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~ - ~i. <br />r. ~ <br />~' <br />PERMITTEE DISCUSSION DRAFT <br />APPROACH FOR DEMONSTRATING MEP <br />3/24/2008 DRAFT - *~'•d~ 3~~ <br />The March 13 version of this document was provided to DEO at the March 13, 2008 ACWA Phase I <br />Permit Renewal Meeting. DEQ will provide comments on this document to the pennittees at the Apri14, <br />2008 ACWA Phase I Permit Renewal MeetinQ. DEO may request additional detail under each evaluation <br />factor. To anticipate this request, this document includes potential examples for the permittees to consider <br />and discuss (shown in track changesl. For reference, under each evaluation factor is applicable text (track <br />cha~ges bold fontl excerpted from DEO's November 15, 2007 MEP document. <br />At DEQ's request, the following outline proposes a common approach the permittees can use to <br />explain the process for demonstrating how their stormwater management program (SWMP) <br />reduces pollutants in stormwater discharges to the maximum extent practicable (MEP) for <br />purposes of the 2008 permit renewal submittal.. ~This approach is intended to respond to DEQ's <br />request for all Phase 1 permittees to use a consistent process, while allowing flexibility for each <br />permittee to address the components as appropriate. <br />INTRODUCTORY STATEMENT (SUGGESTED/OPTIONAL) <br />MS4 pernvttees must implement a program to reduce the discharge of pollutants to the maximum <br />extent practicable (MEP), including management practices, control techniques and systems, and <br />design and engineering methods. The program varies by municipality and should be developed <br />in a flexible manner in considerarion of site-specific conditions to optimize reductions in <br />stormwater pollutants on a location-by-location basis. The program includes best management <br />practices (BMPs), monitoring , and other available and reasonable controls, which are then <br />documented as requirements in the permit and Stormwater Management Plan (SWMP). <br />MS4 permittees initially developed and established the program that met MEP as part of their <br />original 1993 (OR APPLICABLE YEAR) permit application. That program has become the <br />foundation for each permittee's program - a foundation that has been continuously evaluated and <br />improved through adaptive management since 1995 (OR APPROPRIATE PERMIT ISSUANCE <br />YEAR DEPENDING ON JURISDICTION). As a result, the program described in the <br />permittee's proposed SWMP is the result of the cumulative effect of implementing; <br />continuously evaluating, and making corresponding changes (i.e., adaptive management) to a <br />variety of technically and economically feasible BMPS that ensure that the most appropriate <br />controls are implemented in the most effective manner based on site-specific conditions. <br />(PERMITTEE NAME) has used the following four sequential processes to ensure its SWMP <br />meets the MEP standard: <br />- I. The original development of the SWMP submitted with the 1993 permit application. <br />II. The continual adaptive management process reported in annual reports. <br />III. The SWMP review conducted for the Interim Evaluation Report in 2006 (OR <br />SECOND ANNUAL REPORT SUBMITTED IN 2005, DEPENDING ON <br />PERMITTEE). <br />DRAFT MEP Approach 03 24 OR detail added.doc <br />_ - - .4.»~ <br /> <br />