fy20 ms4 annual report and fap summary
TRANSCRIPT
FY20 MS4 Annual Report and FAP SummaryWater Quality Advisory Group, March 8, 2021
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MS4 Permit Update
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• Current Permit Issued February 16, 2010• Expired February 15, 2015• Administratively continued until new permit is issued
• MDE Published Draft MS4 Permit, Fact Sheet and Accounting Guidance on October 23, 2020
• Comment period closed January 21, 2021
• MDE Plans to Finalize Permit in Late Spring/Early Summer 2021
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MS4 Permit Overview
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• Permit Issued to Montgomery County• Compliance and reporting coordinated by DEP• Multiple agencies involved in implementation,
including DGS, DPS, DOT and MCPS
• Water Quality Objectives• Effectively prohibit pollutants in stormwater discharges
or other unauthorized discharges into, through, or from the MS4
• Attain applicable stormwater wasteload allocations (WLAs) for each established or approved Total Maximum Daily Load (TMDL)
• Comply with all other provisions and requirements
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MS4 Permit Structure
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I. IdentificationII. DefinitionsIII. Standard Permit
ConditionsA. Permit AdministrationB. Legal AuthorityC. Source IdentificationD. Discharge CharacterizationE. Management Programs
1. Stormwater Management2. Erosion and Sediment Control3. Illicit Discharge Detection and
Elimination4. Trash and Litter5. Property Management
6. Road Maintenance7. Public Education
F. Watershed AssessmentG. Watershed RestorationH. Assessment of ControlsI. Program FundingJ. Total Maximum Daily Loads
IV. Program Review and Annual Progress Reporting
V. Special Programmatic Conditions
VI. Enforcement and Penalties
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E.1. Stormwater Management
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• Inventory of more than 15,300 BMPs
• DEP maintains almost 5,400
• More than 9,800 are privately maintained
• Performed preventive maintenance on more than 5,000 BMPs
• More than 10,000 BMPs added to inventory since 2010
• Sent 1,425 post cards to property owners to encourage self-inspection of BMPs on single family residential properties
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E.2. Erosion and Sediment Control
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• DPS reviews permit applications, inspects erosion and sediment control practices, issues notices of violation, and collects fines
• Almost 15,000 inspections, 350 enforcement actions• MDE evaluated program and found it to comply with the permit
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E.3. Illicit Discharge Detection and Elimination
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• Inspection and enforcement program to ensure that anything other than stormwater that discharges to the MS4 is either permitted or eliminated
• Screened 156 outfalls, found 46 outfalls with dry weather flows, 2 determined to be illicit discharges;
• Identified 19 new outfalls that were previously not mapped in the inventory
• Performed 47 commercial/industrial hotspot surveys, resulting in 11 notices of violation, 1 warning letter, and 5 verbal warnings
• Water quality and illegal dumping complaints are reported through the County’s call center for non-emergencies (MC311) or through DEP’s website
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E.4. Trash and Litter
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• Multiple programs and partnerships designed to meet goals of Potomac River Watershed Trash Treaty and 2010 Anacostia Trash TMDL
• Distributed 50,000 reusable bags• Due to the COVID-19:
• Increased outreach and education to residents about cleaning reusable bags
• Educational posts on social media outlets about how to dispose of PPE properly
• Sponsored volunteer cleanups stopped in March 2020
• Continued to install and retrofit BMPs that collect trash
• Awarded trash trap installation grant to Anacostia Riverkeeper
• Continued trash monitoring program• Removed trash from County-maintained
stormwater management facilities
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E.5. Property Management
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• All County agencies that operate maintenance facilities must comply with the General Permit for Discharges of Stormwater Associated with Industrial Activities
