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HomeMy WebLinkAboutNCS000504_13_2018 Annual Report Narrative_20181031  NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT SUBMITTED TO THE DIVISION OF ENERGY, MINERAL, AND LAND RESOURCES OCTOBER 2018 I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. _________________________________ Adam G. Mitchell, Town Manager _________________________________ Date TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT    Table of Contents  1.0Storm Sewer System Information 1.1Population Served 1.2Growth Rate 1.3Jurisdictional & MS4 Service Areas 1.4MS4 Conveyance System 1.5Land Use Composition Estimates 1.6TMDL Identification 2.0RECEIVING STREAMS 3.0Existing Water Quality Programs  3.1Local Programs  3.2State Programs  4.0Permitting Information  4.1Responsible Party Contact List  4.2Organizational Chart  4.3Signing Official  4.4Duly Authorized Representative  5.0CO-PERMITTING INFORMATION  6.0RELIANCE ON OTHER GOVERNMENT ENTITY  6.1 Name of Entity  6.2 Element to be Implemented  6.3 Contact Information for the Responsible Party  6.4 Legal Agreement  7.0STORMWATER MANAGEMENT 7.1Public Education and Outreach on Stormwater Impacts 7.2 Public Involvement and Participation 7.3Illicit Discharge Detection and Elimination 7.4 Construction Site Stormwater Runoff Control 7.5 Post-Construction Stormwater Management in New Development and Redevelopment  7.6 Pollution Prevention/Good Housekeeping for Municipal Operations  TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT   1.0 Storm Sewer System Information 1.1 Population Served Data from the Census Bureau indicated that the Town of Fuquay-Varina (referred to hereinto as Town) had a population of approximately 25,949 in 2016. As of July 1, 2017, an estimate places the population at approximately 27,906. The Town does not experience seasonal increase in population. 1.2 Growth Rate Fuquay-Varina’s Economic Development Department estimates the Town’s population in 2017 was 23,987 and projects that the population will reach approximately 33,978 by 2022. This is an increase of approximately 42% over a 5-year period. 1.3 Jurisdictional & MS4 Service Areas The Town’s corporate limits currently comprise approximately 16.55 square miles while the Town’s extraterritorial jurisdiction (ETJ) encompasses approximately 13.49 square miles. The Town MS4 service area is the ETJ and Corporate Limits combined (a total of approximately 30.04 square miles). 1.4 MS4 Conveyance System Most stormwater begins in any given sub-basin as sheet flow (creating a “non-point source” for surface water pollution). Ultimately however, this stormwater runoff will become concentrated flow at the receiving stream. In the Town’s urban areas, stormwater runoff often becomes concentrated prior to the receiving stream as it enters roadside ditches or pipe systems. As development continues to occur in the Town of Fuquay-Varina, an increasing portion of runoff will flow across man-made impervious surfaces and become concentrated in man-made pipes or ditches prior to entering the receiving stream. As with most modern storm sewer systems, the Town’s MS4 is not combined with any portion of its sanitary sewer system or other discharges (unless by an illicit connection). Currently, the responsibility for stormwater conveyances and infrastructure rests solely with the owner, or entity that possesses specific rights to the system. For example, private drainage systems and drainage ditches are maintained solely by property owners or other responsible parties (i.e. homeowner’s associations); and the numero us NCDOT streets, storm drainage, and rights-of-way that traverse throughout the Towns’ ETJ are maintained by the NCDOT. The Town does assume responsibility for the upkeep of storm drainage pipes and roadside ditches that exist inside of Town-owned right-of-way. One of the goals of the Town’s Stormwater Program is to assign responsibility to private owners and public agencies alike and hold all parties, the Town included, accountable for pollutants that enter the MS4 and for the quality of its surface waters in general. TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT   Town Staff has also completed mapping of a large majority of the drainage inlets in the system. The Town has entered a significant percentage of the storm drainage pipes that are available via electronic means (as-builts provided electronically). The Town continues to fill in data gaps and update this mapping as new infrastructure is installed. 