III'2 Program Management and Evaluation

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III.2Program Management and Evaluation
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EPAs Measurable Goals Guidance
http//www.epa.gov/npdes/stormwater/measurablegoal
s
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Guidance for Municipal Stormwater Funding
(NAFSMA, 2006)

• Sources of Funding
• Legal Considerations
• Implementing User-Fee Based Funding
• Examples
• http//www.nafsma.org/Guidance20Manual20Version
  202X.pdf
• Funding is generally not addressed during an
  audit/inspection, but is a major concern of the
  MS4s

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Auditing/Inspecting an MS4s Program
Management/Evaluation

• Focus is on two key questions
• Does the MS4 have a clear, written plan, with
  measurable goals, that describes its stormwater
  program and activities?
• Does the MS4 have a process of evaluating its
  stormwater program through annual reporting,
  monitoring, and other activities?

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Common Program Components

• Comprehensive Stormwater Management Planning
• Stormwater Management Plan (SWMP) Planning
  Document
• Coordination
• Performance standards or goals
• Prioritization
• Monitoring
• Assessment and Evaluation
• Data Collection and Reporting

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SWMP Planning Document

• The SWMP should be described in detail
• Organizational structure and coordination scheme
  of the SWMP
• A description of the proposed controls or program
  components (i.e., public education and outreach)
  that includes performance standards or goals,
  standards, or timelines and a prioritization of
  existing resources
• Identify how the SWMP is enforceable through the
  permit

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SWMP and Planning Documentation

• The SWMP should address each program component
  and the permit requirements for each
• The SWMP should identify program priorities based
  on local pollutants or activities of concern
• The SWMP should describe a schedule for program
  implementation that identifies long-term goals
  and interim milestones

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SWMP and Planning Documentation

• Review the SWMP to see if it is a living
  document or appears to be only a restatement of
  permit requirements
• Throughout the evaluation, compare actual
  program activities to those described in the SWMP
• It may be necessary to review other SOPs or
  implementation documents that may used in
  conjunction with the SWMP

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Coordination/Organization

• The MS4 SWMP may be developed and implemented by
• A single permittee
• One department
• Multiple departments or agencies
• Multiple co-permittees
• The SWMP should include a description of the
  responsible organization and the contact person
  for each SWMP component and/or permit requirement
• The SWMP should also describe how each party
  coordinates and communicates

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Coordination and Communication

• Are roles and responsibilities clearly defined
  and understood by each agency and staff member
  involved in stormwater management?
• Do departments, agencies, and staff communicate
  effectively regarding implementation of the SWMP?

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Performance Standards/Measurable Goals

• Standards/goals should be specific and clearly
  identified in the SWMP
• Phase I MS4s are required to assess water quality
  improvements or degradation and propose changes
  to the SWMP necessary to improve effectiveness
• Phase II MS4s are required to develop measurable
  goals to assess the effectiveness of the SWMP

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Performance Standards/Measurable Goals

• Does the SWMP include goals that directly relate
  to permit requirements that can be evaluated for
  compliance?
• Are the goals quantifiable or measurable?
• Are individual BMPs and program activities being
  evaluated?
• Are BMPs and program activities being modified
  based on the results of effectiveness evaluations?

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Prioritization

• Has the MS4 identified priorities for its
  program?
• Activity-specific
• Pollutant-specific (based on impaired waters or
  TMDLs?)
• How is the MS4 addressing any TMDLs?
• Is the SWMP implemented on a watershed basis?

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Monitoring

• Highly specific to each MS4 and NPDES permit
• Key question How is the MS4 using its monitoring
  results to modify and update the SWMP?
• Is the MS4 complying with monitoring requirements
  specified in the NPDES permit?

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Assessment and Evaluation

• EPAs 1996 Interim Permitting Policy for Water
  Quality-Based Effluent Limits in Stormwater
  Permits described an iterative approach to
  permitting

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Graph illustrating the iterative approach
(California SWRCB)
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Assessment and Evaluation

• Does the MS4 measure progress against performance
  standards and goals?
• Is the MS4 analyzing data in annual reports to
  modify its program?
• Are BMPs tracked?
• Is BMP effectiveness evaluated?
• How is the assessment used to modify and update
  the SWMP?

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Example Paper on Stormwater Program
Effectiveness Assessment

• California Stormwater Quality Association
• Allows MS4 managers to evaluate whether programs
  are resulting in desired outcomes, and whether
  these outcomes are being achieved efficiently and
  cost-effectively.
• Based on an assessment of both implementation and
  water quality information
• http//www.casqa.org/resources/CASQA20White20Pa
  per_An20Introduction20to20Stormwater20Program
  20Effectiveness20Assessment.pdf

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Data Collection and Annual Reporting

• The annual report
• Allows permittees to propose changes to the SWMP
  based on an evaluation of SWMP effectiveness
  during the year before
• Provides opportunities for re-prioritization of
  activities based on new data and changing
  conditions
• Allows for justification of shifting of resources
  or responsibilities

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Data Collection and Annual Reporting

• Is the SWMP reviewed and updated as necessary?
• Are annual report data being used to gauge the
  effectiveness of program activities?
• Is the MS4 responding to State recommendations/
  requests after being audited by the State ?

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Common Compliance Problems

• Lack of intradepartmental coordination on
  stormwater issues
• Lack of co-permittee-specific SWMP
• Lack of SWMP planning documents
• SWMP does not identify pollutants of concern or
  program priorities
• Lack of measurable goals
• SWMP not revised or updated