HomeMy WebLinkAboutITEM IV-ACITY OF -J
WASHINGTON
Agenda Subject: Resolution No. 4679
Date: March 1, 2011
Department: Attachments: Budget Impact:
Public Works Resolution No. 4679 $ 0
Administrative Recommendation:
City Council introduce and adopt Resolution No. 4679.
Background Summary:
Resolution No. 4679 approves the updated Stormwater Management Program for implementation in the
City of Auburn and the Mayor is authorized to include a copy of this program in the National Pollutant
Discharge Elimination System Western Washington Phase II Municipal Stormwater Permit annual report
for 2010 to the Washington State Department of Ecology.
W0321-7
Reviewed by Council & Committees:
Reviewed by Departments & Divisions:
❑ Arts Commission
COUNCIL COMMITTEES:
❑ Building
❑
M&O
❑ Airport
❑ Finance
❑ Cemetery
❑
Mayor
❑ Hearing Examiner
❑ Municipal Serv.
❑ Finance
❑
Parks
❑ Human Services
❑ Planning & CD
❑ Fire
❑
Planning
❑ Park Board
®Public Works
❑ Legal
❑
Police
® Planning Comm.
❑ Other
® Public Works
❑
Human Resources
Action:
Committee Approval
Council Approval:
Referred to
Tabled
❑Yes ❑No
❑Yes ❑No Call for Public Hearing
Until
Until / /
Councilmember: Wagner Staff: Dowdy
Meetinq Date: March 21, 2011 Item Number:
AGENDA BILL APPROVAL FORM
RESOLUTION NO. 4679
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
AUBURN, WASHINGTON, APPROVING THE 2011
STORMWATER MANAGEMENT PROGRAM AND AUTHORIZING
THE MAYOR TO INCLUDE A COPY OF THE PROGRAM IN THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
WESTERN WASHINGTON PHASE II MUNICIPAL STORMWATER
PERMIT ANNUAL REPORT FOR 2010 TO THE WASHINGTON
STATE DEPARTMENT OF ECOLOGY
WHEREAS, The Washington State Department of Ecology issued a
National Pollutant Discharge Elimination System Western Washington Phase II
Municipal Stormwater Permit that regulates the discharge of stormwater from
municipal stormwater systems; and
WHEREAS, the City operates a municipal stormwater system and is
regulated under the National Pollutant Discharge Elimination System Western
Washington Phase II Municipal Stormwater Permit; and
WHEREAS, the National Pollutant Discharge Elimination System
Western Washington Phase II Municipal Stormwater Permit requires
development and implementation of a Stormwater Management Program; and
WHEREAS, the Stormwater Management Program is required to be
updated annually;
WHEREAS, the National Pollutant Discharge Elimination System
Western Washington Phase II Municipal Stormwater Permit requires submittal
of an Annual Report which is to include a copy of the updated Stormwater
Management Program.
Resolution No. 4679
March 1, 2011
Page 1
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF AUBURN,
WASHINGTON, HEREBY RESOLVES as follows:
Section 1. That the updated Stormwater Management Program is
approved for implementation in the City of Auburn in substantial conformity with
the copy of the Program attached hereto, marked as Exhibit "A" and
incorporated herein by this reference.
Section 2. That the Mayor is hereby authorized to implement such
administrative procedures as may be necessary to carry out the directives of
this legislation, including submitting a copy of the Program with the City's
Annual Report to the Department of Ecology.
Section 3. That this Resolution shall take effect and be in full force
upon passage and signatures hereon.
Dated and Signed this day of , 2011.
CITY OF AUBURN
PETER B. LEWIS
MAYOR
ATTEST:
Danielle E. Daskam,
City Clerk
APPROVED AS TO FORM:
Daniel B. Heid,
City Attorney
Resolution No. 4679
March 1, 2011
Page 2
Resolution No. 4679
Exhibit "A"
CITY OF AUBURN
2011 STORMWATER MANAGEMENT
PROGRAM
City of Auburn, WA
March 2011
Table of Contents
TABLE OF CONTENTS
1. INTRODUCTION
1.1 Overview
1.2 Regulatory Background
1.3 City of Auburn Regulated Area
1.4 Total Maximum Daily Load (TMDL) Compliance
1.5 SWMP Implementation Responsibilities............
1.6 Document Organization
2. STORMWATER MANAGEMENT PROGRAM ADMINISTRATION
2.1 Permit Requirements
2.2 Current Compliance Activities
2.3 Planned 2011 Compliance Activities
3. PUBLIC EDUCATION AND OUTREACH
3.1 Permit Requirements
3.2 Current Compliance Activities...........
3.3 Planned 2011 Compliance Activities.
4. PUBLIC INVOLVEMENT
4.1 Permit Requirements
4.2 Current Compliance Activities...........
4.3 Planned 2011 Compliance Activities.
5. ILLICIT DISCHARGE DETECTION AND ELIMINATION
5.1 Permit Requirements
5.2 Current Compliance Activities
5.3 Planned 2011 Compliance Activities
City of Auburn Compliance Strategy and Work Plan
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1-1
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1-2
1-2
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1-3
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2-1
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2-2
3-1
3-1
3-1
3-2
4-1
4-1
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5-1
5-1
5-1
5-2
6. CONTROLLING RUNOFF FROM NEW DEVELOPMENT, REDEVELOPMENT, AND CONSTRUCTION SITES.6-1
6.1 Permit Requirements ....................................................................................................................................6-1
6.2 Current Compliance Activities .......................................................................................................................6-2
6.3 Planned 2011 Compliance Activities .............................................................................................................6-2
POLLUTION PREVENTION AND OPERATION AND MAINTENANCE FOR MUNICIPAL OPERATIONS 7-1
7.1 Permit Requirements ....................................................................................................................................7-1
7.2 Current Compliance Activities .......................................................................................................................7-1
7.3 Planned 2011 Compliance Activities .............................................................................................................7-2
8. MONITORING
8.1 Permit Requirements
8.2 Current Compliance Activities...........
8.3 Planned 2011 Compliance Activities.
APPENDIX A
8-1
8-1
8-2
8-2
A-1
M
Table of Contents
Acronyms and Definitions from Permit
City of Auburn Compliance Strategy and Work Plan
A-1
iii
LIST OF TABLES
Table 2-1. 2011 Stormwater Management Administration Program Work Plan ............................................2-2
Table 3-1. 2011 Public Education and Outreach Work Plan .....................................................................3-2
Table 4-1. 2011 Public Involvement Work Plan .....................................................................................4-2
Table 5-1. 2011 Illicit Discharge Detection and Elimination Work Plan .......................................................5-2
Table 6-1. 2011 Controlling Runoff from Development, Redevelopment, and Construction Sites Work Plan 6-3
Table 7-1. 2011 Pollution Prevention and Operations and Maintenance Work Plan ......................................7-2
Table 8-1. 2011 Water Quality Monitoring Work Plan .............................................................................8-2
iv
1. INTRODUCTION
This document presents the City of Auburn's Stormwater Management Program (SWMP). Preparation and
maintenance of this SWMP is required by the Washington State Department of Ecology (Ecology) as a
condition of the Western Washington Phase II Municipal Stormwater Permit (the Phase II Permit). The
Phase II permit covers discharges from regulated small municipal separate storm sewer systems (MS4s).
Based on criteria outlined in the Phase II Permit, Ecology considers the City of Auburn to be an operator of
a small MS4, and therefore required to obtain permit coverage.
Each municipality's permit for discharging stormwater is designed to reduce the discharge of pollutants,
protect water quality, and meet the requirements of the federal Clean Water Act.
Appendix A includes acronyms and definitions from the Permit to help the reader understand the City's
Stormwater Management Program.
