1. Lessons Learned from Past MS4 Audits 1/3/20161 Lessons Learned from Past MS4 Audits

2. Overview of MS4 audits in California About 40 audits conducted of over 120 MS4s Primarily Phase I MS4s, but also included several Phase II MS4s Audits began in August 2001 Copies of audit reports are available at: http://www.epa.gov/region09/water/npdes/ ms4audits.html

3. Lessons Learned from Past MS4 Audits Municipal Stormwater Program Findings Strong Public Education Programs Refining approach to construction/new development Beginning to evaluate program effectiveness Developing innovative reporting techniques Measurable goals are often lacking Maintenance programs are generally well- established Programs need to address pollutants of concern

4. Lessons Learned from Past MS4 Audits Many MS4s have strong public education programs

5. Lessons Learned from Past MS4 Audits MS4s are refining their approach to construction/new development Developing more specific standards Conducting more inspections Providing technical guidance Training and education

6. Lessons Learned from Past MS4 Audits MS4s are Beginning to Evaluate Program Effectiveness Provides guidance and program focus Helps target resources Ensures continued program support Facilitates the iterative approach Difficulty in conducting water quality monitoring of wet weather events

7. Lessons Learned from Past MS4 Audits MS4s are developing innovative reporting techniques Web-based reporting tools Standard annual reports (Phase II) Using more graphical examples

8. Lessons Learned from Past MS4 Audits Example: Tracking inspections at NOI facilities

9. Lessons Learned from Past MS4 Audits Example: Photos showing structural controls (Fairfax County, VA)

10. Lessons Learned from Past MS4 Audits Example: Evaluating construction inspections via GIS (King Co., WA)

11. Lessons Learned from Past MS4 Audits Example: King Co., WA table for tracking maintenance activities

12. Lessons Learned from Past MS4 Audits MS4 Assessment Report Includes: Audit Approach Special projects Analysis of findings Lessons learned Recommendations

13. Lessons Learned from Past MS4 Audits Common program deficiencies

14. Lessons Learned from Past MS4 Audits Lessons Learned MS4 Permit Language Greatly Affects SWMP Development and Compliance  More specific permit language often resulted in more specific SWMPs  E.g., Los Angeles, San Diego

15. Lessons Learned from Past MS4 Audits Lessons Learned Need for Clear Guidance and Direction from the Water Boards  Even detailed permits need additional guidance  Boards are working with MS4s to issue guidance (e.g., new development requirements)

16. Lessons Learned from Past MS4 Audits Lessons Learned Communication Provides Many Benefits  Audit process builds stronger relationship between MS4 and State  Direct and immediate feedback on the MS4’s program

17. Lessons Learned from Past MS4 Audits Lessons Learned A Well-Written SWMP Plan is Critical for Compliance  Some permits did not specifically require a SWMP, or a single generic SWMP was developed for all co-permittees  An MS4-specific plan is needed to describe implementation procedures, BMPs, schedules, responsibilities, and goals

18. Lessons Learned from Past MS4 Audits Lessons Learned Measurable Goals Should Be Outcome- Based  Goals should be based on the desired outcomes of the stormwater program  Goals should be developed on the basis of the pollutant of concern, sources of the pollutant, behaviors associated with the sources, and the indicator most appropriate to demonstrate a change in those behaviors

19. Lessons Learned from Past MS4 Audits Lessons Learned Annual Reports are not Effective Indicators of Program Compliance  Especially where MS4 permits lack specificity in annual reporting requirements  MS4 reluctant to voluntarily report non- compliance

20. Lessons Learned from Past MS4 Audits Summary All Phase I MS4 permit programs in California have been audited Audits have resulted in increased compliance and attention to MS4 program MS4 permit reissuance building on audit results Questions? John Kosco, john.kosco@tetratech.com