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HomeMy WebLinkAbout02 Storm Water Quality Management Program Plan
Stormwater Quality Management Program Plan
Permit No. NCS000395
(Revised January 26, 2010; August 20, 2010; June 5, 2012; August 14, 2012;
November 2, 2012; March 2014; August 2015; April 2016; August 2017;
October 2018; November 2019; October 2020; March 2021)
Prepared by:
Charlotte-Mecklenburg Stormwater Services
Mecklenburg County Water Quality Program
2154 Suttle Avenue
Charlotte, N.C. 28208-5237
Prepared for:
NPDES Phase II Stormwater Permit (NCS000395) for Mecklenburg County; Charlotte-
Mecklenburg Schools; Central Piedmont Community College; and the Towns of Cornelius,
Davidson, Huntersville, Matthews, Mint Hill and Pineville
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
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Table of Contents
SECTION 1: INTRODUCTION ...........................................................................................1
SECTION 2: CERTIFICATION ...........................................................................................2
SECTION 3: MS4 INFORMATION .....................................................................................3
3.1 Permitted MS4 Area ....................................................................................................3
3.2 Existing MS4 Mapping................................................................................................4
3.3 Receiving Waters ........................................................................................................5
3.4 MS4 Interconnections..................................................................................................9
3.5 Total Maximum Daily Loads (TMDLs) .......................................................................9
3.6 Endangered and Threatened Species and Critical Habitat .......................................... 13
3.7 Industrial Facility Discharges .................................................................................... 13
3.8 Non-Stormwater Discharges ...................................................................................... 14
3.9 Targeted Pollutants and Sources ................................................................................ 16
3.10 Targeted Audiences ................................................................................................... 16
SECTION 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION ......... 18
4.1 Program Goal ........................................................................................................... 18
4.2 BMP Summary Table ............................................................................................... 18
4.3 Organizational Structure ........................................................................................... 19
4.4 Standard Operating Procedures (SOPs)..................................................................... 21
4.5 Documentation ......................................................................................................... 22
4.6 Annual Assessment of SWMP and Implementation of Improvements ....................... 23
4.7 Program Budget and Funding ................................................................................... 30
4.8 Co-Permittees ........................................................................................................... 31
4.9 Shared Responsibilities ............................................................................................ 32
4.10 Coordination Between Co-Permittees ....................................................................... 33
SECTION 5: PUBLIC EDUCATION AND OUTREACH PROGRAM .............................. 34
5.1 Program Goals and Objectives................................................................................... 34
5.2 BMP Summary Table ................................................................................................ 34
5.3 Stormwater Helpline ................................................................................................. 37
5.4 Outreach Program ..................................................................................................... 38
5.4.1 Utility Bill Inserts .................................................................................................. 38
5.4.2 Brochures, Environmental Notices and Newsletters ............................................... 39
5.4.3 Print Ads ................................................................................................................ 39
5.4.4 Media Campaign .................................................................................................... 39
5.4.5 Social Media .......................................................................................................... 39
5.4.6 Targeted Outreach.................................................................................................. 40
5.4.7 Workshops and Video Taped Messages ................................................................. 41
5.4.8 Web Pages ............................................................................................................. 41
5.4.9 Educational Presentations and Public Events .......................................................... 41
5.4.10 Regional Stormwater Partnership of the Carolinas .............................................. 42
5.5 Reaching Mecklenburg County’s Diverse Population ................................................ 42
5.6 Communication Plan ................................................................................................. 42
5.7 Decision Process ....................................................................................................... 43
5.8 Program Evaluation ................................................................................................... 43
SECTION 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM ................. 45
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
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6.1 Program Goals and Objectives................................................................................... 45
6.2 BMP Summary Table ................................................................................................ 45
6.3 Targeted Audience .................................................................................................... 48
6.4 Mechanisms for Public Involvement and Participation .............................................. 49
6.4.1 Charlotte Mecklenburg Stormwater Advisory Committee (SWAC) ........................ 49
4.4.2 Public Meetings ..................................................................................................... 49
6.4.3 Adopt-A-Stream Program ...................................................................................... 50
6.4.4 Storm Drain Marking Program ............................................................................... 50
6.4.5 Surface Water Clean Up......................................................................................... 51
6.4.6 Volunteer Monitoring ............................................................................................ 51
6.4.7 Volunteer Appreciation Campaign ......................................................................... 51
6.5 Decision Process ....................................................................................................... 51
6.6 Program Evaluation ................................................................................................... 52
SECTION 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM .... 53
7.1 Program Goals and Objectives................................................................................... 53
7.2 BMP Summary Table ................................................................................................ 54
7.3 Illicit Discharge Detection & Elimination Manual ..................................................... 58
7.4 Storm Sewer System Mapping................................................................................... 59
7.5 Pollution Control Ordinance ...................................................................................... 60
7.6 Enforcement .............................................................................................................. 63
7.7 Detection and Elimination ......................................................................................... 63
7.7.1 Identifying Priority Areas....................................................................................... 63
7.7.1.1 Citizen Requests for Service ................................................................ 63
7.7.1.2 Routine Water Quality Monitoring Activities ....................................... 65
7.7.1.3 Volunteer Activities ............................................................................. 68
7.7.1.4 GIS Mapping ....................................................................................... 68
7.7.2 Confirming the Presence of an Illicit Discharge ..................................................... 69
7.7.2.1 Illicit Discharge Elimination Program (IDEP) ...................................... 69
7.7.2.2 Short Term Monitoring ........................................................................ 70
7.7.2.3 Hot Spot Investigations ........................................................................ 70
7.7.2.4 Stream Walks ....................................................................................... 70
7.7.2.5 Dry Weather Flow Investigations ......................................................... 70
7.7.3 Tracking the Source of an Illicit Discharge ............................................................ 71
7.7.3.1 Record Reviews ................................................................................... 71
7.7.3.2 Inspections ........................................................................................... 71
7.7.3.3 Monitoring ........................................................................................... 71
7.7.4 Procedures for Removing the Source of the Illicit Discharge .................................. 72
7.7.5 Documentation....................................................................................................... 72
7.8 Outreach.................................................................................................................... 73
7.9 Decision Process ....................................................................................................... 74
7.10 Program Evaluation ................................................................................................... 75
SECTION 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM......................... 76
8.1 Program Goals and Objectives................................................................................... 76
8.2 BMP Summary Table ................................................................................................ 76
8.3 Erosion Control Ordinance ........................................................................................ 78
8.4 Erosion Control Plan Reviews ................................................................................... 79
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
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8.5 Enforcement .............................................................................................................. 79
8.6 Inspections ................................................................................................................ 79
8.7 Erosion Control Hotline ............................................................................................ 80
8.8 Erosion Control Education ........................................................................................ 80
8.9 Government Projects ................................................................................................. 80
8.10 Decision Process ....................................................................................................... 80
8.11 Program Evaluation ................................................................................................... 81
SECTION 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM .............. 82
9.1 Program Goals and Objectives................................................................................... 82
9.2 BMP Summary Table ................................................................................................ 82
9.3 Post-Construction Stormwater Ordinances ................................................................ 85
9.4 Compliance by Co-Permittees with Post-Construction Ordinance Requirements ....... 86
9.5 Requirements for Non-Structural BMPs .................................................................... 87
9.6 Requirements for Structural BMPs ............................................................................ 88
9.7 Natural Resource Protection ...................................................................................... 89
9.8 Open Space Protection .............................................................................................. 89
9.9 Tree Preservation ...................................................................................................... 90
9.10 Green Infrastructure Practices ................................................................................... 90
9.11 Operation and Maintenance ....................................................................................... 90
9.12 Decision Process ....................................................................................................... 92
9.13 Program Evaluation ................................................................................................... 93
SECTION 10: POLLUTION PREVENTION & GOOD HOUSEKEEPING PROGRAM ...... 94
10.1 Program Goals and Objectives................................................................................... 94
10.2 BMP Summary Table ................................................................................................ 94
10.3 Inventory of Municipally Owned or Operated Facilities ............................................ 97
10.4 Training .................................................................................................................. 100
10.5 Operation and Maintenance Programs, Spill Prevention, and Spill Response ........... 102
10.6 Standard Operating Procedures (SOPs) for Municipal Facility Operations ............... 103
10.7 Minimizing Pollution from Municipally Owned Streets and Parking Lots ............... 104
10.8 Operation and Maintenance Plans for MS4s and SCMs ........................................... 105
10.9 Evaluation of BMPs for Streets, Roads, Parking Lots, and Storm Sewer Systems .... 105
10.10 Winter Road Maintenance ....................................................................................... 106
10.11 Management of Pesticide, Herbicide and Fertilizer Application ............................... 106
10.12 Controlling Pollutants from Vehicle/Equipment Maintenance, Cleaning & Fueling . 108
10.13 Waste Disposal ........................................................................................................ 109
10.14 Flood Management Projects .................................................................................... 109
10.15 Decision Process ..................................................................................................... 110
10.16 Program Evaluation ................................................................................................. 110
SECTION 11: TMDL WATER QUALITY RECOVERY PROGRAM ............................... 112
11.1 Program Goals and Objectives................................................................................. 112
11.2 BMP Summary Table .............................................................................................. 113
11.3 TMDL Pollutants of Concern .................................................................................. 114
11.3.1 Fecal Coliform TMDLs .................................................................................... 114
11.3.2 Nutrient TMDL ................................................................................................ 115
11.3.3 Mercury TMDL ............................................................................................... 115
11.4 Watershed Characteristics ....................................................................................... 115
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11.4.1 Rocky River Watershed ................................................................................... 116
11.4.2 Goose Creek Watershed ................................................................................... 120
11.4.3 Lake Wylie Watershed ..................................................................................... 124
11.5 Public Information and Notification ........................................................................ 129
11.6 Implementation Team ............................................................................................. 129
11.7 MS4 Major Stormwater Outfalls in the TMDL Watersheds .................................... 129
11.8 Existing BMP Measures ......................................................................................... 130
11.8.1 Public Education & Outreach ........................................................................... 130
11.8.2 Fats, Oils and Grease Program ......................................................................... 130
11.8.3 Public Involvement and Participation ............................................................... 131
11.8.4 Illicit Discharge Detection and Elimination (IDDE) ......................................... 131
11.8.5 Sewer Use Ordinance ....................................................................................... 131
11.8.6 Sanitary Sewer System Inspections and Maintenance ....................................... 131
11.8.7 SSO Rapid Response ....................................................................................... 132
11.8.8 Construction Site Stormwater Runoff Control .................................................. 132
11.8.9 Post-Construction Site Runoff Control ............................................................. 132
11.8.10 Pollution Prevention and Good Housekeeping .................................................. 133
11.9 Water Quality Monitoring and Data Assessment .................................................... 133
11.9.1 Fecal Coliform Monitoring and Data Assessment for the Rocky River ............. 133
11.9.2 Fecal Coliform Monitoring and Data Assessment for Goose Creek .................. 134
11.9.3 Chlorophyll-A Monitoring and Data Assessment for Lake Wylie ..................... 135
11.9.4 Mercury Monitoring and Data Assessment Statewide ....................................... 135
11.9.5 Effectiveness of BMPs Based on Data Analysis ............................................... 135
11.10 Additional BMP Measures ..................................................................................... 135
11.10.1 Additional BMP Measures in the Rocky River Watershed ................................ 135
11.10.2 Additional BMP Measures in the Goose Creek Watershed ............................... 137
11.10.3 Additional BMP Measures in the Lake Wylie Watershed ................................. 140
11.10.4 Additional BMP Measures Planned for TMDL Watersheds in FY2021 ............ 141
11.11 Tracking and Reporting Success ............................................................................. 141
11.12 Reporting ............................................................................................................... 142
List of Tables:
Table 1: Summary of MS4 Mapping ...........................................................................................5
Table 2: Summary of MS4 Receiving Waters ..............................................................................5
Table 3: Approved TMDLs for Mecklenburg County’s Phase I and Phase II Jurisdictions...........9
Table 4: New TMDL Requirements .......................................................................................... 11
Table 5: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality ...... 13
Table 6: NPDES Stormwater Permitted Industrial Facilities ...................................................... 14
Table 7: Non-Stormwater Discharges ........................................................................................ 15
Table 8: Targeted Pollutants, Potential Impacts/Physical Attributes, Pollutant Sources, Audience
and Contributing Issues ............................................................................................. 16
Table 9: Program Administration BMPs .................................................................................... 18
Table 10: Summary of Responsible Parties ............................................................................... 20
Table 11: Changes to the FY2020 SWMP for Implementation in FY2021 ................................. 24
Table 12: Changes to the FY2021 Work Plan ............................................................................ 26
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Table 13: Changes to the FY2021 SWMP for Implementation Effective February 11, 2021 ...... 29
Table 14: Estimated Cost Breakdown by Jurisdiction/Entity for FY2020 ................................... 31
Table 15: Co-Permittee Contact Information ............................................................................. 31
Table 16: BMP Summary Table for the Public Education and Outreach Program ...................... 35
Table 17: BMP Summary Table for the Public Involvement and Participation Program............. 45
Table 18: BMP Summary Table for the IDDE Program ............................................................. 54
Table 19: BMP Summary Table for the Construction Site Stormwater Control Program ........... 77
Table 20: BMP Summary Table for the Post-Construction Site Runoff Control Program. .......... 83
Table 21: Non-Structural BMPs Required by Post-Construction Ordinances ............................. 87
Table 22: Structural BMPs Contained in the Post-Construction Ordinances............................... 88
Table 23: BMP Summary Table for the Pollution Prevention/Good Housekeeping Program...... 94
Table 24: Municipal Operations Owned and/or Operated by the County and Towns .................. 98
Table 25: Municipal Operations Owned and/or Operated by CMS ............................................ 99
Table 26: Municipal Operations Owned and/or Operated by CPCC ......................................... 100
Table 27: Municipal Operations that have been Issued Stormwater Permits ............................. 100
Table 28: Pounds of Pollutants Removed and Costs for FY2020 ............................................. 106
Table 29: Annual Treatment Area Thresholds ......................................................................... 107
Table 30: Limits on Pesticide Applications in the Goose Creek Watershed .............................. 107
Table 31: BMP Summary Table for the TMDL Program ......................................................... 113
Table 32: Information Regarding the Rocky River Watershed in Mecklenburg County ........... 116
Table 33: Information Regarding the Goose Creek Watershed in Mecklenburg County ........... 120
Table 34: Information Regarding the Lake Wylie Watershed in Mecklenburg County ............. 124
Table 35: Number of Outfalls in each TMDL Watershed......................................................... 130
Table 36: Annual Analysis of the Rocky River Watershed for the Monitoring Plan ................. 134
List of Figures:
Figure 1: Mecklenburg County Phase II MS4 Jurisdictions .........................................................3
Figure 2: MS4 Mapping ..............................................................................................................4
Figure 3: Surface Waters in Phase II Jurisdictions with Approved TMDLs ................................ 12
Figure 4: Utility Bill Insert ........................................................................................................ 38
Figure 5: Web Banner ............................................................................................................... 40
Figure 6: Targeted Education Mailer ......................................................................................... 40
Figure 7: Storm Drain Marker ................................................................................................... 50
Figure 8: Screen Shot from Cityworks of Storm Drain Inlets, Outlets, and Receiving Streams .. 60
Figure 9: Phase II Stream Monitoring Sites ............................................................................... 66
Figure 10: Stream Use Support Index (SUSI) Map (April 1 through June 2020) ........................ 67
Figure 11: GIS Map Available Through Cityworks for Prioritizing Areas for Illicit Discharges . 68
Figure 12: Notices of Violation Issued from 2011 through 2020 ................................................ 73
Figure 13: Stream Restoration in the Torrence Creek Watershed in Huntersville ..................... 110
Figure 14: Location of the Rocky River Watershed in Relation to Mecklenburg County.......... 117
Figure 15: TMDL Waters, Outfalls and Monitoring Sites in the Rocky River Watershed in
Mecklenburg County ............................................................................................... 118
Figure 16: Landuses in the Rocky River TMDL Watershed in Mecklenburg County ............... 119
Figure 17: Location of the Goose Creek Watershed in Mecklenburg ....................................... 121
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Figure 18: TMDL Waters, Outfalls and Monitoring Sites in the Goose Creek Watershed in
Mecklenburg County ............................................................................................... 122
Figure 19: Landuses in the Goose Creek TMDL Watershed in Mecklenburg County............... 123
Figure 20: Location of Lake Wylie Watershed in Mecklenburg County ................................... 126
Figure 21: TMDL Waters, Outfalls and Monitoring Sites in the Lake Wylie Watershed in
Mecklenburg County ............................................................................................... 127
Figure 22: Landuses in the Lake Wylie TMDL Watershed in Mecklenburg County................. 128
Appendices:
Appendix A: BMP Summary Table ......................................................................................... 143
Appendix B: Mecklenburg County Phase II Jurisdictions/Entities Organizational Charts ........ 161
Appendix C: Post-Construction Policy for Transportation Projects .......................................... 171
Appendix D: Phase II Municipal Facility Inventory Procedures............................................... 174
Appendix E: Stormwater Inspection Checklist for Municipal Facilities ................................... 187
Appendix F: Co-Permittee Responsibilities for Compliance with Phase Permit Requirements . 194
Acronyms:
BMP: Best Management Practice
CMS: Charlotte Mecklenburg Schools
CPCC: Central Piedmont Community College
CMSWS: Charlotte Mecklenburg Stormwater Services – County Water Quality Program
EDMS: Environmental Data Management System
FY: Fiscal Year
GIS: Geographic Information System
GPS: Global Positioning System
IDDE: Illicit Discharge Detection and Elimination
LUESA: Land Use and Environmental Services Agency
MEP: Maximum Extent Practicable
MOA: Memorandum of Agreement
MS4: Municipal Separate Storm Sewer System
NCAC: North Carolina Administrative Code
NCDEQ: North Carolina Department of Environmental Quality
NPDES: National Pollutant Discharge Elimination System
SWAC: Stormwater Advisory Committee
S.W.I.M.: Surface Water Improvement and Management
SWMP: Stormwater Management Program
SCM: Stormwater Control Measure
SWMP Storm Water Quality Management Program Plan (aka Stormwater Plan)
TMDL: Total Maximum Daily Load
TSS: Total Suspended Solids
WLA: Waste Load Allocation
WQRP: Water Quality Recovery Program
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
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SECTION 1: INTRODUCTION
The purpose of this Stormwater Quality Management Program Plan (SWMP) is to establish and
define the means by which the Mecklenburg County Phase II jurisdictions/entities will comply
with their National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm
Sewer System (MS4) Permit number NCS000395 and the applicable provisions of the Clean
Water Act to meet the federal standard of reducing pollutants in stormwater runoff to the
maximum extent practicable. The following nine (9) Mecklenburg County Phase II
jurisdictions/entities are covered by this SWMP:
1. Mecklenburg County (unincorporated)
2. Charlotte-Mecklenburg Schools (CMS)
3. Central Piedmont Community College (CPCC)
4. Town of Cornelius
5. Town of Davidson
6. Town of Huntersville
7. Town of Matthews
8. Town of Mint Hill
9. Town of Pineville
This SWMP identifies the specific elements and minimum measures that the Mecklenburg
County Phase II jurisdictions/entities will develop, implement, enforce, evaluate and report to the
North Carolina Department of Environmental Quality (NCDEQ) Division of Energy, Minerals
and Land Resources (DEMLR) in order to comply with the MS4 Permit number NCS000395 as
issued by NCDEQ. This permit covers activities associated with the discharge of stormwater
from the MS4 as owned and operated by the Mecklenburg County Phase II jurisdictions/entities
and located within the corporate limits of the MS4name. This SWMP also includes in Section
11 the Water Quality Recovery Program developed for compliance with the Permit requirement
for reducing levels of the pollutant of concern in accordance with approved Waste Load Allo cation
assigned to stormwater in an approved TMDL.
In preparing this SWMP, the Mecklenburg County Phase II jurisdictions/entities have evaluated
their MS4s and the Permit requirements to develop a comprehensive 5-year SWMP that will
meet the community’s needs, address local water quality issues and provide the minimum
measures necessary to comply with the Permit. The SWMP will be evaluated and updated
annually to ensure that the elements and minimum measures it contains continue to adequately
provide for Permit compliance and the community’s needs.
Once the SWMP is approved by NCDEQ, all provisions contained and referenced in this SWMP,
along with any approved modifications of the SWMP, are incorporated by reference into the
Permit and become enforceable Sections of the Permit. Any major changes to the approved
SWMP will require resubmittal and approval by NCDEQ and may require a new public
comment period depending on the nature of the changes.
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
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SECTION 2: CERTIFICATION
By my signature below I hereby 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 the 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.
I am also aware that the contents of this document shall become an enforceable Section of the
NPDES MS4 Permit, and that both the Division and the Environmental Protection Agency have
NPDES MS4 Permit compliance and enforcement authority.
☐ I am a ranking elected official.
☐ I am a principal executive officer for the permitted MS4.
X I am a duly authorized representative for the permitted MS4 and have attached the
authorization made in writing by a principal executive officer or ranking elected official
which specifies me as (check one):
X A specific individual having overall responsibility for stormwater matters.
☐ A specific position having overall responsibility for stormwater matters.
Signature:
W. Dave Canaan
Print
Name:
W. Dave Canaan
Title:
Division Director, Storm Water Services
Signed this 19th day of March 2021.
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
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SECTION 3: MS4 INFORMATION
3.1 Permitted MS4 Area
This SWMP includes all regulated activities associated with the discharge of stormwater from
the MS4s throughout the corporate limits of the Towns of Cornelius, Davidson, Huntersville,
Matthews, Mint Hill, and Pineville as well as the unincorporated area of Mecklenburg County
outside these corporate limits and the cooperate limits for the City of Charlotte, which is a Phase
I jurisdiction (NCS000240). This SWMP also applies to Charlotte-Mecklenburg Schools (CMS)
and Central Piedmont Community College (CPCC). Figure 1 below shows the corporate limits
of the jurisdictions as of October 2019.
Figure 1: Mecklenburg County Phase II MS4 Jurisdictions
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
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3.2 Existing MS4 Mapping
The current MS4 mapping includes inlets, outlets and receiving streams stored in the County’s
ESRI ArcGIS SDE Geodatabase. New inlets and outlets are added to the system as new
development/redevelopment occurs and existing outlet structures are re-inspected at least every
5-years as part of CMSWS’s Stream Walk Program. Inlet and outlet structures are viewable
through the following link: https://maps.mecklenburgcountync.gov/StormWaterInventory/
(Enter Username: NCDEQ and Password: PsXfYnQXj7qT). Figure 2 represents the data
available in the system. Table 1 provides a summary of the MS4 mapping.
Figure 2: MS4 Mapping
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
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Table 1: Summary of MS4 Mapping
Jurisdiction Inlets All Outfalls
(≥12")
Major Outfalls
(≥36")
Industrial
Outfalls
Cornelius 5,236 828 27 0
Davidson 2,426 397 44 0
Huntersville 11,802 1,667 86 3
Matthews 4,846 740 31 3
Mint Hill 3,469 1,046 41 1
Pineville 2,834 549 7 0
Mecklenburg 3,122 1,822 41 4
CMS 5,361 836 15 0 / NA
CPCC 335 62 1 0 / NA
Total 39,431 7,947 293 11
3.3 Receiving Waters
The Mecklenburg County Phase II jurisdictions/entities are located within the Catawba and
Yadkin Pee-Dee River Basins and discharge directly into receiving waters as listed in Table 2
below. The Applicable water quality classifications, criteria exceeded, and 3030(d) status listed
below are compiled from the following NCDEQ sources:
• Waterbody Classification Map
• 2018 Final NC Integrated Report
https://files.nc.gov/ncdeq/Water%20Quality/Planning/TMDL/303d/2018/2018IR072519.
pdf
Table 2: Summary of MS4 Receiving Waters
Receiving Water
Name
Stream Index
/ AU Number
Water
Quality
Classification
Criteria
Exceeded TMDL Status
CATAWBA
Mountain Island Lake 11-(114) WS-IV (CA);
B Fish Tissue Mercury Approved Statewide
Lake Wylie 11-(117) WS-IV (CA)
Fish Tissue Mercury Approved Statewide
PCB Fish Tissue
Advisory Pending (303(d) listed)
Lake Wyl ie 11-(122) WS-IV (CA);
B
Fish Tissue Mercury Approved Statewide
PCB Fish Tissue
Advisory Pending (303(d) listed)
Lake Wylie (NC
Portion) 11-(123.5)a WS-V, B
Fish Tissue Mercury Approved Statewide
PCB Fish Tissue
Advisory Pending (303(d) listed)
Lake Norman 11-(75) WS-IV (CA);
B
Fish Tissue Mercury Approved Statewide
PCB Fish Tissue
Advisory Pending (303(d) listed)
Temperature Not Required
Gambles Creek 11-107 WS-IV (CA) Not Assessed N/A
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
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Receiving Water
Name
Stream Index
/ AU Number
Water
Quality
Classification
Criteria
Exceeded TMDL Status
(Cathey Creek)
Knox Creek 11-108 WS-IV (CA);
B Not Assessed N/A
Hager Creek 11-109 WS-IV (CA);
B Not Assessed N/A
Ramsey Creek 11-111 WS-IV Not Assessed N/A
McDowell Creek 11-115-(1) C Fish Community Not Required
Fish Tissue Mercury Approved Statewide
McDowell Creek 11-115-(1.5)a WS-IV Fish Community Not Required
Fish Tissue Mercury Approved Statewide
McDowell Creek 11-115-(1.5)b WS-IV Benthos Not Required
Fish Tissue Mercury Approved Statewide
McDowell Creek 11-115-(5) WS-IV (CA) Fish Tissue Mercury Approved Statewide
Caldwell Station
Creek 11-115-2-(1) C Not Assessed N/A
Caldwell Station
Creek 11-115-2-(2) WS-IV Not Assessed N/A
Torrence Creek 11-115-4 WS-IV Not Assessed N/A
Gar Creek 11-116-(1) WS-IV Fish Tissue Mercury Approved Statewide
Gar Creek 11-116-(2) WS-IV (CA) Not Assessed N/A
Harwood Lakes and
Brinkley Twin Lakes 11-118 WS-IV (CA) Not Assessed N/A
Long Creek 11-120-(2.5) WS-IV Fish Tissue Mercury Approved Statewide
Long Creek 11-120-(7) WS-IV (CA) Not Assessed N/A
Dixon Branch 11-120-1 C Not Assessed N/A
Vances Twin Lakes 11-120-1-1 C Not Assessed N/A
Swaringer Lake 11-120-2 C Not Assessed N/A
McIntyre Creek 11-120-3-(1) C Not Assessed N/A
McIntyre Creek 11-120-3-(2) WS-IV Not Assessed N/A
Gutter Branch 11-120-4-(1) C Not Assessed N/A
Gutter Branch 11-120-4-(2) WS-IV Not Assessed N/A
Gum Branch 11-120-5 WS-IV Not Assessed N/A
Thomas Pond 11-120-6 WS-IV Not Assessed N/A
Paw Creek 11-124 C Not Assessed N/A
Ticer Branch (Tiser
Branch) 11-124-1 C Not Assessed N/A
Little Paw Creek
(Danga Lake) 11-125 C Not Assessed N/A
Unnamed Tributary to
Little Paw Creek
(Friday Lake )
11-125-1 B Not Assessed N/A
Beaverdam Creek 11-126 C Not Assessed N/A
Legion Lake and
Shoaf Lake 11-126-1 C Not Assessed N/A
Stowe Branch 11-127 C Not Assessed N/A
Neal Branch (Armour
Creek) 11-128 C Not Assessed N/A
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Receiving Water
Name
Stream Index
/ AU Number
Water
Quality
Classification
Criteria
Exceeded TMDL Status
Long Cove 11-132 C Not Assessed N/A
Porter Branch 11-133 C Not Assessed N/A
Studman Branch 11-134 C Not Assessed N/A
Torrence Branch 11-136 B Not Assessed N/A
Sugar Creek 11-137b C
Benthos Pending (303(d) listed)
Fecal Approved & Implemented
Fish Tissue Mercury Approved Statewide
Sugar Creek 11-137c C
Benthos Pending (303(d) listed)
Fecal Approved & Implemented
Fish Tissue Mercury Approved Statewide
Steele Creek 11-137-10 C Not Assessed N/A
Walker Branch 11-137-10-1 C Not Assessed N/A
Blankmanship Branch 11-137-10-2 C Not Assessed N/A
Stewart Creek 11-137-1-2 C Not Assessed N/A
Coffey Creek 11-137-4 C Not Assessed N/A
Eagl e Branch (W att
Lake, Eagle Lake) 11-137-4-2-(1) B Not Assessed N/A
Eagle Branch 11-137-4-2-(2) C Not Assessed N/A
McCullough Branch 11-137-7 C Benthos Pending (303(d) listed)
Fish Tissue Mercury Approved Statewide
Little Sugar Creek 11-137-8b C
Benthos Pending (303(d) listed)
Fecal Approved & Implemented
Fish Community
TMDL to be developed
for another aquatic
parameter
Fish Tissue Mercury Approved Statewide
Little Sugar Creek 11-137-8c C
Benthos Pending (303(d) listed)
Fecal Approved & Implemented
Fish Community
TMDL to be developed
for another aquatic
parameter
Fish Tissue Mercury Approved Statewide
McAlpine Creek
(Waverly Lake) 11-137-9a C
Benthos Pending (303(d) listed)
Fecal Approved & Implemented
Fish Tissue Mercury Approved Statewide
McAlpine Creek
(Waverly Lake) 11-137-9b C
Benthos Pending (303(d) listed)
Fecal Approved & Implemented
Fish Community Pending (303(d) listed)
Fish Tissue Mercury Approved Statewide
McAlpine Creek
(Waverly Lake) 11-137-9c C
Benthos Pending (303(d) listed)
Fecal Approved & Implemented
Fish Community Pending (303(d) listed)
Fish Tissue Mercury Approved Statewide
McAlpine Creek
(Waverly Lake) 11-137-9d C
Benthos Pending (303(d) listed)
Fecal Approved & Implemented
Fish Tissue Mercury Approved Statewide
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8
Receiving Water
Name
Stream Index
/ AU Number
Water
Quality
Classification
Criteria
Exceeded TMDL Status
Irvins Creek
(McEwen Lake) 11-137-9-2 C Not Assessed N/A
Fourmile Cre ek 11-137-9-4 C Not Assessed N/A
McMullen Creek 11-137-9-5 C Benthos Pending (303(d) listed)
Fish Tissue Mercury Approved Statewide
West Fork
Twelvemile Creek 11-138-1 C Fish Tissue Mercury Approved Statewide
Sixmile Creek 11-138-3 C Fish Community Pending (303(d) listed)
Fish Tissue Mercury Approved Statewide
YADKIN PEE-DEE
Rocky River 13-17a C
Benthos Pending (303(d) listed)
Fecal Approved & Implemented
Fish Tissue Mercury Approved Statewide
Clear Creek 13-17-17a C Fish Tissue Mercury Approved Statewide
Sherman Branch 13-17-17-1 C Not Assessed N/A
Wiley Branch 13-17-17-2 C Not Assessed N/A
Long Branch 13-17-17-3 C Not Assessed N/A
Goose Creek 13-17-18a C Fecal Approved, Implemented &
Meeting Criteria (1)
Fish Tissue Mercury Approved Statewide
Stevens Creek 13-17-18-1 C Not Assessed N/A
Duck Creek 13-17-18-3 C Benthos Not Required
Fish Tissue Mercury Approved Statewide
North Fork Crooked
Creek 13-17-20-1 C Benthos Pending (303(d) listed)
Fish Tissue Mercury Approved Statewide
West Branch Rocky
River 13-17-3 C Not Assessed N/A
South Prong West
Branch Rocky River 13-17-3-1 C Fish Tissue Mercury Approved Statewide
Clarke Creek 13-17-4 C Fish Community Pending (303(d) listed)
North Prong Clarke
Creek 13-17-4-1 C Fish Tissue Mercury Approved Statewide
South Prong Clarke
Creek 13-17-4-2 C Fish Tissue Mercury Approved Statewide
Cane Creek 13-17-4-2-1 C Not Assessed N/A
Ferreltown Creek
(Ferreltown Lake) 13-17-4-3 C Not Assessed N/A
Ramah Creek 13-17-4-4 C Fish Tissue Mercury Approved Statewide
Mallard Creek 13-17-5a C Turbidity Pending (303(d) listed)
Turbidity
Mallard Creek 13-17-5b C
Benthos
TMDL to be developed
for another aquatic
parameter
Copper Pending (303(d) listed)
Fish Tissue Mercury Approved Statewide
Stony Creek 13-17-5-5 C Benthos Pending (303(d) listed)
Fish Tissue Mercury Approved Statewide
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9
Receiving Water
Name
Stream Index
/ AU Number
Water
Quality
Classification
Criteria
Exceeded TMDL Status
Back Creek 13-17-7 C Benthos Pending (303(d) listed)
Fish Tissue Mercury Approved Statewide
Fuda Creek 13-17-7-1 C Not Assessed N/A
Reedy Creek 13-17-8 C Not Assessed N/A
Reedy Creek 13-17-8a C Benthos Pending (303(d) listed)
Fish Tissue Mercury Approved Statewide
Delta Lake 13-17-8-1 C Not Assessed N/A
Crozier Branch 13-17-8-2 C Not Assessed N/A
McKee Creek 13-17-8-4 C
Benthos Pending (303(d) listed)
Fecal Approved & Implemented
Fish Tissue Mercury Approved Statewide
Caldwell Creek 13-17-8-5a C Fish Community Pending (303(d) listed)
Fish Tissue Mercury Approved Statewide
3.4 MS4 Interconnections
The MS4s in Mecklenburg County are interconnected and directly exchange stormwater flow
along with the NCDOT MS4. The Phase II MS4 maps do not show the locations of these
interconnections.
3.5 Total Maximum Daily Loads (TMDLs)
All surface waters with approved TMDLs in Mecklenburg County flow through both Phase I and
Phase II jurisdictions except for Goose Creek and the Rocky River, which lie entirely in Phase II.
To ensure effective coordination, the City of Charlotte, which holds a Phase I Permit, and
Mecklenburg County and the Towns, which hold a joint Phase II Permit, have agreed that the
City of Charlotte will serve as the lead jurisdiction for compliance with TMDL requirements
when the majority of the TMDL watershed lies within the Phase I jurisdiction. When most of the
watershed lies within Phase II, Mecklenburg County will serve as the lead. The lead jurisdiction
is responsible for coordinating and implementing all required TMDL compliance efforts and
submitting all the required plans and reports to the State. They are also responsible for
coordinating with the other jurisdictions as necessary to implement compliance efforts. Table 3
identifies the receiving waters for MS4 discharges in Mecklenburg County that have a TMDL
approved by EPA. The table also indicates the jurisdiction responsible for compliance with
TMDL requirements. The source of the data for Table 3 is NCDEQ’s Water Resources website
located at: NCDEQ Modeling & Assessment Unit web page. Figure 3 shows the locations of
these receiving waters in relation to the Phase I and Phase II jurisdictions in Mecklenburg
County.
Table 3: Approved TMDLs for Mecklenburg County’s Phase I and Phase II Jurisdictions
AU Name AU
Number Class TMDL Pollutant IR
Category
EPA
Approved
MS4
Allocation?
Lead
Jurisdiction
Irwin Creek 11-137-1 C DO 1t 2/5/1996 No Charlotte
Fecal Coliform 4t 3/28/2002 No Charlotte
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
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AU Name AU
Number Class TMDL Pollutant IR
Category
EPA
Approved
MS4
Allocation?
