SEQ CHAPTER \h \r 1Final
Draft
03-06-03
Revised
02-08-05
PHASE
II
STORM
WATER MANAGEMENT PLAN
Deerfield
Township, Warren County
3378 Townsley Drive
Deerfield Township, OH
45140-1045
Telephone: (513) 683-5805
ax: (513) 683-9271
Section A. Executive Summary.
Deerfield Township, Warren County, Ohio is required to submit a storm water
management plan (SWMP) in accordance with 40 CFR Part 122.32 and Ohio law.
This document outlines the steps Deerfield Township needs to take to
develop, implement and enforce a storm water management program designed to
reduce the discharge of pollutants to the maximum extent practicable, to
protect water quality, and to satisfy the appropriate requirements of the
Clean Water Act (CWA) in accordance with the Ohio EPA Phase II Program.
This SWMP addresses the six (6) minimum control members as required by state
and federal regulations. The Notice of Intent (NOI) and this SWMP were
submitted on or before March 10, 2003.
Section
B. Legal Authority.
The
Township’s legal counsel has advised that Ohio townships lack the legal
authority to implement various aspects of the six (6) minimum control
measures. Consequently, the Township is incapable of fully satisfying the
Phase II requirements without the assistance of other entities. One such
entity will be a storm sewer district to be formed under Chapter 6119 of the
Ohio Revised Code in 2003 or 2004. As you will see in the remainder of this
Plan, that district shall be the primary entity implementing much of the
following SWMP. The Township’s legal counsel will also provide a letter
opining on the lack of township authority with respect to Phase II SWMP
requirements.
The Deerfield Regional Storm Water District was formed at
the end of 2003 and the Board convened in March of 2004.
1.
Permanent Coverage Area.
The
storm water management plan covers all properties owned by the Deerfield
Township Board of Trustees or maintained by Deerfield Township and that lie
within an “Urbanized Area” as defined by the U.S. Census Bureau. In
general, this includes all legal road rights of way maintained by the
Township and all Township owned facilities. A map of the affected road
rights of way and a listing of the affected facilities are attached as
Appendix A.
2.
Reporting Requirements.
Deerfield Township will submit its required report annually during the
first term of the permit cycle. The report will include the status of
compliance with the permit conditions, and assessment of the appropriateness
of the BMPs and progress toward achieving the measurable goals for each of
the six (6) minimum control measures. A summary of the activities Deerfield
Township will undertake during the reporting cycle and any changes to BMPs
or measurable goals and all relevant data (monitoring) obtained during the
reporting period.
Section
C.
Storm Water Management
Plan.
The
Plan outlines the six (6) minimum control measures which are expected to
result in reductions in pollutants discharged in Deerfield Township, Ohio.
The six (6) minimum control measures will address the water quality
pollutants that are identified during the planning process. Each minimum
control measure will have four (4) stages: planning, programming,
implementation, and maintenance. During the planning stage, water quality
pollutants will be identified, BMPs will be selected and programs and
program materials will be developed. During the Programming Stage, the
programs developed during the Planning Stage will be scheduled. Finally,
the programs will be implemented and once they are fully implemented,
maintenance procedures will be adopted.
The six (6) minimum controls are:
(1) Public education/outreach;
(2)
Public participation/involvement;
(3)
Illicit discharge detection/elimination;
(4)
Construction site runoff control;
(5)
Post construction runoff control;
(6)
Pollution prevention/good housekeeping.
1. Public Education and Outreach.
Deerfield Township, through the storm sewer district, will work in
cooperation with the Warren County Soil and Water Conservation District (WCSWCD),
with the district staff serving as the lead agency on this minimum control
measure (MCM).
The Township has no major industrial
or
manufacturing sources of pollution.
Therefore, the District will focus on educating the public on construction
and residential runoff. The District will work with the Warren County
Engineer (WCE) and the WCSWCD who are the authorized review agencies to
monitor construction activities.
To address residential issues, the
District will work with the WCSWCD on education in the schools
and storm drain stenciling. The District will
also
provide signage and make information available to the public.
A survey of residents will be used in years three, four, and five to gauge
the rise in public awareness.
Minimum
Measure Objective.
Implement a public education and outreach program to distribute educational
materials to the community or conduct equivalent outreach activities about
the impacts of storm water discharges and steps the public can take to
reduce pollutants in runoff.
BMP:
Storm water information distribution to the general public.
