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− | '''Could we submit a single report for all permittees in a given TMDL project area that share a categorical WLA?''' | + | <!--What follows is the guidance that was located on this page prior to 1/5/2023--> |
+ | <!--The following are some frequently asked questions on how to fill out the [[Upload page with TMDL forms|TMDL Annual Reporting form]] for Municipal Separate Storm Sewer System (MS4) permittees for the 2013 General Permit. Additional information on this reporting requirement is available [[Guidance for completing the TMDL reporting form|here]]. | ||
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+ | *'''Could we submit a single report for all permittees in a given TMDL project area that share a categorical WLA?''' | ||
Because the MS4 permit focuses on individually-owned MS4s, each permittee must report on their implementation activities separate from other permittees. If a single report exists that summarizes information for multiple permittees, a permittee can copy information concerning their MS4 from that report into the TMDL Annual Report form. | Because the MS4 permit focuses on individually-owned MS4s, each permittee must report on their implementation activities separate from other permittees. If a single report exists that summarizes information for multiple permittees, a permittee can copy information concerning their MS4 from that report into the TMDL Annual Report form. | ||
− | '''What if multiple MS4 permittees collaborate to implement BMPs? Can more than one MS4 claim Category 1 credit for a BMP?''' | + | *'''What if multiple MS4 permittees collaborate to implement BMPs? Can more than one MS4 claim Category 1 credit for a BMP?''' |
We encourage permittees to collaborate on BMPs when it results in more efficient stormwater management. It is for this reason that we developed different reporting categories. | We encourage permittees to collaborate on BMPs when it results in more efficient stormwater management. It is for this reason that we developed different reporting categories. | ||
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EXAMPLE<br /> | EXAMPLE<br /> | ||
− | Permittees in TMDL X study area (outlined in blue) have a categorical WLA of 40. | + | Permittees in TMDL X study area (outlined in blue) have a categorical WLA of 40 lbs/day (allowable load) and estimated existing loading to be 60 lbs/day. These four permittees collaborated to implement a BMP/s that reduce loading to 30 lbs/day. Since this BMP is located in City A’s jurisdiction and is reducing the pollutant discharged from their conveyance, they will claim a 30 lb reduction in Category 1. City B, C, and D will claim ‘1’ in Category 2. |
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+ | [[file:CatWLAExample.PNG|thumb|left|alt=catexample|Example]] | ||
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− | '''If multiple permittees work together to implement a BMP in my MS4 and the total pounds reduced by the BMP exceed the WLA, should I only claim enough pounds to meet the WLA?''' | + | *'''If multiple permittees work together to implement a BMP in my MS4 and the total pounds reduced by the BMP exceed the WLA required reduction, should I only claim enough pounds to meet the WLA?''' |
No. Claim the entire load reduction. We are interested in total pounds reduced by BMPs regardless of where those reductions are occurring. Other permittees will take Category 2 credits for the BMP. | No. Claim the entire load reduction. We are interested in total pounds reduced by BMPs regardless of where those reductions are occurring. Other permittees will take Category 2 credits for the BMP. | ||
− | '''How do I know when my WLA is met?''' | + | *'''How do I know when my WLA is met?''' |
The individual permittee makes this determination. The determination may be based on multiple criteria, such as estimates of load reductions that have been achieved; the number of BMPs implemented, water quality in the receiving water, and so on. When a permittee determines they are meeting their WLA, they may tell us in their SWPPP submittal. | The individual permittee makes this determination. The determination may be based on multiple criteria, such as estimates of load reductions that have been achieved; the number of BMPs implemented, water quality in the receiving water, and so on. When a permittee determines they are meeting their WLA, they may tell us in their SWPPP submittal. | ||
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+ | *'''How do I decide who “owns” a BMP for the BMP-activities tab (column L)?''' | ||
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+ | For the purposes of this reporting form: | ||
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+ | Any practice that reduces pollutants prior to your outfalls, from conveyance systems owned by YOU, is a practice that you “own” regardless of who paid for it and who maintains it. If a BMP has been installed within your jurisdictional boundary, it is most likely owned by you. Water leaving one MS4s jurisdiction should be viewed as leaving through an outfall. | ||
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+ | Coordinate with your local partners to create consistency in reporting. If you decide to claim ownership of a BMP this year, that will be your BMP to report in perpetuity. | ||
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+ | *'''Who should take category 1 vs category 2 credit on the Cumulative Reductions tab when there is a collaboration?''' | ||
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+ | The MPCA stormwater program views both types of credit equally in terms of making progress and permit compliance. Category 1 credit can only be taken for BMPs constructed within your jurisdiction. When jurisdiction overlaps, a non-traditional MS4 (ex. county, watershed district, or correctional facility) defer to the City or Township unless the BMP is constructed within the conveyance system of the non-traditional MS4. | ||
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+ | EXAMPLE | ||
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+ | [[file:FAQ_Example.png|thumb|left|alt=catexample|Example]] | ||
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+ | BMP 1: | ||
+ | The watershed district can take category 1 credit. City A, B, and/or C can take category 2 credit if there is a partnership agreement in place. | ||
+ | If BMP 1 happened to be outside the urbanized area, no MS4 would take credit for the BMP. | ||
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+ | BMP 2: | ||
+ | City A can take category 1 credit. The watershed district, City B, and/or C can take category 2 credit if there is a partnership agreement in place. | ||
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+ | BMP 3: | ||
+ | City B can take category 1 credit. The watershed district, City A, and/or C can take category 2 credit if there is a partnership agreement in place. | ||
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+ | BMP 4: | ||
+ | No MS4 can take credit in either category for this BMP because it is constructed outside the TMDL study area.--> | ||
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+ | [[Category:Level 3 - Regulatory/Municipal (MS4)/TMDLs]] | ||
+ | [[Category:Level 2 - Regulatory/Municipal (MS4)]] | ||
+ | [[Category:Level 3 - Regulatory/Municipal (MS4)/Guidance, outreach materials, miscellaneous information]] |
This page was last edited on 5 January 2023, at 17:16.