The City of Cottage Grove’s innovative stormwater pollution prevention program (SWPPP) is effectively reducing the impacts of stormwater on the community and city's surface waters. City staff answered our questions about how their program successfully manages stormwater.
Q: What makes
your SWPPP implementation unique?
A: The Cottage Grove MS4 program is
overseen by the city engineering division, which is part of the Community
Development Department. Being part of Community Development, engineering is
able to work closely with the planning division early on during the planning
process of new development and re-development projects. Engineering is also
able to work closely with the building division during the construction
process. Having the support of the various divisions is key to implementing
construction and post-construction stormwater requirements.
Q: How do these connections play out in the program?
A: During the planning process, specific
construction and post-construction stormwater management requirements for each
project can be identified early on, and included in the conditions of approval.
Plan review is then completed in conjunction with the building division, with
permits not being issued until all stormwater management requirements are met. Finally,
the building division provides support during the construction process
regarding construction stormwater requirements. The building official is copied
on all erosion control inspection reports, and if controls are non-compliant,
building inspections can be halted to ensure compliance is met.
Q: Tell us
about your partnerships with external parties and how they help
you meet permit requirements.
A: The City of Cottage Grove partners with
the South Washington Watershed District to complete erosion and
sediment control inspections on all private construction projects in the city.
Utilizing this process helps to ensure specific city and watershed requirements
are being met, along with the construction stormwater permit requirements. The watershed district
also provides grant funding for post-construction stormwater BMPs that go
above and beyond the minimum requirements. By providing this funding, projects
in the city are able to install enhanced post-construction stormwater BMPs
that provide a greater level of treatment than what would typically be
achieved.
Q: What's your biggest obstacle to complying with MS4 requirements, and how did
you overcome it?
A: One of
the biggest challenges the city has seen is working with private entities on
maintenance of post-construction stormwater BMPs. To help manage this issue, a
stormwater management agreement was drafted that is executed between the city
and owner of all private BMPs. This agreement requires specific inspection and
maintenance criteria be met, and gives the city the right to perform this work
if necessary and assess the owner. These agreements are also recorded and
[transferred] to the new owner in the event of a sale.
Q: How can other MS4s apply your ideas to their communities to
further stormwater protection across the state?
A: One of
the most important aspects of having an effective MS4 program is ensuring that other
departments in the organization have an understanding of what the program is
and why it is important. By having this support, each department is able to
better do their part in achieving various requirements throughout the planning,
construction, and operation process. Whether it is the planning division
engaging engineering early on to determine a development’s stormwater
management requirements, a public works employee identifying a private BMP
maintenance issue, a building inspector addressing a silt fence issue, or code
enforcement finding an illicit discharge, this is a key factor in managing an
effective MS4 program.
All 232 regulated MS4s were required to submit an inventory of all ponds, wetlands, and lakes
(public and private) that collect stormwater
within their jurisdiction. Permittees identified the type of waterbody,
its unique ID number (assigned by the permittee), and its geographic
coordinates in decimal
degrees. The inventories have been combined into one spreadsheet in the Minnesota Stormwater Manual.
The
Minnesota Session Laws of 2009 require the MPCA to incorporate
requirements for inventorying ponds, wetlands, and
lakes into the MS4 general permit reissued in 2013. The law's intent was
to quantify the bodies of water in each regulated MS4 with the
potential for contamination by polycyclic aromatic hydrocarbons (PAHs)
from the use of coal tar sealants.
A sediment removal project at a stormwater pond in White Bear Lake
The MPCA recently published updated guidance on managing
sediment removal from stormwater collection and conveyance systems. Changes since June 2015
include:
Revision of land use category definitions
In the stormwater sediment spreadsheet, it's easier to calculate
benzo[a]pyrene (B[a]P) equivalents and compare contaminant concentrations in stormwater
sediment to soil reference values
Sediment sampling is now required regardless of the volume
of sediment to be excavated
Minor changes to the section called “Determination of excavated soil as regulated solid waste”
General information about hydraulic dredging added
This new publication is
available on the MPCA web site. Additional information on coal
tar sealants and managing stormwater sediment can be found in the Minnesota Stormwater Manual.