Measurable
Goal. The
district will secure brochures and/or fax sheets from Ohio EPA and USEPA and
possibly develop its own newsletter or fact sheet to distribute to all
residents of the Township throughout the five (5) year implementation. The
Township will try to ensure that each resident receives at least one (1)
publication. Additional distribution will be dictated by budget
availability.
BMP: Develop alternative
information sources such as websites, billboards, and refrigerator magnets.
Measurable
Goal.
Either the Township website or the new district’s website will include storm
water information and will be posted within one (1) year after the formation
of the district. The district, Township and WCSWCD will develop
refrigerator magnets and place billboard advertisements as budget
availability dictates.
BMP:
Conduct storm drain stenciling, tagging project with accompanying
doorhangers for residents.
Measurable
Goal. The
district, Township and WCSWCD will develop drain stenciling or tagging to
place on every storm sewer within the Township by the end of the permit
term. As those storm drain stenciling and tags are installed, neighboring
residents will also receive doorhangers providing information about storm
water runoff as budget availability dictates.
BMP:
Stormwater education program for school children.
Measurable
Goal.
Fifty percent (50%) of all school children (K-12) within Deerfield Township
will be educated every two (2) years on storm water pollution by providing
the schools with materials, live presentations, brochures, and other
appropriate and feasible media as budget availability dictates.
BMP:
Organize school/community sponsored action projects such as stream cleanup,
riparian tree planting, stream bank stabilization.
Measurable
Goal. The
district, Township and WCSWCD will organize one (1) action project per year
to cleanup various streams within the Township. They will also organize one
riparian tree planting and stream bank stabilization project twice during
the five (5) year permit term.
BMP: Create a storm water hotline.
Measurable
Goal. If
funding permits, the three (3) entities will create a storm water hotline
for residents to call and report any storm water pollution violations. This
number may be a separate number or may simply be a direct line to the
Township, district or WCSWCD offices.
BMP:
Develop watershed/tributary signage to identify streams.
Measurable
Goal. The
district, Township, and WCSWCD will develop signage to be placed at
strategic locations along all tributaries throughout the Township. This
effort will be completed by the end of the five (5) year permit term as
budget availability dictates.
2.
Public Participation/Involvement.
Deerfield Township, in
cooperation with the new storm sewer district, and the WCSWCD staff will be
the primary entities implementing this MCM.
To evaluate the success of this MCM, the District will track the number of
residents attending public meetings and participating in
the programs. The District will also ask participants to
complete survey cards.
Minimum
Measure Objective.
Involve stake holder groups, including local governments, businesses, and
citizens, in making decisions about storm water management priorities and
programs.
BMP:
Conduct public meetings to obtain community input.
Measurable
Goal. The
district, Township, and WCSWCD will hold one (1) public meeting in 2003 and
one (1) meeting in 2004 to inform citizens about storm water impacts and
gain support for the proposed storm water management plan. These meetings
will both educate the public and provide a forum for public input.
BMP:
Creation of “adopt a storm drain program”, and “adopt a stream” within the
Township.
Measurable
Goal. The
Township will work with community groups to adopt as many storm drains
within the Township as possible to help clear debris from the drain
entrances and report any illicit discharge. The program will be tailored to
allow participation from any group or organization within the Township. By
adopting the stream, the adopter will clean up, monitor, and inspect their
portion of the stream through guidelines adopted at a later date. The
program and activities will be publicized through the various items
distributed in the public education and outreach minimum control measure and
will also be partnered with the local schools to perform various functions
including water quality testing.
3. Illicit Discharge
Detection And Elimination.
The
Township, to the extent permitted by law, and district will be the lead
agencies for this minimum control measure. Significant assistance from the
Warren County GIS, the Warren County Board of Health, and the Warren County
Engineer’s Office in the preparation of intelligent mapping is anticipated.
The Township itself has no authority to regulate illicit discharges.
However, when the Township storm sewer district is established, the district
will coordinate regulations with the Warren County Board of Health.
The District will meet annually with the Warren County Board of Health,
which is the regulatory agency for illicit discharges in the Township,
to monitor and understand changes in their rules and regulations and assist
them in monitoring problems and tracking complaints.
The District will develop a system with the Warren County
Health Department to track complaints through logs and annual reports from
WCHD.
