sewer system, or other sources of non-stormwater discharges. Inspections will be performed by Stormwater Utility staff who will work
with landowners to correct the problems.
Municipal maintenance staff for streets and storm drains within Spokane County will be
trained to look for evidence of non-stormwater discharges to the drainage system during their normal duties. A process for reporting potential problems will included with the
existing Hotline and Request for Investigation processes currently utilized by the County.
6.5 Spill Prevention and Response Program Elements
Hazardous spill prevention and response programs and procedures are in place through
the fire department, emergency management and/or contracts with special emergency
response contractors. These programs and procedures are designed to addresses safe
storage, handling, containment and cleanup of hazardous substances that have the
potential to contaminate surface or ground water.
6.6 Public Reporting Program Elements
Public reporting of illicit discharges or other water quality problems is currently available
through the following avenues:
(a) stormwater Hotline;
(b) calls to Spokane County Public Works;
(c) emails via Spokane County website;
(d) calls to Spokane County Health District; (e) calls directly to the Department of Ecology.
Spokane County added an IDDE “hotline” (509-477-7525) in February of 2009 and
developed a process to following up on calls. We also developed a public informational
mail insert describing the hotline. 6.7 Hazardous Waste Disposal Program Elements
The Spokane Regional Solid Waste System (System) was created by an Interlocal
Agreement between Spokane County and the City of Spokane on October 11, 1988. All ten of the existing regional cities and towns, as well as Fairchild Air Force Base,
subsequently joined the System by executing inter-local agreements with the City and
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County of Spokane. In 2003, the newly incorporated cities of Liberty Lake and Spokane
Valley also executed inter-local agreements and joined the System.
The System operates as a department of the City of Spokane’s government and manages
solid waste facilities and contracts for the benefit of all citizens residing in Spokane
County. The concurrence of the County is required for certain major decisions. A
Liaison Board was established by interlocal agreement in 1987. The Board's purpose is
to recommend policy and provide direction on matters pertaining to the management of solid waste and related environmental issues in the incorporated and unincorporated areas
throughout Spokane County. Areas of responsibility include recycling/waste reduction,
composting, solid waste disposal, household hazardous waste and litter programs. The
Liaison Board is also responsible for monitoring capital assets and recommending capital
improvements of the System.
Spokane County will work with the System to gather information and assist in evaluating
existing household hazardous waste pollution prevention measures.
Spokane County Code, Title 8, Health and Sanitation Code, Chapter 8.26, Litter and
Discriminate Dumping, Litter in General, addresses the disposition of litter upon any public place or private property, or within any waters in Spokane County. See Section
2.2, Existing Legal Authority, for additional details.
6.8 High Priority Water Body Assessment
In 2010, the County conducted field assessments in an effort to find unknown illicit
discharges on three (3) high priority water bodies, including; portions of the Spokane River, Silver Lake and Liberty Lake.
In 2011, the County conducted field assessments in an effort to find unknown illicit
discharges on sections of the Little Spokane River from Colbert Road to the Riverside
State Park river access point near St. George School. See attached, 2010-2012 Compliance Actions Primary Water Body Inspections for updated details.
Each year the County will conduct a field assessment on one additional high priority
water body.
6.9 Priorities and Measurable Goals
In addition to the on-going activities of dry weather monitoring and field inspections, the first priority will be to identify existing inspection programs that are conducted by
maintenance staffs. This will be followed by development of training materials and
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execution of a training program for these staffs. These and other measurable goals are
defined below.
Completed by Measurable Goal/Milestone
End of Permit Year 1
(February 15, 2008) • Review existing local regulations related to discharge of
materials and non-stormwater to stormwater systems
End of Permit Year 2
(February 15, 2009) • Conduct periodic field inspections of open channels
• Evaluate existing practices of municipal maintenance staff
• Conduct public education and outreach as per Section 4
• Develop training materials for municipal maintenance
staff and the public
• Establish a citizen hotline by the end of February 2009
• Draft amendments to Spokane County Code to meet
permit requirements to prohibit illicit discharges by
August of 2009
End of Permit Year 3
(February 15, 2010) • Conduct periodic field inspections of MS4
• Evaluate existing practices of municipal maintenance staff
• Conduct public education and outreach
• Update training materials, as needed, for municipal maintenance staff and the public
• Revise Spokane County Code (Chapter 9.14) to include
IDDE components per the Permit
End of Permit Year 4
(February 15, 2011) • Evaluation of existing non-stormwater related local and
state laws
• Conduct periodic field inspections of MS4
• Evaluate existing practices of municipal maintenance
staff
• Conduct public education and outreach as per Section 5
• Conduct training, as needed, for municipal maintenance
staff and the public
• Develop a IDDE Guidance Manual to direct field personnel on inventory procedures and field inspections
• Conduct field inspections on three primary water bodies
(Spokane River, Silver Lake, Liberty Lake)
End of Permit Year 5
(February 15, 2012) • Conduct dry weather assessments per Section 4
• Conduct semi-annual field inspections of open channels
• Evaluate existing practices of municipal maintenance
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staff
• Evaluate regional maintenance facilities
• Conduct a field inspection of a high priority water bodies
(Spokane River, Liberty Lake, Little Spokane River)
• Continue refining training of field crews
End of Permit Year 6
(February 15, 2013) • Continue implementing previous year Permit requirements
6.10 Staffing and Funding
Staffing and funding for the illicit discharge and elimination system program elements
shall be provided by Spokane County, with assistance from Ecology where available.