Lead
Jurisdiction
Turbidity 4t 2/8/2005 Yes Charlotte
Long Creek 11-120-
(0.5)
C Turbidity 4t 2/8/2005 Yes Charlotte
11-120-
(2.5)
WS-
IV
Turbidity 4t 2/8/2005 Yes Charlotte
Little Sugar
11-137-8a C DO 1t 2/5/1996 No Charlotte
Fecal Coliform 4t 3/28/2002 No Charlotte
11-137-8b C DO 1t 2/5/1996 No Charlotte
Fecal Coliform 4t 3/28/2002 No Charlotte
11-137-8c C
DO 1t 2/5/1996 No Charlotte
Fecal Coliform 4t 3/28/2002 No Charlotte
Turbidity 1t 2/8/2005 Yes Charlotte
McAlpine
Creek
11-137-9a
C
DO 1t 2/5/1996 No Charlotte
Fecal Coliform 4t 3/28/2002 No Charlotte
Turbidity 1t 2/8/2005 Yes Charlotte
11-137-9b C
DO 1t 2/5/1996 No Charlotte
Fecal Coliform 4t 3/28/2002 No Charlotte
Turbidity 1t 2/8/2005 Yes Charlotte
11-137-9c
C
DO 1t 2/5/96 No Charlotte
Fecal Coliform 4t 3/28/2002 No Charlotte
Turbidity 1t 2/8/2005 Yes Charlotte
11-137-9d
C
DO 1t 2/5/1996 No Charlotte
Fecal Coliform 4t 3/28/2002 No Charlotte
Turbidity 1t 2/8/2005 Yes Charlotte
Sugar Creek
11-137b C Fecal Coliform 4t 3/28/2002 No Charlotte
Turbidity 1t 2/8/2005 Yes Charlotte
11-137c C Fecal Coliform 4t 3/28/2002 No Charlotte
Turbidity 1t 2/8/2005 Yes Charlotte
McKee Creek 13-17-8-4 C Fecal Coliform 4t 8/1/2003 Yes Charlotte
Rocky River 13-17a C Fecal Coliform 4t 9/19/2002 Yes Mecklenburg
Steele Creek 11-137-10 C Fecal Coliform SC
TMDL
5/2007 Yes Charlotte
Lake Wylie 11-122 C Chlorophyll-a 1t 2/5/1996 No Mecklenburg
11-
(123.5)a
C Chlorophyll-a 1t 2/5/1996 No Mecklenburg
Goose Creek 13-17-18a C Fecal Coliform 1 7/8/2005 Yes Mecklenburg
13-17-18b C Fecal Coliform 1 7/8/2005 Yes Mecklenburg
The City of Charlotte and Mecklenburg County have developed and are currently implementing
strategies and tailored BMPs within the scope of the six (6) minimum Permit measures for the
TMDL watersheds identified in Table 3 that have a waste load allocation (WLA) assigned to
stormwater. The purpose of these initiatives, which are incorporated into a TMDL Water
Quality Recovery Program (WQRP), is to reduce levels of the pollutant of concern to the MEP in
accordance with approved Waste Load Allocation (WLAs) assigned to stormwater in the
approved TMDL. Section 11 of this document includes the WQRP for those waters where
Mecklenburg County is the lead, including portions of the Rocky River, Lake Wylie and Goose
Creek. The implementation of the BMPs included in this Program are ongoing. Table 4
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
11
describes the activities implemented by Mecklenburg County when new TMDLs are approved
for waters within the Phase II jurisdiction. These requirements are currently being met for all
existing TMDLs. The City of Charlotte develops and implements BMPs for those waters where
they are the lead through the implementation of their Phase I Permit, which includes portions of
Irwin, Long, Little Sugar, McAlpine, Sugar, Steele, and McKee Creeks. Information regarding
these BMPs is included in Charlotte’s NPDES MS4 TMDL Watershed Plan, which is available
through their Phase I contact. These BMPs are applied within the Phase I jurisdiction of the
watershed. For the Phase II jurisdictions, the BMPs described in Section 11 of this document are
applied.
Table 4: New TMDL Requirements
Requirement Schedule
1. Submit a TMDL annual report to NCDEQ including a description of existing programs,
controls, pa rtnerships, projects, and strategies to address impaired waters and a brief
explanation as to how the programs, controls, partnerships, projects and strategies
address impaired waters.
12 months of the
final EPA approval
of a TMDL
2. Submit a TMDL annual report to NCDEQ including an assessment of whether additional
structural and/or non-structural BMPs are necessary to address impaired waters and a
brief explanation as to how the programs, controls, partnerships, projects and strategies
address impaired waters.
24 months of the
final EPA approval
of a TMDL
3. Submit a TMDL annual report to NCDEQ including a description of activities expected
to occur and when the activities are expected to occur.
36 months of the
final EPA approval
of a TMDL
As stated in the Permit, if subject to an approved TMDL, the Permittee is in compliance with the
TMDL if the permittee complies with the conditions of the Permit, including developing and
implementing appropriate BMPs to reduce non-point source pollutant loading to the MEP. While
improved water quality is the expected outcome, the NPDES MS4 Permit obligation is to reduce
non-point source pollutant loading to the MEP. The MS4 Permittee is not responsible for
attaining the water quality standards (WQS) at the ambient monitoring stations. NCDEQ expects
attaining the WQS will only be achieved through reduction from the MS4, along with reductions
from other nonpoint source contributors.
In June 2019, the State finalized its 2018 303(d) list and integrated 305(b) and 303(d) reports. A
review of these reports by CMSWS revealed that no new TMDLs have been approved in
Mecklenburg County; therefore, no surface waters were added to the existing Water Quality
Recovery Program as described in Section 11. In addition, a review of the reports revealed that
the legacy listings for metals on Little Sugar (below Archdale), Sugar, Irwin, and Mallard (from
source to Stoney) were removed and the new criteria for dissolved metals was indicated as being
met. Mallard Creek was placed on Category 5 for exceeding the criteria for Turbidity as a result
of CMSWS’s data submittal. A new TMDL may be triggered from this new listing. The City of
Charlotte will be responsible for compliance with this new TMDL. No new TMDLs have been
developed for Mecklenburg County since 2014.
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12
Figure 3: Surface Waters in Phase II Jurisdictions with Approved TMDLs
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
13
3.6 Endangered and Threatened Species and Critical Habitat
Populations of threatened or endangered species and/or critical habitat are identified within the
regulated MS4 urbanized area as determined by a review of the Endangered and Threatened
Species and Species of Concern by County for North Carolina Map and Listed species believe to
or known to occur in North Carolina map as provided by the U.S. Fish and Wildlife Service. Of
those species listed, Table 5 summarizes the species that may be impacted by the quality of
surface waters within their habitat.
Table 5: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality
Definitions of Federal Listing Status:
• BGPA: Bald and Golden Eagle Protection Act.
• FSC: Federal Species of Concern. FSC is an informal term. It is not defined in the federal Endangered Species
Act. In North Carolina, the Asheville and Raleigh Field Offices of the US Fish and Wildlife Service (Service)
define Federal Species of Concern as those species that appear to be in decline or otherwise in need of
conservation and are under consi deration for listing or for which there is insufficient information to support listing
at this time. Subsumed under the term "FSC" are all species petitioned by outside parties and other selected focal
species identified in Service strategic plans, State Wildlife Action Plans, or Natural Heritage Program Lists.
• T: Threatened. A taxon "likely to become endangered within the foreseeable future throughout all or a significant
portion of its ra nge ."
• E: Endangered. A taxon "in danger of extinction throughout all or a significant portion of its range."
• ARS: At Risk Species. Species that are Petitioned, Candidates or Proposed for Listing under the Endangered
Species Act. Consultation under Section 7(a)(2) of the ESA is not required for Candidate or Proposed species;
although a Conference, as described under Section 7(a)(4) of the ESA is recommended for actions affecting
species proposed for listing.
• C = candidate. A taxon under consideration for official listing for which there is sufficient information to support
listing. (Formerly "C1" candidate species.)
3.7 Industrial Facility Discharges
The Phase II MS4 jurisdictional areas for Mecklenburg County include the industrial facilities in
Table 6, which hold NPDES Industrial Stormwater Permits as determined from the NCDEQ
Active NPDES Stormwater Permit List and Active Stormwater Permit Map. Inspections of these
facilities are performed when they are suspected as a potential pollution source based on
responses to service requests, results from water quality monitoring, and other general water
quality activities, including the Illicit Discharge Detection and Elimination Program (IDEP)
described in Section 7.7.2.1.
Scientific Name Common name Species Group Federal Listing Status
Haliaeetus leucocephalus Bald eagle Vertebrate BGPA
Etheostoma collis collis Carolina darter Vertebrate FSC
Myotis septentrionalis Northern long-eared bat Vertebrate T
Villosa vaughaniana Carolina creekshell Invertebrate FSC
Lasmigona decorata Carolina heelsplitter Invertebrate E
Bombus affinis Rusty-patched bumble bee Invertebrate E
Tsuga caroliniana Carolina Hemlock Vascular Plant ARS
Symphyotrichum georgianum Georgia aster Vascular Plant C
Rhus michauxii Michaux's sumac Vascular Plant E
Eurybia mirabilis Piedmont aster Vascular Plant FSC
Helianthus schweinitzii Schweinitz's sunflower Vascular Plant E
Echinacea laevigata Smooth coneflower Vascular Plant E
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Table 6: NPDES Stormwater Permitted Industrial Facilities
Permit # Facility Name Jurisdiction Address
NCG050218 Foamex Innovations, Inc. Cornelius Hwy 115 and Bailey Rd
NCG210191 Huntersville Hardwoods Inc Huntersville 11701 McCord Rd
NCG210367 Soil Supply, Inc. Huntersville 10219 Hagars Rd
NCG140323 Thomas Concrete of Carolina Inc Huntersville 11531 McCord Rd
NCG080235 D M Bowman Incorporated Huntersville 12801 Mt Holly-Huntersville Rd
NCG120109 North Meck C&D Landfill Huntersville 15300 Holbrooks Rd
NCG050373 Pactiv, LLC - Huntersville Plant Huntersville 14201 Meacham Farm Rd
NCG030664 Southwire Huntersville Plant Huntersville 12331 Commerce Station Dr
NCG050373 Pactiv LLC – Huntersville Plant Huntersville 14201 Meacham Farm Rd
NCG110011 McDowell Creek WWTP Huntersville 4901 Neck Rd
NCG240013 Wallace Farm Inc Huntersville 14410 Eastfield Rd
NCS000020 McGuire Nuclear Power Plant Huntersville NC Hwy 73
NCG050430 Essentra Packaging Pineville 10500 Industrial Dr
NCG050087 Rutland Group, Inc. Pineville 10021 Rodney St
NCG050253 Mexichem Specialty Compounds,
Inc
Pineville 9635 Industrial Dr
NCG030596 Controls Southeast, Inc Pineville 12201 Nations Ford Rd
NCG080959 Migway, Inc. Pineville 9349 China Grove Church Rd
NCG110010 McAlpine Creek WWTP Pineville 12701 Lancaster Hwy
NCG050139 Ipex USA LLC Pineville 10100 Rodney St
NCG160115 Blythe Construction Inc Pineville 10500 Old Nations Ford Rd
NCG050150 Transcontinental Matthews Matthews 700 Crestdale Rd
NCG030663 Select Stainless Products, LLC Matthews 11145 Monroe Rd
NCG160040 Blythe Construction, Inc.-East
Plant
Matthews 1021 Sam Newell Rd
NCG160083 Martin Marietta Materials Inc.
Matthews plant
Matthews 1011 Sam Newell Rd
NCG020202 Martin Marietta Materials Inc.
Matthews Quarry
Matthews 1215 Sam Newell Rd
NCG030208 McGee Corporation Matthews 12701 E Independence
NCG050404 Berry Global Matthews 303 Seaboard Dr
NCG140039 Concrete Supply Co-Matthews
Plant
Matthews 440 Seaboard Dr
NCG140187 Ready Mixed Concrete Co. -
Indian Trail, Plant 102
Matthews 1316 Indian Trail Waxhaw Rd
NCG200521 Keywell Metals, LLC Matthews 1035 Commercial Dr
NCS000183 Radiator Specialty Co-Matthews Matthews 600 Radiator Rd
3.8 Non-Stormwater Discharges
The water quality impacts of non-stormwater discharges have been evaluated by the
Mecklenburg County Phase II jurisdictions/entities as summarized in Table 7 below. These
evaluations were based on responses to service requests, results from water quality monitoring
and other general water quality program activities. The unpermitted, non-stormwater flows
listed as incidental in Table 7 have been determined based on this evaluation to be insignificant
contributors of pollutants to the MS4; therefore, according to Part I paragraph H 2 of NPDES
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
15
Permit No. NCS000395 these discharges are authorized through the MS4s of the co-permittees.
The street washing discharges included in Table 7 are addressed in more detail under Section
10.7 of this SWMP. Based on the evaluation, individual residential (noncommercial) car
washing was determined to be incidental with no significant impact to water quality provided
washing activities do not occur at designated vehicle wash areas that are connected, directly or
indirectly to the stormwater system or surface waters as is sometimes observed at multi-family
residential complexes. With regard to charity car washing, the evaluation revealed no significant
negative water quality impacts provided washing is not performed by the same organization or at
the same location on a routine basis (more than one time in a thirty-day period). The key to the
designation of these car washing activities as incidental with no significant impact to water
quality is that they are all noncommercial in nature and occur infrequently over a dispersed area.
Car washing activities other than those described above are identified as having significant
impacts to water quality and are prohibited by local surface water pollution control ordinances.
These pollutants are primarily addressed through responses to requests for service and
investigations associated with the Illicit Discharge Elimination Program (IDEP) as described in
Sections 7.7.1.1 and 7.7.2.1 of this document, respectively. NCDEQ has not required that non-
stormwater flows other than those listed in Table 7 be specifically controlled by the Mecklenburg
County Phase II jurisdictions/ entities. These other non-stormwater flows are considered a
significant impact to water quality and are addressed through the implementation of the
programs described in this SWMP.
Table 7: Non-Stormwater Discharges
Non-Stormwater Discharge Water Quality Impacts
water line and fire hydrant flushing; Insignificant
landscape irrigation; Insignificant
diverted stream flows; Insignificant
rising ground waters; Insignificant
uncontaminated ground water infiltration; Insignificant
uncontaminated pumped ground water; Insignificant
discharges from potable water sources; Insignificant
foundation drains; Insignificant
air conditioning condensation; Insignificant
irrigation water; Insignificant
springs; Insignificant
water from crawl space pumps; Insignificant
footing drains; Insignificant
lawn watering; Insignificant
individual residential and charity car washing Insignificant (1)
flows from riparian habitats and wetlands; Insignificant
dechlorinated swimming pool discharges; Insignificant
street wash water; and Insignificant
flows from firefighting activities Insignificant
(1) Except for car washing that occurs at designated vehicle wash areas that are connected,
directly or indirectly to the stormwater system or surface waters and recurring charity car
washes.
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
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3.9 Targeted Pollutants and Sources
Table 8 provides important information regarding the targeted pollutants for Mecklenburg
County’s Phase II jurisdictions/entities, including the various SWMP Programs tailored to
address these pollutants. General data and information obtained from water quality monitoring
and inspection activities as well as responses to service requests were considered in the
development of this table. These same considerations are made each year when this table is
evaluated and modified as necessary as part of the annual review process for the SWMP.
Although additional pollutants not in this table are sometimes targeted by the public education
program, the pollutants in this table are considered the primary target pollutants. A more
detailed description of the targeted audiences and why they were selected is provided in Section
3.10. Additional detail regarding the Public Education and Outreach Program is provided in a
document referred to as the “Umbrella” Plan developed and implemented by CMSWS to
coordinate public education efforts between the Phase I and Phase II jurisdictions in
Mecklenburg County. The Umbrella Plan is updated regularly to meet the changing needs of the
community. A copy of this plan is available upon request to the Environmental Manager for
Mecklenburg County’s Water Quality Program.
Table 8: Targeted Pollutants, Potential Impacts/Physical Attributes, Pollutant Sources, Audience
and Contributing Issues
Targeted
Pollutants
Potential
Impacts/Physical
Attributes
Likely
Pollutant
Sources
Targeted
Audiences
Issues Contributing to the
Pollutant Source
SWMPs Addressing Target
Pollutant(s)/Audience(s)
Bacteria
(fecal
coliform
bacteria is
the
indicator)
High levels cause low
oxygen which leads to
fish kills, stressed
aquatic life and can
cause negative human
health impacts. May
appear in stream as a
fungus which is white
and fluffy or may have
normal appearance.
Sewage odor
sometimes present.
Human
Waste
Residential &
Commercial
• Illicit connections to surface
waters and storm drains.
• Illegal dumping, spills and leaks.
• Discharges from sewer collection
and treatment systems.
• Public Education & Outreach
• Public Involvement & Participation
• IDDE
• Construction Site Runoff Control
• Post-Construction Site Runoff Control
• Pollution Prevention/Good
Housekeeping
• TMDL WQ Restoration Program
Pet Waste
Residential &
Commercial
• Failure to collect and properly
dispose of pet waste.
• Discharges from kennels and
other commercial pet facilities.
• Public Education & Outreach
• Public Involvement & Participation
• IDDE
• TMDL WQ Restoration Program
Sediment Typically measured as
Turbidity and can
destroy aquatic habitat,
smother fish eggs and
bottom dwelling
organisms. Will give
water an orange
appearance due to the
soil types in our region.
Eroding
stream
banks,
erosion from
construction
activity
Residential &
Commercial
(with a focus
on the
Construction
Industry)
• Improper erosion control
measures at land development
sites.
• Inadequate post-construction
stormwater controls.
• Inadequate buffers and unstable
stream channels.
• Public Education & Outreach
• Public Involvement & Participation
• IDDE
• Construction Site Runoff Control
• Pollution Prevention/Good
Housekeeping
3.10 Targeted Audiences
Provided below is a description of the targeted audiences selected for the Public Education and
Outreach Program for Mecklenburg County’s Phase II jurisdictions/entities. These audiences
were targeted based on their ability to impact the issues contributing to the likely pollutant
sources described in Table 8. In addition, the targeted audiences were selected based on their
potential for expanding our volunteer programs for protecting and restoring water quality
conditions.
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
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Residential Communities: This group has the ability to positively impact both targeted
pollutants identified in Table 8 above. They also have a significant potential to increase
participation in volunteer programs for protecting and restoring water quality conditions. This is
a large targeted audience composed of many subsets, including but not limited to homeowners,
renters, multi-family facilities, pet owners, etc. CMSWS has developed educational materials for
reaching residential groups and will develop and implement outreach initiatives on an as needed
basis to address specific water quality issues as they arise.
Commercial: This group, like the residential group, has a significant potential to positively
impact water quality and has several subsets, including landscapers, grading contractors,
construction industry, building maintenance companies, mobile washers, automotive repair
shops, etc. CMSWS has developed educational messages for reaching these subsets and will
develop and implement outreach initiatives on an as needed basis to address specific water
quality issues as they arise.
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SECTION 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION
A program has been developed and is currently being implemented for administering the Phase II
Permit for Mecklenburg County’s Phase II jurisdictions/entities for the purpose of ensuring that
all Permit requirements are effectively and efficiently fulfilled by co-permittees in accordance
with the SWMP and that the administration requirements specified in the Permit are being met.
The program is administered by CMSWS’s Water Quality Program as described in the following
Sections.
4.1 Program Goal
The goal of Program Administration is to implement, manage and oversee the provisions of the
SWMP to control to the maximum extent practical the discharge of pollutants from the municipal
storm sewer system associated with stormwater runoff and illicit discharges, including spills and
illegal dumping and to ensure that all Phase II Permit requirements are effectively and efficiently
fulfilled.
4.2 BMP Summary Table
CMSWS will manage and report the BMPs described in Table 9 for the administration of the
SWMP.
Table 9: Program Administration BMPs
Permit
Ref.
Permit Development (Part III Section B; Part IV B; Part V Section A.11): Performing activities necessary to fulfill the
administrative requirements for compliance with permit requirements, including coordinating with co-permittees, completing the
annual assessment report, applying for permit renewal, and updating the Storm Water Management Program Plan as necessary.
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description
of BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
#1
PD-1
(Permit
Development)
Permit Development
Coordinate
with co-
permittees for
Permit
compliance
and complete
audits and
program
assessments
as well as
submit Permit
applications,
reports, etc.
as required.
a. Coordinate with co-permittees
regarding permit compliance
efforts at a minimum of twice
during the fiscal year.
a. Annually
beginning July
1
a. Completion
status
Meet and
coordinate with
CMSWS as
requested as well
as provide data and
information as
requested for
inclusion in
reports, audits,
Permit
applications, etc.
b. Participate in an NPDES MS4
Permit Compliance Audit, as
scheduled and performed by
EPA or NCDEQ.
b. As scheduled
by NCDEQ -
Typically
Permit Year 4
b. Completion
status
c. Self-audit and document any
stormwater program components
not audited by EPA or NCDEQ
utilizing the NCDEQ Audit
Template. Submit Self-Audit to
NCDEQ (required component of
Permit renewal application
package).
c. As scheduled
by NCDEQ
c. Completion
status
d. Certify the stormwater Permit
renewal application (Permit
renewal application form, Self-
d. Permit Year 5 d. Date of
Permit
renewal
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
19
Permit
Ref.
Permit Development (Part III Section B; Part IV B; Part V Section A.11): Performing activities necessary to fulfill the
administrative requirements for compliance with permit requirements, including coordinating with co-permittees, completing the
annual assessment report, applying for permit renewal, and updating the Storm Water Management Program Plan as necessary.
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description
of BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
Audit, and Draft SWMP for the
next 5-year permit cycle) and
submit to NCDEQ at least 180
days prior to Permit expiration.
application
submittal
e. Complete annual assessment of
Phase II Permit compliance,
including all BMPs and
measurable goals. Summarize
the assessment in an annual
report, including
recommendations for
improvement. Provide report to
all Phase II co-permittees and
NCDEQ.
e. Annually
beginning July
1
e. Completion
status
#2
PD-3
(Evaluate
Management
Plan)
Evaluate Effectiveness of Storm Water Plan
Evaluate the
effectiveness
of the Storm
Water
Quality
Management
Program Plan
and update as
necessary,
including all
written
policies and
procedures.
a. Implement through the annual
Work Plan the recommendations
for improvement identified in the
annual report (see PD-1)
summarizing the annual
assessment of Phase II Permit
compliance (PD-1).
a. Annually
beginning July
1
a. Completion
status
Provide data and
information as
requested for
inclusion in
reports, audits, etc.
as well as
implement
recommendations
for improvement
as necessary.
b. Assess the effectiveness of the
Storm Water Management
Program Plan for compliance with
permit. Summarize the assessment
in an annual report, including
recommendations for
improvement. Include the
assessment in the report for PD-1.
b. Annually
beginning July
1
b. Completion
status
4.3 Organizational Structure
The Environmental Manager for CMSWS’s Water Quality Program is responsible for
developing, implementing, managing and overseeing the SWMP. The Environmental Manager
reports to the Director of CMSWS who serves as the Stormwater Program Administrator as
delegated by the Mecklenburg County Board of Commissioners by a resolution dated December
17, 2002. Four (4) Environmental Supervisors that report to the Environmental Manager are
responsible for implementing five (5) of the seven (7) components of the SWMP. An
Environmental Supervisor and Lead Project Manager in the Permitting and Compliance Program
who reports to a Senior Project Manager who reports to the Director of CMSWS are responsible
for implementing the other two (2) components of the SWMP. In most cases, staff under the
direction of their Environmental Supervisor are responsible for completing the activities
necessary for implementing the components of the SWMP. Table 10 illustrates the breakdown
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
20
of responsibilities. Appendix A provides additional information regarding these responsibilities,
including BMPs and measurable goals. Appendix B provides an organizational chart that shows
where the responsible parties fit into the structure of CMSWS. The procedures, specific tasks,
deadlines and assigned staff for fulfillment of the SWMP are described in an annual Work Plan.
A copy of this Work Plan is available upon request to the CMSWS’s Environmental Manager for
Mecklenburg County’s Water Quality Program. Each co-permittee is responsible for compliance
with Permit requirements for the operation and maintenance of facilities, MS4s, stormwater
control measures (SCMs), streets, and parking lots that they own and/or maintain. Operation and
Maintenance (O&M) Plans have been developed and implemented and are available upon
request. Co-permittee contact information is provided in Table 15.
Table 10: Summary of Responsible Parties
Description Responsible
Position
Staff
Name Department Phone
Number Email
SWMP Administration and Management
1. Stormwater Program
Administration
Director,
CMSWS
W. Dave
Canaan
CMSWS 980-314-3209 Dave.cannan@mecknc.gov
2. SWMP Management Environmental
Manager
Rusty
Rozzelle
CMSWS 980-314-3217 Rusty.rozzelle@mecknc.gov
SWMP Components
1. Public Education &
Outreach
Environmental
Supervisor
David
Caldwell
CMSWS 980-314-3218 David.caldwell@mecknc.gov
2. Public Involvement &
Participation
Environmental
Supervisor
David
Caldwe ll
CMSWS 980-314-3218 David.caldwell@mecknc.gov
3. Illicit Discharge
Detection &
Elimination (includes
Spill Response)
Environmental
Supervisor
(IDDE
Program
Activities &
Spill
Response)
Ryan
Spidel
CMSWS 980-314-3219 Ryan.spidel@mecknc.gov
Environmental
Supervisor
(Monitoring)
Olivia
Edwards
980-314-3213 Olivia.edwards@mecknc.gov
4. Construction Site
Runoff Control (1)
Lead Project
Manager
(Permitting)
Tom
Hodge
CMSWS 980-314-3203 Tom.hodge@mecknc.gov
Environmental
Supervisor
(Inspections)
Corey
Priddy
980-314-3221 Corey.priddy@mecknc.gov
5. Post-Construction
Site Runoff Control
(1)
Environmental
Manager
(Administrator)
Rusty
Rozzelle
CMSWS 980-314-3217 Rusty.rozzelle@mecknc.gov
Lead Project
Manager
(Permitting)
Tom
Hodge
980-314-3203 Tom.hodge@mecknc.gov
Environmental
Supervisor
(Inspections)
Corey
Priddy
980-314-3221 Corey.priddy@mecknc.gov
6. Pollution
Prevention/Good
Housekeeping for
Environmental
Supervisor
Richard
Farmer
CMSWS 980-314-3215 Richard.farner@mecknc.gov
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
21
Description Responsible
Position
Staff
Name Department Phone
Number Email
Municipal Operations
(2)
7. Municipal Facilities
Operation &
Maintenance Program
(2)
Environmental
Supervisor
Richard
Farmer
CMSWS 980-314-3215 Richard.farner@mecknc.gov
8. Spill Response
Program (2)
Environmental
Supervisor
Richard
Farmer
CMSWS 980-314-3215 Richard.farner@mecknc.gov
9. MS4 Operation &
Maintenance Program
(2)
Environmental
Supervisor
Richard
Farmer
CMSWS 980-314-3215 Richard.farner@mecknc.gov
10. Municipal SCM
Operation &
Maintenance Program
(2)
Environmental
Supervisor
Ryan
Spidel CMSWS
980-314-3219 Ryan.spidel@mecknc.gov
11. Pesticide, Herbicide
& Fertilizer
Management
Program (2)
Environmental
Supervisor
Richard
Farmer
CMSWS 980-314-3215 Richard.farner@mecknc.gov
12. Vehicle & Equipment
Cleaning Program (2)
Environmental
Supervisor
Richard
Farmer
CMSWS 980-314-3215 Richard.farner@mecknc.gov
13. Pavement
Management
Program (2)
Environmental
Supervisor
Richard
Farmer
CMSWS 980-314-3215 Richard.farner@mecknc.gov
14. Total Maximum
Daily Load (TMDL)
Requirements
Environmental
Manage r
Olivia
Edwards
CMSWS 980-314-3213 Olivia.edwards@mecknc.gov
(1) In the Town of Huntersville and its ETJ, Town staff are responsible for plan reviews and
issuing land development permits as well as conducting inspections during construction to
ensure compliance with Permit requirements. Kevin Fox, Public Works Director, is the
responsible party for the Town of Huntersville (see Table 15 for contact information).
CMSWS serves as the administrator of Huntersville’s Post-Construction Ordinance.
(2) CMSWS is responsible for implementing the BMPs described in the summary tables
contained in this document unless otherwise indicated as well as coordinating with County
staff regarding operation and maintenance of County owned facilities and operations. Co-
permittees are responsible for Permit compliance at the facilities that they own and/or operate
with guidance from CMSWS. Table 15 provides the contact names for the responsible co-
permittees.
4.4 Standard Operating Procedures (SOPs)
Written Standard Operating Procedures (SOPs) are developed to identify specific action steps,
schedules, resources and responsibilities for implementing the six (6) minimum measures for
controlling pollution sources. Written procedures can be free standing, or where appropriate,
integrated into the SWMP. SOPs are also included in SWPPPs for facilities and are made
available to staff for dissemination as appropriate. SOPs generally adhere to the following
outline:
Section 1: Purpose
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
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Provide a brief statement of the purpose of the activity and its contribution to the overall NPDES
program, including identification of the minimum measure that it falls under and why we do it.
This should include a “Description” of the activity (program element) consistent with the annual
Work Plan.
Section 2: Action Steps
Describe the specific action steps necessary to complete the activity.
Section 3: Schedules
Describe the schedule for the completion of each action step.
Section 4: Resources and Responsibilities
Describe the specific staff responsible for implementing the action steps in accordance with the
schedule. Describe the specific responsibilities of these staff in the execution of the action steps.
Section 5: Deliverables
Discuss the results of the activities performed. How do these results contribute toward fulfilling
the requirements of the Permit.
4.5 Documentation
The following summarizes CMSWS’s documentation of Phase II Permit compliance activities.
1. The specific actions and deadlines implemented by CMSWS in the execution of the
BMPs and measurable goals for compliance with Permit requirements is maintained in an
annual Work Plan.
2. Annual Work Plans are maintained in a database referred to as Time Pro. Time Pro is
also used to track staff time toward completion of Work Plan assignments.
3. The Cityworks database maintains documentation of the completion of Work Plan
activities except for water quality monitoring activities that are documented in the Water
Quality Database.
4. The LAN folder at \\hmcf s01\attachments\WQ serves as the backup destination for
Cityworks documentation generated by the Water Quality Program.
5. The LAN folder at G:\Water Quality\WQ_Xfer\WQ\Phase II Permit maintains annual
reports, co-permittee information, Permit applications, Permit audits, Phase II Permits,
presentations, State correspondence, SWMPs, TMDL documentation, and other
information relating to the Phase II Permit.
6. The Environmental Data Management System (EDMS) serves as the reporting
mechanism for data relating to services requests and notices of violation, including repeat
offenders as required by the Permit.
7. The Emerald System maintains documentation of stormwater drainage service requests.
8. The Electronic Plan Review (EPM) system maintains documentation of plan and plat
reviews for compliance with Erosion Control and Post-Construction Programs.
9. Co-permittees are responsible for maintaining documentation for compliance activities
that are their responsibility as described in Appendix F.
CMSWS’s staff are required to documentation all activities performed for compliance with
Phase II Permit requirements as summarized above. The annual Work Plan maintained in Time
Pro informs staff of their assigned activities and deadlines and provides them with tools for
tracking the completion of assignments. It is the responsibility of the lead staff for each activity
as identified in the Work Plan to complete the necessary documentation. Procedures have been
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
23
developed for the proper completion of this documentation and are available to staff in the Water
Quality Program Policies and Procedure Manual. Cityworks is the primary mechanism used to
document the completion of Work Plan activities except for water quality monitoring activities,
which are documented in the Water Quality Database. The Cityworks Server Attachments folder
on the LAN at \\hmcfs01\attachments\WQ that corresponds to the current fiscal year is the back-
up destination for most documentation. The Activity Report in Cityworks is used for
maintaining documentation for most activities. Some of these activities have templates in
Cityworks for more effective documentation, including responses to service requests, issuance of
notices of violation and various routine inspections (i.e. erosion control, industrial and municipal
facilities and BMPs). CMSWS’s staff are required to provide the following information
regarding completed activities:
• Specific date(s) when work was performed.
• Names of individual(s) that performed the work.
• Description of the work that was performed.
• Description of how the work was performed.
• Locations/areas where the work was performed.
• Persons or groups contacted for completion of the work.
• Description of all compliance activities, including notices of violation issued, fines, etc.
• Specific outcomes resulting from the completion of the assigned task.
4.6 Annual Assessment of SWMP and Implementation of Improvements
The SWMP is reviewed and updated as necessary, but at least on an annual basis to identify
modifications and improvements needed to maximize effectiveness to the maximum extent
practicable. As a result of this evaluation, modifications and improvements are identified for
implementation during the following fiscal year. The evaluation is submitted to NCDEQ
annually, including the identification of modifications and improvements to be made to the
SWMP as well as the updated SWMP for the following fiscal year. Annual reports include
appropriate information to accurately describe the progress, status, and results of the permittee’s
SWMP, including, but not limited to, the following components:
1. Describe the status of implementation of the SWMP as a whole. This will include
information on development and implementation of each major component of the SWMP
for the past year and schedules and plans for the year following each report.
2. Describe and justify any proposed changes to the SWMP. This will include descriptions
and supporting information for the proposed changes and how these changes will impact
the SWMP (results, effectiveness, implementation schedule, etc.).
3. Document any necessary changes to programs or practices for assessment of management
measures implemented through the SWMP.
4. Summary of data accumulated as part of the SWMP throughout the year along with an
assessment of what the data indicates in light of the SWMP.
5. Asse ssment of compliance with the Permit, information on the establishment of
appropriate legal authorities, inspections, and enforcement actions.
In October 2020, the annual assessment of the SWMP was completed and a report was submitted
to the NCDEQ. The assessment included a review by all supervisors and key staff as well as the
Environmental Manager responsible for implementation of the SWMP. As a result of this
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
24
assessment, the SWMP was found to effectively and efficiently describe the measures
undertaken by Mecklenburg County for compliance with Permit requirements. Some changes to
the SWMP were identified for implementation in FY2021 to better describe existing practices
and improve documentation that do not necessarily affect Permit compliance. These changes are
described in Table 11 below. In addition, several changes were made in grammar and wording
throughout the document that are not listed below. All changes are documented using the Track
Changes feature in Word. This document is location on the LAN as follows: G:\WaterQuality\
WQ_Xfer\WQ\ Phase II Permit\Storm Water Management Plan\FY21 DRAFTS\FY2021 Storm
Water Quality Management Program Plan with Track Changes. In addition to the changes to the
SWMP, the annual assessment also resulted in changes to the FY2021 Work Plan that is used to
describe in detail the procedures, including staff assignments and deadlines, for implementation
of the SWMP. These changes are described in Table 12 below. The annual assessment and the
FY2021 SWMP are posted on the website at http://stormwater.charmeck.org (select Surface
Water Quality, select Program Overview, select Phase II Permit).
Table 11: Changes to the FY2020 SWMP for Implementation in FY2021
# Locati on of
Change Description of Change Justification Impact to Storm Water
Plan
1 Section 2.5 Updated Table 3 to reflect changes to the
TMDLs for Mecklenburg County’s Phase I
and II jurisdictions.
Document changes to
TMDLs since FY2019.
Compliance with Permit
requirements.
2 Section 2.8 Changed Table 8 to include a column
describing “Potential Impacts/Physical
Attributes” of Targeted Pollutants.
This is a 2020 Internal
Audit recommendation.
Required by Section B,
2, d of or Permit
(#NCS000395).
Compliance with Permit
requirements.
3 Section 2.8 Table 8 was changed to add “Litter” as
Targeted Pollutants.
Litter is a significant
pollutant in
Mecklenburg’s Phase II
areas.
Improve targeting of
educational efforts.
4 Section 3.2 Changed Table 9 to reflect that David
Caldwell and not Deania Russo is the
Responsible Staff assigned to PE-9.
Reflects how this work
is being performed.
Reflects how this work is
being performed.
5 Section
3.4.6
Added a description of targeted outreach on
a watershed scale such as for compliance
with TMDLs.
Reflects how this work
is being performed.
Reflects how this work is
being performed.
6 Section 3.5 Added this Section to describe our outreach
to the County’s diverse population.
Necessary to reach the
targeted audiences.
Compliance with Permit
requirements.
7 Section 3.6 Added this Section to describe the new
Communication Plan that includes the
methodology and tools that we use to
promote public education and involvement
as well as to communicate information
regarding spills and other incidents
responded to by CMSWS.
This is a 2020 Internal
Audit recommendation.
Recommended by EPA.
Improves consistency of
communications.
8 Section 4.2 Changed Table 10 to reflect that Ashley
Smith and not Deania Russo is the
Responsible Staff assigned to PE-I(14).
Reflects how this work
is being performed.
Reflects how this work is
being performed.
9 Section 5.2 Changed Table 11 to reflect changes in
staff responsibilities for ID-1, ID-3, ID-5,
and ID-U.
Reflects how this work
is being performed.
Reflects how this work is
being performed.
10 Section 5.4 Changed Fi gures 8, 11, and 12 to reflect Reflects current Reflects current database.
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
25
# Locati on of
Change Description of Change Justification Impact to Storm Water
Plan
current Cityworks screen shot. database.
11 Section 5.5 Added a description of ordinance changes
in FY2020.
Reflect changes. Reflects current
enforcement provisions.
12 Section
5.7.1.2
Updated Figure 10 (SUSI Map) to the
current 2020 version.
Reflects current map. Reflects current map.
13 Section
5.7.1.2
Added the second Thursday to the second
Tuesday of each month for Fixed Interval
Monitori ng.
Reflects a change made
due to COVID.
Reflects a change made
due to COVID.
14 Section
5.7.2.1
Changed description of Illicit Discharge
Elimination Program (IDEP).
Reflects how this work
is being performed.
Reflects how this work is
being performed.
15 Section 5.10 Added a new measure of success for the
IDDE Program based on minimizing the
number of repeat violators.
Measure effectiveness
of ordinances adopted
in FY2020 and
accompanying
enforcement
procedures.
Measure of success of
BMPs.
16 Section 6 Added a description of the Town of
Huntersville’s role in the implementation of
the erosion control program in their
jurisdiction.
Reflects change in how
work is being done
effective July 1, 2019.
Reflects change in how
work is being done
effective July 1, 2019.
17 Section 8.3 Changed wording to better reflect process
for identifying facilities subject to the
Pollution Prevention & Good
Housekeeping Program.
Reflects how this work
is being performed.
Reflects how this work is
being performed.
18 Section 8.3 Changed Table 17 to include the Latta
Plantation and McDowell Nature Preserves.
These facilities were
added in FY2020.
Compliance with Permit
requirements.
