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Part 2. Process for Developing Measurable Goals Under a General Permit
CONTENTS
As the operator of a regulated small MS4, you have the
flexibility to select the BMPs and measurable goals for each minimum control
measure that are most appropriate for your system and still meet the permit
requirements. You must design and implement a comprehensive program (using the minimum measures framework) to reduce pollutants to the MEP, unless you apply for an alternative permit (though any NPDES permit for MS4s must reduce pollutants to the MEP).
Reasons why MS4s may want to tailor their program:
- To address specific water quality problems and pollutants in your area;
- To protect a significant water resource in your area (e.g., a public water supply, cold water fishery, etc.);
- To build upon existing municipal activities;
- To use an existing State or local program to meet one or more of the minimum measure requirements.
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Once submitted in the permit application, the BMPs and measurable goals that you selected become requirements of your stormwater management program. The NPDES permitting authority, however, can review your program and require changes in the mix of chosen BMPs and measurable goals if all or some of them are found to be inconsistent with the provisions of the small MS4 general permit. If you need to revise your suite of BMPs and measurable goals during the permit term, the small MS4 general permit (that your permitting authority issues) will describe how you can do that.
The following information describes steps you can take to select measurable goals appropriate for your program. As you do this, EPA recommends that you seek input from and actively involve both the public and key stakeholders.
WHAT ARE MEASURABLE GOALS?
Measurable goals are described in the Phase II rule as BMP design objectives or goals that quantify the progress of program implementation and the performance of your BMPs. They are objective markers or milestones that you (and the permitting authority) will use to track the progress and effectiveness of your BMPs in reducing pollutants to the MEP. EPA recommends that you develop a program with a variety of short- and long-term goals. At a minimum, your measurable goals should contain descriptions of actions you will take to implement each BMP, what you anticipate to be achieved by each goal, and the frequency and dates for such actions to be taken. Also, EPA recommends that you use your BMPs and measurable goals to help establish a baseline against which future progress at reducing pollutants to the MEP can be measured. For example, information on current water quality conditions, numbers of BMPs already implemented, and the public¿s current knowledge/awareness of stormwater management would be useful in setting this baseline.
There are a number of different ways you can write your measurable goals. You can consider developing measurable goals based on one or more of the following general categories:
- Tracking implementation over time. Where a BMP is continually implemented over the permit term, a measurable goal can be developed to track how often, or where, this BMP is implemented.
- Measuring progress in implementing the BMP. Some BMPs are developed over time, and a measurable goal can be used to track this progress until BMP implementation is completed.
- Tracking total numbers of BMPs implemented. Measurable goals also can be used to track BMP implementation numerically, e.g., the number of wet detention basins in place or the number of people changing their behavior due to the receipt of educational materials.
- Tracking program/BMP effectiveness. Measurable goals can be developed to evaluate BMP effectiveness, for example, by evaluating a structural BMP's effectiveness at reducing pollutant loadings, or evaluating a public education campaign's effectiveness at reaching and informing the target audience to determine whether it reduces pollutants to the MEP. A measurable goal can also be a BMP design objective or a performance standard.
- Tracking environmental improvement. The ultimate goal of the NPDES stormwater program is environmental improvement, which can be a measurable goal. Achievement of environmental improvement can be assessed and documented by ascertaining whether state water quality standards are being met for the receiving waterbody or by tracking trends or improvements in water quality (chemical, physical, and biological) and other indicators, such as the hydrologic or habitat condition of the waterbody or watershed.
EPA strongly recommends that measurable goals include, where appropriate, the following three components:
- The activity, or BMP, to be completed;
- A schedule or date of completion; and
- A quantifiable target to measure progress toward achieving the activity or BMP.
Measurable goals that include these three components and are easy to quantify will allow both you and your permitting authority to assess progress at reducing pollutants to the MEP.
STEPS TO SELECT MEASURABLE GOALS
To help you select measurable goals, EPA recommends that you:
- Consider your objective for each minimum measure. The BMPs that you choose should work toward one or more common objectives related to stormwater quality improvement and should reduce pollutants to the MEP. The objectives should be based on what is known about existing pollutant sources and problems in the watershed(s) and what is required by the minimum measure. The objective can be something you can quantify, or it can be a goal or purpose statement.
- Review the programs (municipal or other) that are already in place for each minimum measure. Use the self audit, described in Part 4, as a resource. You should coordinate with other agencies, non-profit groups, citizen groups, etc., to identify existing initiatives that can be used as part of the stormwater management program.
- Select BMPs that complement each other and work toward meeting each minimum measure. These BMPs should address the minimum measure objective identified above and meet the regulatory requirements in the minimum measure.
- For each BMP, develop expeditious milestones for implementation. You should include both a timeframe and a quantity to measure, if possible. Consider the following questions:
- When will you start implementing the BMP?
- What institutional, funding, and legal issues, if any, do you need to solve before implementation can occur, and when will these issues be solved?
- How will you keep track of the progress of implementation? (It would be useful for you to develop a spreadsheet or database to track the progress of meeting measurable goals for annual reports.)
- How can you measure whether this BMP has been a 'success at reducing pollutants to the MEP,' e.g., changes in behavior, number of BMPs implemented, or documented improvements in water quality?
- Determine how you will evaluate the effectiveness of each BMP. Although achievement of water quality standards is the goal of all CWA programs, you may need to use other means to ascertain what effects individual and collective BMPs have on water quality and associated indicators. Instream monitoring, such as physical, chemical, and biological monitoring, is ideal because it allows you to directly measure environmental improvements resulting from management efforts. You can use targeted monitoring to evaluate BMP-specific effectiveness, whereas ambient monitoring can be used to determine overall program effectiveness. Alternatives to monitoring include using programmatic, social, physical, and hydrological indicators. Finally, environmental indicators, described in Part 5, can be used to quantify the effectiveness of BMPs.
- Derive measurable goals from the evaluation methods selected in Step 5. Once you determine how to measure each BMP, you should identify the measurable goals to be achieved in the permit term. Consider intermediate goals that can help establish milestones for success. You should also develop measurable goals that consider operation and maintenance for structural BMPs where ongoing maintenance can be a concern. Ultimately, the evaluation methods that you choose for each BMP should lead to a determination of the environmental benefits of each minimum measure and the overall effectiveness of the stormwater management program in reducing pollutants to the MEP.
The Phase II NPDES program encourages you to evolve and refine your program goals throughout the five-year permit term and in subsequent permit cycles. You should consider using BMPs and setting measurable goals that are targeted to address existing water quality problems and prevent new water quality problems. For example, where suspended sediments are the major water quality problem, you may wish to focus more on the construction and post-construction measures and develop a program to address streambank erosion. In cases where information exists to develop more specific conditions or limitations to meet water quality standards, these conditions or limitations should be incorporated into the stormwater permit.
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