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SECTION 7 – CONSTRUCTION SITE STORMWATER RUNOFF
CONTROL
7.1 Introduction
Currently, Spokane County has included
within the site plan review permitting
process for new construction notification
to applicants regarding the criteria and
potential need for coverage under Ecology’s NPDES Construction Permit.
This section describes the construction
site engineering design standards and
best management practice (BMP)
program required by S5.B.4 of the municipal permit. Construction activity
has been singled out by EPA as a
potential source of pollutants that require
special permitting attention.
Also, within the development review process the public is advised that proposed
development projects need to comply with the standards described within the Spokane
Regional Stormwater Manual (SRSM), including the erosion and sediment control plan
requirements during construction.
The proposed program includes activities intended to provide guidance to public and
private groups in Spokane County regarding appropriate construction practices, as well as
activities intended to support Ecology in implementing its construction permitting
program.
7.2 NPDES Construction Stormwater Permit - Ecology Any construction projects disturbing one (1) acre or more of ground, or construction
projects of less than one acre that are part of a common plan of development or sale shall
receive a NPDES Construction Stormwater Permit from Ecology prior to beginning any construction activities.
Figure 7. Construction Site Stormwater Runoff
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7.3 Spokane Regional Stormwater Manual
In 1980, Spokane County Commissioners approved Resolution No. 80-1592, which included the Guidelines for Stormwater Management (GSM). The GSM was prepared to
provide engineers and developers information regarding drainage requirements for land
development in Spokane County. This document has been amended over the years to
include updates such as the adoption of an “Erosion and Sediment Control” section in
April of 1998.
The GSM was replaced by the Spokane Regional Stormwater Manual (SRSM), adopted
by the Board of County Commissioners in June of 2008. The SRSM has been accepted
by Ecology as being equivalent to the Stormwater Management Manual for Eastern
Washington (SWMM).
The SRSM establishes standards for stormwater design and management to protect water
quality, natural drainage systems and downstream/down gradient properties as urban
development occurs. The purpose of the SRSM is not only to protect surface and ground
water quality but also to control stormwater runoff and reduce adverse impacts from flooding.
The SRSM describes, or references recommended design criteria for BMPs that will be
applied to new development and redevelopment. The BMPs include criteria for wetlands,
bio-infiltration swales, bio-filtration channels, oil-water separators, emerging technologies, etc.
7.4 Erosion and Sediment Control Plan - General Requirements
In Spokane County, under the SRSM, the Erosion and Sediment Control Plan (ESC Plan) is equivalent (as approved by Ecology) to the Construction Stormwater Pollution
Prevention Plan (SWPPP), referenced as in Appendix 1 of the Permit. An ESC Plan shall
be submitted with each proposed application for development that is proposing to disturb
more than one acre of land, as required within the municipal permit, and for projects of
less than one acre that are part of a common plan of development or sale, as required within the municipal permit.
When required, a proposed development shall submit an ESC Plan in accordance with the
erosion and sediment control plan requirements described within the SRSM at the time of
application to Spokane County.
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7.5 Developer Notification Program Elements
When a landowner or developer applies for a land action approval (subdivision, etc.) from the County, the applicant is notified of the need to prepare a drainage plan that
meets local and state requirements prior to the actual development of the property.
Public notification of “construction program elements” will also be part of the public
education and outreach efforts described in Section 4. 7.6 Construction Site BMP Elements
Existing construction site engineering design standards and BMPs are described within
the Stormwater Management Manual for Eastern Washington and the Spokane Regional Stormwater Manual. Practices recommended for Spokane County are described in detail within these manuals. As current construction practices evolve, BMP designs in one or more of these manuals are likely to be modified and updated.
In addition, the following chapters of the Spokane County Code include provisions
focusing on stormwater related planning, design, construction and maintenance: 1) Chapter 9.14, Roads, Approach and Drainage in New Construction; 2), Chapter 12.400 Subdivisions; 3) Chapter 14.802.060, Parking Lot Location and Design.
If new or improved BMPs are developed and/or approved by Ecology and included
within the SWMM, those BMPs will be readily available in Spokane County due to the current language within the SRSM that adopts by reference those BMPs approved within the SWMM.
7.7 Contractor Education and Training Program Elements
Spokane County will support Ecology in conducting local construction site permit program workshops for developers, contractors and engineers. This will include
providing venues for workshops, handling local logistics, assisting with advertising, and
providing staff to assist with workshop activities. Informational links will be provided
via the Spokane County website regarding Ecology (or other organization) sponsored training opportunities for contractors.
Existing printed outreach and education materials for the construction site management
program will be reviewed and evaluated.
Printed outreach and education materials for the construction site management program will be distributed with assistance from Ecology and the EPA. Possible examples include
Construction Site Permit Program, How to Prepare an Erosion and Sediment Control
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Plan (Stormwater Pollution Prevention Plan), and Proper Selection and Installation of
Construction Site BMPs. Printed materials will be distributed to developers and
contractors during the land use application process, and will also be available to Ecology and Spokane County staff to distribute at construction sites during field visits.
Spokane County provides information to construction site operators through the SRSM,
the Planning/Permitting processes, brochures, publications, and on the web-page on
erosion and sediment control and BMP requirements for development and redevelopment.