The National Pollutant Discharge Elimination System (NPDES) permit program is a requirement of the
federal Clean Water Act, which is intended to protect and restore waters for "fishable, swimmable" uses. The
federal Environmental Protection Agency (EPA) has delegated permit authority to state environmental
agencies, and these agencies can set permit conditions in accordance with and in addition to the minimum
federal requirements. In Washington, the NPDES-delegated permit authority is the Washington State
Department of Ecology (Ecology).
Municipalities with a population of over 100,000 (as of the 1990 census) have been designated as Phase I
communities and must comply with Ecology's Phase I NPDES Municipal Stormwater Permit. With Auburn's
1990 census falling below the 100,000 threshold, the City must comply with the Phase II Municipal
Stormwater Permit. About 100 other municipalities in Washington must now comply with the Phase II
Permit, along with Auburn, as operators of small municipal separate storm sewer systems (VIS4s). Ecology's
Phase II Municipal Stormwater Permit is available on Ecology's website at
The Permit allows municipalities to discharge stormwater runoff from municipal drainage systems into the
state's water bodies (e.g., streams, rivers, lakes, wetlands) as long as municipalities implement programs to
protect water quality by reducing the discharge of "non-point source" pollutants to the "maximum extent
practicable" (MEP) through application of Permit-specified "best management practices" (BMPs). The BMPs
specified in the Permit are collectively referred to as the Stormwater Management Program (SWMP) and
grouped under the following Program components:
11 Public Education and Outreach
Public Involvement
Illicit Discharge Detection and Elimination
1-1
1: Introduction City of Auburn 2011 SWMP
Controlling Runoff from Development, Redevelopment, and Construction Sites
Pollution Prevention and Municipal Operation and Maintenance
Monitoring
The Permit issued by Ecology became effective on February 16, 2007, was modified on June 17, 2009 and
expires on February 15, 2012. The Permit requires the City to report annually (March 31st of each year) on
progress in SWMP implementation for the previous year. The Permit also requires submittal of
documentation that describes proposed SWMP activities for the coming year. This document contains the
City's proposed activities for 2011. Implementation of various Permit conditions is staggered throughout the
five-year Permit term from February 16, 2007 through February 15, 2012. The Permit will be revised and
reissued at the end of this period.
The Western Washington Phase II Permit applies to operators of regulated small MS4s that discharge
stormwater to waters of Washington State located west of the crest of the Cascade Range (west of the eastern
boundaries of Whatcom, Skagit, Snohomish, King, Pierce, Lewis and Skamania counties). For cities, the
Permit requirements extend to those areas of each City that drain to MS4s. Most of Auburn drains to MS4s
that ultimately discharge into the Green River, the White River, or Mill Creek. In addition, some portions of
the City drain to regional infiltration basins.
The federal Clean Water Act requires that Ecology establish "Total Maximum Daily Loads" (TMDL) for
rivers, streams, lakes, and marine waters that don't meet water quality standards. A TMDL is a calculation of
the maximum amount of a pollutant that a water body can receive and still meet water quality standards.
After the TMDL has been calculated for a given water body, Ecology determines how much each source
must reduce its discharges of the pollutant in order bring the water body back into compliance with the water
quality standards. The Clean Water Act requires that TMDL requirements must be included in the NPDES
permits for dischargers into the affected water bodies.
Stormwater discharges covered under this permit are required to implement actions necessary to achieve the
pollutant reductions called for in applicable TMDLs. Applicable TMDLs are those approved by the EPA
before the issuance date of the Permit or which have been approved by the EPA prior to the date the
permittee's application was received by Ecology. Information on Ecology's TMDL program is available on
Ecology's website at
The current permit does not contain any TMDL requirements for the City of Auburn. However, Ecology
has identified several water bodies that do not appear to meet the water quality standards. If Ecology
establishes TMDLs for one or more of these water bodies prior to 2012, the next version of the Permit may
contain additional requirements specified in the TMDL.
The Utilities Engineering Division in the Public Works Department coordinates the overall administration of
efforts to comply with Permit requirements. The work plan tables in each Chapter provide the lead
departments for the associated task. Other major departments /divisions included in the 2011 SWMP
implementation include Maintenance and Operations (NI&O), Human Resources (HR), Development
Engineering, Permit Center, Information services (IS), and Parks.
1-2
1: Introduction
City of Auburn 2011 SWMP
The contents of this document are based upon Permit requirements and Ecology's "Guidance for City and
County Annual Reports for Western Washington, Phase II Municipal Stormwater General Permits." The
remainder of this SWMP is organized similarly to the Permit:
Section 2.0 addresses Permit requirements for administering the City's Stormwater Management
Program for 2011.
Section 3.0 addresses Permit requirements for public education and outreach for 2011.
Section 4.0 addresses Permit requirements for public involvement and participation for 2011.
Section 5.0 addresses Permit requirements for illicit discharge detection and elimination for 2011.
Section 6.0 addresses Permit requirements for controlling runoff from new development,
redevelopment, and construction sites for 2011.
Section 7.0 addresses Permit requirements for pollution prevention and operations and maintenance
for municipal operations for 2011.
Section 8.0 addresses Permit requirements for the monitoring section of the Permit for 2011.
Each section includes a summary of the relevant Permit requirements, a description of current activities, and
a table showing the planned activities for 2011. This document also includes acronyms and definitions from
the Permit in Appendix A for easy reference.
1-3
2. STORMWATER MANAGEMENT PROGRAM ADMINISTRATION
This section of the SWMP describes Permit requirements related to overall Stormwater Management
Program administration, including descriptions of the City's current and planned compliance activities for
2011.
The Permit (Section S5.A) requires the City to:
Develop and implement a Stormwater Management Program and prepare written documentation for
submittal to Ecology on March 31, 2008, and update the SWMP annually thereafter. The purpose of
the SWMP is to reduce the discharge of pollutants from the municipal Stormwater system to the
maximum extent practicable and thereby protect water quality.
Submit annual compliance reports (for the previous calendar year) to Ecology on March 31, beginning
in 2008 that summarize the status of implementation and provide information from assessment and
evaluation procedures collected during the reporting period.
Coordinate with other permittees on Stormwater related policies programs, and projects within
adjacent or shared areas.
The City has activities and programs that meet many of the Permit requirements. The current compliance
activities associated with the Permit include:
The City is on track to comply with Ecology requirements for submittal of SWMP documentation by
March 31, 2011. The Utilities Engineering Division is currently leading the development of the future
planned activities with input and support from several other departments.
The City created an NPDES implementation management group.
The City set up the systems for tracking training. Training attendance is recorded and kept on file with
Human Resources.
The City has defined its strategy for cost tracking. Cost tracking is managed by staff recording time
spent on Permit elements on their timecards using project coding numbers. Reports can be generated
by the Finance Department to determine annual costs by element.
The City has defined and implemented a strategy for managing SOPS. SOPS are available for staff use
on the City's Intranet.
The City is participating in a regional education and outreach consortium. Staff has ensured that the
City's education and outreach program will work in concert with regional efforts such as the Puget
Sound Starts Here campaign.
The City is on track to comply with Ecology's requirements for submittal of the fourth Annual Report
by March 31, 2011.
2-1
2. Stormwater Management Program Administration
City of Auburn 2011 SWMP
Auburn has positioned itself well to maintain compliance as Ecology phases in the future Permit deadlines.
Table 2-1 presents the proposed work plan for the 2011 SWMP administration activities.
Compliance
Task ID
Task Description
Lead
Timeframe
Summarize annual activities for "Stormwater
The SWMP and Annual
SWMP-1
Management Program" component of Annual Report;
Utilities
Compliance Report submittal
identify any updates to Program document. Define
Engineering
is due on or before March
process and roles for annual updates for SWMP.
31st of each year.