1.5 Land Use Composition Estimates The following land use proportions are estimated for the Town’s MS4 service area: LAND USE SQUARE MILES PERCENT Residential 12.31 mi² 40.98% Commercial 2.17 mi² 7.22% Industrial 0.80 mi² 2.67% Undeveloped 11.92 mi² 39.70% Right of Way 2.84 mi² 9.43% TOTAL 30.04 mi² 100% Estimate Methodology The proportionate land uses as listed in the previous section were estimated for the Town’s MS4 service area using parcel data from Wake County GIS obtained in October 2018. Specifically, land use classification was determined from the Wake County metadata Land_Class_1 for the parcel, resulting in a more accurate estimate from previous reporting years. See the TownGIS website. 1.6 TMDL Identification Section 303(d) of the Clean Water Act requires States to develop a list of waters not meeting federal water quality standards and to correct the impaired waters by developing a management strategy or a total maximum daily loading (TMDL). Currently, portions of Middle Creek, Neill’s Creek and Terrible Creek are listed as impaired waters within the Town’s jurisdiction according to North Carolina’s approved 2016 Impaired Waters List. The 2018 303(d) Listing and Delisting Methodology was approved 3/8/18. TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT2.0 RECEIVING STREAMS NEUSE RIVER BASIN Receiving Stream Name Stream Segment Stream Index # Water Quality Classification Use Support Rating Water Quality Issues (see Note) Middle Creek From dam at Sunset Lake to small impoundment upstream of US 401 27-43-15-(4)a1 C; NSW Impaired The impaired section’s parameter of interest: Fish Community Poor. Basal Creek (Bass Lake, Mills Pond) From source to Sunset Lake, Middle Creek 27-43-15-3 B; NSW FS None identified in the 2002 and 2009 Neuse River Basinwide Plan Terrible Creek (Johnsons Pond) From source to dam at Johnson’s Pond 27-43-15-8-(1) B; NSW FS None identified in the 2002 and 2009 Neuse River Basinwide Plan Terrible Creek From dam at Johnsons Pond to Middle Creek 27-43-15-8-(2) C; NSW Impaired The impaired section’s parameter of interest: Benthos Fair Black Creek (Partins Pond, Panther Lake) From source to dam a Panther Lake 27-45-1 B; NSW FS None identified in the 2002 and 2009 Neuse River Basinwide Plan Little Black Creek From source to Black Creek N/A B; NSW FS None identified in the 2002 and 2009 Neuse River Basinwide Plan TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT CAPE FEAR RIVER BASIN Receiving Stream Name Stream Segment Stream Index # Water Quality Classification Use Support Rating Water Quality Issues (see Note) Neills Creek From Source to a point 0.3 miles upstream of Wake-Harnett County Line 18-16-(0.3) C Impaired The impaired section’s parameter of interest: Benthos Fair. Kenneth Creek From source to Wake-Harnett County Line 18-16-(1) C S The Kenneth Creek Wastewater Treatment Plant was taken offline in 2007. Since then, this section of stream has improved to supporting and is now listed as a category 2 with no impairments. Major Unnamed Tributary to Kenneth Creek From source to Kenneth Creek N/A C FS Same as Kenneth Creek TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT 3.0 Existing Water Quality Programs 3.1 Local Programs Component Program Responsible Position Name Phone Fax Email Overall Administration Town Engineer Tracy A. Stephenson, P.E. 919-753-1039 919-552-7481 tstephenson@fuquay-varina.org Public Education & Outreach Program Staff Engineer Matthew B. Poling, P.E. 919-753-1035 919-552-7481 mpoling@fuquay-varina.org Public Involvement & Participation Program Staff Engineer Matthew B. Poling, P.E. 919-753-1035 919-552-7481 mpoling@fuquay-varina.org Illicit Discharge Detection & Elimination Program Staff Engineer Matthew B. Poling, P.E. 919-753-1035 919-552-3601 mpoling@fuquay-varina.org Construction Site Runoff Program* Staff Engineer Jennifer Mitchell 919-753-1004 919-552-7481 jmitchell@fuquay-arina.org Post-Construction Stormwater Management Program Staff Engineer Jennifer Mitchell 919-753-1004 919-552-7481 jmitchell@fuquay-varina.org Pollution Prevention/Good Housekeeping (Municipal O&M) Program Staff Engineer Jennifer Mitchell 919-753-1004 919-552-7481 jmitchell@fuquay-varina.org * Erosion and sedimentation control permits are required for construction sites that disturb an area of 1 acre or greater. The Town obtained local program delegation for erosion control on September 7, 2018. TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT   3.2 State Programs More than half of the Town’s MS4 service area lies in the Neuse River Basin, and thus drains into nutrient sensitive waters (NSWs). The Town’s Stormwater Management Program and incorporation of Neuse buffer requirements into the LDO ensures compliance with this program. The Town coordinates with NC DEQ and USACE on 401/404 permitting for impacts to waters of the State. 