4: <br />/; <br />! ,!~ <br />,y • _ ~ <br />3.6 Permit Renewal Submittal (September 2008) <br />As described in Section 1.2, the City of Eugene's current, second-term, MS4 permit will expire <br />in February 2009. The City is required by the current permit to submit a permit renewal <br />application package 180 days prior to expiration, by September 2, 2008. The permit renewal <br />application must include an updated SWMP that synthesizes the implementation and findings of <br />the current permit cycle and evaluate the adequacy of the SWMP in reducing pollutants to the <br />maximum 'extent practicable. The permittees worked with DEQ to develop a template and <br />process for evaluating MEP that included the following three factors: <br />: Program effectiveness . <br />• Local applicability <br />• Program Resources <br />This section describes how these three factors are taken into consideration and ensure that the <br />SWMP continues to meet MEP. Subsection 3.6.1 describes the 2008 SWMP evaluation process, <br />results and corresponding SWMP modifications and rationale. Section 3.6.2 describes the public <br />involvement conducted for the 2008 permit renewal, the response to comments, [and <br />corresponding SWMP modifications.] <br />• Program effectiveness: Describe how the program continues to address pollutants of <br />concern in MS4 discharges to local receiving waters. <br />o Biannual stormwater survey and internal coordination on issues that require <br />focused education and outreach. (AI) <br />o Track and document BMP activities in various databases, daily reports, etc. and <br />summarize in annual reports (all) <br />o Review water quality condition and water quality issues to help prioritize capital <br />projects (e.g. water quality facilities in high source areas) and development <br />standards (headwater flow controls) (El, E4) <br />o Analyze water qualiry data and conduct trend analysis for ambient. (Monitoring <br />Results section of this submittal) <br />• Local applicability: Describe how the program continues to be appropriate for local <br />conditions (climate, geology, hydrology, etc.). <br />o Reference process to develop original SWMP and that public is involved in <br />helping shape significant new proposals (stormwater basin plans, SW <br />development standards) <br />o Stormwater basin plans applied CSWMP policy to delineated basins with unique <br />characteristics, problems and opportunities. <br />o Use example of stormwater development standards process, including staff and <br />consultant technical work to customize standards for Eugene's climate, soils, <br />slopes, water quality concerns; DAC review; public outreach; adoption process <br />including Council modification to threshold ISA. <br />o Participate on the steering committee of the LTWC. <br />o Coordination on a local level (IGA with Lane County and RR-SC basin planning <br />with Lane Counry; education and outreach collaboration with Lane County and <br />Sprin~eld; other collaboration as opportunities arise). <br />