Permit condition S9.E.4 requires that the City include
with the annual report submitted no later than March
31, 2011 a summary of identified barriers to the use of
low impact development (LID) and measures to
address the barriers. Also, the City is to include a
The S9.E.4 summary and
Permit
report describing; i) LID practices currently available
Utilities
report are required to be
Condition
that can reasonably be implemented within this permit
E
Engineering
included with the annual
S9.E.4
term, ii) potential or planned non-structural actions
report submitted no later than
and LID techniques to prevent Stormwater impacts, iii)
March 31, 2011
goals and metrics to identify, promote and measure
LID use, iv) potential or planned schedules for
requiring and implementing the non-structural and LID
techniques on a broader scale in the future.
2-2
3. PUBLIC EDUCATION AND OUTREACH
This section describes the Permit requirements related to public education and outreach, including
descriptions of the City's current and planned compliance activities for 2011.
The Permit (Section S5.C.1) requires the City to:
Prioritize and target education and outreach activities to specified audiences, including the general
public, businesses, residents /homeowners, landscapers, property managers, engineers, contractors,
developers, review staff and land use planners, and other City employees to reduce or eliminate
behaviors and practices that cause or contribute to adverse stormwater impacts.
Have an outreach program that is designed to improve the target audience's understanding of the
problem and what they can do to solve it.
Track and maintain records of public education and outreach activities.
The City has activities and programs that meet many of the Permit requirements. The current compliance
activities associated with the Permit include:
Collaboration with other NPDES municipalities through involvement in the Stormwater Outreach for
Regional Municipalities (STORM) integrated public education campaign, Puget Sound Starts Hem
(PSSH). This campaign includes public service ads broadcast locally and on cable tv and the website
. The City of Auburn broadcasts PSSH commercials on the City's
government TV channel (TV 21).
Many of the current education and outreach activities that address stormwater management are
targeted at the general public, residents /homeowners, and some industries. Some of these programs
are listed below:
Natural yard care workshops
Car wash kits
Used motor oil and household hazardous waste program
Residential hazardous waste newsletter
Kids day booth
Water Festival
Green Schools program (district-wide)
Household hazardous waste mobile
Spring Clean-up (curbside appliance pickup )
3-1
3: Public Education and Outreach City of Auburn 2011 SWMP
News letter (quarterly or biannually) for business
The City tracks its education and outreach efforts.
While the City has an existing stormwater public education mud outreach program that meets most of the
Permit requirements, some additional elements will be required. The Permit requires prioritization of specific
target audiences and subject areas. The target audiences are to include:
The general public
Businesses (including home-based and mobile businesses)
Residents /homeowners
Landscapers
Property managers
Engineers, contractors, and developers
City plan review staff, land use planners, and other City employees.
Table 3-1 presents the work plan for the 2011 SWMP public education and outreach activities.
Compliance
Task ID
Task Description
Lead
Timeframe
Continue collaboration with other NPDES
Utilities
EDUC-1
municipalities to identify appropriate program
Engineering
evaluation techniques.
EDUC-2
Refine education and outreach strategy to supplement
Utilities
existing education activities.
Engineering
EDUC-3
Implement new or modify existing education and
Utilities
outreach activities.
Engineering
Refinements to existing
Staff training related to Surface Water Management
public education and
Manual Implementation/Technical Standards
outreach activities are on-
e Permitting
going.
EDUC-4
Plan Review
Utilities
Engineering
Site Inspections
• Maintenance Standards
EDUC-6
Develop strategy and process to evaluate
Utilities
understanding and adoption of target behaviors.
Engineering
Establish baseline measure of public understanding
Utilities
EDUC-6a
by participation in King County Environmental
Engineering
August 2011
Behavior Index survey
Inform public employees, businesses and the general
Utilities
EDUC-7
public of the hazards associated with illegal
Engineering
August 2011
discharges and improper disposal of waste
3-2
3: Public Education and Outreach
City of Auburn 2011 SWMP
Summarize annual activities for "Public Education and
The SWMP and Annual
EDUC-8
Outreach" component of Annual Report; identify any
Utilities
Compliance Report submittal
updates to SWMP.
Engineering
is due on or before March
31 st of each year.
3-3
4. PUBLIC INVOLVEMENT
This section describes the Permit requirements related to public involvement, including descriptions of the
City's current and planned compliance activities for 2011.
The Permit (Section S5.C.2) requires the City to:
Provide ongoing opportunities for public involvement through advisory boards or commissions and
watershed committees, and public participation in developing rate structures and budgets, stewardship
programs, environmental actions, or other similar activities. The public must be able to participate in the
decision-making processes, including development, implementation, and update of the SWMP.
Make the SWMP and Annual Compliance Report available to the public, by posting on the City's website.
Make any other documents required to be submitted to Ecology in response to Permit conditions
available to the public.
The City has activities and programs relevant to the public involvement requirement. These activities are
summarized below.
The City has defined a series of public involvement activities intended to meet the Permit requirements
for public involvement in development of the Stormwater Management Program. This process involves
presenting the draft SWMP to the Planning and Community Development (PCDC) and Public Works
(PWC) Committees. The City will then have a public hearing and presentation to the City Council.
The City will make the Stormwater Management Program document and Annual Compliance Report
available to the public on the City website.
The City of Auburn has a history of including the public in decision making. Table 4-1 below presents the
work plan for the 2011 SWMP public involvement activities.
4-1
4: Public Involvement
City of Auburn 2011 SWMP
Compliance
Task ID
Task Description
Lead
Timeframe
PH
Provide public involvement opportunities for annual
Utilities
SWMP update.
Engineering
Public involvement
Make SWMP document and Annual Compliance
opportunities will be available
PI-2
Report available to public by posting on the City
Utilities
before 3/31/2011 submittal.
website.
Engineering
Summarize annual activities for "Public Involvement
The SWMP and Annual
PI-3
and Participation" component of Annual Report;
Utilities
Compliance Report submittal
identify any updates to SWMP.
Engineering
is due on or before March
31 st of each year.
4-2
5. ILLICIT DISCHARGE DETECTION AND ELIMINATION
This section describes the Permit requirements related to illicit discharge detection and elimination (IDDE),
including descriptions of the City's current and planned compliance activities for 2011.
The Permit (Section S5.C.3) requires the City to:
Implement an ongoing program to detect and remove illicit discharges, connections, and improper
disposal, including any spills into the municipal separate storm sewers owned or operated by the City.
Develop a storm sewer system map, have ordinances that prohibit illicit discharges, and create a
program to detect and address illicit discharges.
Publicly list and publicize a hotline or other local telephone number for public reporting of spills and
other illicit discharges. Track illicit discharge reports and actions taken in response through close-out,
including enforcement actions.
Train staff on proper IDDE response SOPS and municipal field staff to recognize and report illicit
discharges.
Summarize all illicit discharges and connections reported to the City and response actions taken,
including enforcement actions, in the Annual Compliance Report; identify any updates to the SWMP.
The City has activities and programs that meet many of the Permit requirements. The current compliance
activities associated with the Permit include:
The City has completed some of the mapping required for the Permit. The City also has an SOP for
keeping the municipal separate storm sewer system map and inventory up-to-date.
City codes and standards already have sections that address the required illicit discharges and civil
infractions.
Citizens can report illicit discharges or illicit dumping using the published spill hotline number or any
of the phone numbers published by the City. The calls are routed to Operations and Maintenance
where they are recorded and distributed to the appropriate response authority.
The City tracks spills, illicit discharges, and inspections.
The City has chosen to use CarteGraph as its issue tracking and resolution system.
11 The City created an IDDE response and enforcement SOP.
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5: Illicit Discharge Detection and Elimination
City of Auburn 2011 SWMP
The City will need to update current IDDE efforts in order to maintain compliance as the Permit
requirements take effect. Table 5-1 presents the work plan for 2011 SWMP illicit discharge detection and
elimination activities.