7.8 Employee Education and Training Program Elements
Relevant Spokane County staff will receive training on stormwater pollution prevention construction procedures to minimize stormwater pollution from Spokane County
construction activities. Training will be focused to be specific to the various
departments’ operations and functions. “Refresher” training will be provided to County
staff as requested or as needed. See Sections 9.4.1 and 9.4.2 for details about additional
employee construction training activities.
Information for construction site operators about Certified Erosion and Sediment Control
Lead (CESCL) training is displayed in an interactive calendar on the Spokane County
webpage. The CESCL training covers erosion and sediment control topics such as;
BMPs, how to install and maintain erosion and sediment controls, and how to meet related Ecology requirements.
7.9 Priorities and Measurable Goals
Existing laws, programs and procedures will be reviewed and evaluated.
All of the program set-up activities occurred in permit year 1. The first priority achieved
in year 2 was the adoption of the Spokane Regional Stormwater Manual (SRSM). The
SRSM provides the regulatory mechanism to require erosion and sediment controls, and
other construction phase stormwater pollution controls at new development and redevelopment projects.
Other measurable goals are defined below.
Completed by Measurable Goal/Milestone
End of Permit Year 1
(February 15, 2008) • Review existing laws, programs and procedures
• Develop the Spokane Regional Stormwater Manual, in
coordination with City of Spokane and the City of
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Spokane Valley
• Provide information to construction site operators on training in methods for erosion and sediment control.
End of Permit Year 2
(February 15, 2009) • Review existing stormwater facility construction
inspection procedures
• Complete the public review process and final adoption of
the “Spokane Regional Stormwater Manual”
• If required, begin drafting regulations to implement
construction permit requirements by February 2010
• Include construction permitting information in public/design professional education and outreach efforts
End of Permit Year 3
(February 15, 2010) • If necessary, refine plan/process for conducting construction inspections and enforcement
• Review BMP publication documents
• If required, draft and adopt regulations to implement
construction permit requirements by February 2010
• Include construction permitting information in
public/design professional education and outreach efforts
End of Permit Year 4
(February 15, 2011) • Enhance and improve the data base for construction
permits and inspections
• Include construction permitting information in public/design professional education and outreach efforts
• Complete the development of the process for conducting
construction inspections and enforcement
• Begin developing a record keeping system for construction and post construction inspections
End of Permit Year 5 (February 15, 2012) • Continue to refine and improve construction inspection process
• Continue to notify and educate the development
community
• Continue refining record keeping
• Continue construction inspections
• Continue training activities
End of Permit Year 6
(February 15, 2013) • Continue implementing previous year Permit
requirements
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7.10 Staffing and Funding
Spokane County, in coordination with Ecology, will be responsible for preparation of materials and the development of a process for notifying the public, developers and
design professionals of construction permitting, inspection and compliance requirements.
The Spokane County departments involved with construction permitting and inspection
will keep a record of all relevant data, documentation and information.
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SECTION 8 – POST-CONSTRUCTION STORMWATER MANAGEMENT FOR NEW DEVELOPMENT AND REDEVELOPMENT
8.1 Introduction
This section describes the post-
construction stormwater management for new development and redevelopment programs required by S5.B.5 of the
municipal permit.
Post-construction activity has been singled out by EPA as a potential source of pollutants that require special
permitting attention. The proposed
program includes activities intended to
provide for the long term inspection, maintenance and management of
stormwater facilities.
8.2 Post Construction General Requirements
The Spokane Regional Stormwater Manual (SRSM) requires the ESC Plan (described
within section 7) to include post-construction review, inspection and compliance. The
ESC Plan is required to be submitted with each proposed application for new
development or redevelopment that is proposing to disturb more than one acre of land, and from projects of less than one acre that are part of a common plan of development or
sale, as required within the Permit.
Post-construction review, inspection, and compliance requirements are described within
the following chapters of the Spokane County Code: 1) Chapter 9.14, Roads, Approach and Drainage in New Construction; 2), Chapter 12.400 Subdivisions.
Figure 8. Post Construction Stormwater Drainage Problem
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8.3 Post-Construction Notification Program Elements
Public notification of “post-construction program elements” shall be made a part of the public education and outreach efforts described in Section 4.
8.4 Post-Construction Site Inspection Program Elements
The County is currently reviewing all new construction projects located within the Permit jurisdictional boundary within the site plan review process.
The County shall work with Ecology to develop a database of “state permitted”
construction sites within the Permit jurisdictional area. The database, combined with
Spokane County construction project information and other tools will be used to identify areas of recent construction projects and to track adverse impacts to surface waters from
the projects after completion.
8.5 Education and Training Program Elements
When possible, Spokane County will work with Ecology and other jurisdictions to
conduct post-construction inspection training for County personnel. This will include
providing venues for workshops, handling local logistics, assisting with advertising, and
providing staff to assist with training activities.
Spokane County provides information to construction site operators through the SRSM,
the Planning/Permitting processes, brochures, publications, and on the web-page on
erosion and sediment control and BMP requirements for development and
redevelopment.
8.6 Priorities and Measurable Goals
All of the program set-up activities are given high priority and scheduled in Permit Year
1. The contractor education and training program shall take place throughout the permit
cycle. Other measurable goals are defined below.