19 Section 8.3 Updated Tables 19 and 20 to include
current contact information and to remove
the Charlotte Recycling Center.
Reflects changes made
in personnel in
FY2020.
Compliance with Permit
requirements.
20 Sections 8.5
and 8.9
Added the language that CMSWS obtains
pesticide license numbers for all employees
and contractors performing application
activities and conducts a search on the NC
Dept. of Agriculture and Consumer
Services website to ensure all licenses are
valid.
Reflects changes made
in personnel in
FY2020.
Compliance with Permit
requirements.
21 Section 8.9 Added the language that during annual
inspections CMSWS will obtain a copy of
annual pesticide application records. These
records will be reviewed by the inspector
and compared to previous years to
determine if there have been significant
increases in the quantities applied or areas
treated in wh ich case further investigations
will be performed to determine if permit #
NCG560000 should be obtained. The
application records, results of further
investigations and copies of Permits issued
will be maintained in the facility’s file.
Reflects changes made
in personnel in
FY2020.
Compliance with Permit
requirements.
22 Section 9.2 Changed Table 24 to reflect that Tim Besier
and not Rusty Rozzelle is the Responsible
Staff assigned to IW-1, IW-2, and IW-4.
Reflects how this work
is being performed.
Reflects how this work is
being performed.
23 Section Changed the Section title from Improved description of Focuses on nutrient issues
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
26
# Locati on of
Change Description of Change Justification Impact to Storm Water
Plan
9.3.2 Chlorophyll-a to Nutrient TMDL and
described the impacts of nutrients on water
quality as well as the use of Chlorophyll-a
as proxy to nutrient standards in N.C.
TMDL. relating to the TMDL.
24 Section
9.9.1
Changed Table 29 to include new numbers
for 2019 and increases from 2011.
Reflects current data. Reflects current data.
25 Sections
9.9.1, 9.9.2,
and 9.9.3
Updated to include a discussion of data
collected through 2019.
Reflects current data. Reflects current data.
26 Section
9.10.1 and
9.10.2
Added the additional BMP measures
implemented in FY2020.
Reflects current data. Reflects current data.
27 Section
9.10.4
Added the additional BMP measures
implemented in FY2021.
Reflects compliance
measures to be
implemented in
FY2021
Compliance with Permit
requirements.
28 Section 10.2 Added section describing how activities are
documented for Permit compliance.
This is a 2020 Internal
Audit recommendation.
Reflects how this work
is being performed.
Compliance with Permit
requirements.
29 Section 10.3 Added section to describe the annual
assessment of the SWMP and
recommended changes as well as
recommended changes to the FY21 Work
Plan.
Documentation of
existing process.
Compliance with Permit
requirements.
30 Section 10.4 Changed text and Table 31 to reflect
FY2021 budget numbers.
Represents current data. Represents current data.
31 Appendix A Changed PE-I(14), PE-9, ID-U, IW-1, IW-
2, and IW-4 to reflect new staff
assignments and contact information.
Reflects how this work
is being performed.
Reflects how this work is
being performed.
32 Appendix B Updated organizational chart. Reflects staffing
changes from FY2020.
Reflects staffing changes
from FY2020.
33 Appendix D Updated procedures for inclusion of
facilities and/or operations into the
Pollution Prevention Program
Reflects changes that
will be implemented
effective FY2021.
Compliance with Permit
requirements.
34 Appendi x E Updated inspection checklist. Reflects changes that
will be implemented
effective FY2021.
Compliance with Permit
requirements.
Table 12: Changes to the FY2021 Work Plan
# Improvements Identified for Implementation in
FY2021 Desired Result
Work Plan
Program
Element
Responsible
Staff
Public Education and Outreach
1 Continue to promote Stormy (mascot) for various
education events and use Stormy for pollution
prevention messages and videos.
Increase
Awareness
PE-10 Ashley Smith
2 Investigate creating a children’s video using Stormy to
promote storm water education.
Increase
Awareness
PE-10 Ashley Smith
3 Investigate the feasibility of hosting and promoting a
hip hop / rap video using key stormwater pollution
prevention terms for the purpose of promoting
Increase
Awareness
ID-5 Ken Friday
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
27
# Improvements Identified for Implementation in
FY2021 Desired Result
Work Plan
Program
Element
Responsible
Staff
stormwater education.
4 Develop virtual school presentations to use for various
age groups due to COVID19 challenges.
Increase
Awareness
PE-10 Ashley Smith
5 Implement the plan for education regarding the use and
negative impacts of coal tar sealants.
Increase
Awareness
PE-I(15) Ashley Smith
6 Partner with the Regional Stormwater Partnership of
the Carolinas and JC Smith University on a WRRI
grant to improve public awareness and education of
storm water / water quality issues in underserved
communities in Charlotte.
Increase
Awareness
PE-10 David Caldwell
7 Use results from the 2020 Census to evaluate ethic and
economic groups, and languages spoken throughout
Mecklenburg County. Based on this information,
develop a plan to reach appropriate groups with public
education and outreach messaging and material.
Increase
Awareness
PE-10 Ashley Smith
Public Involvement and Participation
1 Implement components of the Adaptive Management
Strategy to increase community involvement.
Increase
Volunteerism
SBP-Involvement David Caldwell
/ Ashley Smith
2 Create and implement a volunteer competition and
promote on social media
Increase
Volunteerism
PE-10 Ashley Smith
3 Promote the virtual Streamside Assessment Volunteer
Monitoring training module on social channels and
volunteer newsletter
Increase
Volunteerism
VM Ken Friday
4 Continue to create monthly newsletters aimed at
volunteers to create motivation and notify them of
upcoming event s.
Increase
Volunteerism
PE-10 Ashley Smith
5 Implement Adopt a Drain Program in Matthews. Increase
Volunteerism
SBP-Involvement Ashley Smith
6 Continue to create monthly volunteer spotlights to
promote volunteerism and praise volunteers.
Increase
Volunteerism
PE-I(14) Ashley Smith
7 Target specific neighborhoods where storm drains have
not been marked and develop marketing to get them
involved with the Storm Drain Marking program.
Increase
Volunteerism
PI-3 Ashley Smith
Illicit Discharge Detection and Elimination
1 Identify and implement new technologies or
applications to improve outfall re-inspections.
Permit
Compliance
ID-1 Silvio Conte
2 Update the IDDE manual. Permit
Compliance
ID-10 Andrew
DeCristofaro
3 Identify areas of missing stormwater inventory in the
Phase II jurisdictions and implement a collection
initiative.
Permit
Compliance
ID-1 Ryan Spidel
4 Expand the used oil inspection (ID-U) program to
include inspections at marinas.
Increase Pollution
Problems
Identified
ID-U Matt Santiago
Construction Site Storm Water Runoff Control
1 Mecklenburg County will continue working on
changing all Erosion Control ordinances to meet the
new State model ordinance.
Improve
Compliance
CS-1 Corey Priddy
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
28
# Improvements Identified for Implementation in
FY2021 Desired Result
Work Plan
Program
Element
Responsible
Staff
2 The Town of Huntersville will create procedural
documents and checklists for developers and
contractors to use for ordinance compliance.
Improve
Compliance
N/A Kevin Fox,
Town of
Huntersville
3 Mecklenburg County will move CMCSI to an online
platform that utilizes technology, video and County
erosion control resources.
Improve
Compliance
CS-2 Corey Priddy
4 Mecklenburg County will fully implement State
remission changes and follow through with
implementation procedure at the local level.
Improve
Compliance
CS-1 Corey Priddy
Post-Construction Site Runoff Control
1 Continue efforts to increase BMP compliance and
reduce repeat problems.
Improve
Compliance
PC-2 Corey Priddy
2 Mecklenburg County will work with the Town of
Huntersville to better transition BMPs from the
construction phase to the annual inspection phase.
Improve
Compliance
PC-3 Corey Priddy
3 Develop a process to better identify when BMPs need
to be inspected base d on the Ordinance for which they
were installed.
Improve
Compliance
PC-2 Corey Priddy
Pollution Prevention/Good Housekeeping for Municipal Operations
1 Continue efforts to ensure Phase II municipal
operations and facilities are complying with NPDES
storm water Permit requirements by emphasizing the
importance of ensuring compliance prior to the State
audit in 2021.
Permit
Compliance
PP-2 Richard Farmer
2 Increase efforts to ensure pesticide licenses are current
and verify continuing education requirements through
the North Carolina Department of Agriculture and
Consumer Services website and document for each
applicator.
Permit
Compliance
PP-2 Richard Farmer
Total Maximum Daily Loads
1 Routine fixed interval monitoring will continue to be
performed monthly at MY-9 on Goose Creek at Stevens
Mill Road, MY-14 on Duck Creek at Tara Oaks Lane,
and at MY1B located upstream of the Rocky River
TMDL watershed. Monthly samples will be analyzed
for 16 parameters including fecal coliform and E. Coli.
Exceedances of established water quality watch and
action levels will be identified and follow up actions
conducted as necessary for the identification and
elimination of pollution sources.
Permit
Compliance
ID-4.1 Olivia Edwards
2 By June 30, 2021, CMSWS will complete a review of
Health Department records to determine where failed
septic systems have been identified in both the Rocky
River and Goose Creek TMDL watersheds. Follow up
inspections and monitoring will be performed as
necessary to ensure the elimination of sources of fecal
coliform ba cteria associated with failed septic systems
thereby addressing impaired waters.
Permit
Compliance
IW-2 Andrew
DeCristofaro
3 By June 30, 2021, major outfalls will be inspected in Permit IW-2 Iva Barnes
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
29
# Improvements Identified for Implementation in
FY2021 Desired Result
Work Plan
Program
Element
Responsible
Staff
the Rocky River TMDL watershed. Dry weather flows
will be identified, and pollution sources eliminated
thereby addressing impaired waters.
Compliance
4 By August 2020, the contractor selection process for
the proposed West Branch Rocky River restoration will
be completed. Const ruction activities associated with
Phase I of the project will begin by October 2020.
Currently, the Rocky River is severely eroded by storm
water flows that eat away at the stream banks. The
restoration project will stabilize the stream banks to
reduce erosion and improve water quality in the creek.
Permit
Compliance
Engineering &
Mitigation
Program
Tim Trautman
In February and March 2021, additional changes were made to the FY2021 version of the
SWMP to capture program modifications. Minor changes to the FY2021 Work Plan were made
as a result of the modifications to the SWMP. Table 13 provides a description of these changes
that were implemented effective immediately.
Table 13: Changes to the FY2021 SWMP for Implementation Effective February 11, 2021
# Location of
Change Description of Change Justification Impact to Storm Water
Plan
1 Section 2.8 Added a sentence to the text and
changed Table 8 to reflect changes to
our Targeted Pollutants.
To align with Charlotte
Storm Water Services since
the media campaign is
conducted jointly.
More accurately reflects
how work is being
performed.
2 Section 3.10 Changed target audiences to reflect
changes to Table 8.
To align with Charlotte
Storm Water Services since
the media campaign is
conducted jointly.
More accurately reflects
how work is being
performed.
3 Sections
4.2, 5.2, 6.2,
7.2, 8.2, 9.2,
10.2 & 11.2
BMP Summary Tables were changed
to reflect the format requested by
NCDEQ.
To align with NCDEQ’s
recommended format.
More accurately reflects
individual measurable
goals and responsibilities
of co-permittees.
4 Section 5.4 Added last paragraph to the Section to
describe the process for updating
storm sewer maps for new
developments.
Reflect improvements made
to the process effective
January 2021.
More accurate, up to date
storm sewer maps.
5 Section 5.5 Added the revision of Davidson’s
Surface Water Pollution Control
Ordinance effective January 26, 2021.
To improve enforcement and
to align Da vidson’s
ordinance with the other
County jurisdictions.
Improve elimination of
IDDEs.
6 Section 7.4 Added a paragraph explaining
maintenance of SCMs owned by co-
permittees.
Comply with requirements
of Permit.
Reflects how this work is
being performed.
7 Section 7.11 Changed #10 to reflect that the owner
of the BMP is responsible for annual
inspections and submitting
documentation to CMSWS as well as
for correcting violations.
Comply with requirements
of Permit.
Reflects how this work is
being performed.
8 Section 8.3 Simplified the description of the
inventory process.
Reflect improvements made
to the process effective
Reflects how this work is
being performed.
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
30
# Location of
Change Description of Change Justification Impact to Storm Water
Plan
January 2021.
9 Section 8.5 Added a section describing SOPs. Comply with requirements
of Permit.
Reflects how this work is
being performed.
10 Section 8.6 Added a paragraph explaining
inspections of public schools.
Reflects how this work is
being performed.
Reflects how this work is
being performed.
11 Section 8.7 Changed the street sweeping BMP. Comply with requirements
of Permit.
Reflects how this work is
being performed.
12 Section 8.8 Added a paragraph at the end of the
section stating that co-permittees are
required to maintain and implement an
Operation & Maintenance Program for
post-construction SCMs that it owns,
including the frequency of inspections
and routine maintenance requirements.
Comply with requirements
of Permit.
Reflects how this work is
being performed.
13 Section 8.10 Added BMP (SOPs) for controlling
pollutants from winter road
maintenance.
Comply with requirements
of Permit.
Reflects how this work is
being performed.
14 Section 8.12 Expanded the BMPs (SOPs) for
controlling pollutants from vehicle and
equipment maintenance, cleaning and
refueling.
Comply with requirements
of Permit.
Reflects how this work is
being performed.
15 Section 10.3 Add a new Table 33 to include
changes made to the 2021 SWMP
effective February 2021.
Comply with requirements
of Permit.
Reflects how this work is
being performed.
16 Section 10.7 Added a Section to describe
coordination between co-permittees.
Comply with requirements
of Permit.
Reflects how this work is
being performed.
17 Appendix A Added a column to indicate the part of
the Permit that applies to each
program eliminate and a column to
indicate co-permittee responsibilities.
Reflects how this work is
being performed.
Reflects how this work is
being performed.
18 Appendix D Simplified the description of the
inventory process.
Reflect improvements made
to the process effective
January 2021.
Reflects how this work is
being performed.
4.7 Program Budget and Funding
For FY2021, the total estimated budget for compliance with Phase II Permit requirements in
Mecklenburg County is $1,858,330.82. A total of $1,206,821.38 or 64% of the total budget is
associated with plan reviews, permitting and inspections for compliance with erosion control and
post-construction ordinance requirements, which includes components 4 and 5 from Table 10 for
both Mecklenburg County and the Town of Huntersville. Funding for these services is provided
through land development fees. A total of $651,509.44 is associated with work performed by
CMSWS for compliance with the other components of the SWMP, including 1, 2, 3, 6, and 7 in
Table 10. Funding for these services is shared among all co-permittees as indicated in Table 14
based on methodology described in the Mecklenburg County Water Quality Program Funding
Strategy, which is available from the Environmental Manager upon request. Funding from the
Towns and County for these services is provided by stormwater fees, which represents
approximately 33% of the total Phase II budget for FY2021. For CMS and CPCC, funding is
provided through their general budgets since they do not receive revenue from storm water fees,
which represents approximately 3% of the total Phase II budget.
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
31
Table 14: Estimated Cost Breakdown by Jurisdiction/Entity for FY2020
Jurisdiction/Entity FY20 Budget
CMS $49,484.56
CPCC $13,999.77
Town of Cornelius $61,793.96
Town of Davidson $26,738.33
Town of Huntersville $161,052.87
Town of Matthews $74,093.07
Mecklenburg County $156,216.72
Town of Mint Hill $73,535.50
Town of Pineville $34,594.66
TOTAL $651,509.44
4.8 Co-Permittees
There are other a total of nine (9) jurisdictions/entities covered as co-permittees under the
NPDES MS4 Permit number NCS000395 for Mecklenburg County. Section 4.9 describes the
responsibilities for Permit compliance that are shared by all co-permittees. Table 15 summarizes
contact information for each co-permittee. Interlocal agreements have been entered into between
CMSWS and the co-permittees, which are available from the Environmental Manager upon
request..
Table 15: Co-Permittee Contact Information
Co-
Permittee Name/Title Phone Mailing Address Email
Cornelius Andrew Grant,
Town Manager
704-892-6031 Cornelius Town Hall, PO
Box 399, Cornelius, NC
28031
agrant@cornelius.org
Cornelius Tyler Beardsley,
Asst. Town
Manager/Public
Works Director
704-892-6031
Cornelius Town Hall, PO
Box 399, Cornelius, NC
28031
tbeardsley@cornelius.org
Cornelius Wayne Herron,
Deputy Town
Manager
704-892-6031
Cornelius Town Hall, PO
Box 399, Cornelius, NC
28031
wherron@cornelius.org
Cornelius Ricky Overcash,
Public Works
Supervisor
704-895-5212 Cornelius Town Hall, PO
Box 399, Cornelius, NC
28031
rovercash@cornelius.org
Davidson Jamie Justice,
Town Manager
704-940-9618 Davidson Town Hall, PO
Box 579, Davidson, NC
28036
jjustice@townofdavidson.org
Davidson Doug Wright,
Public Works
Director
704-892-7591 Davidson Town Hall, PO
Box 579, Davidson, NC
28036
dwright@townofdavidson.org
Huntersville Anthony Roberts,
Town Manager
704-875-6541 Huntersville Town Hall, PO
Box 664 Huntersville, NC
28270
aroberts@huntersville.org
Huntersville Kevin Fox, Public
Works Director
704-766-2220 Huntersville Town Hall, PO
Box 664 Huntersville, NC
kfox@huntersville.org
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
32
Co-
Permittee Name/Title Phone Mailing Address Email
28270
Matthews Hazen Blodgett,
Town Ma nager
704-708-1230 Matthews Town Hall, 232
Matthews Station Street,
Matthews, NC 28105-6713
hblodgett@matthewsnc.com
Matthews C.J. O’Neill,
Public Works
Director
704-708-1242 1600 Tank Town Rd.,
Matthews, NC 28105
cjoneill@matthewsnc.gov
Meck. Co. W. Dave Canaan,
Director of
Stormwater
Services
980-314-3209 2145 Suttle Avenue,
Charlotte, NC 28208-5237
dave.canaan@mecklenburg
countync.gov
Meck. Co. Rusty Rozzelle,
W.Q. Program
Manager
980-314-3217 2145 Suttle Avenue,
Charlotte, NC 28208-5237
rusty.rozzelle@mecklenburg
countync.gov
Mint Hill Brian L. Welch,
Town Ma nager
704-545-9726 Mint Hill Town Hall, 4430
Mint Hill Vi llage Ln., Mint
Hill, NC 28227
bwelch@admin.minthill.com
Mint Hill Steve Frey, Town
Engineer & Public
Works Director
704-545-9726 Mint Hill Town Hall, 4430
Mint Hill Village Ln., Mint
Hill, NC 28227
sfrey@admin.minthill.com
Pineville Ryan Spitzer
Town Manager
704-889-2291 Pineville Town Hall, PO Box
249, Pineville, NC 28134
rspitzer@pinevillenc.gov
Pineville Chip Hill, Public
Works Director
704-889-7467 Pineville Town Hall, PO Box
249, Pineville, NC 28134
chill@pinevillenc.gov
CMS Jeff Mi tchell,
Manager Env.
Services &
Stewardship
980-343-8632
(O); 980-215-
3291 (M)
3301 Stafford Drive,
Charlotte, NC 28208
jefferyg.mitchell@cms.k12.nc.
us
CMS Isiah Glover, EHS
Specialist
(980) 301-
3012 (M)
3301 Stafford Drive,
Charlotte, NC 28208
isiah1.glover@cms.k12.nc.us
CPCC Vicki Saville,
Assoc. V.P.
Facilities
704-330-6316
704-330-6166
CPCC-Central Campus, PO
Box 35009 Charlotte, NC
28235-5009
vicki.Saville@cpcc.edu
4.9 Shared Responsibilities
As specified in the Phase II Permit, each co-permittee is responsible for compliance with the
terms and conditions of the Permit for stormwater activities and Permit requirements applicable
to their jurisdictional area. The Permit further specifies that the State can administer and enforce
the Permit requirements with respect to individual co-permittees found in non-compliance with
the Permit. The Stormwater Management Program Interlocal Agreements entered into between
Mecklenburg County and all the co-permittees provides further clarification by stating that each
co-permittee is responsible for taking the actions necessary within their respective jurisdictions/
entities as described by CMSWS staff to ensure compliance with Permit requirements. For
example, CMSWS staff is responsible for inspecting municipal facilities under the Pollution
Prevention and Good Housekeeping Program and providing written notification to the
responsible jurisdiction/entity regarding inspection results, including all deficiencies. The
jurisdiction/entity and not CMSWS is responsible for implementing the actions necessary to
correct all deficiencies. Each co-permittee is responsible for performing all activities related to
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
33
the maintenance and repair of their property and infrastructure for compliance with Permit
requirements, including facility maintenance as well as inlet, pipe, parking lot, and street
cleaning. A list of co-permittee responsibilities for Phase II Permit compliance is provided in
Appendix F. A description of co-permittee responsibilities for each Permit requirement is also
provided in Appendix A
4.10 Coordination Between Co-Permittees
Proper coordination between all co-permittees is essential for ensuring success at fulfilling
Permit requirements. CMSWS undertakes specific actions for proper coordination as described
below.
1. By March 31st of every year, a Funding Strategy is developed by CMSWS and shared
with all co-permittees describing the methodology to be used during the following fiscal
year to equitably share costs associated with compliance with Phase II Permit
requirements.
2. By April 30th of every year, CMSWS prepares a draft Work Plan and submits to all co-
permittees for review and comment. This Work Plan describes what activities CMSWS
will perform during the next fiscal year to comply with Permit requirements and includes
a list of co-permittee responsibilities as described in Appendix F. The Work Plan also
includes a budget for each co-permittee based on the Funding Strategy developed in #1
above. Comments are received and addressed, and a final, approved Work Plan is
completed and distributed to all co-permittees by June 30 of every year.
3. Quarterly reports are submitted to all co-permittees listing the activities performed, time
involved and associated costs.
4. At a minimal of bi-annually, meetings are held with co-permittees, which are oftentimes
virtual, to provide updates regarding Work Plan implementation and Permit compliance
as well as to give co-permittees an opportunity to ask questions.
5. Inspections are conducted annually at the public works facilities owned and operated by
the co-permittees to ensure compliance with Permit requirements. As part of these
inspections, information is obtained from the co-permittees regarding the activities being
performed for MS4 operation and maintenance as well as street and parking lot cleaning.
Annual inspections are also performed by CMSWS of SCMs owned and/or operated by
co-permittees for compliance with post-construction ordinance requirements. The co-
permittee is also made of their responsibilities for Phase II Permit compliance, and a copy
of Appendix F is provided.
6. By October 30th of every year, a detailed annual report is provided to all co-permittees
describing the specific Permit compliance activities completed and a status of the
measures of success.
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
34
SECTION 5: PUBLIC EDUCATION AND OUTREACH PROGRAM
A Public Education and Outreach Program has been developed and is currently being
implemented for Mecklenburg County’s Phase II jurisdictions/entities to inform the community
of the physical attributes of stormwater runoff, including the pollutants typically contained in
runoff and their likely sources, as well as the impacts of these pollutants on surface water quality.
The Program also describes the steps that the public can take to reduce pollutants in stormwater
runoff and protect water quality. The program is administered by CMSWS’s Water Quality
Program as described in the following Sections.
5.1 Program Goals and Objectives
CMSWS’s establishes its goals and objectives for its Public Education and Outreach Program,
which are evaluated and updated annually as necessary, based on the actions necessary to
effectively address the targeted pollutants and pollutant sources identified in Table 8. The
current goals of the Public Education and Outreach Program are as follows:
1. Change public behaviors to reduce sources of water pollution and improve water quality.
2. Promote participation in activities aimed at restoring water quality conditions.
The current objectives of the Public Education and Outreach Program are as follows:
a. Develop, distribute and advertise public educational and outreach messages to the
community and conduct outreach activities to inform the public of the negative impacts
that stormwater discharges have on water quality by promoting the following concepts:
• All storm drains flow directly to creeks and lakes without treatment.
• Storm drains are only for rain.
• Anything other than rain that enters a storm drain becomes stormwater pollution.
• Buffers around lakes and streams act to filter pollutants and are important for
protecting water quality.
b. Develop, distribute and advertise public educational and outreach messages to inform the
public of the steps they can take to reduce the negative impacts from stormwater
discharges and restore water quality conditions by promoting the following concepts:
• Do not pour anything down a storm drain or in a creek or lake.
• Volunteer to mark storm drains, adopt streams and participate in the annual Big
Spring Clean event (formerly Big Sweep).
• Become a “Water Watcher” and report pollution to 311.
• Maintain a vegetated buffer around lakes and streams.
5.2 BMP Summary Table
Table 16 describes the BMPs implemented as part of the Public Education and Outreach
Program.
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
35
Table 16: BMP Summary Table for the Public Education and Outreach Program
Permit
Ref.
Public Education and Outreach (Part II Section A.4, 5 and 7; Part II Section B.; Part II Section C.2.c; Part II Section D.2.i;
Part II Section E.3): Distributing educational materials to the community or conducting equivalent outreach activitie s about the
impacts of storm water discharges on water bodies and the steps that the public can take to reduce pollutants in storm water
runoff. (Note: SOPs are the same for Phases I and II. Documentation for revising these SOPs and performing training is
contained under the Phase I program element.).
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
#3
PE-10(a)
(Education
and
Outreach)
Planning and Coordination
Coordinate with
Charlotte Storm
Water Services and
the co-permittees to
review work plan
element scope,
direction,
procedures, and
necessary steps to
coordinate efforts.
a. Coordinate with Charlotte
Storm Water and the co-
permittees.
a. Annually
beginning July
1
a. Completion
status
Work with
CMSWS to
ensure an
effective
outreach.
b. Identify and implement
ongoing coordination
measures between Charlotte
Storm Water and the co-
permittees.
b. Annually
beginning July 1
b. Completion
status
c. Review SOPs annually and
revise as necessary.
c. Annually
beginning July 1
c. Completion
status
d. Review target pollutants and
audiences and revise as
necessary.
d. Annually
beginning July 1
d. Completion
status
e. Review residential/
commercial issues and revise
as necessary.
e. Annually
beginning July 1
e. Completion
status
#4
PE-10(b)
(Education
and
Outreach)
Educational Materials
Develop and
distribute
educational
materials to target
audiences.
a. Evaluate available brochures
and update or develop new
ones as necessary.
a. Annually
beginning July
1
a. Completion
status
Inform CMSWS
if new brochures
are needed to
meet a special
need. Ensure
brochures are
maintained in a
location
available to the
public.
b. Make brochures available to
staff for distribution.
b. Annually
beginning July
1
b. Completion
status
c. Provide brochures to Town
Halls and other locations
within the Towns as necessary
for distribution.
c. Annually
beginning July
1
c. Completion
status
d. Maintain a record of the
extent of exposure.
d. Annually
beginning July
1
d. Completion
status;
extent of
exposure
#5
PE-10(c)
(Education
and
Outreach)
Newsletters
Develop and send
newsletter articles to
Pineville for
distribution at a
minimum of
quarterly.
a. Develop newsletter articles
and make available to Town
for distribution.
a. Annually
beginning July
1
a. Completion
status
Ensure
educational
materials are
included in
newsletters
and/or other
regular
communications.
b. Maintain record of extent of
exposure.
b. Annually
beginning July
1
b. Completion
status;
extent of
exposure
#6
PE-10(d)
(Education
Public Education Media Campaign
Develop and a. Develop and implement a a. Annually a. Completion Ensure
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
36
Permit
Ref.
Public Education and Outreach (Part II Section A.4, 5 and 7; Part II Section B.; Part II Section C.2.c; Part II Section D.2.i;
Part II Section E.3): Distributing educational materials to the community or conducting equivalent outreach activitie s about the
impacts of storm water discharges on water bodies and the steps that the public can take to reduce pollutants in storm water
runoff. (Note: SOPs are the same for Phases I and II. Documentation for revising these SOPs and performing training is
contained under the Phase I program element.).
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
and
Outreach)
implement public
education media
campaign.
media campaign, including
television, radio, print ads,
utility bill inserts, etc.
beginning July
1
status availability of
information to
public as
requested by
CMSWS.
Maintain link to
CMSWS
website.
b. Develop and implement
social media posts.
b. Annually
beginning July 1
b. Completion
status
c. Maintain website, including
information regarding
current water quality
conditions, stormwater
pollutants and how to
minimize them, municipal
stormwater projects,
volunteer opportunities, etc.
Ensure co-permittee links to
website are maintained.
c. Annually
beginning July
1
c. Completion
status
d. Maintain record of extent of
exposure.
d. Annually
beginning July
1
d. Completion
status;
extent of
exposure
#7
PE-10(e)
(Education
and
Outreach)
Schools
Conduct
presentations for
students/teachers.
a. Develop age-specific
educational information for
use in schools and for
presentations to school age
children.
a. Annually
beginning July
1
a. Completion
status
None.
b. Present information in
appropriate format.
b. Annually
beginning July
1
b. Completion
status
c. Maintain record of extent of
exposure.
c. Annually
beginning July
1
c. Completion
status;
extent of
exposure
#8
PE-10(f)
(Education
and
Outreach)
Commercial Outreach
Conduct outreach
program for
commercial
facilities.
a. Develop and implement
outreach program.
a. Annually
beginning July
1
a. Completion
status
None.
b. Update commercial sector
BMP flyers as necessary.
b. Annually
beginning July
1
b. Completion
status
c. Maintain record of extent of
exposure.
c. Annually
beginning July
1
c. Completion
status;
extent of
exposure
#9
PE-9
(Evaluate
Evaluate Effectiveness of the Public Education and Outreach Program
Evaluate a. Evaluate program a. Annually a. Completion Notify CMSWS
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
37
Permit
Ref.
Public Education and Outreach (Part II Section A.4, 5 and 7; Part II Section B.; Part II Section C.2.c; Part II Section D.2.i;
Part II Section E.3): Distributing educational materials to the community or conducting equivalent outreach activitie s about the
impacts of storm water discharges on water bodies and the steps that the public can take to reduce pollutants in storm water
runoff. (Note: SOPs are the same for Phases I and II. Documentation for revising these SOPs and performing training is
contained under the Phase I program element.).
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
Education) effectiveness of the
Public Education
and Outreach
Program.
effectiveness at meeting
established goals and
objectives.
beginning July
1
status of actions
necessary to
improve the
effectiveness of
the program.
b. Measure program success
using established criteria.
b. Annually
beginning July
1
b. Completion
status;
criteria
measure
c. Recommend improvements
as necessary. Include the
recommendations in the
report for PD-1.
c. Annually
beginning July
1
c. Completion
status
d. Implement improvements in
the next fiscal year.
d. Annually
beginning July
1
d. Completion
status
#10
PE-10(h)
(Education
and
Outreach)
Annual Report
Complete annual
reports.
a. Complete annual report
detailing activities
completed and summarizing
findings.
a. Annually
beginning July
1
a. Completion
status
None.
b. Include the annual report in
PD-1.
b. Annually
beginning July
1
b. Completion
status;
extent of
exposure;
criteria
measure
5.3 Stormwater Helpline
Charlotte-Mecklenburg maintains a phone helpline at 311 from 7 a.m. to 7 p.m. Monday through
Friday except recognized holidays. This stormwater helpline receives citizen requests for service
that are forwarded to CMSWS for response, provides general water quality information, and
promotes public involvement and participation through established volunteer programs. To
ensure effectiveness, CMSWS has provided the staff at 311 with a “key word” index that is used
to trigger select responses to water quality related questions and requests. These key words are
reviewed and updated annually as necessary and provided to 311 for implementation. For
example, if a caller uses the key word “Stream Cleanup” 311 staff has been provided with a
select response that refers the caller to the appropriate staff contact at CMSWS for more
information. Var ious media, including television, radio, print ads, brochures, social media, etc.,
are used to promote 311 as the number to contact to report suspected pollution problems and
sign-up for volunteer programs. 311 has been in use since September 8, 2008 and has proven to
be an effective helpline service, resulting in CMSWS receiving an average of over 100 reports of
potential water quality problems annually in the Phase II jurisdictions and an additional 600
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
38
reports in Charlotte’s Phase I jurisdiction as well as numerous requests to participate in volunteer
programs. CMSWS maintains a 24-hour a day, 7 days a week response status for all water
quality problems, spills, emergencies, etc. by working in close cooperation with 311 as well as
the Charlotte-Mecklenburg Fire and Police Departments, including all the Towns. Emergency
spill response services are available through 911. Residents can also request services through the
Stormwater Services webpage online and through the use of the mobile CLT Plus app at the
following link: https://charlottenc.gov/Pages/CLTplus.aspx.
5.4 Outreach Program
The outreach strategy for the Mecklenburg County Phase II jurisdictions/entities includes the
mechanisms described in this Section, which are estimated to result in over 6,600,000 contacts
for the protection and restoration of water quality conditions in the Charlotte-Mecklenburg area
during the five (5) year Permit term. Contacts outside the Phase II jurisdictions are included in
this calculation, which is unavoidable due to the fact that the program is administered
countywide. For each media, event or activity included in the outreach program, the extent of
exposure is estimated and recorded.
5.4.1 Utility Bill Inserts
Utility Bill Inserts (UBIs) with educational stormwater topics are placed inside utility bills
(water, sewer, and stormwater) seven (7) times per year and issued to 255,000 customers
throughout Mecklenburg County. This outreach mechanism involves the development and
placement of an insert into this utility bill that results in the stormwater/water quality message
being delivered to over 2,200,000 customers in Charlotte-Mecklenburg during the five (5) year
Permit term. These inserts reach the entire target audience described in Section 3.10 with
general water quality messages such as how to report suspected pollution problems and measures
for reducing stormwater pollution, as well as messages associated with targeted pollutant sources
and volunteer opportunities. Figure 4 is the utility bill insert distributed in June 2020.
Figure 4: Utility Bill Insert
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
39
5.4.2 Brochures, Environmental Notices and Newsletters
This outreach mechanism involves the development and distribution of printed brochures,
Environmental Notices, and Newsletters to select members of the targeted audience described in
Section 3.10, including but not limited to adults, homeowners, pet owners, non-English speaking
residents, businesses, and industries. This outreach includes general water quality messages
regarding pollution prevention, reporting and regulatory compliance as well as messages
associated with specific pollution sources from Table 8 and information regarding water quality
volunteer opportunities. Printed brochures are distributed during responses to citizen requests
for service, inspections and at event displays. Environmental Notices containing specific
information for protection of water quality and compliance with water quality regulations are
typically distributed during responses to citizen requests for service and inspections for
identifying and eliminating pollution sources. For those jurisdictions that do not utilize social
media as described in Section 5.4.5, newsletter articles are sent to residents to inform them of the
measures they should take to eliminate pollution sources. The printed brochures, Environmental
Notices and Newsletters are anticipated to reach a minimum of 100,000 residents in Charlotte-
Mecklenburg during the five (5) year Permit term.
5.4.3 Print Ads
This outreach mechanism involves the development and publication of printed ads in local
newspapers, newsletters, or magazines distributed in the Phase II jurisdiction, including but not
limited to the Charlotte Observer, The Recycler, and Hola magazine. These ads will reach the
targeted audience described in Section 3.10 regarding the impacts of stormwater discharges on
water bodies and the steps they can take to reduce pollution, including participating in volunteer
programs and special events as well as reporting suspected pollution problems. The ads are
anticipated to reach a minimum of 100,000 residents in Charlotte-Mecklenburg during the five
(5) year Permit term.
5.4.4 Media Campaign
This outreach mechanism involves the use of radio and television ads to reach the entire targeted
audience described in Section 3.10 with messages regarding the measures that can be taken to
reduce stormwater pollution as well as messages associated with specific pollutant sources. This
outreach mechanism is also used to promote participation in water quality volunteer activities.
TV and radio ads run throughout the fiscal year with a very wide circulation. Based on
distribution estimates from FY2020, the estimated extent of exposure (also referred to as
impressions) from these ads totaled 6,828,720, which represents an 11% increase from FY2019
at 6,063,651.
5.4.5 Social Media
This outreach method includes, but is not limited to, Facebook, Twitter, Instagram, and Web
Banners to engage citizens in activities for protecting and restoring water quality conditions in
Mecklenburg County. Posts include a variety of stormwater-related topics. Figure 5 is a Web
Banner that was posted on numerous high-profile websites in FY2020 to advertise for the
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40
upcoming Big Spring Clean event. By the conclusion of FY2020, the estimated extent of
exposure from social media totaled 4,242,396. Social media outreach methods increase in
popularity with continued use.
Figure 5: Web Banner
5.4.6 Targeted Outreach
Targeted educational outreach efforts are initiated when responses to service requests,
monitoring results or other program activities reveal pollution sources isolated to specific target
areas. Educational brochures and/or door hangers are the outreach mechanisms of choice in such
situations; however, a very targeted social media campaign could also be conducted. For
example, if elevated fecal coliform levels were detected as a result of water quality monitoring
activities and field investigations revealed a large concentration of dog lots upstream, then a
door-to-door educational campaign would be conducted in the area to promote the proper
disposal of dog waste, including the distribution of various educational materials. Targeted
outreach is also performed on a watershed level based on specific issues such as TMDLs or a
specific pollutant of concern. Figure 6 is an example of a targeted education mailer used in the
Reedy Creek Watershed.