Compliance
Task ID
Task Description
Lead
Timeframe
IDDE-1
Define and implement City-wide IDDE Program and
Utilities
Program development to be
develop any necessary supplemental IDDE activities.
Engineering
completed by 8/19/2011.
Continue to review and update storm system map to
Utilities
ongoing
IDDE-2
address data gaps and Permit requirements.
Engineering
IDDE-2a
Map location of all known outfalls and structural BMPs
Utilities
Map to be completed by
owned/operated by the City
Engineering
02/16/2011
IDDE-2b
For outfalls 24" and larger, map the tributary
Utilities
Map to be completed by
conveyance, associated drainage area, and land use
Engineering
02/16/2011
Conduct a field assessment of one high priority water
Utilities
Complete assessment field
IDDE-5
body
Engineering
work for one high priority
water body this year.
Implement procedure for IDDE program evaluation
Utilities
IDDE-6
including feedback received from public education
Engineering
By August 2011
efforts
Summarize annual activities for "Illicit Discharge
The SWMP and Annual
IDDE-7
Detection and Elimination" component of Annual
Utilities
Compliance Report submittal
Report; identify any updates to SWMP.
Engineering
is due on or before March
31 st of each year.
5-2
6. CONTROLLING RUNOFF FROM NEW DEVELOPMENT
REDEVELOPMENT, AND CONSTRUCTION SITES
This section describes the Permit requirements related to controlling runoff from new development,
redevelopment, and construction sites, including descriptions of the City's current and planned compliance
activities for 2011.
The Permit (Section S5.C.4) requires the City to:
Develop, implement, and enforce a program to reduce pollutants in stormwater runoff (i.e., illicit
discharges) to the municipal separate storm sewer system from new development, redevelopment, and
construction site activities. The program must apply to both private and public projects, including
roads, and address all construction/development-associated pollutant sources.
Adopt regulations (codes and standards) and implement plan review, inspection, and escalating
enforcement SOPS necessary to implement the program in accordance with Permit conditions,
including the minimum technical requirements in Appendix 1 of the Permit.
Develop provisions (plan review, inspection, and enforcement) and SOPS to allow non-structural
preventive actions and source reduction approaches such as Low Impact Development techniques to
minimize the creation of impervious surfaces and the disturbance of native soils and vegetation.
Adopt regulations (codes and standards) and processes to verify adequate long-term operations and
maintenance of new post-construction permanent stormwater facilities and BMPs in accordance with
Permit conditions, including an annual inspection frequency and/or approved alternative inspection
frequency and maintenance standards for private drainage systems as protective as those in Chapter IV
of the 2005 Ecology Stormwater Management Manual for Western Washington.
Provide copies of the Notice of Intent (NOI) for construction or industrial activities to representatives
of the proposed new development and redevelopment.
Provide training to staff on the new codes, standards, and SOPS and create public education and
outreach materials.
Develop and define a process to record and maintain all inspections and enforcement actions by staff.
Summarize annual activities for the "Controlling Runoff' component of the Annual Compliance
Report; identify any updates to the SWMP.
6-1
6: Controlling Runoff from New Development, Redevelopment
and Construction Sites
City of Auburn 2011 SWMP
The City has activities tad programs that meet many of the Permit requirements. The current compliance
activities associated with the Permit include:
The City has existing programs, codes, and standards that address the Permit requirements for
management of stormwater runoff from development, redevelopment, and construction sites. The City
reviews all stormwater site plans for proposed development.
The City adopted a stormwater management manual approved by Ecology as equivalent to the 2005
Stormwater Management Manual for Western Washington.
The City has a site planning process for BMP selection and design criteria.
The City inspects all permitted development sites during construction and after construction.
The City clearly identifies the party responsible for operations and maintenance (O&M) and requires
long-term O&M of permitted facilities and BMPs.
The City tracks and records inspections and enforcement actions by staff.
The City provides copies of Notices of Intent (NOI) for construction and industrial activities in the
pre-application meeting with developers.
Construction inspectors and most building inspectors have the required erosion control training.
The City has a program to help reduce stormwater runoff from new development and construction sites.
Table 6-1 presents the work plan for 2011 SWMP activities related to runoff control for new development,
redevelopment, and construction sites.
Compliance
Task ID
Task Description
Lead
Timeframe
Track and report construction, new development, and
Planning/ Permit
CTRL-1
redevelopment permits, inspections and enforcement
Center
On-going.
actions.
CTRL-2
Conduct annual inspection of all treatment and flow
Utilities
On-going
control (other than catch basins) - private systems
Engineering
Summarize annual activities for "Controlling Runoff
The SWMP and Annual
CTRL-3
from New Development, Redevelopment, and
Utilities
Compliance Report submittal
Construction Sites" component of Annual Report;
Engineering
is due on or before March
identify any updates to SWMP.
31 st of each year.
6-2
POLLUTION PREVENTION AND OPERATION AND
MAINTENANCE FOR MUNICIPAL OPERATIONS
This section describes the Permit requirements related to pollution prevention and operations and
maintenance for municipal operations, including descriptions of the City's current and planned compliance
activities for 2011.
The Permit (Section S5.C.5) requires the City to:
Develop and implement an O&M program, with the ultimate goal of preventing or reducing pollutant
runoff from municipal separate stormwater system and municipal O&M activities.
Establish maintenance standards for the municipal separate stormwater system that are at least as
protective as those specified in the 2005 Stormwater Management Manual for Western Washington.
Perform required inspection frequency of stormwater flow control and treatment facilities and catch
basins, unless previous inspection data show that a reduced frequency is justified.
Have SOPS in place to reduce stormwater impacts associated with runoff from municipal O&M
activities, including but not limited to streets, parking lots, roads, or highways owned or maintained by
the City, and to reduce pollutants in discharges from all lands owned or maintained by the City.
11 Train staff to implement the SOPS and document that training.
Prepare Stormwater Pollution Prevention Plans (SWPPPs) for all heavy equipment maintenance or
storage yards identified for year-round facilities or yards, and material storage facilities owned or
operated by the City.
Summarize annual activities for the "Pollution Prevention and Operations and Maintenance for
Municipal Operations" component of the Annual Compliance Report; identify any updates to the
SWMP.
The City has activities and programs that meet many of the Permit requirements. The current compliance
activities associated with the above Permit requirements include:
The City operates an O&M program intended to minimize pollutant runoff from municipal
operations.
The City adopted the stormwater maintenance standards listed in the Stormwater Management
Manual.
The City conducts and records the necessary maintenance operations identified based on inspections
of stormwater control facilities. The City performs spot checks of potentially damaged permanent
treatment and flow control facilities after storm events.
7-1
Pollution Prevention and 0&M for Municipal Operations
City of Auburn 2011 SWMP
M&O staff involved with pesticides, pest management, and erosion and sediment control, receive
training in these areas. The City has developed procedures for these activities.
The City has developed Stormwater Pollution Prevention Plans for applicable City facilities.
Auburn performs many of the Permit required activities to limit stormwater pollution potential related to its
municipal O&M program. Table 7-1 presents the work plan for 2011 SWMP activities related to pollution
prevention and operations and maintenance for municipal operations.
Task ID
Task Description
Responsible
Schedule Notes
PPOM-1
Conduct annual inspection of all treatment and flow
Utilities
On-going
control (other than catch basins) - public system
Engineering
Inspect all public catch basins at least once during the
PPOM-2
permit cycle and perform maintenance as triggered by
M&O
On-going
the maintenance standards
Summarize annual activities for "Pollution Prevention
The SWMP and Annual
PPOM-3
and Operation and Maintenance" component of
Utilities
Compliance Report submittal
annual report; identify any updates to SWMP.
Engineering
is due on or before March
31 st of each year.