4.0 Permitting Information 4.1 Responsible Party Contact List The above table (See 3.1) provides the contact information for the person and/or position that is responsible for implementation of each goal. TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT   4.2 Organizational Chart   TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT   4.3 Signing Official Adam Mitchell, Town Manager for the Town of Fuquay-Varina, oversees all departments in the Town and has signed this annual report (See Cover Page). 4.4 Duly Authorized Representative Not Applicable. 5.0 CO-PERMITTING INFORMATION Not Applicable. 6.0 RELIANCE ON OTHER GOVERNMENT ENTITY 6.1 Name of Entity Wake County 6.2 Element to be Implemented From November 1, 2017 through September 7, 2018, Construction Site Runoff Program (Sedimentation and Erosion Control Program) was administered by Wake County. The Town obtained local program delegation for erosion control on September 7, 2018. 6.3 Contact Information for the Responsible Party See Section 3.1 for current contact information. Contact for 11/1/17-9/7/18 timeframe: Wake County Environmental Services, Watershed Management Section Melinda Clark, ACIP, CFM Watershed Manger 336 Fayetteville Street Raleigh, NC 27602 919-856-5531 melinda.clark@wakegov.com 6.4 Legal Agreement Wake County administered the Sedimentation and Erosion Control program through September 7, 2018 per the Town of Fuquay-Varina LDO. The LDO was amended on June 4, 2018 for the purpose of erosion control delegation. The amendment became effective on September 7, 2018. TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT   7.0 STORMWATER MANAGEMENT The purpose of the Phase II Stormwater Requirements is to protect, maintain and enhance the public health, safety, environment and general welfare by establishing minimum requirements and procedures to control the adverse effects of increased post development stormwater runoff and nonpoint and point source pollution associated with new development and redevelopment as well as illicit discharges into municipal stormwater systems. It has been determined that proper management of construction-related and post- development stormwater runoff will minimize damage to public and private property and infrastructure, safeguard the public health, safety, and general welfare, and protect water and aquatic resources. The Town administers and enforces its stormwater management program (SWMP) per the Town Land Development Ordinance, §9-1405 Stormwater Management Regulations and the Town Standard Specifications and Construction Details, 110.04 Stormwater Management. 7.1 Public Education and Outreach on Stormwater Impacts Target Pollutant Sources The Town’s public education program will target three main pollutants to begin with: sediment, nitrogen and phosphorous. These pollutants are the major concerns for the Neuse River Basin and Wake County as a whole. The Town will expand the public education program to include other pollutants, as they become a problem for the area. Target Audience The Town of Fuquay-Varina public education and outreach program will target residential, commercial, and industrial property owners, as well as students of all ages. Outreach Program The Town of Fuquay-Varina implements a public education and outreach program that is designed to distribute educational materials to the community and conduct outreach activities that educate the community about the impacts of storm water discharges to local water bodies and the steps that can be taken to reduce storm water pollution. Since the proposed Phase II permit was issued, the Town has been a member of the Clean Water Education Partnership (CWEP). The resources provided by CWEP membership help the Town get stormwater information into the hands of the public. The main element in the Town’s public education and outreach program is the stormwater education section on the Town’s website. The stormwater web site is primarily used for educating citizens on ways to prevent stormwater pollution and help preserve water quality specifically in lawn and garden activities, as well as water conservation practices. TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT   The Town has been involved with stormwater public education and outreach in many ways. The Engineering Department participates in Town outreach events and distributes stormwater education materials to Town residents. Outreach events include Town festivals and school outreach events. Topics included yard waste, animal waste, illicit discharges, and riparian buffer education. The Town also provides outreach and education through mailings with utility bills. The Engineering Department distributed approximately 9,000 