TPDES MCM 7 Makes Life Easier Howard Redfearn Environmental Manager City of Mansfield

What the heck is MCM 7?? Authorizes construction activities where the MS4 is an operator through their SWMP Only good for TPDES permits Still have to meet all TXR150000 requirements Contractors must still obtain separate coverage Reduces paperwork/steps related to capital projects

What was the Problem?? STEERS is horrible Sporadic usage makes worse Lost logins, Clunky GUI, Not user friendly Sporadic usage makes worse Costs money for every capital project Have to harass someone in management Waiting on approval/signatures can delay projects

What was the Solution?? Implement Minimum Control Measure 7 No separate NOIs for each project, uses the signature for the SWMP NOI No separate fee for each capital project Authorized until the end of the permit term

What’s the Catch? Far as I can tell, there isn’t one 3 BMPs in SWMP Review Erosion Control Plans (we were going to do it anyway) Municipal Construction Site Inspections (we were going to do it anyway) SWPPP review and retention (required as we are one of the operators)

It has to be harder in the Annual Report! There is a check box (ooooohhhhhh!) Also a check box on the NOI And report the number of projects, total acres disturbed, and inspections (only for the City) for the year (aaaaaahhhhhhh!) Plus, report the number of SWPPPs reviewed (oooooooooooooooo!) Still have to put up Construction Site Notices

Oh my!

Why aren’t more cities doing this? Honestly have no idea

But it’s the middle of the permit term  That is what the Notice of Change is for We implemented MCM 7 in the 3rd year of the previous permit term because we kept getting locked out of STEERS and having other issues

But I’m a non-traditional MS4 Nothing in the permit language says you cannot take advantage of MCM 7

So you’re saying there’s a chance! Willing to share our BMP language with any other interested parties Simple, reduces head aches, saves money (albeit not a lot), avoids STEERS like the plague (can’t wait for online report submissions), and just makes my life easier

Howard Redfearn 817-276-4240 howard.redfearn@mansfieldtexas.gov