CITY OF TACOMA STORMWATER MANAGEMENT PROGRAM NPDES Phase I S5.C.3 - Coordination NEBC Conference March 8, 2018 Merita Trohimovich, PE S5.C.3 Coordination (Phase I Permit Language) The SWMP shall include coordination mechanisms among departments within each jurisdiction to eliminate barriers to compliance with the terms of this permit. The SWMP shall also include coordination mechanisms among entities covered under a municipal stormwater NPDES permit to encourage coordinated stormwaterrelated policies, programs and projects within a watershed. These are the coordination concepts. 1
S5.C.3 Minimum Performance Measures (Phase I Permit Language) S5.C.3.a. Implement intra-governmental (internal) coordination agreement(s) or Executive Directive(s) to facilitate compliance with the terms of this permit. The agreement is the EASY PART. New memo for each permit cycle. It s the trickle down to every staff member involved in permit implementation that is the TRICKY PART. Tacoma has over 1700 employees that have some involvement with the permit. S5.C.3 Minimum Performance Measures (Phase I Permit Language) S5.C.3.b. Implement: i. Coordination mechanisms clarifying roles and responsibilities for the control of pollutants between physically interconnected MS4s of the Permittee and any other Permittee covered by a municipal stormwater permit. Regardless of Permit requirements this is a basic task for stormwater management because stormwater will naturally cross jurisdictional boundaries. The adjacent jurisdiction staff know each other, have similar challenges and work together. 2
S5.C.3 Minimum Performance Measures (Phase I Permit Language) S5.C.3.b. Implement: ii. Coordinating stormwater management activities for shared waterbodies, among Permittees and Secondary Permittees, as necessary to avoid conflicting plans, policies and regulations. Tacoma works with adjacent permittees and secondary permittees on policies, projects and programs. Tacoma participates in a variety of coordinating groups. S5.C.3 Minimum Performance Measures (Phase I Permit Language) S5.C.3.b.: Permittees shall document their efforts to establish the required coordination mechanisms. Failure to effectively coordinate is not a permit violation provided other entities, whose actions the Permittee has no or limited control over, refuse to cooperate. Staff and other jurisdictions are willing to coordinate, sometimes the day to day pressures of work can limit your focus but all it takes is a phone call. 3
Additional Coordination Requirements in other locations throughout the Permit Stormwater Management Program Plan (S5.C.4 Public Participation) Updates to SWMM and TMC (S5.C.5 Internal and External) LID Code Update (S5.C.5.b Internal and External) Training Requirements (S5.C.5, S5. C. 7, S5.C.8, S5.C.9, S5.C.10) Annual Report and SWMP Preparation Large coordination effort to get answers to all annual report questions and update SWMP every year. Ask for answers to questions early! ~4 month process. Tacoma NPDES Implementation and Coordination Responsibility Environmental Programs Group NPDES Group with support of Senior Management Permit Oversight consists of 5 Staff Part Time for Permit Compliance Heavy on technical assistance and development of training materials and documentation Final preparation and submittal of Annual Report Final preparation of the Stormwater Management Program Plan (SWMP Plan) 4
Why coordination is so important Multiple Skills Sets required for Permit Implementation Engineers Sampling Crew Maintenance Crews Inspection Staff Plan Review Staff Educators Communication Specialists Volunteer Management Staff GIS Lab Staff Etc. Permit compliance skill sets reside in many departments Environmental Program Group overall Permit management Capital Delivery Group construct new and repairs facilities Asset Management Group mapping, capacity Collection Systems Support Group IDDE, drainage complaints Environmental Compliance facility inspection Site Development Group permitting, plan review Street Operations construct and maintain roads Tacoma Public Utilities water/power Code Enforcement enforcement action assistance City Attorney s Office code/policy updates Information Technologies computers, software Public Works Engineering ROW projects OTHERS just finding out who does what is a challenge! 5
S5.C.3 Coordination Internal Challenges Many work groups complete SWMP components Different Focus Different data management systems Accela, SAP, AccessES, Dart, spreadsheets, emails, little bits of paper Different Management Different Budgets and Funding Mechanisms Different Communication Styles: Access to computers is limited for some Departmental Reorganizations New hires and staff departures S5.C.3 Coordination Internal Challenges Other groups have business operations and requirements that is their body of work the body of work is not NPDES related- thus creates a challenge to complete the body of work within the boundaries of the permit Differing opinions regarding compliance Constant reminders needed Confusion regarding compliance does every part of the City have to comply (HINT the answer is YES) 6