brochures, designed by CWEP, with utility bills (See below). These brochures contain tips for good stormwater management. In addition to the above brochures, the town also distributes Focus on Fuquay-Varina Newsletter, an award-winning newsletter that highlights the latest information from Town Hall that keeps citizens informed on what's happening in Fuquay-Varina. The newsletter is mailed monthly with utility bills (~9,000 per month) and is also distributed via email by request. The newsletter frequently includes information on lawn and garden activities as TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT   well as water conservation practices as prescribed by the Engineering Department. Historical newsletters are maintained on the Town website. The Town also utilizes a Facebook page which is used as a tool to help educate citizens about stormwater. The Town will continue existing outreach programs, maintain involvement with CWEP and other agencies and continue to introduce new elements to the program as needed. Evaluation  The Town will evaluate the success of this minimum measure by the number of individuals reached through volunteer activities and mailings, or by using other evaluation strategies as indicated by the measurable goals for each of the BMPs. 7.2 Public Involvement and Participation The Town of Fuquay-Varina implements a public involvement and participation program that at a minimum meets all State and local requirements for public notification throughout the development of the storm water management program and implementation of the BMP’s for all six minimum measures. The Town continues to work on establishing its public participation and involvement programs to help foster broader public support and take advantage of the community’s intellectual resources. Currently the Town encourages volunteer groups and citizens to help cleanup streams on a periodic basis with the Town’s Big Sweep Program. Town staff and volunteers attempted a Big Sweep event on April 7, 2018 at Carroll Howard Johnson Environmental Education Park which was cut short due to inclement weather. The next Big Sweep event is planned for Spring 2019. Weather makeup days will also be scheduled. The Town is also currently working to establish a citizen’s watch group to help monitor the water quality and condition of streams in the Town’s jurisdiction. Stormwater monitoring and complaints are fielded by the Town’s website and Stormwater Hotline. Evaluation  The Town will evaluate the success of this minimum measure by the number of hotline phone calls and emails received, number of trash bags retrieved with Big Sweep events or by using other evaluation strategies as indicated by the measurable goals for each of the BMPs. TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT   7.3 Illicit Discharge Detection and Elimination Storm Sewer Inventory Town Staff also provide mapping of the storm sewer network. The Town has entered a significant percentage of the storm sewer pipes that are available via electronic means (as- builts provided electronically). The Town also continues to fill in data gaps regarding these structures (approximately 75% of existing storm sewer mapped). The below table provides miles of storm sewer added by year. Private Storm Sewer (mi) Public Storm Sewer (mi) Total Storm Sewer (mi) New in 2017 0.77 2.36 3.13 New in 2018 3.01 2.85 5.86 Total Currently Mapped 15.19 45.33 66.38 Mapping and data regarding the Town’s storm drain network can be found at the Town’s Maps and GIS website. Regulatory Mechanism The Town of Fuquay-Varina developed an Illicit Discharge Ordinance after receiving its NPDES Permit from the State. The ordinance focuses on methods of detecting and eliminating illicit discharges and imposes sanctions on those who do not abide. The ordinance includes illicit detection, right of entry, prohibition of certain discharges, enforcement actions and penalties for dumping, spills, and willful illicit discharges. Enforcement The Town of Fuquay-Varina implements an enforcement program to detect and eliminate pollutants that enter the municipal separate storm sewer system (MS4) as defined in 40 CFR 122.26(b)(2). The Town also considers the discharges to surface waters just as important as discharges to the MS4. Therefore, the Town addresses illicit discharges from both a point source and non-point source perspective. The illicit discharge ordinance has been adopted and is part of a larger effort to overhaul the Town’s planning and zoning ordinance and the Town’s Standard specifications. Enforcement measures have been incorporated into the Town’s Illicit Discharge Ordinance. Town staff is currently utilizing all methods available