• Maintain a stormwater pollution prevention plan • Implement good housekeeping practices, such as routine
sweeping• Inspect facilities monthly • Inspect stormwater outfalls quarterly• Annual training of all facility operation employees
• There are 17 permitted sites • 3 belong to DEP, • 8 to DOT/DGS, and • 6 to MCPS
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E.6. Road Maintenance
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• DOT’s annual sweeping of residential routes was canceled due to COVID-19
• DEP swept arterial routes 24 times in FY20
• 227.2 miles per cycle• Focused on Rock Creek and
Anacostia watersheds• DOT removes material
from inlets and storm drains
• Minimal use of herbicides, no fertilizers in the row
• Track de-icing materials applied to roadways to improve salt management
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E.7. Public Education
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• In person outreach events stopped in mid-March 2020 due to COVID-19, switched to online, virtual and video communications
• 164 in person events with more than 32,700 attendees pre-COVID-19
• 70 Stream Stewards volunteers contributed 952 hours • Continued to use the My Green Montgomery
online educational portal (http://www.mygreenmontgomery.org) as news and communication arm of DEP
• 50,438 users, 189,528 page views• Posted 160 blogs (38% more than in FY19)
• Used social media to promote Salt Wise and Holiday Gift Outside the Box campaigns
• Hosted virtual events for Earth Month and Chesapeake Awareness Week
• Pet waste station partnerships with 19 communities, distributed pet waste signs in English and Spanish
• Hosted virtual public meeting with residents for Glenmont Forest green streets project
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F. Watershed Assessment
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• The County has developed implementation plans to control stormwater discharges based on systematic assessment of water quality within all of its watersheds and identification of water quality improvement opportunities
• DEP monitors the aquatic biological community (fish and benthic organisms) and stream habitat conditions on a rotating basis over a five year cycle
• 2019 monitoring was conducted in the Cabin John, Little Seneca and Dry Seneca sub-watersheds of Seneca Creek, and Potomac Direct watersheds
• Conditions have remained fairly consistent over the study period even with habitat conditions in decline since 2006
• Stream conditions generally improve toward the western part of the County where land use is more rural
• More urbanized areas, with older stormwater management, generally have poorer conditions
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G. Watershed Restoration
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• The County met the 2010 permit restoration requirement in December 2018 (3,778 acres restored)
• Restoration work has continued while the County awaits a new permit
• Completed more than 6,500 restoration BMPs including:
• 53 CIP projects• 391 RainScapes projects• 5,287 trees planted through
the Tree Montgomery and DOT Street Tree programs
• Another 14 CIP projects are already in design or construction
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H. Assessment of Controls
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• Assess effectiveness of stormwater management program and control measures
• Breewood Tributary (Anacostia Watershed)• 14 ESD, 3 RainScapes, 1,200 lf stream restoration• Preliminary monitoring results show:
• Improved hydrology• Reduced loads of total suspended solids and
pollutants that bind to it (phosphorus, copper, lead)
• Increased loads of soluble nitrogen (Total KjeldahlNitrogen and Nitrate+Nitrite), biological oxygen demand and zinc
• Assess effectiveness of stormwater management practices for stream channel protection
• Newcut Road Tributary (Little Seneca Creek Watershed)
• Preliminary monitoring results show: • Stream channel may still be in a state of flux in
response to the new development• Change in land use from agricultural to residential
has impacted the test area causing instability (erosion) in the stream channel
• Streams will remain unstable as they adjust to receiving more runoff at a faster rate from impervious surfaces in the newly developed area.