Figure 6: Targeted Education Mailer
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5.4.7 Workshops and Video Taped Messages
This outreach mechanism involves the use of workshops and/or video taped messages to reach a
wide segment of the targeted audience described in Section 3.10. At least two (2) workshops
and/or video taped messages will be provided during the five (5) year Permit term reaching an
estimated 1,500 persons. To date, several video taped messages have been developed and are
available on the website at http://stormwater.charmeck.org (select “Surface Water Quality,”
select “Pollution Prevention”, Select “Pollution Prevention Videos”), including a Pollution
Prevention Video, Pollution Prevention Around the Home, and Keep Yard Waste out of the
Storm Drains and Creeks. In 2015, CMSWS developed a video entitled “Water Pollution: What
to Do?” that describes sources of water pollution, the importance of clean water to the
community and the impacts of water pollution as well as how to detect and report illicit
discharges. Each of the Phase II jurisdictions/entities is responsible for ensuring that its staff
watches this video if as part of their normal job responsibilities they may come into contact with
or otherwise observe an illicit discharge or illicit connection to the storm sewer. This video is
available on the County’s “Meck Edu” website. During the five (5) year Permit term, over 1,000
media contacts are anticipated through the use of videos.
5.4.8 Web Pages
This outreach mechanism involves the use of web pages focused on specific water quality topics
maintained on the CMSWS website located at http://stormwater.charmeck.org. Web pages
describe the specific actions necessary to prevent water pollution and instructions for reporting
suspected pollution sources. The web pages also target specific business sectors with best
management practices relating to pollution prevention. In addition, the web pages include a
description of all the volunteer programs with instructions on how to register for participation.
Web pages are also available that describe water quality monitoring activities in Mecklenburg
County and general water quality conditions. This website is promoted through utility bill
inserts, print ads, brochures, Environmental Notices, Newsletters, media campaign, social media,
and workshops. The website also appears on all emails generated by staff with CMSWS as well
as appears on their business cards. The stormwater website is also available through a link on
the websites maintained by Mecklenburg County and the other co-permittees. During FY2020,
Google Analytics showed CMSWS’s web pages had 350,886 pageviews, which is a decrease
from the 376,617 pageviews in FY2019. The cancellation of many events like The Big Spring
Clean, Creek Week, and Earth Day as a result of COVID could be the cause of this decrease.
5.4.9 Educational Presentations and Public Events
This outreach mechanism involves the combination of educational presentations, displays,
educational materials, handouts, and/or promotional items to reach a very select segment of the
targeted audience described in Section 3.10, including adults, dog owners, civic groups, students,
landscapers, realtors, and land developers. The messages focus on controlling one or more of the
pollutant sources in Table 8 as well as promoting volunteerism. These activities occur
throughout the year. During FY2020, CMSWS conducted 36 educational presentations with
2,908 attendees covering stormwater pollution prevention and reporting, permitting and
compliance, buffers/vegetation, monitoring, structural BMP maintenance, volunteering, etc.
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CMSWS staff also attended 10 events during FY2020 involving 1,806 participants. In addition,
CMSWS has develop age-specific educational information for use in schools and for
presentations to school age children. During FY2020, 11 school presentations were conducted
that were attended by 189 students. During the five (5) year Permit term, it is estimated that over
100 presentations and events will be conducted/attended by CMSWS reaching over 2,000
residents.
5.4.10 Regional Stormwater Partnership of the Carolinas
CMSWS is a member and active participate in the Regional Stormwater Partnership of the
Carolinas (RSPC). The RSPC is a non-profit organization whose mission is to work together to
educate and bring awareness of stormwater issues and their impact on water quality throughout
the Charlotte region. The partnership not only promotes a strong network of stormwater
professionals, but it allows multiple municipalities to share various resources, especially in the
area of public education and outreach.
5.5 Reaching Mecklenburg County’s Diverse Population
Mecklenburg County is recognized as having one of the most diverse populations in the State.
This diversity is taken into careful consideration when developing and implementing all
activities involved in the Public Education/Outreach and Public Involvement Programs. For
example, CMSWS is careful to ensure that all media outlets and educational materials are
designed to reach a broad range of languages. In addition, CMSWS has partnered with the
Regional Stormwater Partnership of the Carolinas and Johnson C. Smith University on a WRRI
grant which involves improving public education/outreach and public involvement in three (3)
low income communities in west Charlotte. This is an area identified for needing additional
outreach and involvement. Dur ing FY2021, plans are underway to identify ways to engage the
citizens in these communities. Lessons learned will be applied countywide. Current diversity
data will be available through the 2020 Census. This data will be used by CMSWS to improve
efforts to target Mecklenburg County’s diverse population.
5.6 Communication Plan
Beginning in FY2021, a Communication Plan was developed and implemented in the Phase II
jurisdictions. The purpose of this Plan is to describe the methodology and tools that will be used
to promote public education and involvement as well as to communicate information regarding
spills and other incidents responded to by CMSWS such as fuel spills, sewage discharges, fish
kills and other impacts to surface waters. The Plan establishes four (4) tiers of communication,
including Tier I – Major Environmental Incident with Immediate Public Health Concern; Tier II
– Environmental Incident with Potential Public Health Concern; Tier III - Environmental
Incident with Little to No Public Health Concern; and Tier IV - Stormwater Public Education
and Public Involvement Message. The Plan describes each of these tiers and provides examples
of incidents/situations where the tier would apply. The Plan provides a description of the step-
by-step process to be followed to communicate the necessary information under each of the tiers.
The Plan also describes the guidelines and communication tools to be used with the public
(external) and with key staff (internal) to ensure clear, factual and transparent communication in
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all situations. The Plan is maintained in CMSWS’s shared folder as follows and is available
upon request to the Environmental Manager: G:\Water Quality\WQ_Xfer\WQ\Communication
Plan.
5.7 Decision Process
The targeted audience for the Public Education Program for the Mecklenburg County Phase II
jurisdictions/entities include a wide range of age, ethnic and economic groups. These groups
rely on varying mechanisms for receiving information; therefore, a multifaceted educational
program was designed to achieve effective communication. The individual BMPs identified in
Table 16 reflect this approach as do the measurable goals associated with each BMP. Emails,
utility bill inserts, Environmental Notices, brochures, Newsletters, and newspaper ads use the
printed word to disseminate information and focus on specific pollutants as well as general water
quality issues. This information can be distributed to a broad audience via mailings as well as
handed out to individuals when responding to citizen requests for service, conducting
inspections, or attending public events. Web pages provide a variety of specific information to a
broad audience including the general public, commercial and industrial facilities. Workshops
and presentations focus on a relatively small audience but are an effective tool for addressing
specific pollution sources and gaining volunteer participation. Television, radio, and social
media campaigns broaden the approach to a wide audience and typically convey a more general
pollution prevention message. The staff responsible for conducting this public education
program for the Mecklenburg County Phase II jurisdictions/entities as identified in Table 10
were selected for their expertise in the development and implementation of a multifaceted public
outreach campaign.
5.8 Program Evaluation
The measurable goals for each BMP are described in Table 8. The overall success of the Public
Education and Outreach Program is evaluated through the successful achievement of these
measurable goals as reported with each NPDES MS4 annual assessment report. At a minimum,
the following metrics are included in this annual report:
• Number of public events attended.
• Number of presentations conducted.
• Number and type of social media posts.
• Results from public opinion surveys.
• Results from using mass media channels of communication, including reach and
frequency.
Other measures of success for the
Public Education and Outreach Program are described below.
• Documentation of Stormwater Program Activities – As a baseline measure of success,
CMSWS staff will document the completion of Work Plan activities annually that
demonstrate achievement of each of the measurable goals for the BMPs associated with
this program. All activities will be documented within CMSWS’s Cityworks database.
• Increasing Awareness – Stormwater Public Opinion Surveys are conducted annually of
the general public to measure their awareness of water quality issues as well as their level
of concern/interest. The measure of success for the Public Education and Outreach
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Program is a minimum of 50% of survey respondents indicating they are aware that water
flowing into storm drains goes directly to creeks and lakes.
• Increasing Extent of Exposure – For each media event and activity employed in the
program, the extent of exposure is estimated in the SWMP and then recorded throughout
the year. In the annual evaluation, the extent of exposure is reported, which is compared
to previous years with the measure of success being to exceed the extent of exposure for
the previous fiscal year.
On an annual basis, CMSWS staff will evaluate the BMPs for this program and assess progress
toward achieving the measurable goals from Table 16 and the measures of success described
above. Recommendations for improvement will be made as necessary. During the following
fiscal year, program activities and BMPs will be modified as necessary based on the results of
this evaluation in order to ensure that the specific goals and objectives of the Public Education
and Outreach Progr am and SWMP are being effectively and efficiently fulfilled. Staff will also
evaluate the continued relevance of Table 8 and the effectiveness of the targeted audience.
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SECTION 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM
A Public Involvement and Participation Program has been developed and is currently being
implemented for Mecklenburg County’s Phase II jurisdictions/entities to comply with the State
and local public notice requirements and to engage the community in program development and
implementation. The program is administered by CMSWS’s Water Quality Program as
described in the following Sections.
6.1 Program Goals and Objectives
CMSWS’s establishes its goals and objectives for its Public Involvement and Participation
Program, which are evaluated and updated annually as necessary, based on the actions necessary
to effectively address the targeted pollutants and pollutant sources identified in Table 8. The
current goal of the Public Involvement and Participation Program is to create opportunities for
the public to participate in Phase II program development and implementation, as well as to get
involved in activities aimed at protecting and restoring water quality conditions. The current
objectives of the program are as follows:
1. Make a minimum of one (1) presentation annually to the Charlotte-Mecklenburg
Stormwater Advisory Committee (SWAC) to describe the activities performed to comply
with Phase II Permit requirements and receive feedback. All SWAC meetings are open
to the public. A minimum of one (1) of these presentations during the five (5) year
Permit term will be advertised for public comment.
2. Develop and implement volunteer programs to involve the public in activities aimed at
protecting and restoring water quality conditions.
6.2 BMP Summary Table
Table 17 describes the BMPs implemented as part of the Public Involvement and Participation
Program.
Table 17: BMP Summary Table for the Public Involvement and Participation Program
Permit
Ref.
Public Involvement & Participation (Part II Section C.2.a, b; Part II Section A.4, 5 and 7; Part II Section B.2.h): Developing
and implementing a program to provide opportunities for the public, including major economic and ethnic groups, to participate
in efforts to protect and restore surface water quality. (Note: SOPs are the same for Phases I and II. Documentation for revising
these SOPs and performing training is contained under the Phase I program element.)
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description
of BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
#11
PI-1
(Public
Meetings)
Phase II Public Meeting
Meet with the
Storm Water
Advisory
Committee
(SWAC) and
co-permittees
to provide
and promote
a mechanism
a. Conduct a minimum of one (1)
meeting annually before SWAC.
Provide information regarding
activities performed to comply
with Phase II requirements.
Promote opportunity to receive
public input during the meeting.
Receive input from the public
regarding storm water issues and
a. Annually
beginning July 1
a. Completion
status
None
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Permit
Ref.
Public Involvement & Participation (Part II Section C.2.a, b; Part II Section A.4, 5 and 7; Part II Section B.2.h): Developing
and implementing a program to provide opportunities for the public, including major economic and ethnic groups, to participate
in efforts to protect and restore surface water quality. (Note: SOPs are the same for Phases I and II. Documentation for revising
these SOPs and performing training is contained under the Phase I program element.)
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description
of BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
for public
involvement
that allows
for input on
stormwater
issues and the
stormwater
program.
the program.
b. Address input as necessary. b. Annually
beginning July 1
b. Completion
status
c. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
c. Annually
beginning July 1
c. Completion
status; #
attending
meeting
#12
PI-2
(Volunteer
AAS)
Adopt-A-Stream
Implementing
an Adopt-A-
Stream
Program that
involves the
adoption of
stream
sections by
the general
public,
businesses
and
institutions.
a. Review SOPs annually and revise
as necessary.
a. Annually
beginning July 1
a. Completion
status
Work with
CMSWS to
maximize
volunteer
participation.
Assist with trash
removal as
requested.
b. Implement program activities
coordinating closely with
volunteers.
b. Annually
beginning July 1
b. Completion
status
c. Maintain data regarding program
activities.
c. Annually
beginning July 1
c. Completion
status; #
volunteers
d. Follow up on reported pollution
problems to ensure compliance.
d. Annually
beginning July 1
d. Completion
status; #
problems
resolved
e. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
e. Annually
beginning July 1
e. Completion
status
#13
PI-3
(Volunteer
SDM)
Storm Drain Marker
Implementing
a Storm
Drain Marker
Program that
involves the
placement by
volunteers of
markers on
storm drain
inlets with
the message
“Do Not
Dump –
Drains To
Creek.”
a. Review SOPs annually and revise
as necessary.
a. Annually
beginning July 1
a. Completion
status
Work with
CMSWS to
maximize
volunteer
participation.
Receive and
respond as
necessary to
reported
problems with
the storm sewer
system.
b. Implement program activities
coordinating closely with
volunteers.
b. Annually
beginning July 1
b. Completion
status
c. Maintain data regarding program
activities.
c. Annually
beginning July 1
c. Completion
status; #
volunteers
d. Follow up on reported pollution
problems to ensure compliance.
d. Annually
beginning July 1
d. Completion
status; #
problems
resolved
e. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
e. Annually
beginning July 1
e. Completion
status
#14
PE-I(4)
(Volunteer
Big Spring
Clean)
Annual Spring Cleanup
Conduct
annual
cleanup event
a. Review SOPs annually and revise
as necessary.
a. Annually
beginning July 1
a. Completion
status
Work with
CMSWS to
maximize b. Implement program activities b. Annually b. Completion
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Permit
Ref.
Public Involvement & Participation (Part II Section C.2.a, b; Part II Section A.4, 5 and 7; Part II Section B.2.h): Developing
and implementing a program to provide opportunities for the public, including major economic and ethnic groups, to participate
in efforts to protect and restore surface water quality. (Note: SOPs are the same for Phases I and II. Documentation for revising
these SOPs and performing training is contained under the Phase I program element.)
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description
of BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
that involves
removing
trash and
debris from
surface
waters and
identifying
pollution
sources.
coordinating closely with
volunteers.
beginning July 1 status volunteer
participation.
Assist with trash
removal as
requested.
c. Maintain data regarding program
activities.
c. Annually
beginning July 1
c. Completion
status; #
volunteers
d. Follow up on reported pollution
problems to ensure compliance.
d. Annually
beginning July 1
d. Completion
status; #
problems
resolved
e. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
e. Annually
beginning July 1
e. Completion
status
#15
VM
(Volunteer
Monit)
Volunteer Monitoring
Implement
volunteer
monitoring
program that
involves the
monitoring of
stream
conditions by
volunteers.
a. Review SOPs annually and revise
as necessary.
a. Annually
beginning July 1
a. Completion
status
Work with
CMSWS to
maximize
volunteer
participation.
b. Implement program activities
coordinating closely with
volunteers.
b. Annually
beginning July 1
b. Completion
status
c. Maintain data regarding program
activities.
c. Annually
beginning July 1
c. Completion
status; #
volunteers
d. Follow up on reported pollution
problems to ensure compliance.
d. Annually
beginning July 1
d. Completion
status; #
problems
resolved
e. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
e. Annually
beginning July 1
e. Completion
status
#16 PE-I(13)
(Educate
Media
Campaign)
Public Involvement Media Campaign
Develop and
implement a
public
involvement
media
campaign to
educate and
solicit
volunteers for
public
involvement
programs.
a. Coordinate with Charlotte Storm
Water Services and co-permittees
to develop and implement an
effective strategy to promote and
increase volunteerism.
a. Annually
beginning July 1
a. Completion
status
Work with
CMSWS to
maximize
volunteer
participation
through media
campaign.
b. Work with the Media Buy vendor
and Creative Services vendor to
develop and implement a media
campaign per the strategy in “a”
including television, radio and
other media outlets.
b. Annually
beginning July 1
b. Completion
status
c. Implement the social media
strategy created in “b” above by
reviewing topics, content and
social posts created by vendor.
c. Annually
beginning July 1
c. Completion
status; extent
of exposure
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48
Permit
Ref.
Public Involvement & Participation (Part II Section C.2.a, b; Part II Section A.4, 5 and 7; Part II Section B.2.h): Developing
and implementing a program to provide opportunities for the public, including major economic and ethnic groups, to participate
in efforts to protect and restore surface water quality. (Note: SOPs are the same for Phases I and II. Documentation for revising
these SOPs and performing training is contained under the Phase I program element.)
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description
of BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
Schedule and post to Facebook,
Twitter and Instagram. Monitor
social media traffic and respond
as necessary.
d. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
d. Annually
beginning July 1
d. Completion
status
#17
PE-I(14)
(Volunteer
Recognition)
Volunteer Appreciation
Conduct
annual
volunteer
appreciation
campaign to
recognize
volunteer
efforts for
protecting
water quality.
a. Update SOPs as necessary. a. Annually
beginning July 1
a. Completion
status
None.
b. Implement program activities. b. Annually
beginning July 1
b. Completion
status; #
volunteers
recognized
c. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
c. Annually
beginning July 1
c. Completion
status
#18
PI-6
(Evaluate
Involvement)
Evaluate Effectiveness of the Public Involvement and Pa rticipation Program
Evaluate
effectiveness
of Public
Involvement
and
Participation
Program.
a. Evaluate program effectiveness at
meeting established goals and
objectives.
a. Annually
beginning July 1
a. Completion
status
None.
b. Measure program success using
established criteria.
b. Annually
beginning July 1
b. Completion
status;
criteria
measure
c. Recommend improvements as
necessary. Include the
recommendations in the report for
PD-1.
c. Annually
beginning July 1
c. Completion
status
d. Implement improvements in the
next fiscal year.
d. Annually
beginning July 1
d. Completion
status
6.3 Targeted Audience
The targeted audience for the Public Involvement and Participation Program includes all age,
ethnic and economic groups in Mecklenburg County as described in Section 3.10. Participation
in the Program will be pr omoted through the Public Education and Outreach Program described
in Section 5. Volunteer opportunities will be made available to all stakeholder groups, including
commercial and industrial facilities, environmental groups, homeowners’ associations, civic
groups, educational organizations, and interested citizens.
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6.4 Mechanisms for Public Involvement and Participation
The Mecklenburg County Phase II jurisdictions/entities utilize the Charlotte Mecklenburg
Stormwater Advisory Committee (SWAC) to provide and promote a mechanism for public
involvement, including receiving input on stormwater issues and the development and
implementation of the SWMP. The public is also actively involved in ongoing efforts to restore
water quality conditions through volunteer participation in a variety of events, including Adopt-
A-Stream, Storm Drain Marking, Volunteer Monitoring, and The Big Spring Clean. The
following Sections provide additional information concerning these mechanisms for public
involvement and participation.
6.4.1 Charlotte Mecklenburg Stormwater Advisory Committee (SWAC)
The City of Charlotte, Mecklenburg County and the six (6) Towns established SWAC as its local
stormwater management panel in 1994 with the development of their stormwater utility
(Charlotte-Mecklenburg Stormwater Services). SWAC reviews stormwater management
policies and long-range plans and budgets to make recommendations or offer comments to
elected officials. The advisory committee also hears appeals and decides on water quality
penalties, service charges, credits, and adjustments. SWAC members are appointed by the
Mecklenburg Board of County Commissioners, Charlotte City Council, Charlotte Mayor and
Town Boards. SWAC includes representation from all the Phase II jurisdictions in Mecklenburg
County. All SWAC meetings are open to the public. Effective January 1, 2003, SWAC began
serving as the mechanism for obtaining public involvement in development and implementation
of the Phase II Permit in Mecklenburg County. In addition, meetings are held with co-permittees
at a minimum of twice a year (oftentimes these meetings are virtual) to provide updates
regarding Work Plan implementation and Permit compliance as well as to give co-permittees an
opportunity to ask questions.
4.4.2 Public Meetings
Public meetings are the mechanism used to comply with the State and local public notice
requirements and to engage the community in program development and implementation. Public
meetings are held before SWAC each year in the spring to obtain support for the upcoming
budget submittal. The meetings include a presentation of the activities performed to fulfill
Permit requirements and a request for comments. An advertised public meeting is held before
SWAC prior to the submittal of the Permit renewal application every five (5) years. The purpose
of this meeting is to provide the public with an opportunity to review and provide comments
regarding the Permit application and SWMP. On March 17, 2016, a public meeting was held
prior to the submittal of the application for the Permit term ending February 16, 2022. This
public meeting was advertised in the Charlotte Observer on February 26, 2016. During the
meeting, a presentation was given by CMSWS staff describing the measures implemented to
control stormwater pollutant sources in the Phase II jurisdictions/entities and the various
activities performed to fulfill Phase II Permit requirements as described in the SWMP. Staff
informed SWAC that no substantial changes were planned for the new Permit or SWMP. The
Permit application and SWMP received SWAC support via unanimous vote. No member of the
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
50
general public provided comments. In addition, a minimum of one unadvertised public meeting
is held before SWAC each year to discuss Water Quality Program activities.
6.4.3 Adopt-A-Stream Program
Mecklenburg County developed a countywide Adopt-A-Stream Program as part of the
Surface Water Improvement and Management (S.W.I.M.) initiative beginning in 1998. This
program was significantly expanded with the implementation of the Phase I and Phase II
Stormwater Programs by the City of Charlotte and Mecklenburg County, respectfully. The
Adopt-A-Stream Program engages volunteers in removing trash and locating pollutant sources in
Mecklenburg County streams. Adoption groups include Boy/Girl Scout troops, environmental
interest groups, homeowners’ associations, schools, families, garden clubs, businesses,
industries, etc. Training is offered to Adopt-A-Stream groups upon request. The purpose of this
training is to familiarize the volunteers with methods for detecting common water quality
problems, proper stream walk techniques, and important safety measures. Typically, volunteer
groups will adopt a one (1) mile long stream segment. Groups walk their assigned stream
segment at least twice a year. The groups are also encouraged to clean their stream segment
during The Big Spring Clean event. The groups keep records of their Adopt-A-Stream activities.
These records are submitted to CMSWS following the completion of stream cleanup activities.
All records are input by staff into the Volunteer Database, which is maintained as part of EDMS.
CMSWS follows up on identified pollution problems to ensure that they are eliminated, and
water quality is restored as well as coordinates the proper disposal of all trash and debris
removed from streams by adoption groups.
6.4.4 Storm Dr ain Marking Program
Mecklenburg County developed a countywide Storm Drain Marking Program as part of the
S.W.I.M. initiative beginning in 1998. This program was significantly expanded with the
implementation of the Phase I and Phase II Stormwater Programs by the City of Charlotte and
Mecklenburg County, respectfully. The Storm Drain Marking Program uses volunteers to place
decals on storm drains with the
message “Do Not Dump – Drains to
Creek” (see Figure 7). Volunteer
groups include Boy/Girl Scout
troops, environmental interest
groups, homeowners’ associations,
schools, garden clubs, families,
businesses, industries, etc.
Typically, volunteer groups will
select several streets within a
neighborhood for marking. CMSWS
provides the groups with decals,
adhesive, safety vests, gloves, and
information forms. Following the completion of storm drain marking activities, the groups
submit a completed information form to CMSWS that includes the street names and number of
drains that were marked as well as information concerning the condition of storm drains and
Figure 7: Storm Drain Marker
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
51
whether any pollutants were detected. All information is input by staff into the Volunteer
Database, which is maintained as part of EDMS. CMSWS follows up to ensure the elimination
of illegal dumping activities and maintains records of storm drains that have been marked.
6.4.5 Surface Water Clean Up
From 1993 through 2014, CMSWS held an annual surface water cleanup day working in
cooperation with N.C. Big Sweep. In March 2015, N. C. Big Sweep was dissolved as a non-
profit organization. CMSWS now sponsors an annual clean up event called The Big Spring
Clean. The purpose of the event is to use volunteers to remove trash and debris from streams
and lakes. During the event, Adopt-A-Stream groups are encouraged to clean up their assigned
stream segments and additional volunteers are used to expand the effort to include un-adopted
stream segments and the shoreline of lakes. The event is advertised, and volunteers are solicited
through the various media outlets previously listed. Records are kept concerning the number of
volunteers and tons of trash and recycling removed. The event is coordinated county-wide by
CMSWS.
6.4.6 Volunteer Monitoring
CMSWS maintains a volunteer monitoring program to assess general water quality conditions in
streams located in the Phase II jurisdictions. There are two types of volunteer monitoring
programs available. The traditional program includes the use of chemical test kits which can be
checked out and used to collect data on stream quality that is submitted to CMSWS for review
and follow up. The newest program which is called Streamside Visual Assessment involves
visually assessing streams and completing a field data sheet to document current conditions.
Both Volunteer Monitoring programs include a one-day training session. Data is used to identify
potential water quality problems that are referred to staff for follow up action. Volunteer groups
are assigned a stream segment to monitor for a one (1) year period with the option to renew the
agreement annually.
6.4.7 Volunteer Appreciation Campaign
An annual appreciation campaign is held to acknowledge the achievements of volunteers toward
restoring the quality and usability of Mecklenburg County’s surface water resources. The
campaign includes a variety of methods to recognize volunteers. For example, volunteer groups
of the year are selected and recognized via social media and provided prizes. Special events for
volunteers may also be held as part of the campaign.
6.5 Decision Process
Mecklenburg County’s Public Involvement and Par ticipation Program focuses on the use of
multiple mechanisms for getting the public involved in efforts to restore the quality of
Mecklenburg County’s surface water resources as well as to comply with the State and local
public notice requirements and to engage the community in program development and
implementation. The rationale for the development of such a program is that multiple
approaches are needed in order to involve all age, ethnic and economic groups in Mecklenburg
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
52
County. Some individuals will prefer more passive involvement through participation in public
meetings whereas others may elect to become more actively involved through participation in the
Adopt-A-Stream, Storm Dr ain Marking and Volunteer Monitoring Programs. The Adopt-A-
Stream Program is more physically challenging and is popular among the age group ranging
from 15 to 50 years of age. The Storm Drain Marking Program appeals to volunteers who are
not interested in walking streams but who are willing to place markers on storm drains in their
neighborhoods. This is particularly popular among volunteers greater than 50 years of age.
Volunteer Monitoring is typically performed by schools whereas tree planting events and The
Big Spring Clean appeal to all age groups and is a popular volunteer event for families and large
groups. The individual BMPs identified in Table 17 reflect this approach as do the measurable
goals associated with each BMP.
6.6 Program Evaluation
The measurable goals for each BMP are described in Table 17. The overall success of the Public
Involvement and Par ticipation Program is evaluated through the successful achievement of these
measurable goals as reported with each NPDES MS4 annual assessment report. At a minimum,
the following metrics are included in this annual report:
• Public meetings held and number attending.
• Volunteer programs conducted and number participating.
• Volunteer recognition activities conducted and number attending.
Other measures of success for the Public Involvement and Participation Program are described
below.
• Documentation of Stormwater Program Activities – As a baseline measure of success,
staff will document completion of Work Plan activities that demonstrate successful
fulfillment of the BMPs associated with this program. All activities will be documented
within CMSWS’s Cityworks database and Environmental Data Management System
(EDMS).
• Increasing Number of Volunteers – CMSWS estimates and records participation in all its
volunteer programs. This information will be compiled and tracked as a measure of
program effectiveness. Data is maintained in a Volunteer Database, which is a
component of as well as Excel spreadsheets. Data is included in each annual report for
this Phase II Permit. The indicator of success is an increase in the number of volunteers
compared to the previous fiscal year, including volunteers involved in Adopt-A-Stream,
Storm Drain Marking, Volunteer Monitoring, The Big Spring Clean, tree planting events
and other events throughout the year.
On an annual basis, CMSWS staff will evaluate the BMPs assigned to this program and assess
progress toward achieving the measurable goals from Table 17 and the measures of success
described above. Recommendations for improvement will be made as necessary. During the
following fiscal year, program activities and BMPs will be modified as necessary based on the
results of this evaluation in order to ensure that the specific goals and objectives of the Public
Involvement and Participation Program and SWMP are being effectively and efficiently fulfilled.
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
53
SECTION 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM
An Illicit Discharge Detection and Elimination (IDDE) Program has been developed and is
currently being implemented in Mecklenburg County’s Phase II jurisdictions/entities for the
purpose of detecting and eliminating illicit discharges into the MS4. The program is
administered by CMSWS’s Water Quality Program as described in the following Sections.
7.1 Program Goals and Objectives
CMSWS’s establishes its goals and objectives for its IDDE Program, which are evaluated and
updated annually as necessary, based on the actions necessary to effectively address the targeted
pollutants and pollutant sources identified in Table 8. The current goal of the IDDE Program is
to detect and eliminate illicit discharges into the MS4, which are defined in 40 CFR
122.26(b)(2)) as discharges that are not composed entirely of stormwater except discharges
pursuant to a NPDES Permit (other than the NPDES Permit for discharges from the municipal
separate storm sewer) and discharges resulting from firefighting activities as well as incidental
non-stormwater discharges or flows that are not significant contributors of pollutants as
described in Section 7.7 of this document. The details regarding this program are described in
CMSWS’s “Illicit Discharge Detection and Elimination Manual” available at the following
website: http://stormwater.charmeck.org (select “Regulations”, select “Mecklenburg County”,
select “Manuals & Guidelines”, select “Illicit Discharge Detection & Elimination Policies and
Procedures”). The objectives of the program are as follows:
1. Develop, implement and enforce a program to detect and eliminate illicit discharges into
the MS4, including appropriate policies, procedures, form letters and enforcement
guidance. Achievement of this objective will be measured by an increase in the number
of pollution problems/notices of violation issued over time (see Section 7.10).
2. Maintain a storm sewer system map, showing the location of all major outfalls and the
names and location of all waters of the United States that receive discharges from those
outfalls.
3. Prohibit, through ordinances, or other regulatory mechanisms, non-stormwater discharges
except incidental non-stormwater discharges or flows that are not significant contributors
of pollutants as described in Section 7.7 and implement appropriate enforcement
procedures and actions.
4. Implement a plan to detect and address non-stormwater discharges, including illegal
dumping, to the MS4.
5. Inform public employees, businesses, and the general public of hazards associated with
illegal discharges and improper disposal of waste.
6. Address the following categories of non-stormwater discharges or flows (i.e., illicit
discharges) only if identified as significant contributors of pollutants to the MS4: water
line flushing, landscape irrigation, diverted stream flows, rising ground waters,
uncontaminated ground water infiltration, uncontaminated pumped ground water,
discharges from potable water sources, foundation drains, air conditioning condensation,
irrigation water, springs, water from crawl space pumps, footing drains, lawn watering,
individual residential car washing, flows from riparian habitats and wetlands,
dechlorinated swimming pool discharges, and street wash water (discharges or flows
from firefighting activities are excluded from the effective prohibition against non-
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
54
stormwater and need only be addressed where they are identified as significant sources of
pollutants to waters of the United States).
7.2 BMP Summary Table
Table 18 describes the BMPs implemented as part of the IDDE Program.
Table 18: BMP Summary Table for the IDDE Program
Permit
Ref.
Illicit Discharge Detection and Elimination (IDDE) (Part II Section A.4, 5 and 7; Part II Section B.2.g; Part II Section C.2.c;
Part II Section A.4, 5 and 7; Part II Section D;): Develop and implement a program to detect and eliminate illicit discharges to the
MS4. (Note: The IDDE Manual and SOPs are the same for Phases I and II. Documentation for revising these documents and
performing training is contained under the Phase I program element.)
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
#19 ID-1
(Storm
Sewer
Mapping)
Storm Sewer System Maps
Maintain a
current a map
showing major
outfalls and
receiving
streams.
a. Receive from GIS a list of the
newly collected storm sewer
system features.
a. Annually
beginning July
1
a. Completion
status
Receive and
respond as
necessary to
reported problems
with the storm
sewer system.
b. Field evaluate GIS data and input
additional attribute information
into ArcGIS Collector.
b. Annually
beginning July
1
b. Completion
status
c. Complete inspections of new
outfalls using the Cityworks
Mobile App. Identify and
eliminate pollution sources.
c. Annually
beginning July
1
c. Completion
status
d. Document the date of inspection,
condition of the outfall, dry
weather flows, and any other
potential illicit discharges as well
as the date and results of any
follow up actions.
d. Annually
beginning July
1
d. Completion
status; #
inlets;
outfalls; dry
weather
flows
e. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
e. Annually
beginning July
1
e. Completion
status
#20 ID-2
(Outfall
Inspection)
Screening for Non-St ormwater Flows
Maintain a
program for
conducting dry
weather flow
field
observations in
accordance
with written
procedures.
a. Identify and investigate areas
where there is a high potential for
illicit discharges in accordance
with procedures contained in the
IDDE Manual (outfalls are also
inspected for ID-1 and ID-8).
a. Annually
beginning
July 1
a. Completion
status
Receive and
respond as
necessary to
reported problems
with the storm
sewer system.
b. Complete follow up actions as
necessary to ensure the
elimination of identified
pollution sources.
b. Annually
beginning
July 1
b. Completion
status
c. Document nature of
investigation, names, dates,
locations, follow up actions,
violations, and final resolution.
c. Annually
beginning
July 1
c. Completion
status; #
problems
resolved
d. Complete annual report detailing d. Annually d. Completion
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
55
Permit
Ref.
Illicit Discharge Detection and Elimination (IDDE) (Part II Section A.4, 5 and 7; Part II Section B.2.g; Part II Section C.2.c;
Part II Section A.4, 5 and 7; Part II Section D;): Develop and implement a program to detect and eliminate illicit discharges to the
MS4. (Note: The IDDE Manual and SOPs are the same for Phases I and II. Documentation for revising these documents and
performing training is contained under the Phase I program element.)
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
activities completed and
summarizing findings. Include in
report for PD-1.
beginning
July 1
status
#21 ID-3
(NOV &
Enforcement)
Maintain an IDDE Program
Maintain a
written IDDE
Program,
adequate legal
authorities
including
ordinances,
and written
procedures for
conducting
investigations
of Illicit
discharges.
a. Review and revise IDDE
Manual.
a. Once during 5-
year permit
term
a. Completion
status
Work with
CMSWS to
update and adopt
ordinances as
necessary.
b. Review and revise SOPs and
ordinances as necessary.
b. Annually
beginning July
1
b. Completion
status; # trained
c. Perform annual IDDE training
for staff.
c. Annually
beginning July
1
c. Completion
status
d. Conduct investigations and
document nature of investigation,
names, dates, locations, follow up
actions, violations, and final
resolution..
d. Annually
beginning July
1
d. Completion
status
e. Prepare and issue NOVs and
initiate enforcement actions in
accordance with SOPs. Follow
up to ensure compliance and
document. Maintain system to
track NOVs for identifying
chronic violators.
e. Annually
beginning July
1
e. Completion
status; #
NOVs; #
enforcements
f. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
f. Annually
beginning July
1
f. Completion
status
#22 ID-4.1; ID-
4.3; ID-4.4;
ID-4.10
(Monit
Oversight;
Monit Fixed
Interval;
Monit Bugs;
Monit Fish;
Monit
CMANN)
Water Quality Monitoring Program
Maintain a
monitoring
program to
assess water
quality
conditions for
identification
and
elimination of
illicit
discharges and
other pollution
sources.
a. Review SOPs annually and
revise as necessary. Perform
staff training.
a. Annually
beginning July
1
a. Completion
status
Receive and
respond as
necessary to
reported problems
with the storm
sewer system.
b. Perform monitoring activities. b. Annually
beginning July
1
b. Completion
status
c. Analyze data and initiate follow
up actions as necessary to identify
and eliminate pollution sources.
c. Annually
beginning July
1
c. Completion
status
d. Document nature of investigation,
names, dates, locations, follow up
actions, violations, and final
resolution.
d. Annually
beginning July
1
d. Completion
status;
summary of
data
collected
e. Complete annual report detailing
activities completed and
e. Annually
beginning July 1
e. Completion
status
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
56
Permit
Ref.
Illicit Discharge Detection and Elimination (IDDE) (Part II Section A.4, 5 and 7; Part II Section B.2.g; Part II Section C.2.c;
Part II Section A.4, 5 and 7; Part II Section D;): Develop and implement a program to detect and eliminate illicit discharges to the
MS4. (Note: The IDDE Manual and SOPs are the same for Phases I and II. Documentation for revising these documents and
performing training is contained under the Phase I program element.)
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
summarizing findings. Include in
report for PD-1.