7-2
8. MONITORING
This section describes the Permit requirements related to water quality monitoring, including descriptions of
the City's current and planned compliance activities for 2011.
The Permit (Section S8) does not require municipalities to conduct water quality sampling or other testing
during this permit term, with the following exceptions:
Sampling or testing required for characterizing illicit discharges pursuant to the SWMP's IDDE
conditions.
Water quality monitoring required for compliance with Total Maximum Daily Load (TMDL)
conditions (water quality clean up plans). The current Permit does not require that Auburn perform
TMDL-related monitoring because Ecology has not established TMDLs for water bodies that receive
stormwater runoff from the City.
Preparing future comprehensive, long-term water quality monitoring plan including two components:
1) stormwater monitoring and 2) targeted Stormwater Management Program effectiveness monitoring.
11 By the 41' Annual Compliance Report (March 31, 2011), Auburn is required to identify two outfalls or
conveyances where permanent stormwater sampling stations can be installed and operated for future
monitoring. The City is also required to develop plans to monitor stormwater, sediment, and receiving
water for physical, chemical, and/or biological characteristics. One outfall must represent high-density
residential land use, and the other commercial land use.
To monitor SWMP effectiveness, the City will need to identify two suitable Program questions and
sites where targeted Program effectiveness monitoring can be conducted and develop a monitoring
plan for these questions and sites. The proposed effectiveness monitoring is required to answer the
following types of questions:
How effective is a specific targeted action or a narrow suite of actions?
Is the Stormwater Management Program achieving a targeted environmental outcome?
In addition, the City is required to provide the following monitoring and/or assessment data in each annual
report:
A description of any stormwater monitoring or studies conducted by the City during the reporting
period. If stormwater monitoring was conducted on behalf of the City, or if studies or investigations
conducted by other entities were reported to the City, a brief description of the type of information
gathered or received shall be included in the annual report.
An assessment of the appropriateness of the best management practices identified by the City for each
component of the SWMP; and any changes made, or anticipated to be made, to the BMPs that were
previously selected to implement the SWMP and why.
8-1
8: Monitoring
City of Auburn 2011 SWMP
The City developed a map of the significant municipal stormwater outfalls and has developed a monitoring
plan to implement future Permit water quality monitoring requirements.
Auburn will submit the Water Quality Monitoring Program document developed in 2010 with the Annual
Report for 2010 (by March 31, 2011). Except for summarizing monitoring activities no actions are required.
Table 8-1 presents the work plan for 2011 SWMP monitoring activities.
Compliance
Task ID
Task Description
Lead
Timeframe
Participate in regional and state monitoring forums
MNTR -1
and future legislative actions in order to influence
Utilities
Continue participation.
development of feasible and effective alternative
Engineering
future monitoring requirements.
Summarize annual monitoring activities for the Annual
The SWMP and Annual
Report; identify any updates to SWMP including
Utilities
Compliance Report submittal
MNTR -2
identification of sites selected for monitoring and a
Engineering
is due on or before March
summary of proposed questions for effectiveness
31st of each year.
monitoring, purpose, design and methods.
8-2
APPENDIX A
Appendix A: Acronyms and Definitions
City of Auburn 2011 SWMP
The following definitions and acronyms are taken directly from the Phase II Permit and are reproduced here
for the reader's convenience.
AKART means all known, available, and reasonable methods of prevention, control and treatment. All
known, available and reasonable methods of prevention, control and treatment refers to the State
Water Pollution Control Act, Chapter 90.48.010 and 90.48.520 RCW.
Basin Plan is a surface water management process consisting of three parts: a scientific study of the basin's
drainage features and their quality; developing actions and recommendations for resolving any deficiencies
discovered during the study; and implementing the recommendations, followed by monitoring.
Best Management Practices ("BMPs") are the schedules of activities, prohibitions of practices,
maintenance procedures, and structural and/or managerial practices approved by the Department that, when
used singly or in combination, prevent or reduce the release of pollutants and other adverse impacts to waters
of Washington State.
BMP means Best Management Practice.
CFR means Congressional Federal Register
Component or Program Component means an element of the Stormwater Management Program listed in
S5 Stormwater Management Program for Cities, Towns, and Counties or S6 Stormwater Management
Program for Secondary Permittees of this permit.
CWA means Clean Water Act (formerly referred to as the Federal Water Pollution Control Act or Federal
Water Pollution Control Act Amendments of 1972) Pub.L. 92-500, as amended Pub. L. 95-217, Pub. L. 95-
576, Pub. L. (6-483 and Pub. L. 97-117, 33 U.S.C. 1251 et seq.
Discharge for the purpose of this permit means, unless indicated otherwise, any discharge from a MS4
owned or operated by the permittee.
Ecology's Western Washington Phase I Municipal Stormwater Permit regulates discharges from
municipal separate storm sewers owned or operated by Clark, King, Pierce and Snohomish Counties, and the
cities of Seattle and Tacoma.
Ecology's Western Washington Phase II Municipal Stormwater Permit covers certain "small"
municipal separate stormwater sewer systems.
Entity means another governmental body, or public or private organization, such as another permittee, a
conservation district, or volunteer organization.
Equivalent document means a technical stormwater management manual developed by a state agency, local
government or other entity that includes the Minimum Technical Requirements in Appendix 1 of this Permit.
The Department may conditionally approve manuals that do not include the Minimum Technical
Requirements in Appendix 1; in general, the Best Management Practices included in those documents may be
applied at new development and redevelopment sites, but the Minimum Technical Requirements in Appendix
1 must still be met.
Heavy equipment maintenance or storage yard means an uncovered area where any heavy equipment,
such as mowing equipment, excavators, dump trucks, backhoes, or bulldozers are washed or maintained, or
where at least five pieces of heavy equipment are stored.
Illicit connection means any man-made conveyance that is connected to a municipal separate storm sewer
without a permit, excluding roof drains and other similar type connections. Examples include sanitary sewer
A-1
Appendix A: Acronyms and Definitions
City of Auburn 2011 SWMP
connections, floor drains, channels, pipelines, conduits, inlets, or outlets that are connected directly to the
municipal separate storm sewer system.
Illicit discharge means any discharge to a municipal separate storm sewer that is not composed entirely of
storm water except discharges pursuant to a NPDES permit (other than the NPDES permit for discharges
from the municipal separate storm sewer) and discharges resulting from fire fighting activities.
IDDE means Illicit discharge detection and elimination.
Low Impact Development (LID) means a stormwater management and land development strategy applied
at the parcel and subdivision scale that emphasizes conservation and use of on-site natural features integrated
with engineered, small-scale hydrologic controls to more closely mimic pre-development hydrologic
functions.
Major Municipal Separate Storm Sewer Outfall means a municipal separate storm sewer outfall from a
single pipe with an inside diameter of 36 inches or more, or its equivalent (discharge from a single conveyance
other than circular pipe which is associated with a drainage area of more than 50 acres); or for municipal
separate storm sewers that receive stormwater from lands zoned for industrial activity (based on
comprehensive zoning plans or the equivalent), an outfall that discharges from a single pipe with an inside
diameter of 12 inches or more or from its equivalent (discharge from other than a circular pipe associated
with a drainage area of 12 acres or more).
Material Storage Facilities means an uncovered area where bulk materials (liquid, solid, granular, etc.) are
stored in piles, barrels, tanks, bins, crates, or other means.
Maximum Extent Practicable (MEP) refers to paragraph 402(p) (3) (B) (iii) of the federal Clean Water Act
which reads as follows: Permits for discharges from municipal storm sewers shall require controls to reduce
the discharge of pollutants to the maximum extent practicable, including management practices, control
techniques, and system, design, and engineering methods, and other such provisions as the Administrator or
the State determines appropriate for the control of such pollutants.