in the Illicit Discharge Ordinance to eliminate the source of an illicit discharge. These measures include Notice of Violations (NOVs), fines, civil penalties and/or criminal penalties. Staff issued one Notice of Violation from November 1, 2017 through October 30, 2018. This site is back in compliance. TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT   Detection and Elimination Illicit discharges to the Town’s storm sewer system are reported by Town staff and the general public. The public education and outreach program is being used to inform citizens as to what constitutes an illicit discharge and how to report the violation to the Town via the complaint hotline (telephone or email). The general public is considered an important element in locating illicit discharges. The better educated the public is on this topic, the more effective they will be in reporting illicit discharges to the complaint hotline. Staff is actively tracking complaints and potential illicit discharges. All Town departments work together and communicate potential violations to the Engineering Department. Town staff continues to take inventory of businesses/industries and other high-risk establishments that may have illicit connections to the storm sewer system and are prioritizing the inventory based on building age and those businesses whose processes have the potential to affect water quality. All information from the complaint hotline and the tracking system are used to identify priority areas for inspection. Engineering staff performs inspections of all complaints and provides inspection reports when warranted noting sources of illicit discharges and corrective actions for removal of the source. Outreach Staff also educates individuals and businesses on mechanisms to prevent discharges in the future. As repeated issues and/or or offenses are identified through this program element, staff will incorporate issues in future mailings and at outreach events. Staff Training Ongoing training for Town employees is conducted on what constitutes an illicit discharge to the storm sewer system and how to report the violation. Training for the Pollution Prevention/Good Housekeeping program is ongoing as well. Evaluation The Town will evaluate the success of this minimum measure by the tracking of illicit connections or by using other evaluation strategies as indicated by the measurable goals for each of the BMPs. 7.4 Construction Site Stormwater Runoff Control As described previously, on September 7, 2018, the Town of Fuquay-Varina obtained local program delegation to administer the sedimentation and erosion control program within the Town’s jurisdiction. TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT    Regulatory Mechanism and Plan Review  The Town Land Development Ordinance was amended on June 4, 2018 for the purpose of erosion control delegation (§9-1407 SOIL EROSION & SEDIMENTATION CONTROL). This amendment became effective on September 7, 2018. The erosion control ordinance establishes requirements for construction site design and implementation to ensure compliance with the North Carolina Sedimentation Pollution Control Act of 1973. All proposed development and redevelopment with an acre or greater of disturbance are required to submit an erosion control plan for approval. The Town began incorporating erosion control review into existing development review upon local program delegation. See Section 7.5 for additional details. Following plan approval, all projects are required to have pre-construction meetings prior to commencing land-disturbing activity. Enforcement The Town will ensure compliance with frequent site inspections, effective communication with site contractors and inspection reports for all site visits. Notice of Violations and civil penalties may also be issued for non-compliant land-disturbing activities per the LDO. Inspections Once a development plan is approved, a Land-Disturbing Permit is issued. During construction, Town staff inspects the site to determine if the approved plan has been implemented and to ensure compliance with the law. These inspections are performed at least monthly, with more frequent inspections for higher risk sites such as sites with early grading, sensitive environmental areas, etc.  