#23 ID-5
(Educate
Prevention)
Pollution Prevention Education
Develop and
implement a
public
outreach
program to
inform public
employees,
businesses and
the general
public of illicit
discharges and
improper
waste disposal
and how they
threaten the
environment
as well as
provide
instructions
concerning
proper
reporting.
a. Ensure that messages are
incorporated into the general
water quality media campaign.
a. Annually
beginning July 1
a. Completion
status
Ensure employees
are properly
trained.
b. Conduct presentations for public
employees, businesses and the
general public regarding the
environmental threat of illicit
discharges and how they are
identified and reported.
b. Annually
beginning July 1
b. Completion
status
c. Provide training to appropriate
municipal staff, who, as part of
their normal job responsibilities,
may come into contact with or
otherwise observe an illicit
discharge or illicit connection to
the storm sewer system.
c. Once during 5-
year permit term
c. Completion
status; #
trained
d. Review and update 311
Keywords annually and
coordinate with 311 staff as
necessary to ensure their
continued effectiveness as a
stormwater helpline for reporting
illicit discharges and as a
mechanism for public education
and involvement.
d. Annually
beginning July 1
d. Completion
status
e. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
e. Annually
beginning July 1
e. Completion
status
#24 ID-6
(Follow up
Insp., CRS
and ER)
Follow up Inspections and Responding to Citizen Requests and Emergencies
Respond to
citizen
requests for
service and
emergency
situations as
well as
conduct follow
up inspections
as necessary to
identify and
eliminate
pollution
problems.
a. Review SOPs annually and
revise as necessary. Perform staff
training.
a. Annually
beginning July 1
a. Completion
status
Receive and
respond as
necessary to
reported problems
with the storm
sewer system.
b. Maintain the duty roster for the
Emergency Response Program.
Ensure SOPs are followed, and
necessary equipment provided.
b. Annually
beginning July 1
b. Completion
status
c. Receive and respond to citizen
requests for service and
emergency responses. Identify
and eliminate pollution sources.
c. Annually
beginning July 1
c. Completion
status
d. Document nature of
investigation, names, dates,
locations, follow up actions,
d. Annually
beginning July 1
d. Completion
status; #
service
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
57
Permit
Ref.
Illicit Discharge Detection and Elimination (IDDE) (Part II Section A.4, 5 and 7; Part II Section B.2.g; Part II Section C.2.c;
Part II Section A.4, 5 and 7; Part II Section D;): Develop and implement a program to detect and eliminate illicit discharges to the
MS4. (Note: The IDDE Manual and SOPs are the same for Phases I and II. Documentation for revising these documents and
performing training is contained under the Phase I program element.)
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
violations, and final resolution. requests; #
problems
resolved
e. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
e. Annually
beginning July 1
e. Completion
status
#25 ID-8
(Stream
Walk)
Stream Walk/Outfall Inventory & Inspection/Dry Weather Flow Analysis
Inspect creeks
for the purpose
of identifying
and
eliminating
illicit
discharges and
collecting
outfall and
stream channel
data as well as
conducting dry
weather flow
field
observations in
accordance
with written
procedures.
a. Review SOPs annually and revise
as necessary. Perform staff
training.
a. Annually
beginning July 1
a. Completion
status
Receive and
respond as
necessary to
reported problems
with the storm
sewer system.
b. Perform stream walk activities in
accordance with established
SOPs. Document the dates and
results of stream walk activities.
b. Annually
beginning July 1
b. Completion
status
c. Analyze data and initiate follow
up actions as necessary to
identify and eliminate pollution
sources.
c. Annually
beginning July 1
c. Completion
status; #
miles
walked; #
problems
resolved
d. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
d. Annually
beginning July 1
d. Completion
status
#26 ID-9
(IDEP)
Illicit Discharge Elimination Program (IDEP)
Investigate
select
locations on a
regular,
recurring
schedule for
the
identification
and
elimination
illicit
discharges and
other pollution
problems.
a. Review SOPs annually and
revise as necessary. Perform staff
training.
a. Annually
beginning July 1
a. Completion
status
None
b. Perform IDEP activities and
follow up as necessary to
identify and eliminate pollution
sources.
b. Annually
beginning July 1
b. Completion
status
c. Document nature of
investigation, names, dates,
locations, follow up actions,
violations, and final resolution.
c. Annually
beginning July 1
c. Completion
status; #
investigations;
# problems
resolved
d. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
d. Annually
beginning July 1
d. Completion
status
#27 ID-U
(Used Oil
Inspection)
Used Oil Inspection
Conduct
inspections of
vehicle
a. Conduct inspections and follow
up as necessary to identify and
eliminate pollution sources in
a. Annually
beginning July 1
a. Completion
status
None
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
58
Permit
Ref.
Illicit Discharge Detection and Elimination (IDDE) (Part II Section A.4, 5 and 7; Part II Section B.2.g; Part II Section C.2.c;
Part II Section A.4, 5 and 7; Part II Section D;): Develop and implement a program to detect and eliminate illicit discharges to the
MS4. (Note: The IDDE Manual and SOPs are the same for Phases I and II. Documentation for revising these documents and
performing training is contained under the Phase I program element.)
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
maintenance
facilities to
ensure the
proper
implementatio
n of good
housekeeping
measures to
prevent the
discharge of
pollutants.
accordance with the procedures
contained in the IDDE Manual.
b. Document nature of
investigation, names, dates,
locations, follow up actions,
violations, and final resolution.
b. Annually
beginning July 1
b. Completion
status; #
investigations;
# problems
resolved
c. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
c. Annually
beginning July 1
c. Completion
status
#28
ID-10
(Evaluate
IDDE)
Evaluate Effectiveness of the IDDE Program
Evaluate
effectiveness
of the IDDE
Program.
a. Evaluate program effectiveness at
meeting established goals and
objectives.
a. Annually
beginning July 1
a. Completion
status
None.
b. Measure program success using
established criteria.
b. Annually
beginning July
1
b. Completion
status;
criteria
measure
c. Recommend improvements as
necessary. Include
recommendations in report for
PD-1.
c. Annually
beginning July
1
c. Completion
status
d. Implement improvements in the
next fiscal year.
d. Annually
beginning July
1
d. Completion
status
7.3 Illicit Discharge Detection & Elimination Manual
CMSWS maintains a written document describing its IDDE Program that is referred to as the
IDDE Manual. All written procedures and forms for the execution of the IDDE Program are
contained in this document, including links to Standard Operating Procedures (SOPs) that
include detailed implementation procedures. The Manual is reviewed and updated every five (5)
years whereas the more detailed SOPs are reviewed and updated annually. The IDDE Manual
includes information regarding the following:
• Legal authority, including right of entry.
• Coordination with other agencies.
• Identification of priority areas likely to have illicit discharges.
• Methods used to identify illicit discharges and connections.
• Written procedures for conducting investigations of identified illicit discharges and
connections.
• Written procedures for conducting dry weather flow field observations.
• Tracking illicit discharges and connections to a source.
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• Eliminating sources of illicit discharges and connections.
• Sanitary sewer failures.
• Documentation.
• Employee training.
• Provisions for program assessm ent and evaluation.
7.4 Storm Sewer System Mapping
On August 31, 2006, CMSWS completed the storm sewer maps for all the Phase II jurisdictions
in Mecklenburg County. These maps show the locations of inlets, outlets and receiving waters
as well as identify the corresponding six-square mile drainage areas. As part of this mapping
program, CMSWS also identified dry weather flows to the storm sewer system and initiated the
measures necessary to eliminate pollution sources. The source of information for the
development of these storm sewer maps was 2002 digital aerial photography (1 foot per pixel
resolution .tif images, compressed 50:1 into .sid format) provided by Mecklenburg County
Mapping/GIS Services. The aerial photography was loaded into Hewlett-Packard iPAQ
handheld computers that were equipped with both ESRI Arc Pad 6.0.3 GIS software and Trimble
GPS Correct. This mapping software package was configured to store important information
relevant to the storm sewer system and the water quality conditions observed. A Trimble
Pathfinder Pocket GPS unit was connected to the handheld computer in order to geo-reference all
data collected. CMSWS staff conducted field inspections to locate all storm sewer system inlets,
outlets and receiving streams using the aerial photos loaded into the handheld computer as a
reference. Once located, a geo-referenced position for the inlets and outlets was determined
using the Trimble GPS unit. Other field data was also collected during the inspections including
the general condition of the storm drain, the name of the receiving stream and whether dry
weather flow or other potential pollution problems were observed. If such problems were
detected, the following additional information was collected:
• Estimated flow rate.
• Odors.
• Coloration.
All observed dry weather flows were sampled for fecal coliform bacteria, surfactants, fluoride,
and oil and grease. Follow up field investigations were performed to identify and eliminate all
pollution sources. All follow up activities were documented in a report maintained in CMSWS’s
computer database. Following the field inspections, the digital data was downloaded by
CMSWS staff and stored in an ESRI shapefile format (with attributes). CMSWS staff post-
processed the data to include the corresponding six-mile sub-basin identification number as an
added attribute. After the inventory was completed, storm sewer system maps were created for
use in the implementation of the IDDE Program. Staff with CMSWS conduct field
investigations to identify dry weather flows to the storm sewer system during responses to citizen
requests for service and while conducting stream walks and various inspection activities. The
necessary follow up actions are performed to identify and eliminate pollution sources as
described in Section 7.7. All data is maintained in a GIS database and is available for use by
staff in the identification and elimination of illicit discharges through the Cityworks database
(see Figure 8).
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Figure 8: Screen Shot from Cityworks of Storm Drain Inlets, Outlets, and Receiving Streams
The storm sewer system map is updated daily by Mecklenburg County’s GIS Department in
order to capture inlets and outlets added by new development. This is completed as part of their
ongoing process to update the impervious area coverage that is included in the stormwater billing
process. GIS staff use “Nearmap Aerial Imagery” to locate the new inlets and outlets. These
high-resolution, frequently updated aerial maps are widely used by both the public and private
sector to rapidly identify features on the ground with a very high degree of accuracy. EagleView
Pictometry is used to enhance images that are difficult to identify due to shadows and other
distortions. This patented high-resolution aerial image capture process uses low-flying airplanes
to photograph locations on the ground, depicting up to 12 oblique perspectives (shot from a 40
degree angle) as well as an orthogonal (overhead) view to produce a 360-degree view making
objects easier to recognize and interpret. Once the inlets and outlets are identified, a new point is
created in ESRI’s ArcGIS, including an object ID number, date collected, feature type (inlet or
outlet), and collection method. On a quarterly basis, GIS provides CMSWS with a list of the
newly collected storm sewer system features. These features are subsequently field validated by
CMSWS’s staff that input additional attribute information using the ArcGIS Collector
application, including the outfall type (major or minor, FES, endwall, exposed pipe, etc.), outfall
shape, outfall material, endwall material, and the diameter of the outfall. Staff also complete an
outfall inspection using the Cityworks Mobile App to record the condition of the outfall, dry
weather flows, and any other potential illicit discharges. Follow up actions are completed as
necessary to ensure the elimination of identified pollution sources. SOPs have been developed
for the storm sewer system mapping process, including follow up for potential pollution sources,
and are available upon request.
7.5 Pollution Control Ordinance
In April 2004, the Town of Davidson adopted a “Surface Water Pollution Control Ordinance”
that prohibits illicit discharges, illicit connections and improper disposal to surface waters and
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storm sewers within their corporate limits as authorized by North Carolina General Statute
(NCGS) 160A-174. On May 5, 2004, Mecklenburg County adopted the same ordinance for the
unincorporated areas of the county as authorized by NCGS 153A-121. A separate ordinance was
required for the Town of Davidson because they have jurisdiction in Iredell County where the
Mecklenburg County ordinance would not be applicable. On June 8, 2004, the Town of
Pineville adopted a resolution allowing Mecklenburg County to enforce its ordinance within their
corporate limits as authorized by NCGS 153A-122. On June 21, 2004, the Towns of Cornelius
and Huntersville adopted the same resolution followed by the Town of Mint Hill on June 24,
2004. The Town of Matthews had adopted a separate Stormwater Pollution Control Ordinance
on November 27, 2000. CMSWS has been delegated the authority to enforce these ordinances in
cooperation with the respective jurisdictions. This regulatory mechanism was chosen for
prohibiting illicit discharges to storm sewers and surface waters in the Phase II area due to the
success of a similar ordinance in effect in the Phase I area in the City of Charlotte since
November 25, 1995 These ordinances prohibit illicit discharges, illicit connections and improper
disposal to the storm drain system except for the incidental non-stormwater flows that do not
significantly impact water quality described in Section 3.8.
CMSWS reviews the above described surface water pollution control ordinances each fiscal year
and modifies them as necessary to ensure that adequate legal authority is maintained to prohibit
illicit connections and discharges, and to properly enforce the provisions of the IDDE Program.
Changes were made to the Town of Matthews’ and Mecklenburg County’s ordinances effective
February 12, 2018 and May 21, 2020, respectively. Enforcement procedures and Notice of
Violation shells, etc. were changed to correspond to the new ordinance requirements. A list of
the major changes is provided below.
1. All Sections: Various wording changes were made throughout the document without
changing the regulatory requirements or overall intent of the ordinance.
2. Definitions: Definitions were added and changed as necessary in Section 4 to support
ordinance revisions.
3. Prohibitions, Accidental Discharge(s): Accidental discharges were added as a violation
of the ordinance.
4. Prohibitions, Use of High PAH Pavement Products Prohibited: The use of pavement
products with greater than 0.1% polycyclic aromatic hydrocarbons (PAH) by weight on
an asphalt or concrete surface was added as a violation of the ordinance.
5. Prohibitions, Obstruction: Obstructing, hampering, or interfering with county personnel
carrying out official duties authorized by this ordinance was added as a violation.
6. Prohibitions, Allowable Incidental Discharges of Non-Storm Water: The following
allowable discharges were added: diverted stream flows; and flows from riparian
habitats and wetlands. Swimming pool and hot tub discharges continue to be allowed
provided they do not contain chlorine, bromine, salt, or any other treatment chemicals.
Backwash discharges from swimming pools and hot tubs and saltwater pool discharges
are identified as prohibited in the revisions. Single-family and charity vehicle washing
continues to be allowed; however, designated vehicle wash areas at multi-family
residential complexes are identified as prohibited in the revisions if they connect,
directly or indirectly, to the stormwater system or the waters of the state. In addition, the
revisions specify that charity vehicle washing performed by the same organization or at
the same location on a routine basis (more than one time in a thirty-day period) is not
allowed.
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7. Powers and Authority for Inspection, Search Warrants: The revisions added a provision
for obtaining a search warrant to conduct inspections to the extent permitted by law.
8. Enforcement and Penalties, Remedies Not Limited: The revisions add a provision that
the remedies provided in the ordinance are not exclusive and may be combined with any
other remedies authorized by law.
9. Enforcement and Penalties, Notice of Violation: The revisions add a provision that any
person who violates the ordinance, or allows a direct or indirect, act or acts which
causes a violation of the ordinance will be issued a written notice of violation. The
specific content of the notice is also described as well as how it will be served.
10. Enforcement and Penalties, Civil Penalties(c): The revisions clarify that a civil penalty
may be assessed for the time period from the date the violation first occurs until the date
that the violation ceases as verified by staff. The revisions also indicate that penalties
may be assessed concurrent with a notice of violation when staff are hampered or
obstructed from carrying out official duties; a repeat or continuing violation has
occurred; and/or there is a willful or intentional violation of the ordinance. In addition,
the revisions add the following factors for inclusion in determining the amount of a civil
penalty: knowledge of the requirements by the violator and/or reasonable opportunity or
obligation to obtain such knowledge; and technical and economic reasonableness of
reducing or eliminating the violation.
11. Enforcement and Penalties, Compliance Agreement(e): The revisions add a provision
for the use of a Compliance Agreement as a remedy to obtain compliance.
12. Enforcement and Penalties, Compliance Order(f): The revisions add a provision for the
use of a Compliance Order to obtain compliance.
13. Enforcement and Penalties, Cease and Desist Order(g): The revisions add a provision
for the use of a Cease and Desist Order to obtain compliance.
14. Enforcement and Penalties, Withholding of Inspections, Permits, or Other Approvals(h):
The revisions add a pr ovision for withholding inspections, permits, and other approvals
as a means for obtaining compliance.
15. Enforcement and Penalties, Abatement by the County: The revisions include specific
information regarding the process for abatement of violations by the County when the
violator fails to comply.
16. Enforcement and Penalties, Emergencies: The revisions include provisions for
immediate cessation and abatement of violations when there is an immediate threat to
public health, safety or the environment.
17. Enforcement Remedies and Penalties, Injunctive Relief: The revisions include a
provision for obtaining injunctive relief through the courts as an added compliance
measure.
On August 25, 2020, changes were made to the Town of Davidson’s ordinance to ban the use of
pavement products with greater than 0.1% polycyclic aromatic hydrocarbons (PAH) by weight,
which is the same as the ban in Mecklenburg County’s and Matthews’ ordinances described in
#4 above. On January 26, 2021, the other 16 changes listed above were made to Davidson’s
ordinances. Enforcement pr ocedures and Notice of Violation shells, etc. were changed to
correspond to the new ordinance requirements.
Copies of the above ordinances are available on the following website:
http://stormwater.charmeck.org (select “Regulations”, select jurisdiction, select “Stormwater
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Pollution Control”).
7.6 Enforcement
Enforcement guidance and procedures were developed and became effective at the same time as
the ordinances described in Section 7.5. These procedures include guidelines on when a notice
of violation is to be issued and the proper sections of the ordinance to cite. The procedures also
provide guidance on the assessment of penalties. All appeals to the ordinances are heard by
SWAC except in the Town of Matthews where appeals are heard by their Environment
Committee. Further information regarding the implementation of the ordinances and
enforcement actions is contained in CMSWS’s IDDE Manual available at the following website:
http://stormwater.charmeck.org (select “Regulations”, select “Mecklenburg County”, select
“Manuals & Guidelines”, select “Illicit Discharge Detection & Elimination Policies and
Procedures”).
7.7 Detection and Elimination
CMSWS’s IDDE Manual describes the actions taken to identify and eliminate illicit discharges,
which includes the following four (4) primary steps:
1. Identify priority areas likely to have illicit discharges.
2. Confirm the presence of an illicit discharge.
3. Track the discharge to its source.
4. Eliminate the source.
The following subsections briefly describe these four (4) components of the IDDE Program.
More detailed information is provided in CMSWS’s IDDE Manual.
7.7.1 Identifying Priority Areas
Priority areas with a higher likelihood of illicit discharges are typically identified through:
1. Citizen requests for service regarding potential water quality problems.
2. Routine water quality monitoring activities.
3. Volunteer activities.
4. GIS mapping.
7.7.1.1 Citizen Requests for Service
CMSWS has an ongoing public education campaign focusing on illicit discharges and
connections for the purpose of increasing public awareness and reports from citizens of
suspected problems. This campaign informs residents how to identify illicit discharges and
connections, how they negatively impact their quality of life and what they can do to eliminate
them, including proper reporting to the 311 stormwater helpline. A broad range of media outlets
have been utilized in this campaign, including television, radio and print. Efforts have been
highly successful as indicated by the increase in the number of reports received from citizens
regarding suspected illicit discharges. CMSWS considers its responses to these citizen reports or
service requests to be of the utmost importance not only from a customer service standpoint, but
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also because this is how most illicit discharges and connections are identified. All staff members
receive annual training regarding responses to service requests and proper customer service.
All service requests are forwarded to Supervisors immediately following receipt. To ensure an
effective and efficient response, Supervisors place all service requests into one of the following
three (3) categories based on the type of response required:
• Category 1: Health / Safety Threat
• Category 2: Spill / Illegal Discharge / Water Quality Violation
• Category 3: Request for Assistance / Information (non-emergency)
Category 1 service requests are considered a threat to the health and safety of the public and are
given the highest priority. They are always responded to within four (4) hours of receipt and
often include involvement by a Supervisor working closely with field staff. Examples of
Category 1 service requests are as follows:
1. Sewage or other pollutant discharge to a known swimming area.
2. Sewage or other pollutant discharge to a playground or other areas where people could
easily come in contact with pollutants.
3. Discharge of pollutant near a drinking water intake.
Category 2 service requests include spills, illegal discharges and water quality violations and are
also considered to be a high priority. They too are responded to within four (4) hours of receipt
since they may easily progress to a Category 1. Examples of Category 2 service requests are as
follows:
1. Any active discharge of pollutants such as sewage and fuel spills.
2. Numerous dead fish in creek.
3. Someone currently in the act of violating a water quality regulation.
4. Request from Fire or Police to respond.
Category 3 service requests include requests for assistance and information that are non-
emergency in nature and do not require immediate attention. These service requests are
responded to as soon as possible, but never any later than two (2) workdays from the receipt of
the request. Examples of Category 3 service requests are as follows:
1. Disturbance has occurred in a stream buffer.
2. Request for water quality data.
3. Someone has routinely dumped oil on ground.
4. XYZ Company may be disposing of waste illegally.
For all responses to citizen requests for service, staff ensure that all pollution sources are
eliminated, negatively impacted areas are restored, and the necessary actions taken to prevent
recurrence, including the distribution of educational information. If violations of water quality
ordinances are observed, notices of violation are issued within two (2) workdays of detection and
a compliance deadline is established. Staff follow up to ensure compliance by this deadline. In
many cases, the violator is required to submit written notification of the actions undertaken to
achieve compliance and prevent recurrence. Responses to citizen requests for service are
overseen by Supervisors and documented in Cityworks. All documentation is reviewed and
approved by Supervisors prior to closing.
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More information regarding responses to citizen requests for service is provided in the Illicit
Discharge Detection and Elimination (IDDE) Manual located at the following website:
http://stormwater.charmeck.org (select “Regulations”, select “Mecklenburg County”, select
“Manuals & Guidelines”, select “Illicit Discharge Detection & Elimination Policies and
Procedures”).
7.7.1.2 Routine Water Quality Monitoring Activities
The monitoring activities performed by CMSWS for identifying priority areas for illicit
discharges include fixed interval monitoring and the use of a Continuous Monitoring and Alert
Notification Network (CMANN). Samples for fixed interval monitoring are collected by hand
(grab samples) on the second Tuesday and Thursday of each month at 10 designated stream
monitoring sites as shown in Figure 9. A minimum of one (1) monthly sampling run a quarter is
conducted under ambient (base flow) conditions to better facilitate the identification of illicit
discharges. At each stream monitoring site, samples are collected and analyzed for 17 water
quality parameters as follows: ammonia-nitrogen, fecal coliform bacteria, total kjeldahl nitrogen,
nitrate/nitrite, total suspended solids, total phosphorus, enterococcus, e. coli, turbidity, suspended
sediment, magnesium, calcium, hardness, and copper (dissolved). Lead (dissolved), chromium
(total), and zinc (dissolved) are collected in the first month of each quarter. The primary purpose
of the fixed interval monitoring program is to assess the general water quality conditions of the
streams and to identify potential pollution problems at the watershed scale. CMANN data is
collected on a fixed time interval (usually every hour) using automated equipment set-up at
seven (7) designated stream monitoring sites as shown in Figure 9, excluding MY14, MC36,
MC2, MC2A1, MC3E, and MC40C. CMANN is used to measure turbidity, pH, temperature,
conductivity, and dissolved oxygen. All data is stored in a data logger and transmitted via a
wireless modem for display on the CMANN website at https://cmann.mecknc.gov/. The primary
purpose of the CMANN monitoring program is to assess water quality conditions for overall
watershed health and identify pollution problems.
All data from the above monitoring activities is delivered electronically to a Quality Assurance
and Quality Control (QA/QC) Officer (position title is Environmental Analyst) with CMSWS,
who is responsible for the compilation, review, verification, validation, and warehousing of all
water quality monitoring data products. Immediately upon receipt of this data, the QA/QC
Officer identifies all exceedances of local Watch/Action Levels and State water quality
standards. Within one workday from receipt of the data, the QA/QC Officer reports all observed
exceedances to Supervisors who establish the area upstream of the sample location as a priority
for the identification of illicit discharges. The Supervisor assigns all priority areas to staff for the
initiation of immediate follow up actions for the purpose of identifying and eliminating pollution
sources and restoring water quality conditions.
In addition to exceedances of local Watch/Action Levels and State water quality standards,
CMSWS uses an index of water quality conditions referred to as the Stream Use Support Index
or SUSI to identify areas with negatively impacted water quality conditions and a high likelihood
of illicit discharges. These are areas where water quality conditions are on the decline but may
not be degraded enough to trigger a follow up for an Action or Watch Level exceedance as
described above. SUSI includes five (5) broad categories of parameters that were determined to
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be the most important indicators of pollution in Charlotte-Mecklenburg. These five (5)
categories, which are called sub-indices, are as follows:
1. Bacteria (Fecal Coliform Bacteria)
2. Metals (Copper, Zinc, Lead and Chromium)
3. Biological (Macroinvertebrate and Habitat)
4. Physical (Turbidity, Dissolved Oxygen, Temperature, and pH)
5. Nutrients (Total Phosphorus and Chlorophyll-a)
Figure 9: Phase II Stream Monitoring Sites
SUSI also incorporates data collected over three (3) time horizons, including short term (data
from the current month), middle term (data from the past 10 to 12 months) and long term (data
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from the past 1 to 2 years). SUSI rates water quality conditions across Mecklenburg County
using data collected over these time horizons and displays these conditions in a color-coded map
as either Supporting, Partially Supporting, Impaired or Degraded (see Figure 10). The QA/QC
Officer pr eviously described generates SUSI maps quarterly and provides them to the
Supervisors who consider areas identified with Impaired and Degraded conditions as priority
areas for illicit discharges or other pollution problems. The Supervisors consider other data and
information available to them in assigning these priority areas to staff for the initiation of follow
up actions for the purpose of identifying and eliminating pollution sources and restoring water
quality conditions.
Additional detail regarding water quality monitoring activities is available on CMSWS’s
website: http://stormwater.charmeck.org (select “Surface Water Quality”, select
“Monitoring”).
Figure 10: Stream Use Support Index (SUSI) Map (April 1 through June 2020)
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7.7.1.3 Volunteer Activities
CMSWS has three (3) volunteer programs that contribute toward the identification of priority
areas with a higher likelihood of illicit discharges, including Adopt-A-Stream, Storm Drain
Marking and Volunteer Monitoring. The objective of these programs is to engage the citizens of
Charlotte-Mecklenburg in activities for protecting and restoring surface water resources,
including the identification illicit discharges. Typically, volunteers will report to the volunteer
coordinator the potential presence of an illicit discharge. This report is forwarded to a
Supervisor who will schedule staff activities to confirm the presence of an illicit discharge as
described in Section 7.7.2.
7.7.1.4 GIS Mapping
CMSWS utilizes GIS mapping capabilities to identify priority areas for illicit discharges.
CMSWS maintains all its water quality data and information, including Work Plan assignments,
activity/inspection reports, asset information, etc., in its Environmental Management Database or
EDMS. EDMS contains multiple databases, including Cityworks that is used for GIS mapping
and citizen requests for service as well as activity and inspection reports. Cityworks is a work
management tool built around the use of ESRI’s GIS environment, which tracks activities based
on identified features referred to as assets. CMSWS has incorporated numerous GIS asset layers
into Cityworks that ar e useful in prioritizing areas for illicit discharges. Figure 11 provides a
screen shot from Cityworks with the GIS asset layers activated for the Phase II storm water
inventory. The green dot in the center indicates the location of a suspected water quality
problem reported through the receipt of a citizen request for service that has been geocoded into
Cityworks. Staff can access GIS asset layers using the “Legend” tab in Cityworks, which is
extremely useful in prioritizing specific locations for illicit discharges. This is one of the many
techniques available to staff for identifying pollution sources through the use of GIS.
Figure 11: GIS Map Available Through Cityworks for Prioritizing Areas for Illicit Discharges
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7.7.2 Confirming the Presence of an Illicit Discharge
Once a priority area for an illicit discharge source is identified as described in Section 7.7.1,
standardized follow up field screening activities are performed to confirm the presence of an
illicit discharge, including but not limited to:
• Illicit Discharge Elimination Program (IDEP).
• Short Term Monitoring.
• Hot Spot Investigations.
• Stream Walks.
• Facility Inspections (including conducting inspections of vehicle maintenance facilities).
• Dry Weather Flow Investigations.
For all these field screening activities described above, staff ensure that pollution sources are
eliminated, negatively impacted areas are restored, and the necessary actions are taken to prevent
recurrence, including the distribution of educational information. If violations of water quality
ordinances are observed, notices of violation are issued within two (2) workdays of detection and
a compliance deadline is established. Staff follow up to ensure compliance by this deadline. In
many cases, the violator is required to submit written notification of the actions undertaken to
achieve compliance and prevent recurrence. All activities are overseen by Supervisors and
documented in Cityworks. All documentation is reviewed and approved by the Supervisor prior
to closing.
7.7.2.1 Illicit Discharge Elimination Program (IDEP)
IDEP involves investigating select locations in identified priority areas to confirm illicit
discharges using visual observations. An example is as follows: A Supervisor identifies a
priority area for an illicit discharge from the receipt of a citizen request for service and assigns to
staff for follow up action. Staff’s investigation does not reveal a pollution problem; however,
based on information provided by the citizen staff is convinced that the problem is associated
with an intermittent discharge. One option available to the Supervisor for confirming the
discharge is to establish an IDEP run in the area. This is accomplished by assigning staff to
perform visual observations at specific intervals in the area, such as bridge crossings, on a short
term, frequent schedule to confirm the presence of a discharge. This is particularly effective for
discharges that are detectable using human senses such as a sewer overflow and surfactants from
vehicle washing. Once the discharge is confirmed and the source identified, the IDEP activities
are discontinued.
Industrial inspections are performed in the Phase II jurisdictions by CMSWS through IDEP.
Every fiscal year CMSWS selects a minimum of six (6) industrial facilities for inspection based
on their potential to pollute. Most inspections are performed at the industrial facilities included
in Table 6. Inspections are conducted and reports generate in accordance with established SOPs
that are available upon request to the Environmental Manager with the Water Quality Program.
Follow up actions are implemented as necessary to identify and eliminate pollution sources
identified through these inspections.
Facility inspections are performed in the Phase II jurisdictions by CMSWS through IDEP. A
common target for these inspections is the multi-family residential complex with a private sewer
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collection system that has a history of poor maintenance and sewer spills. CMSWS will conduct
inspections of these systems on a regular basis through IDEP to identify and eliminate sewer
discharges and ensure proper system maintenance. The complex is thoroughly inspected for
active sewer discharges and signs of previous overflow problems such as limed areas, toilet
paper, etc. Corrective actions are implemented as necessary to ensure that all problems are
corrected, and the system is properly maintained to prevent recurrence.
7.7.2.2 Short Term Monitoring
Short term monitoring involves select parameters at specific stream locations and/or stormwater
outfalls in identified priority areas to confirm illicit discharges. An example is as follows: A
Supervisor identifies a section of stream as a priority area for illicit discharges as a result of an
Action Level exceedance from a fixed interval monitoring run. One option available to the
Supervisor is to establish Short Term Monitoring along the stream section to confirm the
presence of a discharge. This is accomplished by identifying sample collection locations along
the stream reach and assigning staff to monitor these locations for select parameter(s) using field
and/or laboratory analyses on a short term, frequent schedule. This is particularly effective for
discharges that are typically not detectable using human senses such as discharges of organics or
metals. Once the discharge is confirmed and the source identified, the monitoring activities are
discontinued.
7.7.2.3 Hot Spot Investigations
Hot spot investigations are performed at a select stream location, stormwater outfall, sewer
manhole, lift station, etc. with a history of problems in priority areas to confirm illicit discharges
using visual observations. Hot spot investigations are similar to IDEP runs except they involve
investigations of a single location as opposed to IDEP which usually incorporates multiple
locations.
7.7.2.4 Stream Walks
This activity involves walking an entire stream reach in identified priority areas to confirm illicit
discharges using visual observations and monitoring activities. Streams walks differ from IDEP
and hot spot investigations because the entire stream reach is inspected as opposed to select
locations along the reach. In addition, hot spot and IDEP investigations can involve locations
other than streams such as a parking lot or a business corridor. CMSWS is on a schedule to walk
all perennial streams in the Phase II jurisdictions within a rotating five (5) year time frame. Hot
spot stream segments are walked on a more frequent basis.
7.7.2.5 Dry Weather Flow Investigations
Dry weather flow investigations involve inspecting stormwater outfalls after a minimum of 72
hours of no measurable rainfall and identifying dry weather flows. The sources of such flows are
typically either groundwater infiltration into the storm drainpipe, lawn watering, air conditioning
condensate or an illicit discharge. CMSWS utilizes various data and information to identify
areas where there is a high potential for illicit discharges. Staff are assigned to perform outfall
inspections in these areas. During these inspections, data is collected and recorded in a GIS
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application in accordance with established procedures. Immediately following the identification
of dry weather flows, efforts are undertaken by CMSWS to confirm an illicit discharge. Staff
will physically observe the discharge for pollutant indicators such as discoloration, odor, solids,
etc. and perform water quality monitoring for select parameters, including temperature, dissolved
oxygen, conductivity, pH, fecal coliform bacteria, total phosphorus, and flow. Follow up actions
are implemented as necessary to ensure that all pollution sources are eliminated, and recurrence
prevented.
7.7.3 Tracking the Source of an Illicit Discharge
Once an illicit discharge has been confirmed, standardized follow up procedures are performed
to track the discharge to its source, including but not limited to:
• Record Reviews.
• Inspections.
• Monitoring.
7.7.3.1 Record Reviews
CMSWS staff reviews available records and information to assist in the identification of
potential pollution sources, including digital information available through EDMS and the
Mecklenburg County Property Ownership Land Records Information System (POLARIS) as
well as other available data sources. The GIS capabilities of EDMS are a valuable component of
this review process.
7.7.3.2 Inspections
An on-site inspection is conducted of the area, including upstream and upstream of the
confirmed illicit discharge to identify the source. During these inspections, visible observations
are often the best technique for source confirmation. In some cases, visual observations will
isolate the discharge to a storm drain or sanitary sewer system. It is then necessary to inspect
these systems to identify the specific source of the discharge. Standardized methods for source
identification are often employed during these inspections, including but not limited to dye
testing, smoke testing, and pipe videos.
7.7.3.3 Monitoring
If inspections and visual observations are unsuccessful at identifying the pollution source, water
quality monitoring techniques are typically employed. Staff typically use field monitoring
equipment such as a YSI Multiprobe to perform this monitoring provided the pollutant can be
tracked with a parameter measured by the unit, including pH, temperature, dissolved oxygen,
conductivity, and turbidity. The instantaneous data provided by the unit is much more useful
when tracking pollution problems than the delayed data provided by a laboratory. If laboratory
analyses are required to identify the pollution source, the parameters selected are dependent on
the suspected source, including fecal coliform bacteria for a suspected sewer discharge, total
petroleum hydrocarbons (TPH) for a fuel leak, and toxic metals and organics for an industrial
discharge. Whether the YSI Multiprobe unit is used or laboratory samples collected, the
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objective with short term monitoring is to continually narrow the search area until the source is
confirmed.
7.7.4 Procedures for Removing the Source of the Illicit Discharge
Once the source of an illicit discharge has been confirmed, a standardized process is followed by
CMSWS staff for eliminating the source and stopping the discharge. This process includes the
issuance of a written notice of the violation for the applicable Stormwater Pollution Control
Ordinance (see Section 7.5) to the party responsible for the discharge. The notice requires that
the responsible party discontinue the discharge, take action to prevent recurrence, and restore all
impacted areas. Staff conducts follow up activities to ensure compliance. Failure to comply
could result in the assessment of civil penalties. The use of form letters and shell documents are
included in the process.
7.7.5 Documentation
CMSWS uses Cityworks’ Service Request and/or Activity Report forms to track all
investigations and document the following:
1. Date(s) the illicit discharge was observed.
2. Results of the investigation.
3. Notices of violation issued, and enforcement actions taken.
4. Chronic violators for initiation of actions to reduce noncompliance.
5. Storm sewers inspected and dry weather flows identified.
6. Follow-up investigations.
7. Date the investigation was closed.
All documentation is reviewed and approved by a Supervisor prior to being closed in the system.
GIS is integrated into the Cityworks database thus adding a very useful spatial component to data
entry and retrieval. This is illustrated in Figure 12, which is a screen shot from Cityworks
showing the locations of the 776 notices of violation issued in Mecklenburg’s Phase II
jurisdictions over the past 10 years (gray dots) in relationship to the notice of violation in
question (green dot). Data is available for each location with a click of the mouse over the dot.
Many search options are available in Cityworks using this information. The application is also
available for use in the filed using an iPhone.
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Figure 12: Notices of Violation Issued from 2011 through 2020
7.8 Outreach
CMSWS has developed and implemented a public outreach program to inform public
employees, businesses, industries and the general public of the hazards associated with illicit
discharges and improper disposal of wastes. This outreach campaign includes instructions for
properly reporting these problems to CMSWS. Television and radio ads, as well as social media,
handouts and brochures are the primary outreach mechanisms. Handouts and brochures have
been developed and are typically distributed during the performance of facility inspections, when
responding to citizen request for service, and at event displays. This public outreach campaign
for the IDDE Program is conducted by a Senior Environmental Specialist with CMSWS and is
included as a component of the Outreach Program described in Section 5.4.
Problem businesses and industries that have a history of illicit discharges are informed of the
threat to the environment from these discharges as well as the requirements of the Stormwater
Pollution Control Ordinance(s) through the use of “Environmental Notices.” These notices are
distributed by staff when responding to citizen requests for service, conducting facility
inspections and performing other field activities.