Completed by Measurable Goal/Milestone
End of Permit Year 1
(February 15, 2008) • Review current laws relative to post-construction review,
inspection and compliance
• Evaluate and develop procedure for including site plan
review of all construction projects within the Permit
boundary
End of Permit Year 2 • Begin evaluating post-construction procedures
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(February 15, 2009) • Include post-construction information in public/design professional education and outreach efforts
• Work with Ecology to develop a database of current
"NPDES General Permit" construction sites within the
Permit boundary
• Review process for post-construction inspections
• Complete formal adoption of the “Spokane Regional
Stormwater Manual”
• If necessary, begin drafting regulations for policy and public review by the end of Permit Year 3
• Complete including in the site plan review process,
review of all construction projects located within the Permit boundary
End of Permit Year 3
(February 15, 2010) • Begin developing post-construction review, inspection, compliance procedures and if necessary ordinance
revisions
• Enhance and improve the current database for Ecology
NPDES General Permitted construction sites
• Continue with post-construction information in public education and outreach efforts
End of Permit Year 4 (February 15, 2011) • Continue improving the Permit databases and processes
• Finalize post-construction review, inspection,
compliance procedures and if necessary ordinance
revisions
• Post-construction information to the public
• Begin evaluating and developing staff training materials
• Evaluate record keeping process
• Evaluate inspection process
End of Permit Year 5 (February 15, 2012) • Enhance record keeping process
• Enhance inspection practices and procedures
• Develop and implement training programs
• Evaluate existing policy that promotes the maintenance of natural drainage systems
End of Permit Year 6 (February 15, 2013) • Continue implementing previous year Permit
requirements
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8.7 Staffing and Funding
Spokane County will work with Ecology in the preparation of materials and development of a process for notifying the public, developers and design professionals of post-
construction review, inspection and compliance requirements.
The various Spokane County departments involved in compliance with the Permit will
provide relevant data, documentation and information to the Spokane County and Ecology Phase II Permit coordinators necessary to support the successful implementation
of this section of the SWMP.
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SECTION 9 – POLLUTION PREVENTION AND GOOD
HOUSEKEEPING FOR MUNICIPAL OPERATIONS
9.1 Introduction In coordination with multiple
departments, Spokane County has
developed a Stormwater Operations and
Maintenance Plan (O&M Plan). This section describes the various pollution
control, good housekeeping, BMPs and
source control measures that will be
applied to existing and new public
facilities, and operations to mitigate the effects of urbanization on stormwater
quality. These practices and measures
address the miscellaneous requirements
described in special provision S5.B.6 of
the municipal permit.
Specific activities and programs were selected because of their link to existing County
activities (e.g., for street and stormwater system maintenance) and their relevance to the
Spokane County environment. Emphasis is on enhancing and documenting existing
programs and activities.
Many County operations already meet the requirements under the Permit. Therefore, the
SWMP for “Good Housekeeping” will primarily be a documentation of existing activities
and recommendation/implementation of necessary modifications to reduce pollutants to
surface and ground water. The Stormwater Operations and Maintenance Plan is available at the office of Engineering & Roads, Stormwater Utility.
9.2 Municipal Stormwater Facilities and Programs
Public stormwater facilities in unincorporated Spokane County fall into three general categories: (1) regional stormwater facilities; (2) facilities that mainly handle road runoff;
and (3) on-site stormwater facilities at county owned parks, maintenance shops, county
buildings, parking lots, etc. In several cases, county road crews also maintain stormwater
facilities serving a specific development using funds from the owners of the parcels of
land within the area served.
Figure 9. County Crews Cleaning Storm Drain
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In addition, many new developments install on-site stormwater facilities that are owned
and maintained privately. For residential developments this may mean that a
homeowners association is responsible for maintenance of all stormwater facilities in the neighborhood. For commercial and private industrial facilities, the landowner or operator
of the establishment on the site operates and maintains the stormwater facilities.
Spokane County will review the following Public Works O&M activities and document
the activities in relation to complying with the Permit. 9.2.1 Regional Stormwater Facilities
On January 17, 2006, the Board of County Commissioners adopted the Comprehensive Stormwater Management Plan (CSWMP) along with individual stormwater plans for Glenrose, North Spokane and West Plains and their
associated Capital Improvement Plans. Each of the individual basin plans
emphasizes protecting natural drainage features as the most cost effective means
of handling stormwater over the long term.
The Stormwater Utility has constructed or participated in the funding to construct
regional stormwater facilities and has purchased or is planning to purchase parcels
of land for stormwater facilities. Two regional stormwater facilities were
constructed in 2008. Regional stormwater facilities are generally maintained by
the Stormwater Utility, County road maintenance, private landscape maintenance contractors and at times, County Parks crews.
Existing maintenance plans for regional stormwater facilities will be reviewed for
consistency with the Permit and UIC requirements. As maintenance plans are
developed for the new regional facilities, they will comply with Permit and UIC requirements.
9.2.2 Roadway Stormwater Facilities
Stormwater facilities in the county road rights-of-way are maintained by crews from the County Engineering and Roads Maintenance Section. Generally, curbs
and gutters, culverts and ditches alongside County roads make up a large portion
of the MS4. Stormwater Utility staff will work with maintenance section
employees to develop the inventory of facilities and potential outfalls to surface
waters and a program of preventative or proactive maintenance. Topics to be
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addressed include appropriate frequencies for cleaning catch basins, inlets and
storm drains and appropriate ditch cleaning methods and frequencies.
