S5.C.3 Coordination
There are no specific deadlines or actions required for continued compliance with section S5.C.3 for reporting year 2024
"A written internal coordination agreement is required to facilitate internal cooperation between various City departments and divisions. Coordination with adjacent municipal stormwater permittees is also required".
Summary of Program Component
Permit section S5.C.3 addresses coordination mechanisms among departments within the City as well as those mechanisms between the City and interconnected MS4s of neighboring jurisdictions covered by a municipal NPDES SW Permit within a watershed.
The activities outlined in this section are critical to remove barriers, promote understanding of the NPDES SW Permit, and facilitate permit compliance within the departments of the City.
This section of the Permit requires coordination between the City and jurisdictions covered by a municipal NPDES SW Permit and/or connected to the City’s municipal stormwater system specifically to address a coordinated approach to stormwater policies, programs and projects within a given watershed. At its best, coordination between jurisdictions should facilitate information sharing, eliminate duplicate efforts, and promote regional solutions to most efficiently use the City’s valuable and limited resources to improve stormwater quality.
Implement Executive Directive to Facilitate Permit Compliance (S5.C.3.a.)
The City Manager and Tacoma Public Utilities Director issued a joint memorandum in the first quarter of 2020 to all City Department Directors informing them of the Permit and the need for all affected staff’s cooperation and input. The internal coordination memorandum is provided below.
ES/Environmental Programs Group staff has compiled a list of department contacts and coordinates with them to identify SWMP areas needing participation, recordkeeping and staff training.
User Groups are coordinated to bring staff from the City who are responsible for similar program elements together for training and check-ins.
ES/Environmental Programs Group acts as the City’s Stormwater Permit Coordinator and Administrator. Specific tasks for intra-governmental coordination include the following:
Identifying which permit requirements apply to each specific department and work group;
Integrating compliance activities into each department’s programs and operations;
Providing training and technical assistance if required;
Recordkeeping, or technical assistance for recordkeeping, as required in the Permit; and
Facilitating submittal of information for the Permit required Annual Report.
Conducting check-ins with staff responsible for various portions of the Permit to ensure compliance continues.
These coordination efforts ensure ongoing Permit compliance and submittal of the NPDES SW Permit Annual Report by March 31st each year.
Implement Coordination Mechanisms with Other Permittees for Control of Pollutants between Interconnected MS4s and Stormwater Management Activities for Shared Waterbodies (S5.C.3.b.)
This element of the permit has two specific coordination elements:
Coordination between the City and the physically interconnected surrounding municipal stormwater permittees (Pierce County, Lakewood, University Place, Fircrest, Federal Way, and Fife) and secondary permittees (Port of Tacoma, Tacoma Community College and Metro Parks Tacoma) for the control of pollutants; and
Coordination of activities for shared water bodies among Phase I and II Permittees to avoid conflicting plans, policies and regulations.
City staff coordinates with surrounding and Secondary Permittees as appropriate when investigating concerns about the conveyance system; upgrading the stormwater system when it affects others, source tracing stormwater pollutants; and coordinating and communicating watershed issues. The City similarly coordinates with the Puyallup Tribe for stormwater related issues in areas adjacent to properties held in Tribal trust. Coordination between all of these entities has provided an effective network of contacts, productive relationships and more efficient stormwater management.
The SEPA process can also aid in coordination for specific development projects that may impact neighboring jurisdictions. Through SEPA, neighboring jurisdictions have the opportunity to review proposals and provide comments and input.
The City’s 2021 updated Stormwater Management Manual (SWMM) went through the SEPA process to help to facilitate review by other jurisdictions. The City also provided training opportunities for the new SWMM that was open to other jurisdictions.
The City’s SWMM requires that projects that discharge to a neighboring jurisdiction’s stormwater system comply with the more stringent of the two jurisdiction’s stormwater requirements.
City development review staff also coordinate with the Tacoma-Pierce County Health Department (TPCHD) regarding development in the South Tacoma Groundwater Protection District (STGPD) as codified in Chapter 13.01.090 of the TMC. All requests for infiltration of runoff from pollution-generating impervious surfaces are discussed and coordinated with TPCHD. The South Tacoma Groundwater Protection District Infiltration Policy outlines specific requirements for infiltration of pollution generating surfaces within the STGPD and procedures for staff coordination.
On a watershed level, the City currently participates in several regional coordination efforts. The City participates in the Phase I Permittees Group and assists with facilitation of the South Sound Phase II Coordinator’s Group and participates in this and other regional Phase II Stormwater Groups. These groups hold regular meetings to discuss issues related to NPDES SW Permit implementation and share information on BMPs, Permit compliance and policies and programs. City staff also attend the Puyallup River Watershed Council, the Chambers Clover Watershed Council and WRIA 10/12 Lead Entity meetings. The City participates in the local integrating organizations for the Puyallup White River, Puget Sound Action Area (including Puyallup/White WRIA 10) and South Puget Sound Action Area (including portions of Chambers/Clover WRIA 12) supporting the Puget Sound Partnership efforts.
The City participates in the regional stormwater monitoring work group, and Stormwater Action Monitoring (SAM) group.
Environmental Services Environmental Compliance Inspectors have a list of contacts in various jurisdictions, regulatory programs, and organizations including the railroads, neighboring cities, Pierce County, state and federal government, TPCHD, Metro Parks Tacoma, Tacoma Public Schools, Tacoma Police Department, Port of Tacoma, Puget Sound Clean Air Agency, and others. These individuals are informed of spills and complaints when they cross jurisdictional boundaries.