The MPCA is developing several training videos on the use of the MIDS
calculator, some of which should be available in August. See the list of proposed video topics in the Minnesota
Stormwater Manual.
The MIDS calculator has been downloaded more than 1,600 times this year. We would like to know if and
how you are using the calculator; please contact Anne Gelbmann or Mike Trojan to let us know.
Good example of silt fence and mulch used together as temporary BMPs
MPCA construction stormwater
inspectors are busy at construction sites checking on compliance with the
Construction Stormwater General Permit. The use of down
gradient
sediment controls, such as silt fence, is common at construction
sites. But all too often, inspection staff find that sites are not
using erosion prevention BMPs properly. In particular, they are not being installed when earth disturbance has
temporarily stopped on portions of the site.
Permittees are
required to install a temporary soil stabilization BMP (i.e. mulch, hydromulch,
plastic sheeting, or other cover) on portions of the site not worked on for
14 days or more. This includes inactively worked soil piles or any unworked
exposed soils surrounding the active work area. While silt fence is important for helping to
capture sediment that has dislodged from the site, erosion prevention BMPs
prevent soil from moving in the first place, so they more effectively prevent
sediment from leaving the site. Both erosion prevention and sediment control
BMPs must be used during construction.
If portions of the
construction
site discharge stormwater to a special or impaired water located within one mile of the site’s boundary, then the
timeline for
stabilizing these soils drops to seven days. Permittees are required to
immediately stabilize soils once it's known these areas will remain
unworked for 14 or 7 days, as applicable.
In 2017, two large research projects are in full
swing:
Infiltration in roadside swales: Long-term field testing
— The MPCA and MnDOT have identified four new sites for this project, which will
bring the total linear length of field sites to approximately a mile. This full-scale
infiltration performance assessment uses water budgets derived from natural
runoff events over annual periods to follow up on recent swale research
conducted by University of Minnesota. Equipment will be installed this summer, with monitoring
likely through 2018.
Underground infiltration monitoring – TheMPCA and
Capitol Region Watershed District have partnered to monitor two underground
practices: one near Upper Villa Park (Roseville), and one at the Midway Stadium
Business Center (St. Paul). Influent and subsurface sampling points and
equipment are installed at both sites. This will allow assessment of pollutant
loading, transport, and removal in these infiltration BMPs and the unsaturated
zones beneath them. The research is looking at conventional stormwater constituents as
well as sVOCs, VOCs, and other chemicals. Sampling for this project will
continue through 2018.
Mark your calendars for the
next industrial stormwater training session this fall. The next University of Minnesota permit-overview workshop will be on
Wednesday, September 6, at the MNDOT Training Facility in Arden Hills. This day-long session will
cover permit basics, SWPP development and implementation, and stormwater
monitoring and reporting requirements. For additional information or
to register, visit the U of M Erosion and Stormwater Management Certification
Program's web site.
Information on design, construction, and maintenance of pretreatment
settling practices; addition of pretreatment case studies and information on
level spreaders
New information for several construction stormwater best management
practices
MS4 staff at the MPCA (l to r): Megan Handt, Cole Landgraf, Caroline McFadden, and Anne Gelbmann.
Changes at the MPCA have resulted in new staff assignments for
regulated MS4s. Visit the Stormwater Manual's MS4
page to find your MPCA staff
contact.
The MS4
page has also gotten a facelift.We are adding
additional guidance documents and tools in the next few months to help build and manage an effective
MS4 program.
Newsletter contact
If you have questions about or suggestions for this newsletter, contact Anne Gelbmann, MPCA-St. Paul, 651-757-2384