Staff has examined current street sweeping and dust control practices and have
determined that current practices are meeting Permit guidelines. All County
streets are cleaned once in the Spring and once in the Fall of each year. In
addition, spot street cleaning operations are conducted primarily based on field
inspections or in response to public complaints. In addition, Spokane County has placed GPS units on all street sweepers to provide documentation of sweeping
activities, as well as provide the public an opportunity to view street sweeping
progress.
The County also constructs new roads and improves existing roads. Stormwater staff will work with the Engineering and Roads - Design Section regarding
compliance with the Spokane Regional Stormwater Manual (SRSM).
Stormwater staff is also working with the Maintenance Section on common
procedures for tracking and reporting stormwater facility maintenance activities. This will include standardization of the data that will be collected, and how it will
be reported.
9.2.3 Stormwater Facilities at Parks and Other County Owned Properties
Stormwater Utility staff will work with the Parks and Golf Courses, Fair and
Expo, Utilities, Human Resources, Sherriff, and Facilities Maintenance
Departments and with maintenance supervisors at the county shops within the
Permit boundary to review site management practices. Staff will review site
operations, the use of herbicides, pesticides and other chemicals, the disposal of vactor wastes and the treatment and disposal of stormwater from the various sites.
Existing maintenance plans will be reviewed and updated as necessary.
9.2.3.1 Parks and Open Spaces Stormwater Utility staff will interview Parks staff and discuss current
landscaping and maintenance practices. Staff will review any water
quality data collected by Parks personnel. Staff will also discuss current
training opportunities for Parks staff about proper storage, handling and
application of pesticides, herbicides and fertilizers and whether additional training is warranted.
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Spokane County communities are implementing water conservation plans
that have guidelines and ordinances addressing outdoor landscape
irrigation. The plans are aimed at reducing water waste resulting from
over watering. This will also reduce the contribution of pesticides, herbicides and fertilizers to downstream receiving waters.
Spokane County currently operates three golf courses; Meadow Wood
Golf Course and Liberty Lake Golf Course are located within the City of
Liberty Lake, which are outside of the county's Permit boundary.
The Hangman Valley Golf Course is located within the jurisdiction of
Spokane County, however, it is located approximately 3 miles south of the
Permit boundary.
9.2.3.2 Vehicle Fleets, Heavy Equipment Storage Areas, Maintenance Areas
Appropriate frequencies and practices will be reviewed and where
necessary improvements implemented for cleaning, washing, painting and other maintenance activities related to County vehicles, equipment, heavy
equipment and maintenance/repair areas.
The County shall conduct all vehicle and equipment washing, maintenance
and repair in a self-contained covered building or in a designated wash and/or maintenance and repair area operated to separate wash-water
contaminants from discharging to the MS4.
Spokane County has developed a Stormwater Pollution Prevention Plan
(SWPPP) for all vehicle fleets, heavy equipment storage areas, and maintenance areas. The SWPPP is on file at each maintenance or repair
shop.
9.2.3.3 Municipal Buildings
Stormwater Utility staff will work with County Facilities Maintenance
staff to learn about current frequencies and practices for cleaning,
washing, painting and other maintenance activities related to County
owned, operated or maintained buildings.
The staff will discuss any concerns and the need for additional training
regarding pollution prevention and good housekeeping practices for all
County owned, operated or maintained buildings.
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9.2.3.4 Material Storage
All hazardous material storage areas shall be contained within a secure structure, in accordance with all applicable local, state and federal codes
(i.e. Building and Fire Codes, OSHA Regulations, State of Washington,
etc.). Hazardous material handling procedures and practices are currently
being implemented.
All non-hazardous materials shall be stored in secure areas where the
potential for stormwater pollution or contamination are minimal. Material
storage is addressed within the SWPPP at all vehicle fleets, heavy
equipment storage areas, maintenance areas.
9.2.3.5 Industrial Activities and Other Public Facilities The following publicly owned industrial facilities in Spokane County will
be identified using best available information:
(a) Municipal landfills;
(b) Public hazardous waste treatment, disposal and recovery facilities;
(c) Public industrial facilities that could contribute a substantial
pollutant load to the municipal storm sewer system.
Public facilities identified above will be shown on a GIS map. Current
permit requirements and available information about onsite BMPs will be
identified.
At this time, no public industrial facilities have been identified that require coverage under the Permit.
9.3 Construction Projects
See Spokane Regional Stormwater Manual (SRSM) for details regarding engineering design standards, including BMPs relevant to construction projects. Spokane County will
comply with the applicable construction standards relating to stormwater pollution
control.
9.4 Spokane County Employee Education and Training
Relevant Spokane County staff will be periodically trained on operation and maintenance
procedures to minimize stormwater pollution from operations and maintenance activities.
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Training will be focused to be specific to the various departments operations and
functions. “Refresher” training will be provided to County staff as requested or as
needed.
9.4.1 Objectives for Spokane County Employee Education and Training
The overall objectives of the Employee Education and Training Program are to:
(a) Inform the employee about important water quality issues, regulations, BMPs,
and other construction practices related to stormwater management;
(b) Influence behavior of the employee to reduce activities that have a negative
impact on stormwater runoff quality and increase activities that have a
positive impact on stormwater runoff quality.
9.4.2 Employee Education and Training Activities
The following activities will be part of the employee education and training
program.
(a) Training Events. County, in coordination with Ecology, will use training
events for employees that focus on stormwater pollution awareness,
stormwater construction practices, pollution prevention practices and regional
stormwater issues. (b) Printed Materials. County will continue to develop, produce or distribute
printed materials (e.g., brochures, flyers, promotional items) for specific
topics related to stormwater quality. Older printed materials will be updated
as necessary.