S5.C.3 Coordination Internal Challenges Tracking of Training Who needs training? over 1700 employees to be trained Which training is needed? Who was trained? New staff are added each month Support from HR Training Department Help with City-wide training tracking system Online IDDE training module Public Coordination City of Tacoma Website: www.cityoftacoma.org/stormwater Stormwater ListServ Sign up to receive information about policy updates and SWMM at www.cityoftacoma.org/stormwatermanual Specific Stormwater Email: swmupdates@cityoftacoma.org Public Meetings Getting People s Attention is Hard! Example, still trying to educate that we have a separate stormwater and wastewater system 7
Coordination with adjacent jurisdictions Pierce County Fife University Place Fircrest Ruston Federal Way Puyallup Tribes of Indians Lakewood WSDOT Includes Phase I, Phase II and non-permitted jurisdictions Where Does My Stormwater Go or Come From? Jurisdictional Boundaries Do Not Follow Stormwater Flowpaths! Pierce Co. Federal Way Fife Pierce Co. 8
Some of Tacoma s important facilities are located in other jurisdictions Leach Creek Holding Basin Located in Fircrest Gravel Pit Detention Basin Located in Lakewood Why is coordination important? Coordination to ensure that each jurisdictions requirements are met. Equivalent manuals are helpful but each jurisdiction may have additional or more stringent requirements. Source Control investigations Spill Response Review of Special Projects 9
Coordination Methods APWA Stormwater Managers Meeting Phase I NPDES Stormwater Managers South Sound Phase II NPDES Stormwater Managers PSP Local Integrating Organization Ad Hoc Committees for Permit Reissuance Staff contacts Special Project Review WRIA 10/12 Lead Entity Swan Creek Raise the Grade Chambers-Clover Watershed Council Puyallup River Watershed Council Examples of Tacoma S5.C.3.b.ii Implementation Several MOUs and Other Documents to Establish Roles and Responsibilities WSDOT Pipe Maintenance Port of Tacoma Plan Review Project Specific Reviews Grandview Avenue Tacoma Pierce County Health Department Treatment City of Ruston Plan Review and Permitting Provided comments on the Port of Tacoma s SWMM 10
Examples of Tacoma S5.C.3.b.ii Implementation City of Tacoma Stormwater Management Manual contains specific language for when discharges may go to other jurisdictions: Portions of the Flett Creek watershed discharge to adjacent municipalities. In these cases, the more stringent requirements between the City of Tacoma Stormwater Management Manual and the receiving municipality will be applied for determining stormwater mitigation requirements. Coordination with secondary permittees Port of Tacoma Tacoma Community College Metro Parks Tacoma 11
Coordination with Port of Tacoma Written agreement with Port of Tacoma Extensive overlapping systems Port has Phase I Municipal Permit and Industrial Permit which leads to creative implementation by Port to meet all requirements Port has written it s own SWMM to supplement the City s Courtesy review when Port properties apply for construction permits Port participates in Phase I Stormwater Managers group Coordination with Metro Parks / TCC Offer technical assistance when requested Seek collaboration Partnering when possible on projects Permit Review for construction projects Metro Parks has some facilities that take stormwater from Tacoma s system. City / Parks partnership to locate a large treatment facility on Metro Parks Pt. Defiance property 12
Coordination with adjacent Phase Is Operating under the same permit Sections are implemented differently Offer and receive technical assistance Coordination with adjacent Phase IIs The Phase II permit requirements are different but all have the same goals (healthy receiving waters). Offer and receive technical assistance if requested Several Phase II permit requirements are similar to Phase I requirements but often implementation date is later for Phase II share our process and products Ken Gill (Fife) attends most of our stormwater public meetings Tacoma hosts and attends the South Sound Phase II Permit Managers meeting 13
Coordination with adjacent non-permitted Ensure stormwater coming into City is suitable for discharge to receiving waters Offer technical assistance when requested Work on erosion control issues during construction projects Have completed smoke testing in adjacent jurisdictions to check for illicit discharges / sanitary cross connections SWMP for Public Comment Stormwater Management Program (SWMP) SWMP outlines how stormwater is managed in the City of Tacoma and the activities that are needed for permit compliance. SWMP Plan required to be updated each year Available at www.cityoftacoma.org/stormwater - 2018 plan available open to public comment through March 26. More coordination per Permit section S5.C.4 Permittees shall provide ongoing opportunities for public involvement and participation in the Permittee s SWMP and implementation priorities. 14
Thanks! Merita Trohimovich, P.E. City of Tacoma Environmental Services Environmental Programs Group 15