PART VI. Stormwater Management Program Assessment, Reporting and Other Submittals PART VI. Stormwater Management Program Assessment, Reporting and Other Submittals

A. SWMP Assessment

The Permittee shall complete an annual assessment of its Stormwater Management Program based on results of information collected and analyzed during the reporting period, including monitoring, structural pollution control device assessments, inspection findings, and public input received. The purpose of the Stormwater Management Program assessment is to provide information for improving performance (including but not limited to reduced pollutant loading and runoff volumes) and to optimize associated planning and design, construction, operation, and maintenance of the municipal separate storm sewer system. The Permittee shall identify measurable goals for objectives defined in Part VI.A.3 below, which will be employed by the Permittee to quantify performance. The Permittee shall select and implement measurable Minimum Control Measure-specific goals for the assessment program. If another entity has implemented a stormwater assessment program in a portion of the jurisdiction, the Permittee is encouraged to work with that entity to share resources.

The annual assessment of the Stormwater Management Program shall include:

1. an overall evaluation of the nature and extent of the Permittee’s cooperation with other city, county, state and local governmental and non-governmental entities in the overall stormwater management efforts in the drainage area, including the extent to which cooperative monitoring has occurred between agencies listed in Part V.C.7.a of this permit. The evaluation required under Part V.F. of this permit shall consist of successes, impediments realized, and how future efforts could be facilitated so as to reduce costs minimize expenses, improve cooperation, quality and avoid duplication.

2. a description of monitoring and analysis data, including supporting information with relevant Excel spreadsheet with table(s) and graphics, which includes: the date and duration of the storm events sampled, rainfall estimates of the storm event which generated the sampled discharge, and the duration between the storm event sampled and the end of the previous measurable (greater than 0.10 inch rainfall) storm event (estimated build-up and wash-off events). The assessment shall also include estimates of annual and seasonal pollutant loads for parameters listed in Table1, from the cumulative discharges to waters of the state from each identified municipal outfall along with a statement of annual estimated runoff volumes and associated flow-weighted mean concentration for each municipal outfall. The calculation shall be made for all of the pollutants listed in Table 1. This assessment shall also include descriptions of the calculation method(s) used, including identification of software, and calibration of any model employed. Electronic copies of modeling and spreadsheets shall be included in the Annual Report. An analysis of uncertainty associated with loading estimates for unmonitored portions of the municipal separate storm sewer system shall also be included.

The presentation of all required information shall be organized by outfall watershed to the Mississippi River beginning from the north and progressing downstream with tabulations organized by appropriate discharge to (1) the east bank of the Mississippi River and (2) the west bank of the Mississippi River. The Permittee shall:

a. identify each Mississippi River discharge location, its drainage area located within the Permittee’s jurisdiction, land areas by use, and impervious cover, and identify any upstream contributing areas that extend beyond the Permittee’s municipal boundaries; and

b. identify watersheds and storm sewer flow networks located within the Permittee’s jurisdiction for:

1) Shingle Creek;

2) Bassett Creek; and

3) Minnehaha Creek.

For each of these creeks, the Permittee shall, based on available information, identify each discharge location, its drainage area within the Permittee’s jurisdiction, land areas by use, and impervious cover. Identify if there are any upstream contributing areas that extend beyond the Permittee’s municipal boundaries, based on available information.

The Permittee shall incorporate available water quality trend data for Bassett, Shingle, and Minnehaha Creeks and Minneapolis lakes as stormwater system performance indicators.

3. An analysis of the Stormwater Management Program’s effectiveness through implementation of the following:

a. the Permittee’s program to inform and educate the public about the beneficial onsite reuse of leaves and grass clippings and proper use of lawn and garden fertilizers and pesticides, proper management of pet wastes and prevention of non-stormwater discharges into the storm sewer system, as required under Parts V.C.1.e and V.C.3.b;

b. the Permittee’s leaf and grass clipping collection and management system;

c. the Permittee’s street sweeping, including an assessment of the effectiveness of conventional and high efficiency sweepers;

d. the Permittee’s program for detection and elimination of illicit discharges to the storm sewer;

e. the Permittee’s program of operation and maintenance of structural pollution control devices;

f. the Permittee’s identification of stormwater hotspots as required under Parts V.C.3.f.2.i and V.C.3.f.3; and

g. the Permittee’s post-construction stormwater management including:

1) results, efforts and barriers to reduce stormwater runoff volume; and

2) results, efforts and barriers to runoff volume and rate reductions for street projects.