(c) Website. County will continue to enhance, maintain and update the “stormwater” section of the existing Spokane County webpage, to provide
information to employees on stormwater pollution potential sources and
pollution prevention practices, Spokane County water quality issues, BMPs,
and links to other related websites.
(d) Construction Program. County will conduct education and training activities targeting County employee construction and maintenance personnel.
9.5 Priorities and Measurable Goals
The first priority is to evaluate pollution prevention and good housekeeping areas of interest within the Permit jurisdiction.
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The second priority is to determine and evaluate existing tracking/reporting procedures
within the various County departments in order to establish needs and goals for the
following years.
These and other measurable goals are listed below.
Completed by Measurable Goal/Milestone
End of Permit Year 1 (February 15, 2008) • Begin reviewing pollution prevention and good housekeeping areas of interest within the Permit jurisdiction
End of Permit Year 2 (February 15, 2009) • Review the availability of information on cleaning catch basins, inlets and storm drains
• Review existing available information for tracking and
reporting storm drain system maintenance
• Review existing available information on street sweeping and dust control
• Review existing available information on pesticide,
herbicide and fertilizer monitoring data and existing management procedures
• Review existing available information on vehicle fleet and
heavy equipment maintenance/repair procedures
• Review existing available information on hazardous material storage
• Begin determining where employee training may be needed
End of Permit Year 3
(February 15, 2010) • Evaluate a reporting program for the various items activities
listed in years 2 and 3
• Begin developing a database to track various activities listed in years 2 and 3
• Conduct employee training as determined in Years 2 and 3
• Continue reviewing the availability of information on
cleaning catch basins, inlets and storm drains
• Continue reviewing available information for tracking and
reporting storm drain system maintenance
• Continue reviewing available information on street sweeping and dust control
• Continue reviewing available information on pesticide,
herbicide and fertilizer monitoring data and existing
management procedures
• Continue reviewing available information on vehicle fleet and heavy equipment maintenance/repair procedures
• Continue reviewing available information on hazardous
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material storage
• Evaluate future training needs
End of Permit Year 4 (February 15, 2011) • Continue to develop a reporting program for the various activities listed in years 2 and 3
• Begin developing a database to track various activities listed
in years 2 and 3
• Conduct employee training as needed
• Evaluate future training needs
• Complete the development of the O&M Plan
End of Permit Year 5
(February 15, 2012) • Complete reporting program development for the various
O&M activities
• Update files for various activities
• Conduct employee training
• Evaluate future training needs
• Evaluate and update the O&M Plan as needed
End of Permit Year 6 (February 15, 2013) • Vehicle Fleets, Heavy Equipment Storage Areas, Maintenance Areas
9.6 Staffing and Funding
The evaluation of existing procedures and practices relating to pollution prevention and
good housekeeping measures will be funded by Spokane County. Staffing will also be provided by Spokane County.
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SECTION 10 – SWMP IMPLEMENTATION RESPONSIBILITIES
10.1 Introduction This section describes how the
responsibilities for implementing the
adopted SWMP programs will be shared among the various Spokane County entities.
This section is in compliance with
the Eastern Washington Phase II Municipal Stormwater Permit, special provision S5.A and S5.B,
which requires an implementation
strategy within the Stormwater
Management Program (SWMP). 10.2 Implementation Responsibilities
In general, Spokane County provides overall program oversight, funding and staffing for
activities that are described within the SWMP. Responsibility for implementing the various elements of the SWMP will be primarily by
various Spokane County entities as described below:
Public Works, Engineering and Roads – Development Services, Stormwater Utility, Fleet Management and Road Maintenance Sections
Building and Planning
Public Works, Utilities Parks, Recreation and Golf Department
Facilities
Human Resources
Figure 10: Residential Grassy Swale
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Fair & Expo Center
The State of Washington, Department of Ecology will provide various services in support of the SWMP.
The various Spokane County entities shall coordinate through the Stormwater O&M
Plan.
10.3 Implementation in New Areas
The programs outlined in this SWMP will be applied to Spokane County areas described
as United States Census classified urbanized areas, Urban Growth Areas (UGA)
associated with Phase II Permit regulated cities under the jurisdictional control of the County, and UGA areas contiguous to urbanized areas (see Spokane County -
Comprehensive Plan for UGA details) that are under the jurisdictional control of the
County, as required by Section S1.A.2. Those areas that become urbanized or are
included in an UGA area during the period of the current municipal permit will be
documented and included within the next subsequent Phase II Municipal Stormwater Permit cycle.
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SECTION 11 – MEASURABLE GOALS
11.1 Year 1 Goals This section summarizes the measurable goals proposed in the previous sections for years
1, 2, 3 and 4 of the five year Permit cycle. Many activities are proposed from year to
year establish a foundation for public education and outreach, public involvement, IDDE,
construction, post-construction programs, and operations and maintenance. Year 1 measurable goals are summarized in the following table.