MEP means Maximum Extent Practicable.
MS4 - see Municipal Separate Storm Sewer System.
MTRs means Minimum Technical Requirements.
Municipal Separate Storm Sewer System (MS4) means a conveyance, or system of conveyances (including
roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, manmade channels, or
storm drains):
(i) owned or operated by a state, city, town, borough, county, parish, district, association, or other public body
(created by or pursuant to state law) having jurisdiction over
disposal of wastes, storm water, or other wastes, including special districts under state law such as a sewer
district, flood control district or drainage district, or similar entity, or an Indian tribe or an authorized Indian
tribal organization, or a designated and approved management agency under section 208 of the CWA that
discharges to waters of the United States.
(ii) designed or used for collecting or conveying stormwater.
(iii) which is not a combined sewer; and (iv) which is not part of a Publicly Owned Treatment Works
(POTW) as defined at 40 CFR 122.2.
A-2
Appendix A: Acronyms and Definitions City of Auburn 2011 SWMP
National Pollutant Discharge Elimination System (NPDES) means the national program for issuing,
modifying, revoking, and reissuing, terminating, monitoring and enforcing permits, and imposing and
enforcing pretreatment requirements, under sections 307, 402, 318, and 405 of the Federal Clean Water Act,
for the discharge of pollutants to surface waters of the state from point sources. These permits are referred to
as NPDES permits and, in Washington State, are administered by the Washington Department of Ecology.
Notice of Intent (NOI) means the application for, or a request for coverage under this General Permit
pursuant to WAC 173-226-200.
Outfall means point source as defined by 40 CFR 122.2 at the point where a municipal separate storm sewer
discharges to waters of the State and does not include open conveyances connecting two municipal separate
storm sewer systems, or pipes, tunnels, or other conveyances which connect segments of the same stream or
other waters of the State and are used to convey waters of the State.
O&M means Operations and Maintenance.
Permittee unless otherwise noted, the term "Permittee" includes Permittee, Co-Permittee, and Secondary
Permittee, as defined below:
(i) A "Permittee" is a city, town, or county owning or operating a regulated small MS4 applying and receiving
a permit as a single entity.
(ii) A "Co-Permittee" is any operator of a regulated small MS4 that is applying jointly with another applicant
for coverage under this Permit. Co-Permittees own or operate a regulated small MS4 located within or
adjacent to another regulated small MS4.
(iii) A "Secondary Permittee" is an operator of regulated small MS4 that is not a city, town, or county.
Small Municipal Separate Storm Sewer System or Small MS4 is a conveyance or system of conveyances
for municipalities having populations of less that 100,000 according to the 1990 US census. Such systems
include road drainage systems, municipal streets, catch basins, curbs, gutters, ditches, man-made channels,
and/or storm drains that are:
a. Owned or operated by a city, town, county, district, association or other public body created
pursuant to State law having jurisdiction over disposal of sewage, industrial wastes, stormwater, or other
wastes, including special districts under state law such as a sewer districts, flood control districts or drainage
districts, or similar entity.
b. Designed or used for collecting or conveying stormwater.
c. Not a combined sewer system,
d. Not part of a Publicly Owned Treatment Works (POTW) as defined at 40 CFR 122.2.
e. Not defined as "large" or "medium" pursuant to 40 CFR 122.26(b) (4) & or designated under
40 CFR 122.26 (a) (1) (v).
Small MS4s include systems similar to separate storm sewer systems in municipalities such as: universities,
large publicly owned hospitals, prison complexes, highways and other thoroughfares. Storm sewer systems in
very discrete areas such as individual buildings do not require coverage under this Permit.
Small MS4s do not include storm drain systems operated by non-governmental entities such as: individual
buildings, private schools, private colleges, private universities, and industrial and commercial entities.
A-3
Appendix A: Acronyms and Definitions
City of Auburn 2011 SWMP
Stormwater means runoff during and following precipitation and snowmelt events, including surface runoff
and drainage.
Stormwater Associated with Industrial and Construction Activity means the discharge from any
conveyance which is used for collecting and conveying stormwater, which is directly related to manufacturing,
processing or raw materials storage areas at an industrial plant, or associated with clearing grading and/or
excavation, and is required to have an NPDES permit in accordance with 40 CFR 122.26.
Stormwater Management Manual for Western Washington means the 5-volume technical manual
(Publication Nos. 99-11 through 15 for the 2001 version and Publication Nos. 05-10-029-033 for the 2005
version (The 2005 version replaces the 2001 version) prepared by Ecology for use by local governments that
contains BMPs to prevent, control, or treat pollution in storm water.
Stormwater Management Program (SWMP) means a set of actions and activities designed to reduce the
discharge of pollutants from the regulated small MS4 to the maximum extent practicable and to protect water
quality, and comprising the components listed in S5 or S6 of this Permit and any additional actions necessary
to meet the requirements of applicable.
Total Maximum Daily Load (TMDL) is a calculation of the maximum amount of a pollutant that a
waterbody can receive and still meet water quality standards,
A-4
I. Permittee Information
Permittee Name Permittee Coverage Number
City of Auburn WAR04-5502
Contact Name Phone Number
Chris Thorn 253-804-5065
Mailing Address
25 West Main
City State Zip + 4
Auburn IWA 98001-4998
Email Adddress
cthorn@auburnwa.gov
II. Regulated Small MS4 Location
Jurisdiction
Citv of Auburn
Entity Type: Check the box that applies
County City/Town Other
X
Major Receiving Water(s)
White River, Green River, Mill Creek
III. Relying on another Governmental Entity
If you are relying on another governmental entity to satisfy one or more of the
permit obligations, list the entity and briefly describe the permit obligation(s) they
are implementing on your behalf below. Attach a copy of your agreement with the
other entity to provide additional detail.
Name of Entity: Permit Obligation(s):
IV. Certification
All annual reports must be signed and certified by the responsible official(s) of permittee or co-
permittees. Please print and sign this page of the reporting form and mail it (with an original
signature) to Ecology at the address noted below. An electronic signature will not suffice.
I certify under penalty of law, that this document and, all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that Qualified Personnel properly gathered and
evaluated the information submitted. Based on my inquiry of the person or persons who manage the system or
those persons directly responsible for gathering information, the information submitted is, to the best of my
knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting
false information, including the possibility of fine and imprisonment for willful violations.
Name Title Date
Name Title Date
Name Title Date
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Western Washington Phase II Municipal Stormwater Permit
2010 Annual Report Attachment
City of Auburn Public Education Summary
City of Auburn 2010 Public Education Summary
Public Education Activity
Target Audience
Comments
City Storm Drainage Web Site
General Public
City website provides general information
on the City's storm drainage program,
links to the City's SWMP and annual
reports and lists the Spill Reporting
hone number.
Stcrmwater Outreach for
General public
Auburn participated in this regional public
Regional Municipalities
education program. Links between the
(STORM)
City Stormwater web page and the
"Puget Sound Starts Here" web page
were established.
ECOSS Spill Kit Program
Businesses that use products
76 businesses were provided with spill
that are potential stormwater
response training and spill kits.
pollutants
Individualized spill response plans were
developed and provided to each
business. Pre-education survey was
completed.
Water Festival
Fourth and fifth grade students
471 Auburn students attended Water
Festival where they learned about
stormwater, pollution prevention,
wetlands, salmon, drinking water and
sanitary sewer issues through hands on
activities and presentations.
Natural Yard Care Workshops
Homeowners
The three workshops were attended by
113 people from the Lea Hill
neighborhood on average. Attendees
learned that they could have beautiful,
healthy yards while reducing their
dependence on pesticides and fertilizer.
Kid's Day
School children and their
One day fair where approximately 1,000
parents
children visited the Auburn Utilities booth
and learned about stormwater pollution
prevention and other water resource
information.
