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4.3 Public Involvement and Participation This permit requires the involvement of the public, which includes an annual public SWMP workshop to solicit feedback on the stormwater program, and opportunities for citizens to participate in implementation of the stormwater program. Public participation in implementation of the stormwater program can include many different activities such as stream clean-ups, storm drain markings, and volunteer monitoring. Permittees are encouraged to work together with other entities that have an impact on stormwater (for example, schools, homeowner associations, DOTs, other MS4 permittees). Permittees are also encouraged to use existing processes in order to implement these public involvement requirements.
II. STATUS OF PERMIT ADEQ issued the Phase I MS4 stormwater permit to the Permittee on July 30, 2010, with an effective date of August 30, 2010. In September 2014 the Permittee submitted the fourth year annual report to ADEQ for their renewal of their MS4 permit. The stormwater permit for the Permittee expired on August 29, 2015. The permit has remained administratively continued until the new permit is issued, in accordance with A.A.C. R18- 9-B904(C).
> This permit replaces the Permittee’s Phase I MS4 stormwater permit issued by ADEQ in 2010. ADEQ’s development of this permit included discussions with the Permittee and EPA, a review of information, including the associated audit report, the existing MS4 permit (AZS000004), the existing fact sheet, annual reports and other reference materials as appropriate.
ADEQ modified the permit in September, 2021 to incorporate new state requirements for dischargers to Protected Surface Waters as defined in A.R.S 49-221(G). III. SUMMARY OF PERMIT CHANGES This permit has been written to include and expand on specific permit conditions (including the Stormwater Management Program) and clarify reporting requirements.
Current Permit Proposed
Permit Reason for Change Stormwater Management Program; Appendix A (SWMP Measurable Goals) and Appendix C (SWMP Requirements) Directly incorporate all Stormwater Management Program requirements into the permit as permit conditions in place of separate appendices. Provide clarity and eliminate confusion. The SWMP requirements and conditions in the permit are fixed for the permit term. The permit will contain all requirements that will be used to assess compliance. SWMP: Public Education and Outreach and Public Involvement and Participation SWMP: Evaluation of target groups and changes adopted in response to targeted behaviors. Host an annual SWMP workshop to create opportunity for the public to participate in development and implementation of the Permittee’s SWMP. These requirements provide clarity on how the Permittee should respond to public outreach behaviors and provide involvement opportunities.
FACT SHEET Page 4 Current Permit Proposed Permit Reason for Change SWMP: Illicit Discharge Detection and Elimination (IDDE) SWMP: Inspections and screening for non-stormwater discharges into the MS4 may be conducted using the Illicit Discharge Detection and Elimination: A Guidance Manual for Program Development and Technical Assessments or another method of equal or improved effectiveness. To establish clear policies and procedures for tracing and eliminating illicit discharges and to ensure that individual incidents are addressed consistently. New language will provide clarity and certainty for implementing the IDDE program.
SWMP: Post Construction requirement to establish standards SWMP: Implement specific Post Construction measurable standard that the MS4 requires in ordinance
The 2010 permit required the Permittee to develop a postconstruction standard.
For the renewal permit ADEQ is incorporating the postconstruction standard that the Permittee has implemented and incorporated in code. SWMP: Post Construction no retrofit assessment SWMP: A retrofit feasibility assessment to address pollution-generating MS4 infrastructure. Determine feasibility to address repeat high pollutant discharges during the next permit term through retrofitting. Monitoring Requirements: Annual Pollutant Loading Removal of requirement for calculating annual pollutant loadings Based on annual reported data the pollutant loadings have shown little variation. Monitoring data that is collected during the permit term can be used during the next renewal to re-evaluate pollutants of concerns for the Permittee. Monitoring Requirements: 126 Priority Pollutants Monitoring Requirements: Reduced parameters required for annual wet weather monitoring Historic data is provided to reduce the required parameters for wet weather monitoring. The reduced table includes parameters that are commonly found in stormwater, have had exceedance in this MS4, or had detectable values that could potentially exceed a surface water quality standard.
FACT SHEET Page 5 Current Permit Proposed Permit
Reason for Change Monitoring Requirements: No discharge characterization requirement Monitoring Requirements: Discharge characterization monitoring during year 4 of the permit term Analytical characterization monitoring has been added for year 4 of the permit term and includes all other priority pollutants not monitoring throughout the permit term. The characterization data will be used during the next renewal application to reevaluate the Permittee’s pollutant of concerns and identify potential changes in stormwater quality during the permit term.
Annual Report paper form submittal, largely narrative Annual Report electronic submittal Electronic reporting rule deadline is December 21, 2020 for annual report requirement.
On February 28, 2020 (85 FR 11909) EPA proposed an extension of the deadline to December 21, 2023. ADEQ is collecting information that is measurable and enforceable.
Report Non-filers by mail semi-annually
Report Non-filers electronically to
AZPDES@azdeq.gov within 30 days of identification
Reporting non-filers as soon as possible allows ADEQ to follow up on these facilities more effectively.
Electronic reporting available with the AZPDES inbox. Submit Discharge Monitoring Reports (DMRs) with annual report in paper form Submit Discharge Monitoring Reports (DMRs) electronically through myDEQ Electronic reporting rule deadline December 21, 2016 for DMRs and myDEQ is now available.
IV. SUMMARY OF PERMIT CONDITIONS
4.6 Industrial and Commercial Facilities (Non-municipally Owned)
MS4 permits must address stormwater discharges to the MS4 from industrial and commercial facilities. The permit requires the Permittee to continue to implement an inspection and oversight program to monitor and control pollutants in stormwater discharges to the MS4 from industrial and commercial facilities.
The Permittee is required to continue to implement and maintain an inventory of known industrial and commercial facilities that are identified in 40 CFR 122.26(d)(2)(iv)(C) which may be significant sources of pollutants and have the potential to discharge to the MS4.
4.7 Construction Sites MS4 permits must address construction-related requirements (and often more specific state requirements) found in the following Federal regulations – Phase I MS4 Regulations 40 CFR 122.26(d)(2)(iv)(D). Stormwater discharges from construction sites generally include sediment and other pollutants such as phosphorus and nitrogen, turbidity, pesticides, petroleum derivatives, construction chemicals, and solid wastes that may become mobilized when land surfaces are disturbed. The permit requires the Permittee to require construction site operators at
FACT SHEET Page 9
defined sites to meet certain minimum stormwater requirements relating to erosion and sediment control and pollution prevention, and to meet other restrictions imposed on them by the State, or local regulations. These minimum requirements clearly specify the expectations for addressing erosion control, sediment control, and pollution prevention control measures at construction sites.
4.8 Post-Construction Developed land changes the hydrology of sites, increasing impervious surfaces which lead to higher stormwater discharge volumes and higher pollutant loads. The purpose of implementing a post-construction standard under
4.8.B.1 is to reduce stormwater pollutants by maintaining or restoring stable hydrology in protected surface waters thereby protecting water quality by having post-construction hydrology mimic the original natural hydrology of the area.
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