Stormwater Permit Renewal Update

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~ 1% Measurable Goals ~ The current permits require that permittee's SWMPs include "measurable performance indicators" in their SWMPs in order to assist with reporting on the status of implernentation. The permit also uses the term "performance measures" with respect to TMDL. parameters. There was considerable confusion amongst the, permittees about what these ferms mean and when they should be applied, as evidenced by the wide variety of approaches used in their SWMPs and annual reports. However, measures of performance (regardless of the terminology used) were consistently reported by permittees retroactively. For example, a SWMP would use "miles of streets swept" as a pertormance measure and their annual report would indicate the number of miles swept during the previous year. DEQ believes that the intent of including performance measures in a SWMP is so that someone can look at the SWMPs and know what is going to be done and when. To clarify and simplify~this requirement, DEQ proposed to borrow the "Measurable Goals" requirement from the Phase II stormwater rules. Measurable goals are quantitative and prospective. Using the example above,~the SWMP would indicate how many miles of streets the permittee intends to sweep per year and the annual report would indicate how many miles were actually swept. DEQ requested that the SWMPs submitted with the permit renewal applications include prospective, measurable goals. Permittees agreed on the need for measurable goals and will include them in their SWMPs. The goals will identify things the permittees intend to do and when they intend to do them. For example, permittees will estimate the miles of streets that will be swept or number of catch basins that will be cleaned annually. Anticipated Permit Language DEQ will remove references to "pertormance measures" and "performance indicators" and ~~ replace them with Measurable Goals. This will be consistent with what the Phase II communities . are doing and will allow DEQ and the public to evaluate what the permittees intend to accomplish during the perrriit cycle. In reviewing the SWMPs submitted as part of the permit renewal application package, DEQ will evaluate the adequacy of the Measurable Goals prior to issuing the next round of permits. Subsequent annual reports will show progress toward achieving the Measurable Goals. TMDL Benchmarks TMDL benchmarks serve to gauge the overall performance of MS4 stormwater programs compared with the TMDL wasteload allocation(s) assigned to urban stormwater. In order to foster creative approaches, the existing MS4 permits allowed flexibility in how the municipalities developed and expressed the benchmarks. The eight municipalities that have developed TMDL benchmarks chose to use a variety of modeling and other analytical techniques and a range of methods. The number of municipalities that will be required to develop and express TMDL benchmarks will increase as a result of the Willamette River TMDL. Therefore, some level of consistency amongst the municipalities is needed in order for DEQ to evaluate progress toward achieving TMDL wasteload allocations. DEQ requested that benchmarks be consistent in the following areas: • Modeling Scenacio Time Periods • How Benchmarks are Expressed • Structural BMP effectiveness • Accounting for non-structural BMPs • Accounting for Development and Re-development S~ ,; The permittees agreed to provide consistency in most of the areas that DEQ requested, but ; s~ voiced concern about being able to be consistent when it comes to "Development and Re-. 7