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I. Program Funding
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The County has invested more than $129 million in CIP projects and more than tripled its WQPC funding over the permit term• In FY16, legal challenges against the WQPC limited expenditures• In FY20, total expenditures associated with permit requirements decreased by 10.4% to
$59,696,011• Decrease in operating expenditures from reduced programming due to COVID-19• Decrease in design and construction projects while awaiting new MS4 permit
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J. Total Maximum Daily Loads
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• Implementation plans developed to achieve progress toward the County’s Waste Load Allocations associated with TMDLs in place when permit was issued in 2010
• Additional TMDLs added after the permit was issued also have TMDL implementation plans or are included in the Countywide Coordinated Implementation Strategy
• County stormwater controls and watershed restoration initiatives have made progress toward meeting the TMDL goals
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FY20 Financial Assurance Plan
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• Biennial Financial Assurance Plan (FAP) required by Section 4-202.1 of the Environment Article, Maryland Code
• Must be submitted every two years on the anniversary date of permit issuance (currently February 15)
• Must “demonstrate that the County […] has sufficient funding in the current fiscal year and subsequent fiscal year budgets to meet its estimated costs for the 2–year period immediately following the filing date”
• The FY20 FAP is focused mainly on ISR and documents:• Activities completed from FY10 through FY20• Planned and programmed activities from FY21 through FY25
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FY20 FAP Table 2
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PAST CURRENT PROJECTED PROJECTED PROJECTED PROJECTED PROJECTED TOTALUP THRU YEAR YEAR 1 YEAR 2 YEAR 3 YEAR 4 YEAR 5 COSTSFY 2019 a FY 2020 FY 2021 FY 2022 FY 2023 FY 2024 FY 2025
Operating Expenditures (costs)Street Sweeping Program $1,810,952 $229,220 $231,160 $231,160 $231,160 $231,160 $231,160 $3,195,972Inlet Cleaning $3,316,913 $155,664 $460,000 $460,000 $460,000 $460,000 $460,000 $5,772,577DEP Tree Montgomery $1,831,529 $531,234 $816,700 $816,700 $816,700 $816,700 $816,700 $6,446,263DEP Watershed Grants $821,723 $345,442 $400,000 $400,000 $400,000 $400,000 $400,000 $3,167,165New BMPs treating existing (Drainage Area Delineation)/Redevelopment $818,828 $118,829 $207,000 $207,000 $207,000 $207,000 $207,000 $1,972,657SWM BMP Inspection and Maintenance $17,786,537 $10,242,020 $10,683,245 $10,800,215 $10,882,122 $10,966,507 $11,053,424 $82,414,070Debt Service Payment $30,278,476 $6,100,007 $8,166,992 $8,607,600 $9,045,400 $9,114,950 $9,121,650 $80,435,075RainScapes $4,464,825 $1,172,832 $1,022,060 $1,043,532 $1,065,719 $1,088,576 $1,112,119 $10,969,663
Capital Expenditures (costs)G.O Bonds $1,645,000 $0 $0 $0 $0 $0 $0 $1,645,000General Fund (Paygo) $390,000 $0 $0 $0 $0 $0 $0 $390,000Fed Aid (Grants) $331,000 $0 $0 $2,670,000 $330,000 $0 $0 $3,331,000State Aid (Grants) $24,262,082 $0 $1,660,000 $3,000,000 $2,180,000 $2,680,000 $2,060,000 $35,842,082Water Quality Protection Charge (CIP) (Paygo) $23,540,922 $3,585,412 $6,150,000 $4,300,000 $3,230,000 $2,590,000 $3,640,000 $47,036,334Water Quality Protection Revenue Bonds $74,243,383 $0 $0 $0 $0 $0 $0 $74,243,383Stormwater Management Waiver Fee (Paygo) $2,321,000 $0 $200,000 $180,000 $180,000 $180,000 $180,000 $3,241,000Contributions (Paygo) $844,000 $0 $0 $0 $0 $0 $0 $844,000MD Water Quality Revolving Loan $4,391,707 $5,575,012 $13,110,000 $16,380,000 $10,950,000 $10,140,000 $10,250,000 $70,796,719Intergrovernmental (Paygo) $156,005 $0 $0 $0 $0 $0 $0 $156,005Subtotal Operation and Paygo: $88,381,709 $22,480,660 $28,337,157 $27,046,207 $26,518,101 $26,054,893 $27,222,053 $246,040,780Total Expenditures: $193,254,881 $28,055,671 $43,107,157 $49,096,207 $39,978,101 $38,874,893 $39,532,053 $431,898,963
Total ISRP costs except debt service: $351,463,888Compare ISRP costs (except debt service) / total ISRP actions: 155%
DESCRIPTION
Article 4-202.1(j)(1)(i)2: Projected annual and 5-year costs for the county or municipality to meet the impervious surface restoration plan requirements of its National Pollutant Discharge Elimination System Phase I Municipal Separate Storm Sewer System Permit.
Contact: Kate BennettSenior Planning Specialist, Watershed Restoration Division
Questions?