Public Information The Town provided an announcement of local program delegation on the website and to engineers and developers that do work in the town. Additionally, the existing Stormwater Hotline will be utilized for public involvement. Evaluation The Town will monitor the effectiveness of the program with an inventory of active erosion control sites and mitigation of non-compliance with frequent site inspections and by using other evaluation strategies as indicated by the measurable goals for each of the BMPs. TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT    7.5 Post-Construction Stormwater Management in New Development and Redevelopment Regulatory Mechanism and Plan Review Through the LDO, the Town implements and enforces a program to reduce pollutants entering the MS4 and pollutants that directly impact surface waters due to post-construction run-off associated with development. Town staff reviews all new development and re- development and ensures compliance with the Town’s LDO, the Town’s Standard Specifications and Construction Details and with NCDEQ’s New Stormwater Design Manual. Wake County permits all on-site wastewater systems and operates their own oversight program. The Town offers predevelopment, presubmittal, and comment review meetings for developers for all projects. Through this coordination, staff identifies projects in excess of 1- acre of disturbance and those that are part of a larger common plan of development. At this level of involvement, Town staff works with development to effectively tie into existing infrastructure and plan for future infrastructure.       The Town has developed an operation and maintenance component of the Post-Construction Stormwater Management program that ensures the adequate long-term operation of the structural SCM’s required by the program. If a project includes one or more structural SCM’s, it will have to comply with provisions of the Town’s Structural SCM Operation & Maintenance (O&M) program. Once a SCM is constructed, an as-built and Engineer Certification is required by the Town to ensure that the structure was built as per the approved plans. Operation and Maintenance agreements along with Operational Manuals are required for each structural stormwater SCM (prior to plat recordation for subdivisions and prior to CO for non-residential development). For residential development, the Town allows for bonding at plat recordation for incomplete SCMs through an Underlying Agreement between the developer and the Town. As of October 30, 2018, the Town has Underlying Agreements for 37 SCMs and approximately $1,300,000 in stormwater sureties. In addition, the SCM O&M program will ensure that the structural SCM’s constructed within the Town’s jurisdiction are inspected at least annually and maintained in good working condition to provide the most benefits to water quality. The inspection is required to be conducted by a qualified professional and must be submitted on the Town’s designated inspection forms. The Town maintains a SCM inventory for all approved SCMs in the Town’s MS4. The inventory currently includes one hundred and twelve` (112) SCMs. Once SCMs are constructed and all required documents are received and/or recorded, Town staff also performs inspections. Staff generates inspection reports all non-compliant SCMs as well as SCMs in need of general maintenance. TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT       All streams within the Neuse River Basin hold the supplemental classification of nutrient sensitive waters (NSW). More than half of the Town’s MS4 service area lies in the Neuse River Basin, and thus drains into NSWs. While the Town does not require a nutrient load reduction, draft rules are in review that will necessitate a modification to the LDO to incorporate nutrient loading requirements. Estimated implementation will be within 5 years. In the meantime, the Town requires that SCMs achieve 85% TSS removal meaning that development is already treating nutrients at a high level. Ninety (90) of the one hundred and twelve (112) permitted SCMs are primary devices 14 Bioretentions, 14 Constructed Wetlands, 2 Infiltration Basin, 60 Wet Ponds). –     The Town offers a low-density option for residential development. Through limitation of impervious surface coverage (<24%) and use of vegetative conveyances, projects are able to address stormwater management non-structurally. As discussed in previous sections, natural resource protection is also achieved through the Town’s LDO and coordination with NCDEQ and the USACOE. The Town LDO also encourages the use of Open Space Development and form-based zoning districts (mixed-use). Open Space development encourages the preservation of open space by clustering residential development integrated with open space and green infrastructure that facilitates pedestrian common areas. The Open Space standards promote an alternative to urban sprawl that will support future development growth patterns for the Town.These developments are intended to preserve agricultural, historical, natural and cultural features of the community that