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

2. 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 TXR requirements
Contractors must still obtain separate coverage
Reduces paperwork/steps related to capital projects

3. 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

4. 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

5. 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)

6. 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

7. Oh my!

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

9. 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

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

11. 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

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