Minimum Measure Objective. Develop a
comprehensive map of the storm drain system, establish and carry out
procedures to identify and remove illicit discharges, establish legal
authority for enforcement actions, and encourage public education and
involvement in eliminating illicit discharges. (Illicit discharges are
defined as any discharge not entirely composed of storm water and are
considered “illicit” because MS4s are not designed to accept, process, or
discharge such non-storm water waste.)
BMP: Create a map of the home
sewage treatment systems.
Measurable
Goal.
Within the five (5) year permit term, the Township and the district will
work with Warren County GIS to create a map of the home sewage treatment
systems. An associated database containing the owner’s name and address as
well as other information about the HSTS will be connected to the map by
Warren County GIS.
The District will complete the mapping on the following schedule: 2005
–
30%,
2006
–
35%,
2007 – 35%.
After this mapping is complete,
the District will be better able to identify problems with
older sanitary sewer lines and will work with the Warren County Health
Department on a case by case basis to correct these problems.
BMP:
Identify illicit connections through dry weather screening and targeted
video inspection.
Measurable
Goal. A
survey during dry weather of the twenty percent (20%) of the storm drain
system outfalls per year will be conducted to identify non storm water
flows. Once each year’s survey is complete, areas with suspicious
discharges will be inspected again to detect suspected direct connections to
the wastewater system and identify areas where wastewater might be leaking
into adjacent storm water pipes.
In 2005 the District will meet with the Warren County Health Department to
discuss this screening.
BMP: Develop a storm drain system map.
Measurable
Goal.
Within the five (5) year permit term, the Township and the district will
work with the Warren County Engineer’s Office to develop a storm drain
system map showing the location of all pipes, structures, outfalls,
detention basins, and the names and locations of all surface waters of the
state within the Township. The Township and the district will also develop
and prioritize a list of outfalls that discharge into the Deerfield Township
MS4, based on the degree of development and/or other determining factors.
The District will complete
this goal
on the following schedule: 2005 – 30%, 2006 – 35%, 2007 – 35%.
BMP:
Illicit discharge/illegal dumping hotline.
Measurable
Goal. A
hotline for citizens to report illegal dumping and suspicious discharges
will be established during the five (5) year permit term if funds are
available. If no independent hotline is established, residents will be
educated through the various publications and outreach materials of the need
to report illicit discharges and the appropriate district or township phone
number to call to report such discharges.
4. Construction Site
Runoff Control.
The
Warren County Soil and Water Conservation District will be the lead agency
for this minimum control measure. Significant assistance from the Warren
County Engineer’s Office (WCEO) is also anticipated.
Minimum
Measure Objective.
Develop, implement, and enforce a program to reduce pollutants in storm
water runoff to the small MS4 from construction activities that result in a
land disturbance of one (1) or more acres.
BMP: The WCSWCD currently
administers construction site runoff control within Deerfield Township for
projects involving areas of disturbances of five (5) acres or greater in
size. A copy of the current regulations can be found in Appendix B. After
the storm sewer district is formed, that district will adopt similar
regulations for all projects disturbing one (1) acre or more within the
Township.
Measurable
Goal.
Draft regulatory guidelines will be developed within one (1) year after the
formation of the proposed storm sewer district. Final regulations will be
available within two (2) years after the establishment of the district. In
any event, these regulatory mechanisms will require the implementation of
proper erosion and sediment controls, and controls for other wastes, on
applicable construction sites. These procedures will also include site plan
review of construction plans that consider potential water quality impacts;
procedures for site inspection and enforcement of control measures;
sanctions to ensure compliance; and procedures for the receipt and
consideration of information submitted by the public. Maximum compliance
with the ordinance should be achieved after three (3) years. Improved
clarity and reduced sedimentation of local water bodies should be
measurable.
BMP:
Develop a certification program for contractors.
1. Measurable Goal. Achieve eighty percent
(80%) compliance with the requirements by the end of the first permit term.
5. Post Construction
Runoff Control.
Deerfield Township, to the extent permitted by law, and the district will
cooperate with the WCEO to be the lead agencies for this minimum control
measure.
Minimum
Control Objective.
Develop, implement, and enforce a program to address storm water runoff from
new development and re-development projects that disturb one (1) or more
acres of land.
By 2007 Warren County regulations will require as-built
documentation that a site is constructed as designed for parcels one acre or
more. They will also be requiring BMPs for post construction storm water
management. Deerfield Township will be covered by these regulations. The
Warren County Soil and Water Conservation Department also monitors streams
within the Township. Volunteer groups also test the Little Miami River and
Landen Lake periodically.