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At a minimum of once during each five (5) year Permit term, CMSWS provides training to
appropriate municipal staff, who, as part of their normal job responsibilities, may come into
contact with or otherwise observe an illicit discharge or illicit connection to the storm sewer
system. This training informs staff of the threat to the environment from these discharges and
the proper reporting process as well as the requirements of the Stormwater Pollution Control
Ordinances. By September 30, 2015, field staff in the following Mecklenburg County programs
completed this training: Air Quality, Code Enforcement, Solid Waste, Environmental Health,
Social Services, Parks and Recreation, and the Sheriff’s Office. The following employees at the
Towns, CPCC and CMS also completed this training: maintenance workers, firefighters,
policemen, public works and utility workers, and parks and recreation. This satisfied the IDDE
municipal staff training requirement for the Permit term ending November 10, 2016. The second
round of training will be completed prior to end of the next Permit term on February 16, 2022.
7.9 Decision Process
The IDDE Program for the Mecklenburg County Phase II jurisdictions/entities rely primarily on
public involvement and par ticipation as well as data collected through water quality monitoring
activities and field investigations to identify priority areas for illicit discharges. Standardized
follow up field screening activities are employed in these identified priority areas to confirm
pollution sources, which are eliminated through the enforcement of the local Stormwater
Pollution Control Ordinances. The decision process followed in the development of this
approach included an examination of techniques used successfully in the past by CMSWS for the
identification and elimination of pollution sources as part of the City of Charlotte’s Phase I
Program. Public involvement has always played a key role in the identification of problem
areas. The outreach campaign included as part of the program is designed to increase public
awareness of water quality issues and inform them of the correct process for reporting suspected
pollution problems.
CMSWS water quality monitoring activities have been performed in the Phase II jurisdictions for
over 25 years and they have proven successful at identifying water quality problem areas. This
ongoing monitoring effort was expanded for the Phase II Permit. This expanded monitoring
program includes the use of continuous automated water quality monitoring equipment. Water
quality monitoring data is summarized using the Stream Use Support Index or SUSI at least
quarterly and is used by CMSWS staff to target/direct pollution control activities.
Another tool that has proven effective in the implementation of Charlotte’s Phase I Program and
thus has been applied in the Phase II Program areas is the enforcement of local Stormwater
Pollution Control Ordinances. CMSWS has found these ordinances to be an effective tool for
the elimination of pollution sources and also for deterring future violations.
The storm sewer mapping effort has assisted in the implementation of the IDDE Program by
providing a thorough examination of the inlets and outlets to the MS4s as well as identifying dry
weather flows, both of which have led to the elimination of pollution sources. The availability of
storm sewer maps and other data in GIS through the Cityworks database has facilitated the
tracking of discharges to their source.
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The selection of CMSWS staff for the execution of the measurable goals associated with the
IDDE Program was based on their familiarity with the identification and elimination of pollution
problems as well as their expertise in the enforcement of pollution control ordinances. The
selection of the Senior Environmental Specialist to implement the Public Outreach component of
the program was based on that positions experience and expertise at the development and
implementation of media campaigns and other public outreach and community involvement
efforts.
7.10 Program Evaluation
The measurable goals for each BMP are described in Table 18. The overall success of the IDDE
Program is evaluated through the successful achievement of these measurable goals as reported
with each NPDES MS4 annual assessment report. At a minimum, the following metrics are
included in this annual report:
• Number of inlets and outlets identified.
• Types of water quality monitoring performed, and summary of criteria exceeded.
• Number of field screenings completed for non-stormwater flows.
• Number of illicit discharges detected and eliminated.
Other measures of success for the IDDE Program are described below.
• Documentation of Stormwater Program Activities – As a baseline measure of success,
staff will document the completion of Work Plan activities that demonstrate the
successful fulfillment of the BMPs associated with this program element. All activities
will be documented in CMSWS’s Cityworks database.
• Increasing Pollution Problems Identified – CMSWS will track the ratio of the number of
notices of violation issued to the number of IDDE inspections conducted with an increase
from the previous fiscal year serving as an indicator of the success of our efforts to find
and eliminate pollution sources.
• Repeat Violators Minimized (added in FY2021) – CMSWS will track the percentage of
written Notices of Violation issued to repeat violators compared to the average of the
percentages for the past three (3) fiscal years with a percentage equal to or less than this
average serving as an indicator of success.
On an annual basis, CMSWS staff will evaluate the BMPs assigned to this program and assess
progress toward achieving the measurable goals from Table 18 and the measures of success
described above. Recommendations for improvement will be made as necessary. During the
following fiscal year, program activities and BMPs will be modified as necessary based on the
results of this evaluation in order to ensure that the specific goals and objectives of the IDDE
Program and SWMP are being effectively and efficiently fulfilled.
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SECTION 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
Construction Site Runoff Control Programs have been developed and are currently being
implemented for addressing the discharge of sediment and other pollutants from construction
sites in Mecklenburg County ’s Phase II jurisdictions that disturb one or more acres of land
surface and those activities less than one acre that are part of a larger common plan of
development as authorized under the Sediment Pollution Control Act of 1973. These are
delegated programs under NCGS 113A-60. CMSWS’s Permitting and Compliance Program
administers the program for the County and Towns of Davidson, Cornelius, Matthews, Mint Hill,
and Pineville. In November 2019, the Town of Huntersville received delegated authority from
the State to administer a local erosion control program in their jurisdiction. The Town of
Huntersville coordinates with the County in the completion of the activities associated with the
Construction Site Erosion Control Program described in this Section. Kevin Fox, Public Works
Director, serves as the responsible party for compliance with the Permit requirements for the
Construction Site Storm Water Runoff Control Program in the Town of Huntersville. His
contact information is as follows: 704-766-2220 and kfox@huntersville.org.
8.1 Program Goals and Objectives
CMSWS’s establishes its goals and objectives for its Construction Site Runoff Control Program,
which are evaluated and updated annually as necessary, based on the actions necessary to
effectively address the targeted pollutants and pollutant sources identified in Table 8. The
current goal of the Construction Site Runoff Control Program is to reduce pollutants in
stormwater runoff from construction activities that result in a land disturbance of greater than or
equal to one acre. Construction activities disturbing less than one acre are included in the
program if they are part of a larger common plan of development or sale that would disturb one
acre or more. The current objectives of the program are as follows:
1. Implement and enforce a program to ensure the proper permitting, installation and
maintenance of erosion control measures in compliance with local ordinances as well as
the N.C. Sediment Pollution Control Act of 1973 and Chapter 4 of Title 15A of the North
Carolina Administrative Code.
2. Ensure the proper control of waste at construction sites to prevent illicit discharges and
negative impacts to surface water quality, including but not limited to discarded building
materials, concrete truck washout, chemicals, litter, and sanitary waste.
3. Provide and promote a means for the public to notify the Permitting and Compliance
Program of observed erosion and sedimentation problems.
4. Educate contractors, developers and others engaged in land disturbing activities in the
proper methods for installing and maintaining erosion control measures and preventing
pollutants from discharging from construction sites.
8.2 BMP Summary Table
Table 19 describes the BMPs implemented as part of the Construction Site Runoff Control
Program.
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Table 19: BMP Summary Table for the Construction Site Stormwater Control Program
Permit
Ref.
Construction Site Runoff Control Program (Part II Section E.1; Part II Section A.4, 5 and 7): Enforce erosion and
sedimentation control ordinances by permitting and controlling development activities disturbing one or more acres of land
surface and those activities less than one acre that a re part of a larger common plan of development as authorized under the
Sediment Pollution Control Act of 1973.
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
#29 CS-1
(SOPs
contained
in the
Erosion
Control
Policy &
Procedure
Manual)
Enforce Erosion Control Ordinances
Enforce erosion
and
sedimentation
control
ordinances by
permitting and
controlling
development
activities
disturbing one
or more acres of
land surface and
those activities
less than one
acre that are
part of a larger
common plan of
development.
a. Review and revise Erosion
Control Policy and Procedure
Manual and train staff as
necessary.
a. Annually
beginning July
1
a. Completion
status
Huntersville
administers its
own Erosion
Control Program.
County
administers a
program for the
other Towns. All
co-permittees
ensure compliance
at their
construction sites.
b. Conduct inspections and
document the date(s)
violations are observed, the
results of investigations, and
follow up actions conducted
for compliance.
b. Annually
beginning July
1
b. Completion
status; #
inspections
c. Prepare and issue NOVs and
initiate enforcement actions
in accordance with SOPs.
Follow up to ensure
compliance. Document dates,
locations, names, nature of
the violations, and final
resolution. Track NOVs for
identifying chronic violators.
c. Annually
beginning July
1
c. Completion
status; #
NOVs; #
enforcements
d. Complete annual report
detailing activities completed
and summarizing findings.
Include in report for PD-1.
d. Annually
beginning
July 1
d. Completion
status
#30 CS-2
(Erosion
Education)
Erosion Control Education
Develop and
implement an
outreach
program to
educate
contractors and
land developers
regarding
proper erosion
control.
a. Distribute educational
materials prior to or when
conducting pre-construction
meetings and during
inspection activities as
necessary.
a. Annually
beginning
July 1
a. Completion
status
Participate in
training as
requested by
CMSWS.
b. Implement and
update/enhance as necessary
the Charlotte-Mecklenburg
Certified Site Inspector
(CMCSI) Training Program
(program has gone virtual
during the pandemic).
b. Annually
beginning
July 1
b. Completion
status; #
trained
c. Complete annual report
detailing activities completed
and summarizing findings.
Include in report for PD-1.
c. Annually
beginning
July 1
c. Completion
status
#31 CS-3
(Evaluate
Erosion
Evaluate Effectiveness of the Erosion Control Program
Evaluate
effectiveness of
a. Measure program success
using established criteria.
a. Annually
beginning
a. Completion
status; criteria
Huntersville
provides
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78
Permit
Ref.
Construction Site Runoff Control Program (Part II Section E.1; Part II Section A.4, 5 and 7): Enforce erosion and
sedimentation control ordinances by permitting and controlling development activities disturbing one or more acres of land
surface and those activities less than one acre that a re part of a larger common plan of development as authorized under the
Sediment Pollution Control Act of 1973.
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
Control) the Erosion
Control
Program.
July 1 measure information for
inclusion in
annual assessment
and report.
b. Recommend improvements as
necessary. Include
recommendations in report
for PD-1.
b. Annually
beginning
July 1
b. Completion
status
c. Implement improvements in
the next fiscal year.
c. Annually
beginning
July 1
c. Completion
status
8.3 Erosion Control Ordinance
Mecklenburg County has a delegated Sediment and Erosion Control Program and is therefore
responsible for compliance with the Sediment Pollution Control Act of 1973 and Chapter 4 of
Title 15A of the North Carolina Administrative Code. The delegated Sediment and Erosion
Control Program effectively meets the MEP standard for Construction Site Runoff Controls by
permitting and controlling development activities disturbing one or more acres of land surface
and those activities less than one acre that are part of a larger common plan of development as
authorized under the Sediment Pollution Control Act of 1973 and Chapter 4 of Title 15A of the
North Carolina Administrative Code. The regulatory mechanism established for this program is
the Mecklenburg County Soil Erosion and Sedimentation Control Ordinance effective October
21, 1974 and amended 14 times as follows: March 5, 1979, June 16, 1980, April 2, 1984,
October 7, 1985, February 27, 1986, April 21, 1987, December 7, 1987, February 4, 1991, May
10, 1993, February 7, 1995, June 3, 1997, September 6, 2000, May 21, 2002, and October 7,
2008. The County’s ordinance is currently enforced by the Permitting and Compliance Program
in the Towns of Cornelius, Pineville and Matthews. The Towns of Davidson and Mint Hill have
their own sediment and erosion control ordinances, which are very similar to Mecklenburg
County’s and are also enforced by the Permitting and Compliance Program. The Town of
Huntersville has a similar ordinance that it enforces. These ordinances require an approved
Erosion Control Plan for construction activities that result in the disturbance of greater than or
equal to one acre of land. The ordinances further require that all construction site operators
implement appropriate erosion and sediment control BMPs, including those sites that disturb less
than an acre. Copies of the ordinances are available at the following website:
http://stormwater.charmeck.org (select “Regulations”, select jurisdiction, select “Soil Erosion
and Sedimentation Control”). The Mecklenburg County Soil Erosion and Sedimentation Control
Policies and Procedures describe how ordinances are enforced and the local program is
implemented, including inspection procedures, record keeping requirements, form letters for
notices of violation, and enforcement guidance. A copy of these policies and procedures is
available upon request to the Environmental Manager for Mecklenburg County’s Water Quality
Program. The Surface Water Pollution Control Ordinances (see Section 7.5) are used to regulate
pollutants other than sediment that are generated from construction sites and have the potential to
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79
negatively impact water quality such as discarded building material, concrete truck washout,
chemicals, litter, and sanitary waste. Staff inspecting for compliance with soil erosion and
sediment control ordinance also inspect for compliance with the pollution control ordinance.
8.4 Erosion Control Plan Reviews
Section 6(b) of the erosion control ordinances requires an approved Erosion Control Plan for
construction activities that result in the disturbance of greater than or equal to one acre of land.
Erosion control inspectors conduct a site plan review and on-site inspection prior to plan
approval. Section 10 of the ordinance specifies the content of the plan, which includes all BMPs
planned for the control of erosion and sedimentation. Staff with CMSWS’s Permitting and
Compliance Program reviews all Erosion Control Plans for the Phase II jurisdictions in
Mecklenburg County, except for in the Town of Huntersville where their staff performs these
reviews and government projects which are reviewed by NCDEQ staff. Reviews are typically
completed within 30 days of submittal and the person submitting the plan is notified as to
whether the plan is approved, approved with modifications, approved with performance
reservations, or disapproved. The applicant has the right to appeal the disapproval before the
Charlotte-Me cklenburg Stormwater Advisory Committee. Plan approval is considered void if
land disturbing activities do not commence within three (3) years of the approval date. The
Mecklenburg County Soil Erosion and Sedimentation Control Policies and Procedures describe
the process for site plan review, which incorporates consideration of potential water quality
impacts.
8.5 Enforcement
Section 13 of the Mecklenburg County Soil Erosion and Sedimentation Control
Ordinance specifies that any person who violates any of the provisions of the ordinance is
subject to a civil penalty in an amount not to exceed $5,000 per day for each day the violation
continues. The Permitting and Compliance Program has established guidance in its policies and
procedures for setting penalty amounts for different types of violations. The Stormwater
Advisory Committee (SWAC) hears appeals to enforcement actions. The Mecklenburg County
Soil Erosion and Sedimentation Control Policies and Procedures describe the enforcement
process, including procedures for issuing notices of violation, assessing penalties and handling
appeals.
8.6 Inspections
All erosion and sedimentation control inspections in the Phase II jurisdictions are performed by
staff of the Permitting and Compliance Program, except for in the Town of Huntersville where
their staff performs these inspections and government projects which are inspected by NCDEQ
staff. Following plan approval and issuance of the NPDES Permit (NCG010000), but prior to
initiating land disturbing activities and issuance of a local grading permit, staff conducts a pre-
construction meeting involving all parties associated with the land disturbing activity to ensure
that everyone is familiar with the approved Erosion Control Plan and ordinance requirements.
The construction site is evaluated during this pre-construction meeting and a checklist
completed. Following the pre-construction meeting, erosion control measures are installed by
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80
the contractor after which the Permitting and Compliance Program conducts an inspection to
confirm pr oper installation in accordance with the approved Erosion Control Plan and ordinance
requirements. Following this confirmation, the inspector issues a local grading permit
authorizing grading of the site. Once grading activities commence, staff perform compliance
inspections on a routine interval based on an established prioritization scheme. If inspections
reveal noncompliance with the approved Plan or other ordinance violations, a written or verbal
notice of violation is issued identifying the violation(s) and specifying the specific action(s)
needed to ensure compliance. Follow up inspections are conducted to verify compliance after
which penalties may be assessed depending on the nature of the violation and effectiveness of
the response. The Mecklenburg County Soil Erosion and Sedimentation Control Policies and
Procedures describe the inspection process and include inspection logs and checklists.
8.7 Erosion Control Hotline
Mecklenburg County provides a means for the public to notify the Permitting and Compliance
Program of observed erosion and sedimentation control problems in the Phase II jurisdictions
through contacting the 311 helpline as described in Section 5.3. This reporting mechanism is
promoted through the media campaign conducted as part of the Public Education and Outreach
Program. Staff conducts follow up investigations on reported problems and initiates the actions
necessary to ensure proper erosion and sedimentation control and the protection of water quality.
8.8 Erosion Control Education
The Permitting and Compliance Program with CMSWS provides erosion control education
through its “Charlotte Mecklenburg Certified Site Inspector” (CMCSI) course, which includes
six (6) hours of training on proper erosion and sedimentation control and a written test. Courses
are held a minimum of twice a year. Section 8(f) of the Soil Erosion and Sedimentation Control
Ordinances for Mecklenburg County and the Towns of Huntersville, Davidson and Mint Hill
requires that persons conducting land-disturbing activity or their agent perform inspections of all
erosion and sedimentation control measures at least once a week and within 24 hours after any
storm event of greater than 0.5 inch of rain per 24-hour period. Local policies and procedures
state that the person performing these inspections must be certified and technically competent
and that a self-inspection log must be maintained. Satisfactorily completing the CMCSI training
qualifies a person to perform these activities.
8.9 Government Projects
All government projects within the Phase II jurisdictions are regulated by NCDEQ’s Erosion and
Sediment Control Program, which conducts plan reviews, inspections and enforcement activities.
This includes construction activities performed directly by the Phase II entity or by a company
under contract with the entity.
8.10 Decision Process
Construction site pollutants have been successfully controlled in the Phase II jurisdictions
through a locally delegated program for almost 40 years. The Phase II jurisdictions have elected
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81
to continue their reliance on this local program due to its past successes and the improvements
recently brought about through program modifications.
8.11 Program Evaluation
The measurable goals for each BMP are described in Table 19. The overall success of the
Construction Site Runoff Control Program is evaluated through the successful achievement of
these measurable goals as reported with each NPDES MS4 annual assessment report. At a
minimum, the following metrics are included in this annual report:
• Number of new projects permitted.
• Number of acres disturbed.
• Number of erosion control inspections conducted.
• Number of notices of violation issued.
• Number of penalties assessed.
• Description of educational activities completed.
Other measures of success for the Construction Site Runoff Control Program are described
below.
• Documentation of Stormwater Program Activities: As a baseline measure of success,
staff will document completion of Work Plan program activities annually that
demonstrate successful fulfillment of BMPs associated with this program element. All
activities will be documented within CMSWS’s Cityworks database.
• Improving Compliance: CMSWS will track the ratio of the number of notices of
violation issued to erosion control inspections conducted with a decrease from the
previous fiscal year serving as an indicator of success.
On an annual basis, the Permitting and Compliance Program will evaluate the BMPs assigned to
this program and assess progress toward achieving the measurable goals from Table 19 and the
measures of success described above. Recommendations for improvement will be made as
necessary. During the following fiscal year, program activities and BMPs will be modified as
necessary based on the results of this evaluation in order to ensure that the specific goals and
objectives of the Construction Site Runoff Control Program and SWMP are being effectively and
efficiently fulfilled.
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82
SECTION 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
A Post-Construction Site Runoff Control Program has been developed and is currently being
implemented for addressing post-construction stormwater runoff from new development and
redevelopment projects in Mecklenburg County’s Phase II jurisdictions. The program is
administered by CMSWS’s Water Quality and Permitting and Compliance Programs as
described in the following Sections except for in the Town of Huntersville and its ETJ where
effective July 1, 2020 Town staff are responsible for plan reviews and issuing land development
Permits as well as conducting inspections to confirm project completion in compliance with
Permit requirements. Kevin Fox, Public Works Director, serves as the responsible party for
compliance with the Permit requirements for the Post-Construction Site Runoff Control Program
in the Town of Huntersville. His contact information is as follows: 704-766-2220 and
kfox@huntersville.org.
9.1 Program Goals and Objectives
CMSWS’s establishes its goals and objectives for its Post-Construction Site Runoff Control
Program, which are evaluated and updated annually as necessary, based on the actions necessary
to effectively address the targeted pollutants and pollutant sources identified in Table 8. The
current goal of the Post-Construction Site Runoff Control Program is to prevent or minimize
negative water quality impacts during post-construction conditions at new developments and
redevelopments, including public transportation maintained by the permittee. The current
objectives of the program are as follows:
1. Implement and enfor ce a program to address stormwater runoff from new development
and redevelopment projects, including public transportation maintained by the permittee,
that disturb greater than or equal to one (1) acre, including projects disturbing less than
one (1) acre that discharge to the storm sewer system.
2. Implement strategies which include a combination of structural and/or non-structural
BMPs appropriate for the community.
3. Use an ordinance or other regulatory mechanism to address post-construction runoff from
new development and redevelopment projects.
4. Ensure adequate long-term operation and maintenance of BMPs. Achievement of this
objective will be measured by a reduction in the number of noncompliant BMPs over
time (see Section 9.13).
9.2 BMP Summary Table
Table 20 describes the BMPs implemented as part of the Post-Construction Site Runoff Control
Program.
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83
Table 20: BMP Summary Table for the Post-Construction Site Runoff Control Program.
Permit
Ref.
Post-Construction Site Runoff Control Program (Part II Section F a through i; Part II Section A.4, 5 and 7; Part II Section G.2.g):
Implement and enforce a program to address storm water runoff from new development and redevelopment projects, including
public transportation maintained by the permittee, that disturb greater than or equal to one acre, including projects less than one acre
that are part of a larger common plan of development or sale, that discharge into the small MS4.
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
#32 PC-1 (PCO
Admin)
Implement Post-Construction Ordinances
Develop,
implement and
enforce
ordinances that
will minimize
negative water
quality impacts
to surface
waters from
post-
construction
discharges in
accordance with
local and State
regulations.
a. Complete an annual review of
the post-construction ordinances
and the Administrative Manual.
Document any suggested
changes/updates and follow
through for implementation
a. Annually
beginning July
1
a. Completion
status
CMSWS serves as
the Storm Water
Administrator for all
Post-Construction
Ordinance except
for Cornelius where
their Zoning
Administrator
fulfills this role
working with
CMSWS.
b. Provide interpretations of
ordinance requirements as
requested by staff and the
general public. Maintain a log of
all interpretations of the
ordinances and a log of all
changes to the Administrative
and Design Manual.
b. Annually
beginning July
1
b. Completion
status; #
interpretations
c. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
c. Annually
beginning July
1
c. Completion
status
#33 PC-2 (PCO
inspections)
Post-Construction Ordinance Inspections
Conduct site
inspections of
stormwater
controls
installed for
compliance
with ordinance
requirements.
a. Update/revise the SCM Inspection
Manual and train staff as
necessary.
a. Annually
beginning July 1
a. Completion
status
Huntersville reviews
plans, issues permits,
and conducts
inspections during
construction.
CMSWS reviews
plans, issues permits,
and conducts
inspections during
construction for the
other Towns.
Following
construction,
CMSWS administers
an inspection
program for both
public and private
SCMs in
Huntersville as well
as the other Towns.
All co-permittees
ensure compliance
for the SCMs that
they own/maintain.
b. Review and approve site plans
and issue permits for compliance
with ordinance requirements.
Ensure mechanisms are in place
for long-term maintenance of the
project, including SCMs,
consistent with approved plans
and permit requirements. Conduct
inspections during construction to
ensure compliance.
b. Annually
beginning July 1
b. Completion
status
c. Conduct annual inspections of
SCMs owned by co-permittees
following construction except for
County owned SCMs that are
inspected and maintained by the
controlling County agency.
Require annual inspections of
private SCMs. Document the
date(s) deficiencies are observed,
the results of investigations, and
follow up actions conducted.
c. Annually
beginning July 1
c. Completion
status; #
inspections
d. Prepare and issue inspection d. Annually d. Completion
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Permit
Ref.
Post-Construction Site Runoff Control Program (Part II Section F a through i; Part II Section A.4, 5 and 7; Part II Section G.2.g):
Implement and enforce a program to address storm water runoff from new development and redevelopment projects, including
public transportation maintained by the permittee, that disturb greater than or equal to one acre, including projects less than one acre
that are part of a larger common plan of development or sale, that discharge into the small MS4.
BMP
No.
County
Work Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
reports and notices of
deficiencies. Track for identifying
chronic maintenance problems.
beginning July 1 status; #
deficiencies
e. Maintain an inventory of public
and private SCMs installed for
compliance with post-construction
ordinances.
e. Annually
beginning July 1
e. Completion
status
f. Verify that Operation &
Maintenance (O&M) Plans have
been established and recorded for
SCMs at the time of plan
approval, including municipally
owned and maintained SCMs.
f. Annually
beginning July 1
f. Completion
status
g. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
g. Annually
beginning July 1
g. Completion
status
#34 PC-3 (PCO
education)
Post-Construction Ordinance Education
Implement a
program to
educate the
development
community and
the general
public
concerning the
post-
construction
requirements.
a. Work with Charlotte Storm Water
Services to develop a post-
construction ordinance training
event for the development
community.
a. Annually
beginning July 1
a. Completion
status
Participate in
training as requested
by CMSWS.
b. Conduct training event. b. Annually
beginning July 1
b. Completion
status; #
trained
c. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
c. Annually
beginning July 1
c. Completion
status
#35 PC-5
(Evaluate
PCO)
Evaluate Effectiveness of the Post-Construction Controls Program
Evaluate
effectiveness of
the Post-
Construction
Controls
Program.
a. Measure program success using
established criteria.
a. Annually
beginning July 1
a. Completion
status;
criteria
measure
Huntersville
provides information
for inclusion in
annual assessment
and report. b. Recommend improvements as
necessary. Include
recommendations for report in
PD-1.
b. Annually
beginning July 1
b. Completion
status
c. Implement improvements in the
next fiscal year.
c. Annually
beginning July 1
c. Completion
status
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9.3 Post-Construction Stormwater Ordinances
The post-construction stormwater ordinances developed by the Phase II jurisdictions were
reviewed and approved by the State and subsequently adopted effective June 30, 2007. These
regulations meet or exceed the minimum requirements for the control of post-construction
stormwater runoff specified by 40 Code of Federal Regulations 122.34(b)(5) (1 July 2003
Edition). These regulations meet the objectives of the Post-Construction Site Runoff Control
Program and provide the authority to:
1. Review designs and proposals for new development and redevelopment to determine
whether adequate stormwater control measures will be installed, implemented, and
maintained.
2. Request information such as SWMPs, inspection reports, monitoring results, and other
information deemed necessary to evaluate compliance with the Post-Construction
Stormwater Management Program.
3. Enter private property for the purpose of inspecting at reasonable times any facilities,
equipment, practices, or operations related to stormwater discharges to determine whether
there is compliance the Post-Construction Site Runoff Control Program.
Administrative and BMP Manuals have been developed and are being maintained by CMSWS to
guide the implementation and enforcement of ordinance requirements. The Administrative
Manual includes application requirements, forms, submission schedules, fee schedules,
maintenance plans and agreements, criteria for mitigation approval, criteria for recordation of
documents, inspection report forms, requirements for submittal of bonds, and other information
and forms used in the administration of the post-construction ordinances. The BMP Manual
includes the designs for structural stormwater controls as well as methods for calculating built-
upon area and other information used in the construction of BMPs required by the ordinances.
Copies of the ordinances as well as the Administrative and Design Manuals, design standards
checklist, and other materials appropriate for developers are available at the following website:
http://stormwater.charmeck.org (select “Regulations”, select jurisdiction).
CMSWS’s Environmental Manager for the Water Quality Program serves as the Stormwater
Administrator responsible for the implementation and enforcement of the post-construction
ordinances for the Towns and County except for the Town of Cornelius, which uses its Planning
Director to fulfill this role. All appeals and variances are heard by the Charlotte-Mecklenburg
Stormwater Advisory Committee (SWAC) very similar to the process used for the Sediment and
Erosion Control Program described in Section 8. The only exceptions are that the Towns of
Cornelius and Huntersville use their Boards of Adjustment to hear all appeals and variances.
Implementation of the post-construction ordinances consists of the following activities:
1. Maintaining and updating the ordinances as necessary.
2. Providing interpretations regarding the applicability of ordinance requirements to new
developments and redevelopments.
3. Maintaining and updating the Charlotte-Mecklenburg BMP Design Manual as necessary.
4. Maintaining and updating the Administrative Manual as necessary.
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5. Performing site plan reviews of all new development and redevelopment projects that
disturb greater than or equal to one acre (including sites that disturb less than one acre
that are part of a larger common plan of development or sale) and performing reviews
on new development and redevelopment that disturb less than an acre as required by
specific ordinance requirements. The site plan review addresses how the project meets
the performance standards and how the project will ensure long-term maintenance.
6. Conducting site inspections during construction to ensure compliance with approved
plans and all ordinance requirements.
7. Conducting a post-construction inspection before issuing a certificate of occupancy to
verify that performance standards have been met or a bond is in place to guarantee
completion.
8. Inspection findings and enforcement actions will be documented, and records maintained.
Notices of violation and enforcement actions will be tracked, and a reporting mechanism
established to identify chronic violators for initiation of actions to reduce noncompliance.
9. Maintaining an inventory of public and private projects with structural stormwater
control measures installed for compliance with post-construction ordinance requirements.
10. Ensuring that mechanisms are in place to guarantee that projects will be maintained
consistent with approved plans in compliance with ordinance requirements.
11. Ensuring the implementation of long-term oper ation and maintenance plans for structural
BMPs in accordance with ordinance requirements, including ensuring that the owner of
each structural BMP has a qualified professional perform annual inspections and
maintains records of these inspections.
12. Conducting site inspections of structural stormwater controls installed for compliance
with ordinance requirements at least once during the Permit term. Records of inspection
findings and enforcement actions are maintained in the Cityworks database. Notices of
violation and enforcement actions are tracked and used to identify chronic violators for
initiation of actions to reduce noncompliance.
13. Implementing a program to educate the development community and the general public
concerning the post-construction stormwater management requirements. Ordinances,
post-construction requirements, design standards checklist, and other materials
appropriate for developers are made available through paper or electronic means.
9.4 Compliance by Co-Permittees with Post-Construction Ordinance Requirements
New developments constructed by or under contract with the Phase II entities are required to
comply with the local post-construction ordinance requirements adopted by the jurisdiction
where the project is located, including the City of Charlotte, Mecklenburg County, and the
Towns of Cornelius, Davidson, Huntersville, Matthews, Mint Hill, and Pineville. New roads and
road expansions interior to land development projects required to comply with post-construction
requirements must adhere to these same requirements regardless of whether these roads will be
privately maintained or maintained by the jurisdiction. For such projects, the built-upon area for
the roads is incorporated into the built-upon area for the project and BMPs are installed as
necessary to comply with ordinance requirements. There are a few exceptions to compliance
with local post-construction requirements for other types of transportation projects as described
in Appendix C.
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CMSWS maintains a current inventory of the structural SCMs owned and/or operated by the
Phase II jurisdictions/entities that were installed for compliance with Post-Construction
Ordinances. This inventory is available upon request to the Storm Water Administrator. The
Phase II jurisdictions/entities maintain and implement O&M Plans for these SCMs, which
specify the frequency of inspections and routine maintenance requirements. The Phase II
jurisdictions/entities inspect and maintain their SCMs in accordance with the schedule contained
in the O&M Plan. Plans vary based on SCM type. Sample O&M Plans are available upon
request. To ensure that all structural SCMs are being maintained pursuant to their O&M Plan, all
co-permittees conduct annual inspections of the SCMs that they own and/or operate using a
qualified professional. A qualified professional is either a qualified NC professional engineer or
registered landscape architect performing services only in their area of competence, or someone
who has a valid Stormwater SCM Inspection & Maintenance Certification from NC State
University. All inspections of SCMs are documented on an inspection form and submitted to the
Storm Water Administrator for review and follow up as necessary. These forms are available at
the following link:
https://mecklenburgcounty.exavault.com/p/waterquality/PCO%20Forms/BMP_Maintenance_Ins
pection_Checklists_PCO21/. For Charlotte-Mecklenburg Schools, Central Piedmont
Community College, and the Towns, these inspections are performed by CMSWS staff.
Inspections of County owned facilities are the responsibility of the Department that manages the
facility where the SCM is located, including Asset and Facility Management, Park and
Recreation and the Sheriff’s Department.
9.5 Requirements for Non-Structural BMPs
The post-construction ordinances include stream buffer and undisturbed open space requirements
as summarized in Table 21, which serve as non-structural BMPs. Prior to the adoption of the
post-construction ordinances, non-structural stormwater controls were in effect in the Phase II
jurisdictions that continue to apply, including zoning ordinances to direct growth to identified
areas. In addition, Mecklenburg County’s Park and Recreation Department actively acquires and
maintains open space for parks and nature preserves. This program concentrates on preserving
environmentally sensitive and natural resource areas within the County, including wetlands and
riparian buffers.
Table 21: Non-Structural BMPs Required by Post-Construction Ordinances
Jurisdiction
Post-
Construction
Ordinance
Watershed
District
Undisturbed
Open Space
Requirements
Based on Project
Area
<24% BUA =
25%; >24% BUA
= 17.5%; >50%
BUA = 10%
Buffer Widths
Streams
draining <50
acres = 30 ft.;
>50 acres = 35
ft.; >300 acres
= 50 ft.: >640
acres = 100 ft.
+ floodplain
Streams
draining <50
acres = 50 ft.;
>50 acres = 100
ft. for all
intermittent &
perennial
streams
200-ft on perennial
and intermittent
streams inside
FEMA floodplain;
100 ft. on all other
perennial and
intermittent streams
Cornelius N/A N/A X
Davidson Catawba X X
Yadkin X X (3 zone buffer)
Huntersville N/A N/A X
Matthews Catawba X X
Yadkin X X(3)
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Mint Hill
Catawba (1) X
Yadkin (1) X
Goose Cr. (1) X (undisturbed)
Pineville N/A X (2)
Mecklenburg N/A X (2)
(1) <20% BUA = no undisturbed open space is required; >20% BUA = 15%; >50% = 10%
(2) Streams draining <100 acres = 30 ft; >100 acres = 35 ft.; >300 acres = 50 ft.; >640 acres = 100 ft + 50% of
floodfringe.
(3) Buffer also includes 100% of the floodplain and is undisturbed.
Since 1999, buffers ranging in width from 35 feet to the entire FEMA floodplain have been
required along per ennial streams in the Phase II jurisdictions. These buffer requirements were
implemented as part of Mecklenburg County’s Surface Water Improvement and Management
(S.W.I.M.) Program. The northern Towns of Cornelius, Davidson and Huntersville have
portions of their jurisdictions in WS-IV watersheds and have maintained water supply watershed
rules in their zoning ordinances since the mid-1990s. These rules require buffers ranging from
50 to 100 feet in width along the lake shoreline as well as along perennial streams delineated on
USGS quadrangle maps.
9.6 Requirements for Structural BMPs
The post-construction ordinances adopted on June 30, 2007 by the Phase II jurisdictions contain
requirements for the installation of structural BMPs to control and treat stormwater runoff to
meet specific volume, peak and water quality requirements when a built-upon area threshold is
reached. These BMPs must meet the design criteria contained in the Charlotte-Mecklenburg
BMP Design Manual. This manual includes design criteria for the following types of BMPs:
bioretention, wet pond, stormwater wetland, enhanced grass swale, grass channel, infiltration
trench, filter strip/woody buffer strip, sand filter, extended dry detention, and proprietary BMPs.
The design volume of the BMPs takes into account the runoff at build out for on-site
improvements and the maximum low-density option for off-site areas from all surfaces draining
to the structure. BMPs are sized to treat and control stormwater runoff from all surfaces draining
to the structure, including streets, driveways, and other built-upon area. Table 22 provides a
general summary of the structural BMP requirements.
Table 22: Structural BMPs Contained in the Post-Construction Ordinances
Jurisdiction
Post-
Construction
Ordinance
Watershed
District
Treatment
Threshold
(BUA)
Treatment Type Treatment Volume
85%
TSS
Removal
70% TP
Removal LID
Runoff
from
1st inch
of
rainfall
Runoff from pre
minus post
development for
1-yr, 24-hr storm
Cornelius N/A >24% X Optional X
Davidson Catawba >12% X X Optional X
Yadkin >10% X X Optional X
Huntersville N/A >12% Required (2) X
Matthews Catawba >24% X Optional X
Yadkin >10% X X Optional X
Mint Hill
Catawba >24% X Optional X
Yadkin >12% X Optional X
Goose Cr. None (1 ) X Required (3) X
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Jurisdiction
Post-
Construction
Ordinance
Watershed
District
Treatment
Threshold
(BUA)
Treatment Type Treatment Volume
85%
TSS
Removal
70% TP
Removal LID
Runoff
from
1st inch
of
rainfall
Runoff from pre
minus post
development for
1-yr, 24-hr storm
Pineville N/A >24% X Optional X
Mecklenburg N/A >24% X Optional X
(1) Treatment required for all built-upon area.
(2) A combination of LID and conventional stormwater treatment measures is allowed in the form of a treatment
train.
(3) Water quality treatment systems that promote the infiltration of flows and groundwater recharge (LID) shall be
used unless it can be demonstrated that such treatment systems are not a practical alternative for the site.