might otherwise be lost through conventional development and procedures. Mixed use developments decrease impervious surfaces associated with parking and also decrease vehicle miles traveled—resulting in a reduction of hydrocarbons left on roadways and reduced air deposition. Additionally, Town LDO, Article O Landscaping & Tree Protection Standards, encourages the preservation of existing vegetation, the reduction of the amount of impervious surface, and mitigation of soil erosion and sedimentation through the use of vegetative covers. The Town of Fuquay-Varina desires to develop in a manner that allows development to occur in harmony with the natural environment and protect existing vegetation when and where practical to improve the quality and character of the Town. The Clear-Cutting and Protection of Heritage Trees Regulations (Town LDO §9-1406) works in unison with improving air quality, stormwater management, economic value to property and the environment of the Town. The Town encourages and accepts the use of LID principles such as green design, however, there is not currently a mechanism in place to incentivize these practices. Please see the Town’s website for a link to the LDO. TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT    7.6 Pollution Prevention/Good Housekeeping for Municipal Operations  The Town of Fuquay-Varina has developed and is implementing a Pollution Prevention/Good Housekeeping Program for its own municipal operations to reduce pollutants entering the municipal storm sewer system and reduce pollutants that directly impact surface waters. At a minimum, this program requires the Town to adhere to its own policies and regulations set forth for the public in the previous Sections. Municipal operations are not exempt from any of the requirements established for the Illicit Discharge Detection & Elimination Program, the Construction Site Runoff Program, or the Post-Construction Stormwater Program. Sites that have the potential to generate stormwater have been identified and are inspected, at a minimum, annually. The Town implements a street sweeping program. Daily logs are kept, and material is swept up and dumped. In 2017, the sweeper was unloaded 90 times respectively. The street sweeper has a volume of 7.3 cubic yards. It is estimated that the truck is at one fourth to one half full each time it is dumped. This puts the range of material collected at 164 to 329 cubic yards in 2017. Engineering staff conducts inspections at facilities owned by the Town. Municipal facilities are inspected for illicit discharges, illicit connections and/or stormwater management violations. TOWN OF FUQUAY-VARINA NPDES PHASE II STORMWATER MANAGEMENT PROGRAM ANNUAL REPORT    The below table shows a list of municipal facilities within the MS4. Use Property PARKS ACTION PARK PARKS ALSTON RIDGE PARK PARKS BANKS RD ELEM PARK PARKS CAROL HOWARD JOHNSON PARK PARKS CENTENNIAL TRAIL PARKS DOG PARK UTILITY EAST REG PUMP STATION PARKS FALCON PARK WORKS FIRE STATION 1 WORKS FIRE STATION 2 PARKS FLEMING LOOP RD SOCCER FIELDS PARKS HONEYCUTT RD PARK UTILITY KENNETH CRK WWTP PARKS LIBRARY PARK UTILITY MILLS RIDGE PUMP STATION PARKS MINERAL SPRING PARK & ADMIN OFFICES UTILITY NW REG PUMP STATION WORKS POLICE DEPARTMENT PARKS SOUTH PARK UTILITY TERR CRK WWTP WORKS THE HILL / WATER TANK / PUBLIC WORKS OPS WORKS TOWN HALL PARKS WEST JONES PARK WORKS PUBLIC SERVICE CTR - HOLLAND RD Employees with duties that pertain to any of the activities in the previous section will be educated and trained in methods to prevent pollution from entering the municipal storm system or nearby surface waters. Employees that operate and maintain the Town’s storm sewer system, including any Town-owned structural SCM’s, will require further training to ensure that the Town’s MS4 and structural SCM’s are maintained and functioning properly. For many activities, this training will coincide very closely with training that will be necessary for the Illicit Discharge Detection & Elimination Program. There are two distinct elements to the Town’s Pollution Prevention/Good Housekeeping program. The first component educates, trains, and instructs Parks and Recreation employees about pollution that may be associated with specific operational activities that they perform. The second component educates, trains, and instructs Public Works/Public Utilities employees for specific duties related to maintenance and inspection of Town-owned MS4 facilities. Multi-departmental training occurs throughout the year. Related Engineering staff certifications currently include Stormwater BMP Reviewer Certifications, Stormwater BMP Inspector Certification, and Certified Floodplain Managers.