FAQs
Frequently Asked Questions About Regional Stormwater Monitoring
Why were Recommendations for Municipal Stormwater Permit Monitoring needed?
In 2007-2012, the largest National Pollutant Discharge Elimination System (NPDES) municipal stormwater permittees conducted expensive discharge monitoring that was not delivering enough information to support better management decisions across the region. A Pollution Control Hearings Board (PCHB) ruling directed the Department of Ecology (Ecology) to require stormwater monitoring by all jurisdictions covered under the NPDES municipal stormwater permits. Without a comprehensive framework for regional stormwater monitoring, the permits would likely have required expensive individual monitoring programs. Priorities needed to be set to provide meaningful information to improve stormwater management and control costs. Permittees asked Ecology for a different approach to permit monitoring requirements. In 2008:
· The Puget Sound Partnership (Partnership) identified stormwater as a critical gap in ecosystem monitoring and the Puget Sound Action Agenda directed the SWG to establish a regional stormwater monitoring program.
· Ecology’s director formally requested a stormwater monitoring framework specific to the permits.
What is the Stormwater Work Group’s charge?
SWG defines and oversees a comprehensive stormwater component of a regional coordinated ecosystem monitoring program for Puget Sound.
Who is the Stormwater Work Group?
SWG is a diverse group of stakeholders. There are seats at the table for federal, tribal, state and local governments, public ports, environmental and business groups, and agriculture interests. SWG developed a regional stormwater monitoring and assessment strategy for Puget Sound at the request of the Partnership and Ecology. Within this framework, SWG recommended a comprehensive monitoring approach for the NPDES municipal stormwater permits. SWG continues to make broader and more detailed recommendations for stormwater monitoring and science.
What jurisdictions are affected by the regional stormwater monitoring program and permit requirements?
The Phase I and Western Washington Phase II cities and counties, the state Department of Transportation, and the ports of Tacoma and Seattle are subject to Special Condition S8 Monitoring and Assessment in the NPDES municipal stormwater permit monitoring requirements. Recently, US EPA has begun to add the option to join the regional stormwater monitoring program in the municipal stormwater permits they issue in western Washington.
What are the implications for Phase I, Phase II, and non-permitted jurisdictions, and for jurisdictions located outside of Puget Sound?
All local governments in Puget Sound benefit from the information generated by the program. Phase I and II permittees are required to choose whether to pay into a collective fund to administer a regional monitoring program or conduct alternate monitoring. Permittees and others with monitoring capacity will have the opportunity to receive funds to conduct parts of the monitoring program. Some, but not all, of the SWG’s recommendations include and benefit permittees outside Puget Sound. Ecology funded a separate effort to prioritize and plan monitoring in the lower Columbia basin, where permittees also benefit from regionally funded studies. Eastern Washington permittees conduct effectiveness studies in a separate effort.
What process did the SWG use in developing the plan?
Ecology gave SWG a great deal of flexibility to create the new approach to stormwater monitoring. Participants knew there would be monitoring in the permits and did not want to conduct the stormwater discharge monitoring required in prior permits. SWG spent two years developing a scientific framework and an implementation plan for the regional monitoring. The process included talking to people who have done this and succeeded elsewhere around the country, two public comment periods, and three large regional workshops. The plan published in 2010 has continued to be adaptively managed and implemented during the 2013-2018 permits and into the 2019-2024 permit term.
What are the advantages to local governments of adopting this new approach?
The new framework that was proposed by the SWG enabled local jurisdictions to meet their permit requirements for stormwater monitoring in an efficient and cost-effective manner. The plan:
· Helps local governments lower current and potential monitoring costs and reduce duplication of effort by allowing them to pool resources with other local jurisdictions to perform required monitoring;
· Reduces liability by paying into a collective fund to conduct the monitoring and thereby relieving them of the responsibility to collect monitoring information themselves; and
· Facilitates successful adaptive management by providing useful information about how our management actions are doing and how we can improve our approach.
How would locals proceed in the absence of a coordinated monitoring plan for Puget Sound?
Local jurisdictions subject to the NPDES municipal stormwater permits for Puget Sound would have to meet all monitoring requirements in the permit on their own – an approach that would likely be more costly and not yield information that is as regionally (or locally) meaningful and useful as we would expect from a more coordinated effort.
Why was Ecology recommended as the administrator of the pooled funds for regional monitoring?
SWG considered numerous potential entities that might serve this important role and ultimately concluded that Ecology provided the only viable option at the time because Ecology was the only entity with the administrative capacity and willingness to assume this role and responsibilities for the 2013 permits. SWG decided not to consider a different organization for the 2019 permits because Ecology received a favorable evaluation from the Pooled Resources Oversight Committee, which further cautioned that transferring the program management and administration duties to another entity would be unnecessarily costly and inefficient.
When did the plan go into effect?
The SWG-proposed regional stormwater monitoring program permit requirements were adopted by Ecology and went into effect in the 2013 NPDES municipal stormwater permits. Most permittees were not required to contribute funds until the second year of the permit. 2013 and 2014 were dedicated to preparing for implementation of the monitoring program, which was fully implemented in 2015-2016. More than two dozen studies are underway, have been completed, or are in the contracting process. The regional stormwater monitoring program was renamed Stormwater Action Monitoring (SAM) midway through the permit term. We completed the third round of solicitations for effectiveness studies in 2020.
What are the next steps?
The SWG made new recommendations for the permit monitoring requirements in June 2016 and reviewed and commented on the monitoring language proposed by Ecology for the permits issued in 2019. The next permit reissuance is in 2024 and we will work with Ecology to discuss any proposed changes. Recently, three Navy bases with permits issued by US EPA joined Stormwater Action Monitoring (SAM) and we welcome more permittees joining the regional effort. The fourth round of effectiveness study solicitations is in 2023.
How can I get involved?
SWG meetings are open to the public; find meeting dates on the SWG webpage. Join one or more SWG subgroups.