4. An analysis of the appropriateness and performance of the Permittee’s stormwater management techniques and BMPs in reducing runoff volumes and pollutant loading to waters of the state. This should include consideration of weather variability including extreme events, extended dry periods, extended wet periods, and storm intensities that may affect stormwater system performance.

5. An analysis of the overall effectiveness of the Stormwater Management Program in achieving the long-term goals.

6. A fiscal analysis of the budget implementing the Stormwater Management Program that includes, but shall not be limited to, the expenditures for the previous fiscal year, the budget for the current fiscal year, the source of funds, and an estimated annual budget for the next five years. The analysis shall include the capital, operation, maintenance and staff resource costs of each item in the program.

The assessment completed under Part IV.A of this permit shall be submitted with the Annual Report required under Part V.E of this permit.

B. Recordkeeping.

The Permittee shall keep records required by the NPDES permit for at least three years beyond the term of this permit, including all records of the exact place, date and time of any inspection, sample, measurement, analysis, or assessment; the name of each person who performed the sample collection, measurement, analysis, calculation or assessment; the analytical technique, procedures and methods used; the results of the analysis or assessment; and any calculations, original recordings from automatic monitoring instruments, and laboratory sheets. The Permittee shall extend these record retention periods upon request of the MPCA and/or during the course of an unresolved audit or enforcement action (Minn. R. 7001.0150, subp. 2(C)).

C. Public Availability

The Permittee shall make its records, including the Stormwater Management Program, available to the public at reasonable times during regular business hours (see 40 CFR § 122.7 for confidentiality provision). The Permittee may assess a reasonable charge for copying. The Permittee may require a member of the public to provide advance notice.

Except for data determined to be confidential according to Minn. Stat. § 116.075, subd. 2, all reports required by this permit shall be available for public inspection at the MPCA St. Paul office. Monitoring or effluent data shall not be considered confidential. Confidential material shall be submitted according to Minn. R. 7000.1300.

D. Annual Reporting

The Permittee shall submit each year the Annual Report required under Part V.E on the schedule under VI.E of this permit. The report shall communicate in detail the following:

1. The status of the Permittee’s compliance with conditions of this permit and the current Commissioner-approved Stormwater Management Program.

2. Minimum Control Measures.

a. General Reporting. The Annual Report shall include a discussion of the status of implementation of the Minimum Control Measures of the Stormwater Management Program. For each of the Minimum Control Measures, the discussion shall include, but not be limited to:

1) a comparison of the Permittee’s accomplishments in the preceding year to the long-term and Minimum Control Measure-specific goals set in the previous year’s Annual Report;

2) proposed long-term and Minimum Control Measure-specific goals for the following year;

3) operation and maintenance activities;

4) performance;

5) effectiveness;

6) inspections;

7) enforcement activities;

8) public education activities for each program; and

9) change in identified BMPs or measurable Minimum Control Measure-specific goals.

b. Minimum Control Measure Specific Reporting. The Permittee shall report the annual results of performance measures established in the Stormwater Management Program for each Minimum Control Measure including, but not limited to, the following:

1) public education and outreach on stormwater impacts:

i. copies of educational materials and/or links to websites with descriptions of the education activities, and the quantity of material distributed and the number of visits by the public to education websites;

ii. a summary of the outreach and education activities regarding Minimum Control Measure education required under Part V.C.1.b of this permit; and

iii. if the Permittee relied upon other entities for some, or all, of its education program, a summary of education program activities conducted by those other entities.

2) public participation, public involvement:

i. a summary of the oral and written public input on the Stormwater Management Program required under Part V.C.1.f and V.C.2.c and the Permittee’s response to it; and

ii. a formal resolution from the Permittee's governing body adopting the Annual Report and the Stormwater Management Program as required under Part V.C.2.e

3) illicit discharge detection and elimination:

i. the status of the electronic storm sewer system inventory and map required under Part V.C.3.a of this permit if not completed. If completed, the date of the last update to the inventory and map;

ii. the number of spills and unauthorized discharges that occurred and the Permittee’s response to the spills including the time from discovery to responding and the time to elimination of the illicit discharges;

iii. the number and description of illicit discharge screening activities conducted in the previous calendar year, results of those activities, and the Permittee’s responses to identified illicit discharges; and

iv. update the inventory of hazardous waste and other industrial facilities with information required under Part V.C.3.f.1 of this permit;

4) construction site stormwater runoff control:

i. the number of construction site plans reviewed and approved;

ii. the number of public complaints received and the responses to those complaints; and

iii. the number of site inspections completed and a summary of inspection findings.