BMP:
Continue to administer, in cooperation with the WCEO, the “post development
runoff management” program through the existing “Warren County, Ohio Rules
and Regulations for the design of sewer and storm water management systems”.
(See Appendix C)
Measurable
Goal. The
WCEO Rules and Regulations will be immediately implemented within the
Township. The newly developed district and township will work with the
engineer’s office to modify those rules in any way, including expansion of
the Rules and Regulations, to ensure adequate long term operation and
maintenance of the controls.
BMP:
Develop master plans, comprehensive plans, and integrated zoning ordinances
to promote and improve water quality by guiding the growth of the community
away from sensitive areas and restricting certain types of growth to areas
that can support it without compromising water quality.
Measurable
Goal. By
the end of the five (5) year permit term, a master plan would be developed
to direct development away from sensitive areas and which integrates post
construction runoff regulations.
6. Pollution
Prevention/Good Housekeeping.
The district, working with the Township, will be the lead agency on this
minimum control measure.
The Township does not own or operate any facility subject to Ohio EPA
Industrial Storm Water Permit.
Minimum
Measure Objective.
Develop and implement an operation and maintenance program that includes a
training component and has the ultimate goal of preventing pollutant runoff
from municipal operations.
BMP:
Training program for public employees of the Township.
Measurable
Goals.
Within the first year of the permit, all Township and district employees
will receive pollution prevention materials. Within the first year, the
district, working in conjunction with the Township, will develop a pollution
prevent workshop for all Township employees responsible for grounds
maintenance and landscaping at public facilities. Each year after that, the
district and Township will hold an additional workshop once per year for new
employees and crew managers. By the end of the five (5) year permit term,
the goal is to achieve a reduction in fertilizer and pesticide use by the
Township, as budget availability dictates.
BMP:
Develop a pollution prevention plan within the first year of the permit term.
Measurable
Goals.
The district, working with the Township, will develop a Pollution Prevention
Plan which details controls and programs to promote recycling, minimize
pesticide use, insure the proper disposal of animal waste, storm drain
system cleaning procedures and schedules, street sweeping, etc. This plan
should be completed within the first year and fully implemented within the
third year of the permit term.
BMP:
Develop spill prevention and control plans for Township facilities.
Measurable
Goals.
The Township will develop a plan to reduce spill prevention, including spill
containment, spill response training and additional training to reduce
pollution from Township facilities resulting from automobile maintenance,
vehicle washing, and other pollution causing activities.
BMP:
Incorporate the use of road salt storage control and implement road salt
alternatives for roadway de-icing.
Measurable
Goals.
Within the first year, the Township will develop a program to improve salt
storage controls, including siting and design considerations. The Township
will also investigate the feasibility of less toxic alternatives for roadway
de-icing. The implementation of these alternative de-icing mechanisms will
be somewhat dependent on budget considerations.
Section
D. The Deerfield Township Storm Sewer District.
As you
will see from the accompanying letter from our attorney, Deerfield Township
(and other townships in the state of Ohio) lack legal authority under the
Ohio Revised Code to fully perform all functions necessary to implement a
storm water management plan. Consequently, Deerfield Township has embarked
upon the formation of a storm sewer district under Chapter 6119 of the Ohio
Revised Code. This district will have the authority to implement those
aspects of the above plan that the Township itself was not able to
implement. At the time of the preparation of this plan, the formation of
said storm sewer district appeared to have no organized opposition.
Consequently, the formation of said district is likely. Nevertheless, in
the event that some opposition or some other factor would prevent the
formation of the said district, the Township would be placed in a position
of inability to comply with all aspects of this storm water management plan,
and thus an inability to fully comply with all Phase II requirements. In
the event the district is not formed, this plan will require significant
modification at some future date. Those modifications will need to seek
assistance from other entities capable of assisting the Township with the
implementation of the plan. Of course, if the Ohio Revised Code is amended
to supply townships with specific and sufficient authority to comply with
Phase II requirements, the Township would be in a position to be able to
comply. While the formation of the storm sewer district is likely, the
amendment of the Ohio Revised Code is certainly unknown at this time.
Section
E. Certification.
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
managed the system, or those persons directly responsible for gathering the
information, information submitted is, to the best of my knowledge, true,
accurate and complete. I am aware that there are significant penalties for
submitted false information including the possibility of fine and
imprisonment for known violations.
________________________________
Deerfield
Administrator