Program Category Measurable Goal/Milestone
Section 2: Legal Authority • Begin to Assemble and summarize existing legal authority
Section 3: Stormwater
System Map • Begin preparing MS4 base maps
Section 4: Public
Education and Outreach • Begin reviewing public outreach and education opportunities
with various departments and jurisdictions
Section 5: Public
Involvement and Participation
• Begin reviewing public involvement and participation opportunities with various departments and jurisdictions
Section 6: Illicit
Discharge Detection and Elimination Program
• Review existing local regulations related to discharge of materials and non-stormwater to stormwater systems
Section 7: Construction Site Stormwater Control
Program
• Review existing laws, programs and procedures
• Develop the Spokane Regional Stormwater Manual, in
coordination with City of Spokane and the City of Spokane
Valley
• Provide information to construction site operators on training in methods for erosion and sediment control
Section 8: Post Construction
Management for New
Development and
Redevelopment
• Review current laws relative to post-construction review, inspection and compliance
• Evaluate and develop procedure for including site plan review
of all construction projects within the Permit boundary
Section 9: Pollution
Prevention and Good
Housekeeping for Municipal Operations
• Begin reviewing pollution prevention and good housekeeping
areas of interest within the Permit jurisdiction
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11.2 Year 2 Goals
This section summarizes the measurable goals proposed in the previous sections for year
2 of the five year Permit. Many activities proposed for year 2 will build and expand on year 1 goals.
Year 2 measurable goals are summarized in the following table.
Program Category Measurable Goal/Milestone
Section 2: Legal Authority • Develop a plan for addressing deficiencies in current legal
authority
• Begin developing policy and code revisions in legal authority
Section 3: Stormwater
System Map • Continue Developing the MS4 base maps
• Begin evaluation of existing stormwater infrastructure, facilities and properties
Section 4: Public Education and Outreach • Coordinate public outreach and education with various departments and jurisdictions
Section 5: Public
Involvement and Participation
• Coordinate public involvement and participation with various departments and jurisdictions
• Post SWMP on the Spokane County web-site by May 31,
2008
Section 6: Illicit
Discharge Detection and
Elimination Program
• Conduct periodic field inspections of open channels
• Evaluate existing practices of municipal maintenance staffs
• Conduct public education and outreach as per Section 4
• Develop training materials for municipal maintenance staff
and the public
• Establish a citizen hotline by the end of February 2009
• Draft amendments to Spokane County Code to meet permit
requirements to prohibit illicit discharges by August of 2009
Section 7: Construction
Site Stormwater Control
Program
• Review existing stormwater facility construction inspection
procedures
• Complete the public review process and final adoption of the “Spokane Regional Stormwater Manual”
• If required, begin drafting regulations to implement
construction permit requirements by February of 2010
• Include construction permitting information in public/design professional education and outreach efforts
Section 8: Post Construction • Begin evaluating post-construction procedures
• Include post-construction information in public/design
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Management for New Development and Redevelopment
professional education and outreach efforts
• Work with Ecology to develop a database of current "Ecology - NPDES General Permit" construction sites within the Permit
boundary
• Review process for post-construction inspections
• Complete formal adoption of the “Spokane Regional
Stormwater Manual”
• If necessary, begin drafting regulations for policy and public
review by the end of Permit Year 3
• Complete including in the site plan review process, review of
all construction projects located within the Permit boundary
Section 9: Pollution
Prevention and Good
Housekeeping for
Municipal Operations
• Review the availability of information on cleaning catch
basins, inlets and storm drains
• Review existing available information for tracking and reporting storm drain system maintenance
• Review existing available information on street sweeping and
dust control
• Review existing available information on pesticide, herbicide and fertilizer monitoring data and existing management
procedures
• Review existing available information on vehicle fleet and
heavy equipment maintenance/repair procedures
• Review existing available information on hazardous material
storage
• Begin determining where employee training may be needed
11.3 Year 3 Goals
This section summarizes the measurable goals proposed in the previous sections for year
3 of the five year Permit. Many activities proposed for year 3 will build and expand on
years 1 and 2 goals.
Year 3 measurable goals are summarized in the following table.
Program Category Measurable Goal/Milestone
Section 2: Legal
Authority • Complete implementing policy and code revisions relating to
illicit discharge (September 1, 2009)
• If necessary, revise existing codes relating to construction and post construction
Section 3: Stormwater
System Map • Update stormwater GIS data layers and maps
• Complete the analysis and development of the MS4 outfall
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coverage from 2008 field investigations
Section 4: Public
Education and Outreach • Coordinate public outreach and education with various
departments and jurisdictions
Section 5: Public
Involvement and
Participation
• Coordinate public involvement and participation with various
departments and jurisdictions
• Post updated SWMP on the Spokane County web-site by May
31, 2009
Section 6: Illicit
Discharge Detection and
Elimination Program
• Conduct periodic field inspections of MS4
• Evaluate existing practices of municipal maintenance staff
• Conduct public education and outreach
• Updated training materials, as needed, for municipal
maintenance staff and the public
• Revise Spokane County Code, Chapter 9.14, to include IDDE components per the Permit
Section 7: Construction
Site Stormwater Control Program
• If necessary, refine plan/process for conducting construction inspections and enforcement
• Review BMP publication documents
• If required, draft and adopt regulations to implement
construction permit requirements by February 2010
• Include construction permitting information in public/design
professional education and outreach efforts
Section 8: Post
Construction
Management for New
Development and
Redevelopment
• Begin reviewing developing post-construction review,
inspection, compliance procedures and if necessary ordinance
revisions
• Enhance and improve the current database for "Ecology - NPDES General Permit" construction sites
• Continue with post-construction information in public
education and outreach efforts
Section 9: Pollution
Prevention and Good
Housekeeping for Municipal Operations
• Evaluate a reporting program for the various items activities
listed in years 2 and 3
• Begin developing a database to track various activities listed in years 2 and 3
• Conduct employee training as determined in Years 2 and 3
• Continue reviewing the availability of information on cleaning catch basins, inlets and storm drains
• Continue reviewing available information for tracking and
reporting storm drain system maintenance
• Continue reviewing available information on street sweeping
and dust control
• Continue reviewing available information on pesticide,
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herbicide and fertilizer monitoring data and existing management procedures
• Continue reviewing available information on vehicle fleet and
heavy equipment maintenance/repair procedures
• Continue reviewing available information on hazardous material storage
• Evaluate future training needs
11.4 Year 4 Goals
This section summarizes the measurable goals proposed in the previous sections for year
4 of the five year Permit. Many activities proposed for year 4 will build and expand on years 1, 2 and 3 goals.