5) pollution prevention and good housekeeping for municipal operations:

i. as required under Part V.C.6.b.4 of this permit, the results of all outfall inspections including the dates of inspection and the date, or scheduled date, of completion of additional erosion protection;

ii. the reasons for delaying needed repairs or maintenance of municipal separate storm sewer system facilities including the identification of the facility or facility component and a schedule for completion as required under Part V.C.6.b.6 of this permit;

iii. as required under Part V.C.6.b.7 of this permit, the results of structural pollution control device inspections, assessments, maintenance, and repair activities including:

a) date;

b) antecedent weather conditions;

c) sediment storage capacity and percent capacity remaining;

d) maintenance and/or repairs performed or recommended including completion date; and

e) the quantity and categories (by structural pollution control devices, types of substances and, when possible, seasons) of removed substances;

iv. as required in Part V.C.6.c.5 of this permit, the quantity of material removed by street sweeping. Seasonal sweepings for spring sand and fall leaves shall be itemized as part of the total quantity;

v. as required in Part V.C.6.c.5 of this permit, the quantity of deicing materials, chemicals, and sand applied to roadways under its jurisdiction. The location and description of all storage facilities shall be identified in the Annual Report; and

vi. the number, type, and schedule of flood control projects planned, in addition to a description of the pollutant removal capabilities associated with each project as required in Part V.C.6.e.2 of this permit;

6) monitoring and analysis:

i. proposed Stormwater Management Program modifications to substitute sources of monitoring and analysis data including a discussion of how the data will be utilized to demonstrate compliance with this permit and how it will characterize the nature of stormwater discharges;

ii. the public and local watershed district or watershed management organization comments on the proposed Stormwater Management Program modifications to substitute sources of monitoring and analysis data, with a Record of Decision on the comments;

iii. any request by the Permittee for proposed substitution of alternative sources of monitoring and analysis data as established in Part V.C.7 of this permit; and

iv. any significant operational differences in monitoring and monitoring protocols as established in Part V.C.7.d of this permit; and

v. the results of the monitoring and sampling data analysis established in Parts V.C.7.c and f of this permit;

7) Section 303(d) listings:

i. as required under Part V.C.8.c of this permit, the results of the comparison(s) of estimated pollutant loading(s) to each impaired water body in the Permittee’s jurisdiction and the municipal separate storm sewer system’s Waste Load Allocation (WLA) for that impaired water body; and

ii. changes to, or addition, of BMPs to the municipal separate storm sewer system to reduce loading of pollutants of impairment to impaired waters.

3. In addition to the compliance status and Minimum Control Measure reporting requirements, the Permittee shall include the following in the Annual Report:

a. a discussion of modifications made to the Stormwater Management Programs in the previous calendar year and proposed modifications to the Stormwater Management Program in accordance with Part V.D.4 of this permit. The discussion shall include a description of why the modifications were/are needed. When feasible, this discussion shall include qualitative and/or quantitative data demonstrating the effectiveness of the program elements or identifying impacts on the receiving waters.

b. a discussion of proposed modifications to the Stormwater Management Program under Parts V.D.5 of this permit. The discussion shall include a description of why the modifications are needed. Subject to approval by the Commissioner, any modifications to meet the WLA or change monitoring sites may be requested.

c. a report of the results of the annual assessment of the Stormwater Management Program required under Part VI.A of this permit.

E. Reporting and Other Submittals.

The Permittee shall submit to the Commissioner:

1. The Annual Report required under Part V.E of this permit, by June 30, for each year of the permit term;

2. the revised Stormwater Management Program required under Part II.C.1 of this permit including a revised stormwater monitoring and analysis program, within 180 days of permit issuance; and

3. the plan to reduce stormwater runoff volume required under Part V.C.5.a of this permit, within 36 months of permit issuance.

4. the Stage 1 Inventory information required under Part V.C.6.g.1 of this Permit within 12 months of permit issuance.

The plan and reports shall be submitted to:

Supervisor, Municipal Stormwater Unit
MS4 Stormwater Program
MPCA
520 Lafayette Road North
St. Paul, MN 55155-4194