Prior to the adoption of the post-construction stormwater ordinances, the installation of structural
stormwater controls was required for developments and redevelopments located in the WS-IV
watersheds in the Towns of Davidson, Cornelius and Huntersville. In addition, beginning on
July 2, 1979 the Phase II jurisdictions required the submission and approval of a drainage plan
for land development activities that involved the cumulative creation of more than 20,000 square
feet of impervious ground cover. This requirement is typically applied to commercial
development but could be applied to residential development at the election of the Town. If the
impervious cover proposed in the plan increased the peak level of stormwater runoff from the
site, then the plan was required to identify measures to control and limit runoff to peak flows no
greater than would occur from the site if impervious area were not increased for the 2-year and
10-year storm events. BMPs installed for compliance with the WS-IV watershed ordinances and
those BMPs installed for the July 2, 1979 drainage plan requirements are not subject to the post-
construction ordinance requirements for inspection and maintenance.
9.7 Natural Resource Protection
The Division of Nature Preserves and Natural Resources within the Mecklenburg County Park
and Recreation Department is responsible for the protection and conservation of Mecklenburg
County's parks designated as Nature Preserves. Mecklenburg County’s nature preserves protect
the county's biological resources and natural areas, while providing opportunities for
environmental education, nature-based programs, and outdoor recreation. The Division of
Nature Preserves and Natural Resources offers more than 5,000 programs annually, performs
natural resource management on over 7,400 acres, maintains more than 30 miles of nature
trails, and operates 3 nature centers and a public campground.
9.8 Open Space Protection
As described in Section 9.5 above, the post-construction ordinances for Mecklenburg County and
the Towns of Davidson, Matthews, Mint Hill, and Pineville require open space preservation
based on project area as described in Table 21. Failure to adequately protect these open space
areas constitutes a violation of the ordinance, which is subject to fines. The Towns of Cornelius
and Huntersville have open space requirements as a Section of their land development code, but
these requirements are not enforced as a component of the post-construction ordinance.
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9.9 Tree Preservation
To varying degrees, the Phase II jurisdictions in Mecklenburg County require the planting of
additional trees to enhance the urban tree canopy as well as the protection and maintenance of
trees on public and private property. Street trees are also required. These requirements are
generally contained in Land Development or Zoning Ordinances.
9.10 Green Infrastructure Practices
The post-construction stormwater ordinances adopted by the Phase II jurisdictions contain the
following green infrastructure practices:
1. The use of vegetated conveyances for the transport stormwater to the MEP.
2. The optional use of permeable pavement systems as a structural BMP to help manage
stormwater runoff.
3. The optional use of green roofs as structural BMPs to help manage stormwater runoff.
4. The optional use of consultation meetings early in the development review process to
discuss the post-construction stormwater management measures necessary for the
proposed project, as well as to discuss and assess constraints, opportunities and potential
approaches to stormwater management designs before formal site design engineering is
commenced.
5. The designation of undisturbed open space areas ranging from 25% to 10% of the total
project area based on the jurisdiction (except in Cornelius and Huntersville) (see Table
21).
6. The protection of buffers ranging in width from 30 feet to the entire FEMA floodplain
depending on the watershed area and jurisdiction (see Table 21).
7. The optional use of low impact development techniques except in the Town of
Huntersville and Goose Creek watershed where it is required (see Table 22).
8. The optional use of payment-in-lieu as well as off-site and on-site mitigation to satisfy
post-construction stormwater ordinance requirements in cases where on-site alternatives
are not technically feasible. These options provide money for tree planting, open space
acquisition, installation of off-site BMPs, etc.
Practices are in place to ensure the long-term maintenance of green infrastructure, including
recording the infrastructure on final plats at the Mecklenburg County Register of Deeds Office
and performing periodic inspections.
9.11 Operation and Maintenance
The Phase II jurisdictions have included requirements in their post-construction programs to
ensure the adequate long-term operation and maintenance of structural and non-structural BMPs
as summarized below.
1. A BMP Operation and Maintenance Agreement must be completed and recorded at the
Mecklenburg County Register of Deeds Office for all structural BMPs. A BMP
Maintenance Plan must be included as an addendum to this agreement. This is a binding
legal agreement prepared using the format provided by the Stormwater Administrator that
specifies the responsibilities for performing BMP maintenance and provides a description
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of the maintenance activities to be performed, including a schedule. In addition, the
following language must be included on the final plat for all developments and
redevelopments subject to post-construction ordinance requirements: “This property
contains water quality features that must be maintained according to the Operations and
Maintenance Agreement and Plan recorded in Deed Book____ and Page ______.”
2. As-built plans are required that show the final design specifications for all structural
BMPs and the field location, size, depth, and planted vegetation associated with the BMP
as installed, as well as the location and size of all undisturbed open space areas and tree
plantings. The designer of the stormwater management measures and plans must certify,
under seal, that the as-built stormwater measures, controls, and devices are in compliance
with the approved plans and designs and with the requirements of the post-construction
ordinance.
3. Maintenance and access easements must be established and recorded on the final plat for
all BMPs except those installed for public facilities.
4. The location and dimensions of all BMPs must be included on the final plat recorded at
the Mecklenburg County Register of Deeds Office. The following language must be
included on the final plat: “The purpose of the BMP is to treat/reduce the pollutants
associated with stormwater runoff in order to minimize negative effects to downstream
receiving waters. The easement around the BMP is to allow stormwater conveyance and
system maintenance. The removal of plants or disturbance of the BMP structure or
otherwise affecting the overall functionality of the BMP for reasons other than
maintenance is strictly prohibited.”
5. The location of undisturbed open space must be included on the final plat recorded with
the Mecklenburg County Register of Deeds Office. The following language must be
included on the final plat: “Undisturbed Open Space Area: Future disturbance is
prohibited in these areas except for greenway trails with unlimited public access, new
Charlotte-Mecklenburg Utility lines and channel work/maintenance activities by
Charlotte-Mecklenburg Stormwater Services.”
6. The location of water quality buffers must be included on the final plat recorded with the
Mecklenburg County Register of Deeds Office. The top of the stream bank must be field
located and shown on the plat. Each buffer zone must also be shown on the plat and the
stream side zone must be labeled as “UNDISTURBED.”
7. If requested by the owner, Mecklenburg County and all the Towns except Cornelius and
Huntersville will accept the maintenance responsibility for structural BMPs that are
installed pursuant to the post-construction stormwater ordinance following a warranty
period of two (2) years from the date of the final approval of the BMP, provided the
BMP:
• Serves a single-family detached residential development or townhomes all of
which have public street frontage.
• Is satisfactorily maintained during the two-year warranty period by the owner or
designee.
• Meets all the requirements of the applicable post-construction stormwater
ordinance and the Design Manual.
• Includes adequate and perpetual access and sufficient area, by easement or
otherwise, for inspection, maintenance, repair, or reconstruction.
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The maintenance of all BMPs not covered by this provision is the responsibility of the
owner or their designee.
8. The Towns, Mecklenburg County, CMS and CPCC will maintain the BMPs that they
install for their respective projects when they retain ownership. An O&M Plan has been
developed for this maintenance and is available upon request..
9. BMP Maintenance Bonds are required for all structural BMPs installed for both
residential and commercial developments. BMP Maintenance Bonds are not required for
BMPs installed for public facilities. The purpose of these bonds is to ensure that funds
are available to maintain BMPs if the owner should fail to do so in which case the Town
or Mecklenburg County would cash the bond to obtain the money to perform the
necessary maintenance. The bonds must be posted by the owner for a period of not less
than two (2) years from the final approval of the BMP by the Stormwater Administrator.
10. All BMPs installed for compliance with post-construction stormwater ordinance
requirements must be inspected at a minimum of annually. The owner of the BMP is
responsible for ensuring that these inspections are performed, and for the submittal of the
necessary documentation to CMSWS. They are also responsible for correcting all BMP
violations. In all the jurisdictions except the Town of Huntersville, BMPs must be
inspected by a qualified registered N.C. professional engineer or landscape architect at a
minimum of annually. In Huntersville, a “qualified professional” is authorized to inspect
these BMPs. The minimum requirements for a qualified professional and the established
process for verifying these qualifications are contained in the post-construction ordinance
Administrative Manual available on the website. The Stormwater Administrator has
developed BMP inspection forms that are also available on this website.
9.12 Decision Process
Between April 2004 and September 2005, a stakeholders’ group deliberated in the development
of a draft post-construction ordinance for Charlotte-Mecklenburg. The resulting consensus
document was subsequently reviewed and modified as necessary by the Phase II jurisdictions to
meet their specific requirements. These documents were submitted to NCDEQ and following
approval were adopted into law effective June 30, 2007. Following adoption, workshops were
held for the development community and staff to help ensure effective implementation. It was
decided that a stakeholders’ process would be used in the development of the post-construction
ordinance based off the successes of previous such efforts. For example, CMSWS relied on a
similar approach in the development of the S.W.I.M. stream buffer ordinances and local water
supply watershed rules.
During the development of the draft post-construction ordinances, efforts were undertaken to
conform these rules to each jurisdiction’s specific water quality needs. For example, the Towns
of Matthews, Mint Hill and Pineville have streams within their jurisdictions identified on the
N.C. 303(d) list for fecal coliform bacteria and TMDLs have been developed. In addition, Goose
Creek in the Town of Mint Hill is an identified habitat for the Carolina heelsplitter, a federally
endangered species of freshwater mussel. The Towns in northern Mecklenburg County have
similar challenges. McDowell Creek in Huntersville and Cornelius as well as Long Creek and
Clarke Creek in Huntersville and the Rocky River in Davidson are identified on the N.C. 303(d)
list for biological impairment, fecal coliform bacteria and/or turbidity. These are all high priority
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issues that were taken into consideration during the stakeholder process for development of the
post-construction ordinances for the Phase II jurisdictions.
9.13 Program Evaluation
The measurable goals for each BMP are described in Table 20. The overall success of the Post-
Construction Site Runoff Control Program is evaluated through the successful achievement of
these measurable goals as reported with each NPDES MS4 annual assessment report. At a
minimum, the following metrics are included in this annual report:
• Number of new projects permitted.
• Number of acres disturbed.
• Number of structural BMP inspections conducted.
• Number of notices of violation issued.
• Number of penalties assessed.
• Description of educational activities completed.
Other measures of success for the Post-Construction Stormwater Runoff Control Program are
described below.
• Documentation of Stormwater Program Activities – As a baseline measure of success,
staff will document completion of Work Plan program activities annually that
demonstrate successful fulfillment of BMPs associated with this program element. All
activities will be documented within CMSWS’s Cityworks database.
• Improving Compliance – Structural BMPs installed for compliance with post-
construction ordinance requirements will be inspected at a minimum of once a year.
CMSWS will also periodically inspect buffers, undisturbed open space and other non-
structural BMPs to ensure their long-term effectiveness. CMSWS will track and report
the ratio of the number of deficiencies detected compared to the number of BMP
inspections conducted with a decrease serving as an indicator of success.
On an annual basis, CMSWS staff will evaluate the BMPs assigned to this program and assess
progress toward achieving the measurable goals from Table 20 and the measures of success
described above. Recommendations for improvement will be made as necessary. During the
following fiscal year, the program activities and BMPs will be modified as necessary based on
the results of this evaluation in order to ensure that the specific goals and objectives of the Post-
Construction Stormwater Runoff Control Program and SWMP are being effectively and
efficiently fulfilled.
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SECTION 10: POLLUTION PREVENTION & GOOD HOUSEKEEPING PROGRAM
A Pollution Prevention/Good Housekeeping Program has been developed and is currently being
implemented for addressing discharges of pollution from municipal facilities and operations
owned and/or operated by Mecklenburg County’s Phase II jurisdictions. The program is
administered by CMSWS’s Water Quality Program as described in the following Sections. Each
co-permittee is responsible for pollution prevention and good housekeeping at facilities that they
own and control.
10.1 Program Goals and Objectives
CMSWS’s establishes its goals and objectives for its Pollution Prevention/Good Housekeeping
Program, which are evaluated and updated annually as necessary, based on the actions necessary
to effectively address the targeted pollutants and pollutant sources identified in Table 8. The
current goal of the Pollution Prevention/Good Housekeeping Program is to reduce pollutants in
stormwater runoff from municipal operations. The current objectives of the program are as
follows:
1. Develop and implement an operation and maintenance program to prevent or reduce
stormwater pollution from facilities and operations owned and/or operated by the Phase II
jurisdictions/entities. Achievement of this objective will be measured by a decrease in
the number of deficiencies observed during municipal facility inspections over time (see
Section 10.16).
2. Train the employees at these facilities and operations to prevent and reduce stormwater
pollution from activities such as park and open space maintenance, fleet and building
maintenance, new construction and land disturbances, and stormwater system
maintenance.
10.2 BMP Summary Table
Table 23 describes the BMPs implemented as part of the Pollution Prevention/Good
Housekeeping Program.
Table 23: BMP Summary Table for the Pollution Prevention/Good Housekeeping Program
Permit
Ref.
Pollution Prevention & Good Housekeeping (Part II Section G a through j except g that is included in BMP #31; Part II Section
A.4, 5 and 7): Implement an operation and maintenance program that includes a training component and has the ultimate goal of
preventing or reducing pollutant runoff from municipal operations. Provide employee training to prevent and reduce storm water
pollution from activities such as park and open space maintenance, fleet and building maintenance, new construction and land
disturbances, and storm water system maintenance.
BMP
No.
County
Work
Plan Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
#36 PP-1
(Municipal
Training)
Employee Training
Implement a
training program
for employees
involved in
implementing
a. Review training program annually
and revise as necessary.
a. Annually
beginning
July 1
a. Completion
status
Ensure employees
receive annual
training. Maintain
training records. b. Coordinate with co-permittees on
scheduling and conducting
b. Annually
beginning
b. Completion
status
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Permit
Ref.
Pollution Prevention & Good Housekeeping (Part II Section G a through j except g that is included in BMP #31; Part II Section
A.4, 5 and 7): Implement an operation and maintenance program that includes a training component and has the ultimate goal of
preventing or reducing pollutant runoff from municipal operations. Provide employee training to prevent and reduce storm water
pollution from activities such as park and open space maintenance, fleet and building maintenance, new construction and land
disturbances, and storm water system maintenance.
BMP
No.
County
Work
Plan Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
pollution
prevention and
good
housekeeping
practices.
training. July 1
c. Conduct training and document
dates, persons attending, and
topics covered.
c. Annually
beginning
July 1
c. Completion
status; # trained
#37 PP-2
(Municipal
Inspection)
Inspections
Implement
inspection
program for
municipal
facilities with the
significant
potential for
generating
polluted
stormwater
runoff.
a. Review and revise SOPs annually
and train staff.
a. Annually
beginning
July 1
a. Completion
status
Ensure issues
identified in
inspection reports
are addressed in a
timely manner.
Submit
documentation of
completion to
CMSWS. Co-
permittees are
responsible for the
property, facilities,
infrastructure, etc.
that they
own/control,
including
maintaining and
complying with
O&M Plans for
their facilities
(SWPPPs), SCMs,
MS4s, streets and
parking lots.
b. Conduct inspections, generate
reports, and follow up as
necessary to identify and eliminate
pollution sources.
b. Annually
beginning
July 1
b. Completion
status; #
inspections; #
problems
resolved
c. Evaluate the Operation and
Maintenance programs for
facilities with the significant
potential to pollute as described in
their Stormwater Pollution
Prevention Plans (SWPPPs),
which also includes a spill
response plan. Work with co-
permittee to update/revise as
necessary.
c. Annually
beginning
July 1
c. Completion
status
d. Ensure that municipal employees
and contractors are properly
trained and all permits,
certifications, and other measures
for applicators are followed by
verifying the validity of pesticide
licenses as a component of the
facility inspection process in “b”
above.
d. Annually
beginning
July 1
d. Completion
status
e. Ensure that measures are
implemented to prevent or
minimize contamination of the
stormwater runoff from all areas
used for vehicle and equipment
cleaning as a component of the
facility inspection process in “b”
above.
e. Annually
beginning
July 1
e. Completion
status
f. Document the date of inspections
and/or evaluation of O&M Plans,
results, follow up actions, and
final resolution.
f. Annually
beginning
July 1
f. Completion
status
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96
Permit
Ref.
Pollution Prevention & Good Housekeeping (Part II Section G a through j except g that is included in BMP #31; Part II Section
A.4, 5 and 7): Implement an operation and maintenance program that includes a training component and has the ultimate goal of
preventing or reducing pollutant runoff from municipal operations. Provide employee training to prevent and reduce storm water
pollution from activities such as park and open space maintenance, fleet and building maintenance, new construction and land
disturbances, and storm water system maintenance.
BMP
No.
County
Work
Plan Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
g. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
g. Annually
beginning
July 1
g. Completion
status
#38 PP-5
(Municipal
Inventory)
Inventory
Maintain, a
current inventory
of facilities and
operations
owned and
operated by the
permittee with
the significant
potential for
generating
polluted
stormwater
runoff.
a. Review SOPs annually and revise
as necessary.
a. Annually
beginning July
1
a. Completion
status
Notify CMSWS of
all new properties
purchased.
b. Complete inventory process. b. Annually
beginning July
1
b. Completion
status
c. Document nature of investigation,
names, dates, locations, follow up
actions, violations, and final
resolution.
c. Annually
beginning July
1
c. Completion
status; #
facilities
d. Notify co-permittees of any
changes in their inventory of
facilities with the significant
potential to pollute and work them
to ensure permit compliance.
d. Annually
beginning July
1
d. Completion
status
e. Complete annual report detailing
activities completed and
summarizing findings. Include in
report for PD-1.
e. Annually
beginning July
1
e. Completion
status
#39 PP-9
(Evaluate
Pollution
Prevention)
Evaluate Effectiveness of the Pollution Prevention/ Good Housekeeping Program
Evaluate the
effectiveness of
the Pollution
Prevention/
Good
Housekeeping
Program.
a. Evaluate program effectiveness at
meeting established goals and
objectives.
a. Annually
beginning July
1
a. Completion
status
Notify CMSWS of
actions necessary
to improve the
effectiveness of
the program.
b. Measure program success using
established criteria.
b. Annually
beginning July
1
b. Completion
status; criteria
measure
c. Evaluate the effectiveness of the
O&M Plan for reducing polluted
stormwater runoff from
municipally owned streets, roads,
and public parking lots based on
cost and the estimated quantity of
pollutants removed. Work with
co-permittees to update/revise as
necessary.
c. Annually
beginning July
1
c. Completion
status
d. Evaluate the O&M Plan for
reducing polluted stormwater
runoff from municipally owned or
maintained catch basins and
conveyance systems. Work with
d. Annually
beginning July
1
d. Completion
status
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Permit
Ref.
Pollution Prevention & Good Housekeeping (Part II Section G a through j except g that is included in BMP #31; Part II Section
A.4, 5 and 7): Implement an operation and maintenance program that includes a training component and has the ultimate goal of
preventing or reducing pollutant runoff from municipal operations. Provide employee training to prevent and reduce storm water
pollution from activities such as park and open space maintenance, fleet and building maintenance, new construction and land
disturbances, and storm water system maintenance.
BMP
No.
County
Work
Plan Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
co-permittees to update/revise as
necessary.
e. Recommend improvements as
necessary. Include
recommendations in report for
PD-1.
e. Annually
beginning July
1
e. Completion
status
f. Implement improvements in the
next fiscal year.
f. Annually
beginning July
1
f. Completion
status
10.3 Inventory of Municipally Owned or Operated Facilities
During the first Permit term, CMSWS completed an inventory of over 1,530 properties owned
and/or operated by the Phase II jurisdictions/entities and identified those municipal facilities and
operations that should be covered by the Pollution Prevention and Good Housekeeping
requirements of the Phase II Permit using procedures developed by CMSWS and incorporated
into the SWMP. These procedures were implemented effective July 1, 2005 and are based on
guidelines provided by NCDEQ. These guidelines are contained in Appendix D and include an
evaluation of 20 percent of the identified facilities each year for the 5-year Permit term. As new
facilities were identified, they were incorporated into the Pollution Prevention/Good
Housekeeping Program based on the application of these guidelines.
During the second Permit term beginning in 2011, CMSWS updated its SWMP to comply with a
new Phase II Permit requirement that properties with a “significant potential for generating
polluted stormwater runoff” must be included in an Operations and Maintenance (O&M)
Program that specifies a frequency of inspection and routine maintenance requirements. This
new requirement was less inclusive than those applied during the first Permit term; therefore,
facilities and operations identified for coverage prior to 2011 were left in the program thus going
beyond minimum Permit requirements. CMSWS uses the following criteria to determine if a
facility has a significant potential for generating polluted stormwater runoff:
1. Exposure of significant materials based on the “Exposure Checklist” included in numbers
12 through 14 of NCDEQ’s “No Exposure Certification Form” (NCGNE0000) (see
Appendix D) as described in CMSWS’s “Form for Evaluating Exposure of Significant
Materials” (see Appendix E), and
2. No written procedures or controls in place to prevent pollution.
Facilities that meet the above criteria are added to the Pollution Prevention/Good Housekeeping
Program and the co-permittees that own and/or operate these facilities are required to implement
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long-term pollution prevention measures to reduce the potential for polluted stormwater runoff,
including (but not limited to) the following:
1. Development of a full Stormwater Pollution Prevention Plan.
2. Development of written Standard Operating Procedures (SOPs) for activities on-site
that have a significant potential to pollute stormwater.
3. Completion of required inspections.
4. Completion of required pollution prevention training for on-site staff.
As of FY2021, CMSWS’s inventory included a total of 3,052 properties owned by the co-
permittees that have all been evaluated based on the above criteria with a total of 38 identified as
having a significant potential for generating polluted stormwater runoff that have been included
in the Pollution Prevention and Good Housekeeping Program as described in Tables 24, 25, 26
and 27 below. Table 24 includes a list of facilities operated by Mecklenburg County and the
Towns. Five (5) private operations located on property owned by a co-permittee that have the
significant potential for generating polluted stormwater runoff are also included in Table 24.
These facilities are inspected once every five (5) years. Tables 25 and 26 include facilities
operated by CMS and CPCC, respectively. Of the facilities and operations included in Tables
24, 25 and 26, a total of five (5) are subject to NPDES stormwater general or individual Permits
as described in Table 27. These five (5) facilities ar e owned and/or operated by Mecklenburg
County. A more detailed explanation of the evaluation process for inclusion of facilities into the
Pollution Prevention/Good Housekeeping Program is provided in Appendix D. In addition, a
separate O&M Plan has been developed and is available upon request that includes the
information provided in Sections 10.3, 10.4, 10.5, 10.6, 10.7, and 10.8 as well as Appendix E of
this document.
Table 24: Municipal Operations Owned and/or Operated by the County and Towns
Facility Contact Name & Title Phone Number Physical Address
Matthews Public Works C.J. O’Neill, Public Works Director 704-847-3661 1600 Tanktown Road,
Matthews
Huntersville Public
Works Kevin Fox, Public Works Director 704-766-2220 11316 Sam Furr Road,
Huntersville
Cornelius Public Works Ricky Overcash, Public Works
Supervisor 704-895-5212 18521 Starcreek Drive,
Cornelius
Mint Hill Public Works Steve Frey, Public Works Director 704-545-9726 7151 Matthews-Mint
Hill Road, Mint Hill
Davidson Public Works Doug Wright, Public Works Director 704-892-7591 151 W. Walnut Street,
Davidson
Pineville Public Works Chip Hill, Public Works Supervisor 704-889-7476 402 Dover Street,
Pineville
Mecklenburg Emergency
Medical Services
(MEDIC)
Patrick Crane 704-943-6130 4425 Wilkinson
Boulevard, Charlotte
Stormwater Operations John McCulloch, Environmental
Manager 980-314-3288 5841 Brookshire Blvd.,
Charlotte
Meck. Co. Parks &
Recreation Peter Cook, Park & Rec Mgr. 980-314-1040 5841 Brookshire Blvd.,
Charlotte
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99
Facility Contact Name & Title Phone Number Physical Address
Parks & Recreation
Horticulture Center Tim Turton, Horticulture Team Leader 704-549-5617 11826 Mallard Creek
Road, Charlotte
North Mecklenburg
Recycling
Derrick Harris, Senior Environmental
Specialist 980-314-3859 12100 Statesville Rd.,
Huntersville
Mecklenburg County
White Goods & Tire
Nick Crawford, Senior Environmental
Specialist 980-406-1109 5740 Rozzelles Ferry
Road, Charlotte
Charlotte Recycling
Center* Mike Gurley 704-400-6557 1007 Amble Drive,
Charlotte
New Compost Ce ntral &
Recycling Center
Jake Wilson, Senior Environmental
Specialist 980-314-3862 140 Valleydale Road,
Charlotte
Old Com post Central &
Recycling Center*
Jake Wilson, Se nior Environmental
Specialist
980-314-3862 5631 West Boulevard,
Charlotte
Hickory Grove
Recycling
Nick Crawford, Senior Environmental
Specialist 980-406-1109 8007 Pence Road,
Charlotte
CT Myers Golf Course* Del Ratcliffe, Presi dent, Ratcliffe Golf
Services 704-622-0105 7817 Harrisburg Road,
Charlotte
Fox Hole Recycling Steve Curry, Landfill Manager 980-314-3867 17131 Lancaster
Highway, Charlotte
Fox Hole Landfill Steve Curry, Landfill Manager 980-314-3867 17131 Lancaster
Highway, Charlotte
Tradition Golf Course* Kim Worrell, Pinnacle Golf 704-585-8286 3800 Prosperity Church
Road, Charlotte
Dr. Charles L Sifford
Golf Course*
Del Ratcliffe President, Ratcliffe Golf
Services
704-622-0105
704-392-0018
2661 Barringer Drive,
Charlotte
Harry L Jones Golf
Course
Del Ratcliffe President, Ratcliffe Golf
Services 704-357-3373 1525 W Tyvola Rd
Sunset Hills Golf
Course*
Del Ratcliffe President, Ratcliffe Golf
Services
704-622-0105
704-392-0018
800 Radio Road,
Charlotte
U.S. Na tional
Whitewater Center* Jeff Wise, President 704-393-6355 5000 Whitewater Center
Pkwy, Charlotte
Meckl enburg Co. Fleet
Management Facility* Marcus McAdoo, Shop Manager 704-249-5290 900 W.12th Street,
Charlotte
Latta Plantation Nature
Preserve
Todd Hammond, Maintenance
Supervisor
1-704-432-4280 6211 Sample Road,
Huntersville
McDowell Nature
Preserve
Chris Talkington, Maintenance
Supervisor
1-704-249-4363 15222 York Road,
Charlotte
* Operations not performed by the co-permittee on property that the co-permittee owns that has
the significant potential for generating polluted stormwater runoff. These facilities are
inspected once every five (5) years (except the U.S. National Whitewater Center and Fleet
Management which are inspected annually).
Table 25: Municipal Operations Owned and/or Operated by CMS
Facility Contact Name & Title Phone Number Physical Address
Bus Staging Site Jeff Mitchell, Environmental Health &
Stewardship Specialist 980-343-8632 11719 Downs Rd.
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Facility Contact Name & Title Phone Number Physical Address
Independence High
School
Jeff Mitchell, Environmental Health &
Stewardship Specialist 980-343-8632 1967 Patriot Dr.
Harding/West Meck
Transportation
Jeff Mitchell, Environmental Health &
Stewardship Specialist 980-343-8632 3101 Wilkinson Blvd.
Building Services Jeff Mitchell, Environmental Health &
Stewardship Specialist 980-343-8632 3301 Stafford Dr.
Craig Avenue
Transportation
Jeff Mitchell, Environmental Health &
Stewardship Specialist 980-343-8632 3901, 3903, 3905 Craig
Ave,
Northpointe
Transportation
Jeff Mitchell, Environmental Health &
Stewardship Specialist 980-343-8632 4440 Northpointe
Industrial Blvd.
Orr Road Admin Jeff Mitchell, Environmental Health &
Stewardship Specialist 980-343-8632 6520 Orr Rd.
Table 26: Municipal Operations Owned and/or Operated by CPCC
Facility Contact Name & Title Phone Number Physical Address
CPCC Central Campus Zachary Harris, Facilities Services 704-330-6233 East 7th Street (1203
Elizabeth Avenue)
CPCC Merancas Campus Zachary Harris, Facilities Services 704-330-6233 11930 Verhoeff Drive
CPCC Cato Campus Zachary Harris, Facilities Services 704-330-6233 9400 East WT Harris
Blvd.
CPCC Harper Campus Zachary Harris, Fa cilities Services 704-330-6233 317 West Hebron Street
Table 27: Municipal Operations that have been Issued Stormwater Permits
Facility Permit
Number Contact Name & Title Phone Number Physical Address
Mecklenburg County
and Towns Phase II
MS4 Permit
NCS000395
Dave Canaan, Director of
Stormwater Services 980-314-3209 2145 Suttle Ave.
Charlotte
New Compost Ce ntral
& Recycling Center NCG240019 Darren Steinhilber,
Project Manager 980-314-3857 140 Valleydale Road,
Charlotte
Old Compost Central &
Recycling Center* NCS000382 Darren Steinhilber,
Project Manager 980-314-3857 5631 West Boulevard,
Charlotte
Fox Hole Landfill
(Hwy 521 Landfill) NCG120068 Steve Curry, Landfill
Manager 980-314-3864 17131 Lancaster
Highway, Charlotte
Mecklenburg Co. Fleet
Management Facility NCG080063 Marcus McAdoo, Shop
Manager 704-249-5290 900 W.12th Street,
Charlotte
* Operations are still being conducted at the Old Compost Central & Recycling Center.
However, according to Joe Hack (Program Manager) these operations are planned to be
discontinued in late 2021. Joe will notify CMSWS when this occurs, and the facility will be
removed from the inspection list provided pollution sources have been eliminated.
10.4 Training
Annual training is provided to the employees involved in implementing pollution prevention and
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101
good housekeeping practices at the municipally operated facilities listed in Tables 24, 25, 25, and
27 above. Privately-operated facilities located on properties owned by a co-permittee as
identified in Table 24 are responsible for conducting their own training. Training is also
provided for other employees involved in municipal operations that have the potential to cause
negative water quality impacts. The goal of this training seminar is to inform employees of the
actions necessary to reduce the discharge of pollution and protect water quality from activities
such as park and open space maintenance, fleet and building maintenance, new construction and
land disturbances, storm sewer system maintenance, and other municipal activities as well as the
steps for reporting suspected illicit discharges and actions required for compliance with Permit
requirements. The following topics are covered in the training seminar:
1. Overview of general water quality conditions in Mecklenburg County and reasons for
protecting water quality.
2. Description of common pollutants, their sources and water quality impacts associated
with illicit discharges.
3. Description of the actions that each facility and/or operation should take to reduce
discharges of pollutants, including good housekeeping and proper herbicide, pesticide,
and fertilizer application and management.
4. Description of effective spill prevention measures that should be employed at each
facility and/or operation.
5. Discussion of typical pollution sources at municipal operations and the specific action
that should be taken to eliminate these sources and protect water quality.
6. Description of techniques for identifying and reporting illicit discharges and connections.
This training is a Permit requirement for all municipal staff, who, as part of their normal
job responsibilities, may come into contact with or otherwise observe an illicit discharge
or illicit connection to the storm sewer system.
7. Description of new requirements in the Permit issued in November 2011 as follows:
• Post-construction stormwater controls for municipally owned transportation
projects (see Section 9.4).
• Minimizing pollution from municipally owned streets, roads, and public parking
lots (see Section 10.7).
• Operation and maintenance of municipally owned and maintained storm sewer
system including catch basins and conveyance systems (see Section 10.8).
• Management of pesticide, herbicide and fertilizer application (see Section 10.11).
8. Review of the Stormwater Pollution Prevention Plan and/or Spill Response Plan.
9. Explanation of the consequences of failing to control pollutants at facilities and/or
pollutants associated with municipal operations.
10. Proper reporting of illicit discharges.
The above training is conducted separately from the outreach programs conducted for the IDDE
Program previously described under program element ID-5, which includes training for
municipal staff, who, as part of their normal job responsibilities, may come into contact with or
otherwise observe an illicit discharge or illicit connection to the storm sewer system. The
training for the Pollution Prevention and Good Housekeeping Program described under program
element PP-1 focuses on municipal staff involved in implementing pollution prevention and
good housekeeping practices. Due to the very distinct differences in the two (2) target audiences
it is necessary to separate this training.
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10.5 Operation and Maintenance Programs, Spill Prevention, and Spill Response
Stormwater Pollution Prevention Plans (SWPPPs) have been developed and implemented that
describe the Operation and Maintenance Programs implemented at the facilities listed in Tables
24, 25, 26, and 27 above for the purpose of reducing the discharge of pollution in stormwater
runoff. At a minimum, SWPPPs include the following:
1. Site Map that shows the location of the facility and all access roads. The map must also
indicate the name of the receiving stream and specify if it is impaired and the source of
that impairment. A USGS quadrangle map is acceptable.
2. Site Plan that shows the location of all structures on the site and the general uses of these
structures (i.e. storage, vehicle maintenance, offices, etc.) as well as the locations of all
stormwater inlets and outlets at or adjacent to the facility, potential pollution sources and
access on and off the site.
3. Stormwater Management Plan that includes an evaluation of BMPs (if any) on the site,
and descriptions of storage practices, waste handling and disposal methods and the
potential on-site pollution sources including exposed significant materials.
4. Spill Prevention and Response Plan that identifies the specific actions to be taken to
prevent and respond to spills, including clean up contractors and their contact
information, etc.
5. Preventative Maintenance and Good Housekeeping Plan that describes the measures
taken to prevent or minimize contamination of stormwater runoff from areas identified as
potential pollution sources, including but not limited to areas used for vehicle and
equipment cleaning. The Plan must also describe the type and frequency of site
inspections and routine maintenance and the staff responsible for performing these
activities.
6. Training Schedule that describes the employees that will receive training, the type of
training to be provided and the schedule for that training. This training must include a
discussion of all the material contained in the Stormwater Pollution Prevention Plan. All
staff must be made aware of the location of this Plan at the facility.
CMSWS conducts inspections of all the facilities listed in Tables 24, 25, 26, and 27 above.
Facilities operated by a co-permittee ar e inspected annually and facilities operated by private
entities on property owned by a co-permittee are inspected once every 5 years. These
inspections include the following:
1. Thorough assessment of facility operations, maintenance activities, maintenance
schedules and long-term inspection procedures for controls to reduce floatables and other
pollutants. Pollution sources will be identified and minimized to the MEP.
2. Evaluation and documentation of the procedures for the disposal of waste removed from
the MS4 and municipal operations, including street sweeping wastes, dredge spoil,
accumulated sediment, floatables, and other debris, as applicable.
3. Visual evaluation of storm water outfalls at the facility and identification and
minimization of pollution sources to the MEP.
4. Review of spill response and clean up procedures. Procedures will be revised as
necessary to ensure protection of water quality.
5. Evaluation of housekeeping practices that will be revised as necessary to minimize
potential pollution sources to the MEP.
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6. Identification of all potential discharges of pollution, including parking lots, maintenance
and storage yards, waste transfer stations, fleet and maintenance facilities, outdoor
storage areas, salt/sand storage areas, etc.
7. Evaluation of areas used for vehicle and equipment cleaning to ensure that all discharges
are to the sanitary sewer system.
8. Identification and elimination of dry weather discharges.
9. Review of Stormwater Pollution Prevention Plans annually.
10. Review of educational materials.
11. Review the timeliness of any monitoring reports required by the NPDES Permits issued
to the facilities listed in Table 27 above.
12. Evaluation of the co-permittees status regarding compliance with Permit requirements,
including: post-construction stormwater controls for transportation projects; maintenance
of municipally-owned streets, roads, and public parking lots; operation and maintenance
of municipally-owned or maintained catch basins, conveyance systems, and structural
stormwater controls; and management of pollutants from vehicle and equipment cleaning
areas. In addition, CMSWS obtains the pesticide license numbers for all employees and
contractors performing application activities and conducts a search on the NC Dept. of
Agriculture and Consumer Services website to ensure all licenses are valid.
13. Completion of a written report documenting findings and listing actions taken to
minimize pollution sources and protect water quality to the MEP.
Additional inspection details are contained in the Stormwater Inspection Checklist that is
reviewed and updated as necessary as part of the Phase II Work Plan developed and
implemented annually by CMSWS. A copy of this checklist is provided in Appendix E. Follow
up inspections are conducted as necessary to ensure the minimization of all potential pollution
sources to the MEP and documentation of corrective actions. Supervisors of facilities are
contacted and provided with a copy of the written report. All reports of inspection activities are
reviewed by the Water Quality Program Supervisor prior to closure. These reports are
maintained in the Cityworks database.
As of January 1, 2021, CMS owns and/or operates 176 schools. These schools have all been
evaluated and determined not to have a significant potential for generating polluted stormwater
runoff. However, the schools have the potential to generate pollutants that are not considered
significant from food service areas, dumpsters without lids and plugs, erosion from high traffic
areas, etc. Therefore, the schools are inspected roughly once every eight (8) years and training is
provided to staff as necessary. During these inspections, pollution sources are identified and
eliminated, and inspection reports completed.