Powerful Choices for the
8 grade students
29 classroom presentations to 763
Environment
students taught students to consider
"What are the connections between my
personal choices and the health of the
Puget Sound ecosystem?"
IDDE Response
Homeowners
103 "Rain Drain" postcards were mailed to
two neighborhoods where evidence of illicit
discharges was detected. No additional
evidence of illicit discharges has been
noted.
Carwash Kit Program / IDDE
Property owners / managers
Mailed letters to 57 potential charity car
wash host sites with a reminder that car
wash runoff cannot enter the storm
drainage system, and that the City has car
wash kits available for fundraisers to use.
~L
Western Washington Phase II Municipal Stormwater Permit
2010 Annual Report Attachment
City of Auburn Low-Impact Development Barriers
City of Auburn Low-impact
Development Barriers
Prepared for the City of Auburn's
March 31, 2011, NPDES Municipal
Stormwater Permit Annual Report
submittal to the Washington State
Department of Ecology
Table of Contents
1. Introduction ...........................................................................................................................................1-1
1.1 Background ..........................................................................................................................................1-1
1.2 Purpose .................................................................................................................................................1-1
2. Potential LID Barriers and Measures to Address Them .................................................................2-1
3. LID Report: Practices, Goals, Planned Actions, and Timelines .....................................................3-1
3.1 LID Practices Currently Available ......................................................................................................3-1
3.2 Potential or Planned Non-Structural Actions and LID Techniques ..............................................3-1
3.3 Goals and Metrics ................................................................................................................................3-2
3.4 Schedules .............................................................................................................................................3-2
List of Tables
Table 1. LID Barriers and Potential Measures in Auburn ........................................................................2-2
Section 1
Introduction
The Western Washington Phase II Municipal Stormwater Permit (Phase II permit) regulates stormwater
discharges for small municipal separate storm sewer systems (MS4s) as established in Code of Federal
Regulations (CFR) Title 40, Part 122.26. The Phase II permit, issued in 2007 and modified in 2009,
includes requirements (S9.E.4.a) for permittees to summarize identified barriers to the use of low-
impact development (LID) in their jurisdictions and measures to address these barriers. These are
described in Section 2.
Permit condition S9.E.4.b requires that the permittee complete a report that describes currently
available LID practices; potential or planned non-structural LID techniques, goals, and metrics; and
schedules for implementation. This report can be prepared individually or in cooperation with other
permittees. This report is provided in Section 3.
The City of Auburn (City) prepared this document to meet the Permit S9.E.4.a and S9.E.4.b
requirements.
1.1 Background
LID techniques can help sites mimic the hydrology and water quality of pre-developed conditions.
However, due to site conditions or other obstacles, LID cannot be implemented everywhere. The
Washington State Department of Ecology (Ecology) has required permittees to implement LID
techniques "where feasible." This document is the first step in determining where LID implementation
appears feasible. Although the City cannot control barriers such as soil infiltration rate, high
groundwater table, or steep slopes, it can manage codes and standards to allow for LID
implementation where feasible.
1.2 Purpose
Special Condition S9.E.4 of the Phase II permit requires permittees to submit an LID barriers report
with the annual report by March 31, 2011, that includes the following information:
• a summary of identified barriers to the use of LID within the area covered by the permit and
measures to address these barriers
• a report describing:
- LID practices that are currently available and that can reasonably be implemented within this
permit term
- potential or planned non-structural actions and LID techniques to prevent stormwater impacts
- goals and metrics to identify, promote, and measure LID use
- potential or planned schedules for the permittee(s) to require and implement the non-structural
and LID techniques on a broader scale in the future.
Ecology suggests that permittees focus this task on preparing to implement LID requirements expected
in the next permit cycle.
1-1
Section 2
Potential LID Barriers and
Measures to Address Them
This section discusses some barriers that could apply to Auburn to make LID implementation
infeasible. This section also includes suggested actions to remove those barriers and includes potential
actions by others (e.g., Ecology, contractors, and developers) as well as the City.
Many current City codes and standards were written before current LID practices were developed. A
portion of the City's codes and related documents have been reviewed to identify challenges to
implementing. The documents reviewed included:
Auburn City Code (ACC) .
Auburn Design Standards (ADS)
2009 Auburn Stormwater Management Manual (ASWMM)
International Building Code (IBC).
Several codes and sections may need to be revised to remove barriers to LID implementation. As the
City moves forward with LID implementation, the identified barriers will be addressed during the
expected timelines set forth in the forthcoming 2012 Phase 11 permit. The identified codes, barriers,
and potential measures to remove those barriers are summarized in Table 1.
All potential measures must still be evaluated to ensure that they remain consistent with City
objectives, including transportation, safety, and economic goals.
2-1
N
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1 1
of Auburn Low-Impact Development Barriers
Section 2
The following barriers are more general and not necessarily specifically called out in City codes or
standards.
LID definitions: There is some uncertainly about what activities and best management practices
(BMPs) are included in LID, so it would be beneficial if Ecology provided more clarification on defining
LID.
Perceptions of compromised public safety and property damage: Some people perceive certain LID
techniques as potentially compromising public safety. Some concerns include reduced emergency
vehicle access/response by using "narrow" streets to reduce impervious area, and exacerbating
landslide potential and causing water damage on adjacent properties by using infiltration and
dispersion. Ecology and the Puget Sound Partnership should consider mounting a public awareness
campaign to inform the public about the benefits and risks of LID techniques.
LID credit calculations: Ecology is working to refine LID credits to be used in reducing detention storage
volume and for other potential LID incentives. Some LID credits may be available only on lots with an
area greater than 1 acre and relatively few such lots are located in residential neighborhoods within
the city. Ecology should complete its work to define the allowable LID credit calculation. LID credits
against local stormwater management fees could significantly reduce available funding for utility
operation and maintenance activities.
City incentives: Current codes do not allow for incentives for property owners or developers to
implement LID measures.
Insufficient areas on smaller lots: Certain LID techniques may not be appropriate for application on
smaller lots. The City should develop a strategy for assessing small-lot feasibility.
Poorly draining soils: Many areas of the City have soils that are inappropriate for implementation of LID
measures that require infiltration. To assist property owners, the City should consider developing a
strategy for identifying such areas (perhaps involving definition of appropriate soil conditions, mapping
areas of suitable soils, and/or defining how to perform onsite soil suitability analyses).
Moderate and steep slopes: Some areas of the city have slopes that might be too steep for certain
infiltration and flow attenuation LID options. To assist property owners, the City should consider
developing a strategy for identifying such areas (perhaps involving definition of appropriate slope
conditions, mapping areas of suitable slopes, and/or defining how to perform onsite slope suitability
analyses).
Unstable slopes: Some areas of the city might be inappropriate for certain infiltration and flow
attenuation LID options due to slope instability. To assist property owners, the City should consider
developing a strategy for identifying such areas (perhaps involving definition of appropriate slope
stability conditions, mapping areas of suitable slope stability, and/or defining how to perform onsite
slope suitability analyses).
Aquifer and wellhead protection areas: Some areas of the city require aquifer and wellhead protection
to ensure adequate supplies of safe drinking water. To assist property owners, the City should consider
developing a strategy for identifying such areas and measures to protect them consistent with Code
sections addressing critical areas building requirements.
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City of Auburn Low-Impact Development Barriers Section 2
High groundwater and ground/surface interflow: Some areas of the city have high groundwater and
ground/surface interflow conditions that may preclude certain infiltration, flow attenuation, and flow
reduction LID options. To assist property owners, the City should consider developing a strategy for
identifying such areas (perhaps involving definitions of appropriate groundwater conditions, mapping
areas of suitable conditions, and/or defining how to perform onsite groundwater suitability analyses).
