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Appendix C Summary of Responses from State Stormwater Coordinators On February 21, 2007, on behalf of the committee, Jenny Molloy of EPA’s Of- fice of Wastewater Management sent the following questions to a group of state stormwater program managers and received six responses (found in Tables C-1 and C-2). 1. For industrial and/or construction: do you have information on non-filers, i.e., folks who should have submitted NOIs, but did not? If so, how old are these data, and how do they compare to overall numbers of those with permit coverage? How did you find and/or estimate the number of non-filers? 2. Also for industrial and/or construction: do you have information on compli- ance rates? Yes, this is a really broad question, but something along the lines of: based on inspections (or monitoring data, or whatever metric you use), have you made any determinations on numbers of facilities out of compliance, or alterna- tively, in compliance? If so, define what you mean by compliance (paper viola- tions, SWPPP/BMP inadequacies, water quality standards violations, etc.). TABLE C-1 Nonfilers Information Estimate on Percent Basis of Period of State Comment Industrial Non-Filers Estimate Estimate Non-Filers as of Total CA Yes 50 percent of Study—CA Wa- 1995–1998 heavy ter Board, 1999; industry Duke and statewide Shaver, 1999. 69 percent Study— 1998–2000 Of industry Swamikannu et within City of al., 2001 Los Angeles MN No Study in progress OH No Plan outreach to business OR No Do not compile data VT Yes 88–90 Mass mailing 2006 No response percent of from 2,400 of industry 3,000 mail- ings WI No 575

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576 URBAN STORMWATER MANAGEMENT IN THE UNITED STATES TABLE C-2 Compliance Estimate of Information on Covered Period Basis of State Compliance Facilities of Comment Estimate Rates Non- Estimate Compliant MS4 con- 40 percent struction audit deficient in in Los Ange- Prioritized 2002, Yes paperwork; 30 les and Ven- large CGP 2004, (Construction) percent with tura counties, sites for and 2005 inadequate and large inspection E&S controls CGP con- CA struction sites Transporta- 60 percent tion sector, poor house- plastics keeping prac- 2005 and Yes (Industrial) manufacturing tices; 40 per- 2007 inspections in cent incom- Los Angeles plete SWPPPs County Inspect in NH No response to complaints Inspect construction OH No sites as a priority Do not OR No compile data Plan to VT No inspect for compliance Monitoring 66 percent Mailed report WV Yes (Industrial) failed to sub- 2007 deficiency submittal mit report notices tracking Perform 38 percent inspections with minor and A subsample Yes annually; no WI 43 percent of 1 percent of 2007 (Construction) central with major CGP sites database violations tracking

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APPENDIX C 577 In September 2007, the NRC Committee on Reducing Stormwater Discharge Contributions to Water Pollution sent the following survey to 50 state stormwa- ter program managers. Responses were received from 18 states, including at least one from every EPA region. The blank survey is shown below, and Tables C-3 through C-9 contain the states’ responses. The NRC committee members will greatly appreciate receiving the following information from State Stormwater Coordinators. Please complete both sides of this form and return to Xavier Swamikannu, CalEPA, Los Angeles Regional Water Board, xswami- kannu@waterboards.ca.gov or Fax: (213) 576-6625. State: Name of information provider: Please summarize your State’s Stormwater Permit Program Industrial Construction Municipal Permit General Permit General Permit What are the monitor- ing requirements? How is compliance demonstrated (monitor- ing or other activity)? To whom is the SWPPP submitted? Can an MS4 perform an inspection of an indus- try within its boundary? What industries are considered "high-risk”? Do BMP manuals exist for implementation guidance? No. of dedicated staff or FTEs

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578 URBAN STORMWATER MANAGEMENT IN THE UNITED STATES Does your State Storm Water BMP Manual contain the following, and what are they? WQ sizing criteria Recharge criteria Channel protection criteria Overbank flood criteria Extreme flows Acceptable BMP list Detailed engineering specs for BMPs Soil and erosion control requirements (unless this is left to the local government)

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APPENDIX C continued next page 579

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580 URBAN STORMWATER MANAGEMENT IN THE UNITED STATES TABLE C-3 Continued

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APPENDIX C 581

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582 URBAN STORMWATER MANAGEMENT IN THE UNITED STATES

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APPENDIX C 583

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584 URBAN STORMWATER MANAGEMENT IN THE UNITED STATES

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APPENDIX C continued next page 585

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586 URBAN STORMWATER MANAGEMENT IN THE UNITED STATES TABLE C-5 Continued

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APPENDIX C 587

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588 URBAN STORMWATER MANAGEMENT IN THE UNITED STATES

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APPENDIX C continued next page 589

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590 URBAN STORMWATER MANAGEMENT IN THE UNITED STATES TABLE C-8 Continued

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APPENDIX C 591

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