NCS000421_High Point Draft SWMP v1 DEQ Comment Letter_20210127

January 27, 2021

VIA EMAIL ONLY
RETURN RECEIPT REQUESTED

City of High Point
Attn: Randy McCaslin, Interim City Manager
211 S. Hamilton
High Point, NC 27261

Subject: COMMENTS ON DRAFT SWMP v1 (NOD-2019-PC-0205)
City of High Point
NPDES MS4 Permit No. NCS000421
Guilford, Randolph, Davidson & Forsyth County

Dear Mr. McCaslin:

On August 19-20, 2019, staff from the North Carolina Department of Environmental Quality (DEQ)
audited the City of High Point (City) for compliance with the subject NPDES MS4 permit. As a result, a
Notice of Deficiency (NOD) was issued to the City on January 22, 2020. The NOD defined specific
document submittals and deadlines, which have been provided in a timely manner.

DEQ received the required Draft Stormwater Management Plan (SWMP) submittal on September 24,
2020. Staff have reviewed the submitted Draft SWMP and request that the following comments be
addressed. The revised Draft SWMP v2 is required to be signed and submitted to DEQ within
thirty (30) calendar days of receipt of this letter.

Comments

1. Section 3.4: Please include the following items regarding inter-connection with the NCDOT
MS4, as appropriate.
The MS4 interconnects with the NCDOT MS4. The interconnection(s) with the NCDOT
MS4 include:
o Receiving stormwater from the NCDOT MS4. The number of interconnections is
known / estimated / unknown. Quantity:
o Discharging stormwater into the NCDOT MS4. The number of interconnections is
known / estimated / unknown. Quantity:
The MS4 mapping does / does not identify interconnections with the NCDOT MS4.
The MS4 mapping does / does not include NCDOT MS4 outfalls.

2. General Comment: Number BMPs consecutively through all BMP tables. Do not restart
numbering for each table or permit reference.

3. General comment: Include both a frequency and applicable permit year(s) in Column C -
Schedule for Implementation (Once, Annually, Continuously, etc.). See SWMP Template
Instructions and General SWMP Guidance on the DEQ MS4 Forms & Resources web page for
additional information. Please note that the new permit is expected to become effective on July 1,
2021, so “permit years” will coincide with the state fiscal year and annual reporting cycle. Please
remove statement such as “as needed” in all entries or change frequency to “Continuously” to be
more specific.
4. General Comment: Annual Reporting Metrics in Column D should be brief - a quantity, number
trained, Y/N/Status, date completed, etc. See SWMP Template Instructions and the new General
SWMP Guidance on the DEQ MS4 Forms & Resources web page for additional information.
Details such as “To maintain the current map…”, “Document all aspects…” and “Update…” are
tasks/actions that should be listed as measurable goals.
Please note that the new permit will be issued with an annual reporting template that is specific to
the approved SWMP, and this information will be utilized to ensure that the MS4 is on track to
maintain compliance. The provided template will be an Excel spreadsheet, which will facilitate
future electronic reporting requirements, but will not support the submittal of details and
additional documentation such as agendas, documents, etc. That information will be requested by
DEQ as necessary.

5. General Comment: Measurable Goals and Schedule for Implementation columns cannot be left
blank.

The required revised Draft SWMP v2 submittal must include a hard copy with a certifying statement and
original “wet” signature by the City’s ranking elected official or designated staff member in compliance
with Part IV, Paragraph G of the current MS4 Permit.

Please submit the required signed Draft SWMP v2 to:

DEQ-DEMLR Stormwater Program
Attn: Jeanette Powell
1612 Mail Service Center
Raleigh, NC 27699-1612
[e-mail]

Upon acceptance of an approvable Draft SWMP, a Draft Permit and Final Draft SWMP will be published
for a required 30-day public notice which includes an EPA and public comment period. The permit will
be issued following resolution of any comments received, and is expected to become effective on July 1,
2021.

Thank you for your prompt attention to this matter. Should you have any questions, please contact me at
[phone] or [e-mail].

Sincerely,

Jeanette Powell
MS4 Program Coordinator

Cc via email:
[e-mail]
[e-mail]
Annette Lucas, DEMLR Stormwater Program Supervisor
Tamera Eplin, Winston-Salem Regional Office
DEMLR NPDES MS4 Permit Laserfiche File