Year 4 measurable goals are summarized in the following table.
Program Category Measurable Goal/Milestone
Section 2: Legal
Authority • Continue evaluating construction and post construction codes
and procedures
Section 3: Stormwater
System Map • Gather data and develop infrastructure maps for all public
facilities and activities relating to the development of the
O&M Plan
• Conduct priority water body outfall field investigations and continue updating outfall database
• Update stormwater GIS coverages and maps
Section 4: Public
Education and Outreach • Coordinate public outreach and education with various
departments and jurisdictions
Section 5: Public
Involvement and
Participation
• Coordinate public involvement and participation with various
departments and jurisdictions
• Post updated SWMP on the Spokane County web-site by May 31, 2010
Section 6: Illicit Discharge Detection and
Elimination Program
• Evaluation of existing non-stormwater related local and state laws
• Conduct periodic field inspections of MS4
• Evaluate existing practices of municipal maintenance staff
• Conduct public education and outreach as per Section 5
• Conduct training, as needed, for municipal maintenance staff
and the public
• Develop a IDDE Guidance Manual to direct field personnel on inventory procedures and field inspections
• Conduct field inspections on three primary water bodies
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(Spokane River, Silver Lake, Liberty Lake)
Section 7: Construction
Site Stormwater Control
Program
• Enhance and improve the data base for construction permits
and inspections
• Include construction permitting information in public/design
professional education and outreach efforts
• Complete the development of the process for conducting
construction inspections and enforcement
• Begin developing a record keeping system for construction
and post construction inspections
Section 8: Post
Construction
Management for New
Development and
Redevelopment
• Continue improving the Permit databases and processes
• Finalize post-construction review, inspection, compliance
procedures and if necessary ordinance revisions
• Post Construction information to the public
• Begin evaluating and developing staff training materials
• Evaluate record keeping processes
• Evaluate inspection processes
Section 9: Pollution Prevention and Good
Housekeeping for
Municipal Operations
• Continue to develop a reporting program for the various items activities listed in years 2 and 3
• Begin developing a database to track various activities listed in
years 2 and 3
• Conduct employee training as needed
• Evaluate future training needs
• Complete the development of the Stormwater Operations and Maintenance Plan
11.5 Year 5 Goals
This section summarizes the measurable goals proposed in the previous sections for year
5 of the five year Permit. Many activities proposed for year 5 will build and expand on
years 1, 2, 3 and 4 goals.
Year 5 measurable goals are summarized in the following table.
Program Category Measurable Goal/Milestone
Section 2: Legal Authority • Monitor previous Code revisions.
Section 3: Stormwater
System Map • Update stormwater GIS coverage areas and maps
• Develop public facility site maps to accompany the
Stormwater O&M Plan site assessment analysis
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• Develop material storage, heavy equipment storage area and maintenance area maps for the Stormwater O&M Plan SWPP
• Conduct priority water body outfall field investigations and
continue updating outfall database
Section 4: Public
Education and Outreach • Coordinate public outreach and education with various
departments and jurisdictions
Section 5: Public
Involvement and
Participation
• Coordinate public involvement and participation with various
departments and jurisdictions
• Post updated SWMP on the Spokane County web-site by May 31, 2011
Section 6: Illicit Discharge Detection and
Elimination Program
• Conduct dry weather assessments per Section 4
• Conduct semi-annual field inspections of open channels
• Evaluate existing practices of municipal maintenance staff
• Evaluate regional maintenance facilities
• Conduct field inspection of a high priority water bodies
(Spokane River, Liberty Lake, Little Spokane River)
• Continue refining training of field crews
Section 7: Construction
Site Stormwater Control Program
• Continue to refine and improve construction inspection process
• Continue to work with notification and education of the
development community
• Continue refining record keeping
• Continue refining construction inspections
• Continue training activities
Section 8: Post
Construction
Management for New
Development and Redevelopment
• Enhance record keeping processes
• Enhance inspection practices and procedures
• Develop and implement training programs
• Evaluate existing policy that promotes the maintenance of
natural drainage systems
Section 9: Pollution
Prevention and Good
Housekeeping for Municipal Operations
• Continue to develop a reporting program for the various O&M
activities
• Begin developing a database to track various activities
• Conduct employee training
• Evaluate future training needs
• Complete the development of the Operations and Maintenance Plan
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11.6 Year 6 Goals
This section summarizes the measurable goals proposed in the previous sections for year 6 of the extended five year Permit. Year six will be a continuation of the implementation
of previous year Permit actions and requirements. See above sections for details.