Local LID designer and contractor expertise: Local experience with LID design and construction is
limited. The State should provide training to increase the pool of knowledgeable LID designers,
installation and maintenance contractors, and local government permit reviewers.
Performance, reliability, life-cycle cost, and unintended impacts: Early stormwater management efforts
using some LID techniques (such as infiltration) achieved limited success. Perceptions exist that LID
technique performance may be difficult to predict and that LID facilities may be susceptible to failure,
may have relatively high replacement costs over time, and may negatively affect groundwater quality.
Moreover, failure of LID measures on private land could lead to public drainage and water quality
problems that require expensive capital improvement projects to address. The State should provide
monitoring to better understand LID performance and help with LID education efforts.
Property owner education: Many property owners do not clearly understand the maintenance
requirements for LID facilities. Local governments need the resources to provide those property owners
with necessary information on LID systems and local conditions affecting those systems.
Code development: Current codes do not cover all of the potential LID BMPs, so new codes may need
to be developed. Potential code gaps include green roofs and cisterns.
Training and code development: The codes, standards, manuals, and standard operating procedures
may need to be updated to address the barriers discussed above. New training programs will be
necessary to teach City staff about updates.
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Section 3
LID Report: Practices, Goals,
Planned Actions, and Timelines
This section addresses the requirements of Phase II permit conditions S9.E.4.b.i through S9.E.4.b.iv.
These are: LID practices available now; potential future LID practices, goals, and metrics; and
schedules. The information contained in this section does not constitute commitments or
requirements.
3.1 LID Practices Currently Available
"LID practices" broadly refer to LID as defined in the Phase II Municipal Stormwater Permit. LID
practices include both non-structural actions and LID techniques. The City of Auburn is open to all LID
practices where feasible as allowed by local codes and standards. This report section lists LID practices
currently employed, allowed, or required, as well as those that could be implemented in the future.
Auburn LID projects include:
• parking lot permeable pavement, concrete, and asphalt
• public project rain gardens
• private project rain gardens
• public roadway (in design).
The City of Auburn makes development project proponents aware of LID options at pre-application
meetings and encourages the use of LID where feasible.
3.2 Potential or Planned Non-Structural Actions and LID Techniques
This section of the report looks beyond the current permit cycle and explores opportunities for actions
and techniques that could be enhanced in the future or are not currently in use.
Potential actions for future enhancement of LID practices include the following:
assess lot coverage requirements for opportunities to take advantage of clustering and reducing
impervious surfaces
• assess the feasibility of reduced roadway widths
• employ lot setbacks totaling 15 feet on both sides of lot lines
• implement a credit transfer program
• install green roofs
• install cisterns
• install permeable pavement roadways.
The City will continue to encourage small-scale engineered facilities and devices or installations that
are built for the purpose of mimicking pre-development hydrologic functions through its project pre-
application process. It is anticipated that Ecology will be revising the Western Washington Stormwater
Management Manual to update and bring more clarity to implementation of LID techniques. The City
will update the Auburn manual to reflect any changes.
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City of Auburn Low-Impact Development Barriers
3.3 Goals and Metrics
Section 3
To identify, promote and measure LID use the City intends to:
• encourage LID at all pre-application meetings
• allow LID techniques to be constructed on sites requesting LID, where feasible
• develop a method for tracking LID implementation.
3.4 Schedules
The City of Auburn is already encouraging and implementing LID practices. All future LID actions will
be scheduled to be implemented as required by the Washington State Department of Ecology.
Future plans for LID include:
• review the Auburn City Code for opportunities to further enhance LID practices in 2011
• revising the Auburn City Code to take advantage of identified opportunities to enhance LID practices
in 2011
• revise the Auburn Design Standards to reflect and facilitate implementation of changes in the
Auburn City Code, the Municipal Stormwater Permit, and the Auburn Stormwater Management
Manual in 2011
• implement new LID requirements through revisions to the Auburn Stormwater management Manual
(anticipated in 2012 and 2013)
Western Washington Phase II Municipal Stormwater Permit
2010 Annual Report Attachment
City of Auburn Stormwater Monitoring and Targeted Stormwater
Management Program (SWMP) Effectiveness Monitoring
December 29, 2010
City of Auburn
Stormwater Monitoring and Targeted Stormwater
Management Program (SWMP) Effectiveness Monitoring
This monitoring plan has been prepared to comply with the requirements of Section S8
of the Western Washington Phase II Municipal Stormwater Permit effective February
16, 2007 and modified June 17, 2009. The Permit includes requirements for permittees
to prepare to conduct a monitoring program in future permits. The Phase II Monitoring
Program described in Section S8.C includes two types of monitoring:
1. Stormwater Monitoring (S8.C.1.a): requires permittees to identify sites suitable
for monitoring stormwater discharges based on jurisdictional size and land use
types, and on known water quality problems and/or targeted areas of interest for
future monitoring.
2. Targeted SWMP Effectiveness Monitoring (S8.C.1.b): requires permittees to
identify questions that monitoring may answer to determine the effectiveness of
specific components of their Stormwater Management Program (SWMP). The
permittee must identify sites for monitoring and create monitoring plans to
answer at least two effectiveness questions.
The following sections describe the City's plan to meet each of the above requirements.
While the City prepared this plan to comply with its permit conditions, the City reserves
the right to modify the plan (in part or in its entirety) to reflect potential changes in City
priorities. The City is concerned that preparing a stormwater monitoring plan without a
clear problem statement and supporting experimental design may lead to collecting the
wrong data and/or inconclusive results. The City will discuss any potential changes with
Ecology before modifications are made to this plan.
STORMWATER MONITORING (U.CA.A)
Permittees shall select outfalls or conveyances based on known water quality problems
and/or targeted areas of interest for future monitoring. The Permittee shall document:
• Why sites were selected;
• Possible site constraints for installation of and access to monitoring equipment;
• A brief description of the contributing drainage basin including size in acreage,
dominant land use, and other contributing land uses;
• Any water quality concerns in the receiving water of each selected outfall or
conveyance.
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December 29, 2010
TARGETED SWMP EFFECTIVENESS MONITORING (S8.C.1.B)
Special condition S.8.C.1.13 requires that the Permittee develop a monitoring plan
designed to answer two questions pertaining to the effectiveness of the SWMP. For
each question, the plan must contain the following elements:
• A statement of the question, an explanation of how and why the issue is
significant to the Permittee and a discussion of whether and how the results of
the monitoring may be significant to other MS4s.
A specific hypothesis about the issue or management actions that will be tested.
• Specific parameters or attributes to be measured.
• Expected modifications to management actions depending on the outcome of
hypothesis testing.
The following table summarizes the two questions and the types of monitoring to be
performed.
Question
Monitoring
Are current flow control requirements appropriate
Physical channel monitoring at key cross section
for preventing channel erosion in Mill Creek?
locations.
Do stormwater discharges from Mill Pond exceed
Grab samples of water entering the Mill Pond vault
water quality criteria for fecal coliform?
and water entering the White River from the Mill
Pond outlet.
Question 1: Are current flow control requirements appropriate for preventing
channel erosion in Mill Creek?
Substantial portions of the Mill Creek basin, particularly the lower areas along the valley
floor, have been developed for many years. However, erosion and channel instability
have not been observed in the lower portions of Mill Creek, perhaps because of the flat
gradient and/or unique geology of the area. The purpose of this monitoring is to assess
the stability of Mill Creek and to evaluate the need for flow control criteria to protect the
channel.
Hypothesis: The current flow control standard is unnecessarily stringent for
preventing erosion in Lower Mill Creek.
This is a significant issue to the City of Auburn because most of the highly urbanized
areas located in the City's downtown discharge to Mill Creek. The development and
redevelopment of these core areas of the City is vital to its existence and requiring an
unnecessarily stringent flow control standard places a huge financial burden on
landowners.
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