10.6 Standard Operating Procedures (SOPs) for Municipal Facility Operations
Written SOPs have been developed to describe the actions co-permittees are to undertake to
control the discharge of pollutants from their facilities and operations to protect downstream
water quality. These SOPs are provided to co-permittees and are included in their SWPPPs.
CMSWS evaluates the effectiveness of the implementation of these SOPs during facility
inspections as described in the previous section.
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10.7 Minimizing Pollution from Municipally Owned Streets and Parking Lots
CMSWS has evaluated BMPs for reducing the discharge of floatables and other pollutants from
municipally owned streets and parking lots and has selected the following that are currently in
use by the Phase II jurisdictions/entities (except for the Extra Territorial Jurisdiction (ETJ) areas
of the Towns):
• Ordinances – Each co-permittee will continue enforcement of existing litter and illicit
discharge ordinances adopted by each jurisdiction.
• Solid Waste Collection and Recycling – Each co-permittee will continue existing solid
waste collection and recycling services.
• Public Education – Each co-permittee will continue public education to encourage
citizens to properly dispose of waste and to recycle as many materials as possible.
• Parking Lot Cleaning – Each co-permittee will clean parking lots in identified problem
areas. These problem areas are identified by staff based on accumulations of leaves,
trash, debris, blockages, flooding, etc. It may also be performed after special events and
festivals where additional trash and other pollutants are expected. The Town of
Cornelius does the majority of its street cleaning through leaf vacuuming services that
run from November 1 through January 31 each year and use their street sweeper on major
thoroughfares. Each co-permittee provides trash receptacles at public parking lots and
performs scheduled manual trash pick-up. Each co-permittee maintains records
documenting the number of parking lots cleaned and the pounds of trash, sediment, and
other pollutants removed as well as the estimated cost of the program. This data is
provided to CMSWS by July 31st of every year for use in evaluating program
effectiveness and for inclusion in the annual report to the State. An O&M Plan has been
developed for parking lot cleaning and is available upon request.
• Street Sweeping – Each co-permittee will sweep their municipal streets in identified
problem areas. These problem areas are identified by staff based on accumulations of
leaves, trash, debris, blockages, flooding, etc. Co-permittees maintain records
documenting the number of streets cleaned and the pounds of trash, sediment, and other
pollutants removed as well as the estimated cost of the program. This data is provided to
CMSWS by July 31st of every year for use in evaluating program effectiveness and for
inclusion in the annual report to the State. The County does not assume ownership or
perform any maintenance activities on streets outside the jurisdictions of the Towns and
City of Charlotte. For County owned parking lots, litter is picked up daily by
maintenance staff, but no routine street sweeping activities are performed. An O&M
Plan has been developed for street sweeping and is available upon request.
• Waste Disposal – Each co-permittee will be responsible for characterizing the street
sweeping waste that they collect and for proper disposal of this waste based on this
characterization. CMSWS will be contacted if unusual conditions are observed with the
collected waste, such as the presence of oil or chemicals, unusual odors or discoloration,
etc., so that testing can be performed prior to disposal. Recycling or composting is the
preferred method for handling street sweeping waste. Any disposal should occur at an
approved landfill. The land application of this waste onto public or private property is
discouraged; however, if this does occur the application area should be a minimum of 50
feet from any stream or other water body and proper erosion control measures must be
utilized to prevent off-site discharges.
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The above BMPs were implemented effective November 11, 2012. CMSWS performs an annual
evaluation of the effectiveness of these BMPs for maintenance of municipally owned streets,
roads, and public parking lots based on costs and the estimated quantity of pollutants removed.
This data is presented in the annual assessment report sent to the State. CMSWS changes the
BMPs as necessary based on this annual evaluation and will work with the Phase II
jurisdictions/entities to ensure the timely implementation of these changes. A separate O&M
Plan has been developed for maintenance of streets and parking lots and is available upon
request.
10.8 Operation and Maintenance Plans for MS4s and SCMs
CMSWS has evaluated BMPs for reducing the discharge of floatables and other pollutants from
the municipally owned MS4, including catch basins and conveyance systems and has selected
the following that are currently in use by the Phase II jurisdictions/entities:
• Catch Basin and Conveyance System Cleaning – Each co-permittee will clean catch
basins and conveyance systems as well as repair the MS4 in identified problem areas.
These problem areas are identified by staff based on accumulations of leaves, trash,
debris, blockages, flooding, etc. Each co-permittee maintains record documenting the
number of inlets, outlets and pipes cleaned and the pounds of trash, sediment, and other
pollutants removed as well as the estimated cost of the program. This data is provided to
CMSWS by July 31st of every year for use in evaluating program effectiveness and for
inclusion in the annual report to the State.
• Waste Disposal – Same as for 8.6 above.
The above BMPs were implemented effective November 11, 2012. CMSWS will evaluate
annually the effectiveness of the above described BMPs for maintenance of the storm sewer
system based on costs and the estimated quantity of pollutants removed. CMSWS will change
the SWMP as necessary based on this annual evaluation and will work with the Phase II
jurisdictions/entities to ensure the timely implementation of these changes. An O&M Plan has
been developed for the maintenance of MS4s and is available upon request.
The co-permittees are required to implement an Operation & Maintenance Program for post-
construction SCMs that it owns, including the frequency of inspections and routine maintenance
requirements. All BMPs must be inspected and maintained in accordance with this schedule.
The co-permittees are required to document inspections and maintenance of all municipally
owned or maintained post-construction structural stormwater control measures. Section 9.4
describes how these requirements are being fulfilled. A separate O&M Plan including the above
BMPs has been developed for maintenance of SCMs and is available upon request.
10.9 Evaluation of BMPs for Streets, Roads, Parking Lots, and Storm Sewer Systems
The effectiveness of the BMPs identified in Sections 10.7 and 10.8 above for streets, roads,
public parking lots, and storm sewer systems was evaluated in FY2020 based on cost and the
estimated quantity of pollutants removed. Table 28 below summarizes the data collected as a
result of this evaluation, including an estimate of the pounds of pollutants removed at 1,046,538
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at a cost per pound at $0.57. Based on this data, these BMPs are determined to be highly
effective and will therefore continue in use due to the significant number of pounds removed at a
very low cost. This determination is based on a report produced by R.C. Sutherland, P.E. in
2013 entitled Clean Streets Mean Clean Streams that indicates an acceptable pollutant removal
range is $3 to $5 per pound.
Table 28: Pounds of Pollutants Removed and Costs for FY2020
BMPs Lbs. Removed Cost Cost/Lb.
Street Sweeping 934,733 $455,390 $0.48
Parking Lot Cleaning 11,150 $11,831 $1.06
Conveyance Systems
Cleaning 100,700 $130,950 $1.30
TOTALS 1,046,538 $598,171 $0.57
10.10 Winter Road Maintenance
The co-permittees perform maintenance activities to ensure safe winter driving conditions on its
roads and parking lots. The following practices are employed by the co-permittees to reduce the
discharge of pollutants from these activities.
1. Minimize the use and optimize the application of sodium chloride and other salt (while
maintaining public safety) and consider opportunities for use of alternative materials.
2. Optimize sand and/or salt-brine solution rates through the use, where practicable, of
automated application equipment (e.g., zero velocity spreaders), anti-icing and pre-
wetting techniques and implementation of pavement management systems.
3. Prevent exposure of deicing product (salt, sand, or alternative products) to precipitation
by enclosing or covering storage piles. Implement good housekeeping, diversions,
containment or other measures to minimize exposure resulting from adding to or
removing materials from the pile. Store piles in such a manner as not to impact surface
water resources, groundwater resources, and wells.
10.11 Management of Pesticide, Herbicide and Fertilizer Application
CMSWS has evaluated BMPs for ensuring that municipal employees and contractors are
properly trained in pesticide, herbicide and fertilizer application as well as for ensuring
compliance with all applicable permits and certifications. Based on this evaluation, the
following BMPs have been selected and are currently in use by the Phase II jurisdictions/entities:
• Training – Proper pesticide and fertilizer application is covered as a component of the
municipal employee training described in Section 10.4.
• Applicator Licenses – Each co-permittee is responsible for verifying that an employee or
contractor has the pr oper license and/or certification for the pesticide and/or herbicide
applications to be performed. Every co-permittee collects and stores copies of licenses
and/or license numbers. Every year as part of the municipal inspection process described
in Section 10.5, CMSWS verifies the validity of these licenses through a search of the
NC Dept. of Agriculture and Consumer Services website. These licenses and
certifications are updated at least annually and within 30 days of hiring a new employee
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or contractor. This documentation is made available in the event of an audit. Training is
required for obtaining and renewing an applicator license; therefore, by verifying a
license the co-permittee is also verifying that the proper training has been received.
• Treatment Areas – In FY2012, an assessment was completed of each co-permittee’s
pesticide application and management practices. This assessment revealed that the co-
permittees were in compliance with applicable NPDES requirements. Information
provided by each co-permittee during this assessment revealed that their pesticide
applications were below the annual treatment area thresholds contained in NCDEQ’s
Pesticides General Permit (NCG560000) as described in Table 29. It is the responsibility
of each co-permittee to ensure continued compliance with NPDES requirements,
including applying for coverage under NCG560000 if pesticide applications in the
applicable treatment areas will exceed one or more of the thresholds in Table 29 during
the calendar year. It is also the co-permittee’s responsibility to notify CMSWS if such an
application is made. During annual inspections, CMSWS will obtain a copy of annual
pesticide application records. These records will be reviewed by the inspector and
compared to previous years to determine if there have been significant increases in the
quantities applied or ar eas treated in which case further investigations will be performed
to determine if Permit # NCG560000 should be obtained. The application records,
results of further investigations, and copies of permits issued are maintained in the
facility’s file.
Table 29: Annual Treatment Area Thresholds
Pesticide Use Annual Threshold
Mosquitoes and Other Flying Insect Pests 15,000 acres of treatment area (adulticide applications only) (1)
Aquatic Weed and Algae Control - In Water 1,000 acres of treatment area
Aquatic We ed and Algae Control - At Water’s Edge 200 linear miles of treatment area at water’s edge (2)
Aquatic Nuisance Animal Control - In Water 200 acres of treatment area
Aquatic Nuisance Animal Control - At Water’s Edge 200 linear miles of treatment area at water ’s edge (2)
Forest Canopy Pest Control 10,000 acres of treatment area
Intrusive Vegetation Control 500 linear miles (3)
(1) Multiple applications to the sa me area are added together only for mosquito and other flying insect pest control.
(2) Applications tha t occur at the water’s edge in a ditch or canal are counted only once when one or both sides are
treated.
(3) Applications to both sides of a road are added together for the total miles.
The N.C. Pesticide Board regulates pesticide application in the Goose Creek watershed in 02
NCAC 09L .2201 through .2203. These rules apply to critical habitat areas in Goose Creek
outside of the Phase II jurisdiction in Mecklenburg County. However, since critical habitat areas
are prone to change, these rules will be applied in the Phase II jurisdiction/entities as one of the
BMPs for this SWMP as described in Table 30. It is the responsibility of each co-permittee to
ensure that the limits in Table 30 ar e met in the Goose Creek Watershed. CMSWS will notify
the co-permittees of this requirement during annual training and inspection activities.
Table 30: Limits on Pesticide Applications in the Goose Creek Watershed
Pesticide Active Ingredient Code/Limitations
Azinphos-methyl (2)
Benomyl (1)
Captan (1)
Carbaryl (2)
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Pesticide Active Ingredient Code/Limitations
Carbofuran (1)
Chlorpyrifos (3)
Diazinon (2)
Dicofol (2)
Dimethoate (2)
Endosulfan (2)
Esfenvalerate (1)
Ethion (2)
Ethoprop (1)
Fenamiphos (2)
Fonofos (2)
Malathion (2)
Methidathion (2)
Methomyl (1)
Mevinphos (2)
Naled (1)
Parathion (ethyl) (2)
Pendimethalin (2)
Permethri n (1)
Phorate (1)
Phosmet (1)
Phosphamidon (1)
Propiconazole (1)
Pyrethrins (2)
Terbufos (2)
Trichlorfon (2)
(1) This pesticide shall not be applied within 20 yards from the edge of water for ground applications and within
100 yards for aerial applications.
(2) This pesticide shall not be applied within 40 yards from the edge of water for ground applications and within
200 yards for aerial applications.
(3) This pe sticide shall not be applied wi thin 100 yards from the edge of wa ter for ground applications and within
one-fourth mile for aerial appl ications.
The above BMPs were implemented effective November 11, 2012. CMSWS continues to assess
the effectiveness of these BMPs when it conducts facility inspections and receives information
from the responsible party regarding compliance with the above stated provisions. CMSWS
changes the BMPs as necessary and works with the Phase II jurisdictions/entities to ensure the
timely implementation of these changes when inspection findings reveal a significant decline in
compliance with BMP requirements.
10.12 Controlling Pollutants from Vehicle/Equipment Maintenance, Cleaning & Fueling
The following procedures are followed when performing vehicle and equipment maintenance to
prevent discharges to the storm drain system:
1. Vehicle maintenance should be performed indoors where contact with storm water is
minimal.
2. If minor vehicle maintenance must take place outdoors, ensure that it is done during
times of non-precipitation and that tarps are placed on the ground surface to collect any
potential fluid spillage.
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3. Any fluid spillage should be cleaned up immediately and properly disposed. Refer to the
spill response procedures in the SWPPP.
The following procedures are followed when performing vehicle and equipment cleaning to
prevent discharges to the storm drain system. An SOP has been developed for vehicle washing
and is available upon request.
1. Vehicle washing areas should drain to a permitted sanitary sewer system, if available.
2. If no sanitary sewer connection is available, the facility should either wash vehicles at a
car wash facility or designate an on-site vehicle washing area that is not directly
connected to a storm drain system, such as grassed areas, gravel parking areas, or a water
quality BMP. This washing area must be designated on the Site Plan Map in the SWPPP.
The following restrictions apply to these designated washing areas not connected to the
sanitary sewer system:
• Only biodegradable detergents can be used with a pH between 4.0 and 9.0.
• Solvents cannot be used to clean vehicles in this area.
• Only vehicle exteriors should be washed. Engines or oily equipment / parts
cannot be washed in these areas.
• Water usage should be minimized to the extent practicable by using a pressure
washer or low flow nozzle.
The following procedures are followed when performing vehicle and equipment fueling to
prevent discharges to the storm drain system:
1. Employees are to remain with vehicles and equipment during fueling operations.
2. Vehicles should not be “topped off.”
3. Spill kit materials should be available in the immediate vicinity of the fueling area in the
event of a spill.
4. Any spilled fuel should be cleaned up immediately and properly disposed. Refer to the
spill response procedures in the SWPPP.
10.13 Waste Disposal
During the inspections described in Section 10.5 above, CMSWS evaluates methods for
disposing of waste removed from each jurisdiction’s MS4 and municipal operations, including
dredging spoil, accumulated sediments, cooking oils, trash, wash water, and debris. Actions are
taken as necessary to minimize pollution sources associated with these waste storage and
disposal measures by working closely with the facility supervisor and/or public works director.
10.14 Flood Management Projects
CMSWS designs and constructs flood management and stream restoration projects in the
Mecklenburg County Phase II jurisdictions as well as the City of Charlotte. Where practicable,
CMSWS incorporates structural BMPs into these projects to reduce pollutant loads and improve
aquatic habitat. In some cases, chemical, physical and/or biological monitoring is performed
upstream, downstream and within the boundaries of the project. This monitoring usually begins
prior to the initiation of construction activities and continues throughout the duration of the
project and for a minimum of one year following project completion. Data generated from these
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monitoring activities is evaluated to identify those techniques that are most effective at restoring
water quality for use in future projects. Figure 13 illustrates one such project in the Hidden
Valley community in Charlotte where wet ponds, wetlands and stream meanders were
incorporated into a flood management project for enhancement of water quality.
Figure 13: Stream Restoration in the Torrence Creek Watershed in Huntersville
10.15 Decision Process
The individual BMPs for the Pollution Prevention/Good Housekeeping Program were selected
because they have proven effective when used by the City of Charlotte for compliance with their
Phase I Permit requirements. Staff was selected for implementation of the BMPs for the
Pollution Prevention/Good Housekeeping Program based on their knowledge of proper facility
operation and pollution prevention.
10.16 Program Evaluation
The measurable goals for each BMP are described in Table 23. The overall success of the Post-
Pollution Prevention/Good Housekeeping Program is evaluated through the successful
achievement of these measurable goals as reported with each NPDES MS4 annual assessment
report. At a minimum, the following metrics are included in this annual report:
• Number of employees trained.
• Number of streets and parking lots cleaned, and amount of material removed.
• Number of inlets, outlets and pipes cleaned, and amount of material removed.
• Description of educational activities completed.
Other measures of success for the Pollution Prevention and Good Housekeeping Program are
described below.
• Documentation of Stormwater Program Activities: As a baseline measure of success,
staff will document completion of Work Plan program activities annually that
demonstrate successful fulfillment of BMPs associated with this program element. All
activities will be documented within CMSWS’s Cityworks database.
Before Construction After Construction
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• Improving Compliance: CMSWS will track the ratio of the number of deficiencies
observed at municipal facilities to the number of inspections conducted with a decrease
from the previous fiscal year serving as an indicator of success.
On an annual basis, CMSWS staff will evaluate the BMPs assigned to this program and assess
progress toward achieving the measurable goals from Table 23 and the measures of success
described above. Recommendations for improvement will be made as necessary. During the
following fiscal year, the program activities and BMPs will be modified as necessary based on
the results of this evaluation in order to ensure that the specific goals and objectives of the
Pollution Prevention and Good Housekeeping Program and SWMP are being effectively and
efficiently fulfilled. The evaluation will include an assessment of the effectiveness of BMPs in
use to reduce pollutants from municipally owned streets, roads, parking lots, catch basins, and
stormwater conveyance systems. This evaluation will be based on data received from the co-
permittees regarding costs and the estimated quantity of pollutants removed. CMSWS will
change the SWMP as necessary based on this annual evaluation and will work with the Phase II
jurisdictions/entities to ensure the timely implementation of these changes.
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SECTION 11: TMDL WATER QUALITY RECOVERY PROGRAM
A Water Quality Recovery Program has been developed and is currently being implemented for
addressing nonpoint source pollutant loadings associated with the Total Maximum Daily Loads
(TMDLs) approved by EPA for the receiving waters of the Phase II MS4 stormwater discharges
and/or waters downstream of these discharges. Section 3.5 of this document describes the
TMDLs applicable to Mecklenburg County Phase II jurisdictions and entities. The Program is
administered by CMSWS’s Water Quality Program as described in the following Sections. The
purpose of this Program is to facilitate the implementation of activities within the scope of the
Phase II Permit’s six (6) minimum measures to reduce the assigned WLAs for the stormwater
pollutant of concern to the maximum extent practicable (MEP). This Program is intended to
meet the TMDL requirements of MS4 Permit number NCS000395.
11.1 Program Goals and Objectives
CMSWS establishes its goals and objectives for its TMDL Program, which are evaluated and
updated annually as necessary, based on the actions necessary to effectively address the
pollutant(s) of concern in the applicable TMDL and to address the targeted pollutants and
pollutant sources identified in Table 8. The goal of the TMDL Program is to reduce levels of the
pollutant(s) of concern to the MEP in accordance with approved Waste Load Allocation (WLAs)
assigned to stormwater in the approved TMDL. The current objectives of the program are as
follows:
1. Develop and implement appropriate structural and/or non-structural BMPs to reduce
nonpoint source loading for the pollutant(s) of concern to the MEP in the TMDL
watersheds.
2. Assess the effectiveness of existing BMPs and identify and implement additional
measures as necessary to address impaired waters. Incorporate additional measures into
the SWMP and annual Work Plan for implementation.
3. Submit a report to NCDEQ annually describing activities completed in the
implementation of existing BMPs as well as the results of the annual assessment and
additional BMPs that have been identified for implementation, including a brief
explanation as to how the BMPs will address impaired waters.
Part II, Section H of Mecklenburg County’s Phase II Permit requires compliance with TMDLs
applicable to the receiving waters for MS4 discharges from the Phase II jurisdictions and/or
waters downstream of these discharges. To comply with this requirement, CMSWS evaluates
the current 305(b) report and 303(d) list for N.C. at least annually and identifies those impaired
waters with an approved TMDL applicable to Mecklenburg County’s Phase II jurisdictions. For
these applicable TMDLs, CMSWS develops and implements strategies and tailored BMPs to
reduce nonpoint source loading for the pollutants of concern to the MEP. These strategies and
BMPs are evaluated annually for effectiveness and modified as necessary. While improved
water quality is the expected outcome, the Phase II Permit obligation is to reduce nonpoint
source pollutant loading to the MEP. The Phase II jurisdictions are not responsible for attaining
water quality standards at the ambient monitoring stations. Attaining the water quality standards
will only be achieved through reduction from the MS4, along with reductions from other
pollutant contributors.
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11.2 BMP Summary Table
Table 31 describes the BMPs implemented as part of the TMDL Program.
Table 31: BMP Summary Table for the TMDL Program
Permit
Ref.
Total Maximum Daily Load (TMDL) Program (Section H.1 through 6; Part II Section A.4, 5 and 7): Implement a program to
reduce levels of the pollutant of concern in accordance with approved Waste Load Allocation (WLAs) assigned to stormwater in an
approved TMDL.
BMP
No.
County
Work
Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
#40 IW-1
(Evaluate
Impaired
Waters)
Evaluate Impaired Waters
Identify those
impaired
waters with an
approved
TMDL in
Mecklenburg
County that
have a waste
load allocation
assigned to
stormwater.
a. Complete an evaluation of the latest version
of the 303(d) list and the integrated 305(b)
and 303(d) reports. Identify all changes to
designations in Mecklenburg County.
a. Annually
beginning July
1
a. Completion
status
None.
b. Identify and review all TMDLs that have
been developed and approved by EPA for
receiving waters in Mecklenburg County.
b. Annually
beginning July
1
b. Completion
status
c. Complete annual report detailing
activities completed and summarizing
findings. Include in report for PD-1.
c. Annually
beginning July
1
c. Completion
status
#41 IW-2
(WQRPs
for
TMDLs)
Water Quality Recovery Plans for TMDLs
Develop and
implement
Water Quality
Recovery Plans
(WQRPs) to
reduce non-
point source
pollutant
loading to the
maximum
extent
practicable
(MEP) for
TMDL waters
with a waste
load allocation
assigned to
stormwater.
a. Based on the results from IW-1 above,
identify those TMDL waters in
Mecklenburg County with a waste load
allocation assigned to stormwater. Work
with Charlotte Stormwater on a
compliance strategy for these waters.
a. Annually
beginning
July 1
a. Completion
status
None.
b. Develop WQRPs for the waters from “a”
above that are the responsibility of
Mecklenburg County, including
structural and/or non-structural BMPs
and a brief explanation as to how the
programs, controls, partnerships, projects
and strategies address impaired waters.
b. Annually
beginning
July 1
b. Completion
status
c. Incorporate BMPs from “b” above into
Work Plans for implementation.
c. Annually
beginning
July 1
c. Completion
status
d. Complete annual report detailing
activities completed and summarizing
findings. Include in report for PD-1.
d. Annually
beginning
July 1
d. Completion
status
#42 IW-2
(WQRPs
for
TMDLs)
Water Quality Recovery Plans for TMDLs
Assess the
effectiveness
of structural
and non-
structural
BMPs at
addressing
TMDL waters
a. Identify and assess the effectiveness of
existing programs, controls,
partnerships, projects, and strategies for
all TMDL waters identified in IW-2
above.
a. Annually
beginning
July 1
a. Completion status None.
b. Based on the results from “a” develop
additional structural and non-structural
BMPs as necessary to reduce non-point
b. Annually
beginning
July 1
b. Completion status
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Permit
Ref.
Total Maximum Daily Load (TMDL) Program (Section H.1 through 6; Part II Section A.4, 5 and 7): Implement a program to
reduce levels of the pollutant of concern in accordance with approved Waste Load Allocation (WLAs) assigned to stormwater in an
approved TMDL.
BMP
No.
County
Work
Plan
Code
A B C D E
County Activities
Co-Permittee
Responsibilities Description of
BMP Measurable Goal(s) Schedule for
Implementation
Annual
Reporting
Metric
with a waste
load allocation
assigned to
stormwater and
modifying as
necessary.
source pollutant loading to the
maximum extent practicable (MEP).
c. Incorporate BMPs from “b” above into
Work Plans for implementation.
c. Annually
beginning
July 1
c. Completion status
d. Complete annual report detailing
activities completed and summarizing
findings, including a description of the
effectiveness of existing structural
and/or non-structural BMPs and a brief
explanation as to how the existing
programs, controls, partnerships,
projects and strategies address impaired
waters as well as whether additional
BMPs are necessary and when they will
be implemented. Include in report for
PD-1.
d. Annually
beginning
July 1
d. Completion status
11.3 TMDL Pollutants of Concern
The following sub-sections describe the pollutants of concern for those TMDLs where
Mecklenburg County is assigned as the lead in Table 3, including portions of the Rocky River,
Lake Wylie and Goose Creek. The pollutants of concern for those TMDLs where the City of
Charlotte is assigned as the lead in Table 3 are described in their NPDES MS4 TMDL Watershed
Plan, which is available through their Phase I contact.
11.3.1 Fecal Coliform TMDLs
Fecal coliform bacteria are present in the intestines of humans as well as warm- and cold-
blooded animals. Fecal coliform themselves are usually harmless but serve as indicators of the
presence of pathogenic bacteria. Fecal coliform in surface waters can originate from many point
and nonpoint sources, including but not limited to wildlife, pet waste, failing septic systems,
cross connections resulting in dry weather flow in stormwater outfalls, sanitary sewer overflows
(SSOs), sewer exfiltration, and permitted discharges such as wastewater treatment plants
(WWTPs). The control of fecal coliform is necessary for protection of human health. The NC
in-stream standard for fecal coliform is a 30-day geometric mean of 200 colonies/100 ml or a
daily maximum value of 400 colonies/100 mL (15A NCAC 2B .0211 (3)(e)). Due to a greater
than 10% exceedance of the 400 colonies/100 ml standard, a fecal coliform TMDL was
developed and subsequently approved for the Rocky River effective September 19, 2002 and for
Goose Creek effective July 8, 2005. The TMDL for the Rocky River established reductions in
fecal coliform load allocations for nonpoint sources in wet weather conditions as follows: high
density development at 91%, low density development at 91%, livestock grazing at 86%, and
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manure application at 80%. Reductions in load allocations for nonpoint sources in dry weather
conditions are as follows: high density development at 33%, low density development at 33%,
livestock grazing at 30%, and manure application at 30%. The TMDL for Goose Creek
established reductions in fecal coliform load allocations for nonpoint sources at 92.5%.
11.3.2 Nutrient TMDL
High concentrations of nitrogen and phosphorus in surface waters can degrade aquatic
environments, resulting in excessive algal growth, decreased dissolved oxygen concentrations,
and stressed aquatic biota. Elevated nutrient levels are often associated with point and nonpoint
pollution sources, including but not limited to agriculture, urban runoff, and permitted discharges
such as WWTPs. The monitoring and control of nutrients is therefore necessary to limit algal
growth that can degrade water quality. Chlorophyll-a concentration is currently utilized as a
proxy parameter for monitoring nutrient levels in surface waters, as water quality standards have
not been established for nitrogen and phosphorus. NCDEQ regulates nutrient concentrations
through a Chlorophyll-a standard of 40 ug/l.
In a 1992 Report by NCDEQ and the S.C. Department of Health and Environmental Control
(Report # 92-04), eutrophic conditions were documented in Lake Wylie and several of its major
tributaries. In response, NC developed a point and nonpoint source nutrient control strategy for
the Lake Wylie Watershed. For point sources, the strategy required state-of-the-art nutrient
removal for all new or expanded wastewater discharges in the vicinity of the lake. In addition,
existing facilities on tributaries to the three (3) most highly eutrophic arms of the lake, including
the South Fork, Catawba Creek and Crowders Creek, were required to meet stringent nutrient
removal requirements. For nonpoint sources, the strategy included the targeting of funds from
the State’s Agricultural Cost Share Program for the reduction of nonpoint source pollution for
implementation of BMPs on agricultural lands to highly impacted watersheds on Lake Wylie.
The strategy subsequently was approved for implementation as a TMDL by EPA effective
February 5, 1996. The TMDL does not include a WLA assigned to stormwater.
11.3.3 Mercury TMDL
In 2012, NCDEQ developed a statewide mercury TMDL to determine how wastewater
discharges, including in-state and out-of-state air sources, contribute to the surface water
mercury loading. This TMDL acknowledged that most mercury in stormwater comes from
atmospheric deposition and that concentrations are typically within the same range as mercury
concentrations in rainwater, which is between zero and 10 ug/l. This TMDL does not include a
WLA assigned to stormwater; therefore, there is not an NPDES MS4 Permit obligation to reduce
non-point source pollutant loading. For this reason, TMDL compliance measures for this TMDL
are not included in this SWMP.
11.4 Watershed Characteristics
The following sub-sections describe the characteristics for those TMDL watershed where
Mecklenburg County is assigned as the lead in Table 3, including portions of the Rocky River,
Lake Wylie and Goose Creek. The watershed characteristics for those TMDLs where the City of
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Charlotte is assigned as the lead in Table 3 are described in their NPDES MS4 TMDL Watershed
Plan, which is available through their Phase I contact.
11.4.1 Rocky River Watershed
The Rocky River Watershed (Assessment Unit 13-17a) is located in the Yadkin/Pee Dee River
Basin in the northeast corner of Mecklenburg County and extends into portions of Iredell and
Cabarrus Counties. Table 32 includes information regarding the watershed. Figure 14 illustrates
the location of the Rocky River Watershed in relation to Mecklenburg County. Figure 15
illustrates the TMDL waters, stormwater outfalls and monitoring sites in the Rocky River
Watershed in Mecklenburg County. Figure 16 illustrates the landuses in this watershed.
Table 32: Information Regarding the Rocky River Watershed in Mecklenburg County
Watershed Area 1.16 square miles or 747 acres in the Rocky River Basin (Upper Pee Dee).
Stream Length Approximately 1.19 main channel miles
Stream
Classification
Class C: Protected for secondary recreation, fishing, aquatic life, including
propagation and survival, and wildlife.
Predominant
Land-Uses
Residential = 426.92 acres, 57% of watershed
Undeveloped - Vacant = 211.26 acres, 28% of watershed
Open Space - Recreation = 55.45 acres, 7% of watershed
Agriculture = 29.2 acres, 3% of watershed
Topography Highest elevation = 828 feet MSL. Lowest Elevation = 636 feet MSL.
Generally, watershed topographic features have moderate slopes of 2-8%, with
some slopes exceeding 15%. General aspect of existing topographic features is
north, northeast, and east.
Vegetation Vegetation is a mix of hardwood forested areas, scrub shrub understory, with
warm season grasses associated with open areas and suburban type
development.
Climate Monthly mean temperatures range from 40.1°F to 78.5°F, with approximately
237 days of growing season (above 32°F); including a yearly annual mean total
precipitation of 42 inches.
Hydrology Hydrology follows a typical dendritic drainage pattern typified by most
piedmont areas.
Geology Watershed is primarily underlain by Granitic Rock (0.7 sq. miles)
(Devonian/Ordovician Age). The remaining geologic formations consist of
Gabbro of Concord Plutonic Suite (0.32 sq. miles) (Devonian/Ordovician Age)
and Metamorphosed Quartz Diorite (0.15 sq. miles) (Paleozoic/Late Proterozoic
Age).
NPDES
Dischargers
Mecklenburg County – (stormwater)
Soils Pacolet sandy loam 15 to 35 percent slopes is the primary soil type within the
watershed. Other major soil types include: Chewacia sandy loam 0 to 2 percent
slopes and Cecil sandy clay loam 8 to 15 percent slopes, moderately eroded.
Population 2010 U.S. Census Data identified the watershed population to be 4,952. The
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majority of the watershed consisted of 1 Census tract and 2 Block Groups.
Aquatic Species Typical piedmont aquatic species including several varieties of caddisflies,
mayflies and stoneflies, terrestrial insects, fish, amphibians, mussels, snails and
other species.
# Stormwater
Outfalls
4
Figure 14: Location of the Rocky River Watershed in Relation to Mecklenburg County
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Figure 15: TMDL Waters, Outfalls and Monitoring Sites in the Rocky River Watershed in
Mecklenburg County
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Figure 16: Landuses in the Rocky River TMDL Watershed in Mecklenburg County
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11.4.2 Goose Creek Watershed
The Goose Creek Watershed is located in the Yadkin/Pee Dee River Basin in southeastern
Mecklenburg County and extends into portions of Union County. Table 33 includes information
regarding the watershed. Figure 17 illustrates the location of the Goose Creek watershed in
relation to Mecklenburg County. Figure 18 illustrates the TMDL waters, stormwater outfalls and
monitoring sites in the Goose Creek Watershed in Mecklenburg County. Figure 19 illustrates the
landuses in this watershed.
Table 33: Information Regarding the Goose Creek Watershed in Mecklenburg County
Watershed Area 11.23 square miles or 7,189.96 acres in the Rocky River Basin (Pee Dee).
Stream Length Approximately 28.03 main channel miles
Stream
Classification
Class C: Protected for secondary recreation, fishing, aquatic life, including
propagation and survival, and wildlife.
Predominant Land-
Uses
Residential = 3,224.47 acres, 44% of watershed
Undeveloped - Vacant = 1,818.22 acres, 25% of watershed
Agriculture = 803.57 acres, 11% of watershed
Open Space - Recreation = 565.62 acres, 7% of watershed
Topography Highest elevation = 794 feet MSL Lowest Elevation = 552 feet MSL.
Generally, watershed topographic features have moderate slopes of 0-5%,
with some slopes exceeding 10%. Overall, general aspect of existing
topographic features is south, southwest and east.
Vegetation Vegetation is a mix of hardwood forested areas, agriculture (row crops and
hay) and warm season grasses associated with suburban development.
Climate Monthly mean temperatures range from 40.1°F to 78.5°F, with
approximately 237 days of growing season (above 32°F); including a
yearly annual mean total precipitation of 42 inches.
Hydrology Hydrology follows a typical dendritic drainage pattern typified by most
piedmont areas.
Geology Watershed is underlain primarily by Metavolcanic Rock (9.2 sq. miles)
(Cambrian/Late Proterozoic Age). The remaining geologic formations
consist of Granitic Rock (1.29 sq. miles) (Devonian/Ordovician Age) and
Phyllite and Schist (0.64 sq. miles) (Cambrian/Late Proterozoic Age).
NPDES Dischargers Oxford Glen WWTP: 15349 Bexley Place (0.075 mgd)
Ashe Plantation WWTP: Quarters Lane (0.154 mgd)
Country Woods WWTP: Country Woods Drive (1.036 mgd)
Fairfield Plantation WWTP: Stoney Ridge Rd (0.108 mgd)
Mint Hill and Mecklenburg County (stormwater)
Stallings (stormwater)
Indian Trail (stormwater)
Soils Cecil sandy clay loam 2 to 8 percent slopes, moderately eroded is the
primary soil type within the watershed. Other major soil types include:
Cecil sandy clay loam 8 to 15 percent slopes, moderately eroded and
Helena sandy loam, 2 to 8 percent slopes.
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Population 2010 U.S. Census Data identified the watershed population to be 9,053.
The majority of the watershed consisted of 3 Census tracts and 5 Block
Groups.
Aquatic Species Typical piedmont aquatic species including several varieties of caddisflies,
mayflies and stoneflies, terrestrial insects, fish, amphibians, mussels, snails
and other species.
# Stormwater
Outfalls
183
Figure 17: Location of the Goose Creek Watershed in Mecklenburg
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Figure 18: TMDL Waters, Outfalls and Monitoring Sites in the Goose Creek Watershed in
Mecklenburg County
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Figure 19: Landuses in the Goose Creek TMDL Watershed in Mecklenburg County
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11.4.3 Lake Wylie Watershed
The Lake Wylie Watershed (Assessment Unit 13-17a) is located in the Catawba River Basin in
the southwestern corner of Mecklenburg County and extends into portions of Gaston County in
N.C. and York County in S.C. Table 34 includes information regarding the watershed. Figure
20 illustrates the location of the Lake Wylie watershed in relation to Mecklenburg County.
Figure 21 illustrates the TMDL waters, stormwater outfalls and monitoring sites in the Lake
Wylie TMDL watershed in Mecklenburg County. Figure 22 illustrates the landuses in this
watershed.
Table 34: Information Regarding the Lake Wylie Watershed in Mecklenburg County
Watershed Area 50 square miles or 32,444 acres in the Upper Catawba Basin (Santee).
Stream Length Approximately 100.49 main channel miles
Stream
Classification
WS-V: Protected for water supply.
Class B: Protected for primary recreation activities involving human body
contact.
Class C: Protected for secondary recreation, fishing, aquatic life, including
propagation and survival, and wildlife.
Predominant Land-
Uses
Undeveloped - Vacant = 9,879.21 acres, 30% of watershed
Residential = 8,183.81 acres, 25% of watershed
Open Space - Recreation = 3,041.94 acres, 9% of watershed
Commercial = 2,072.48 acres, 6% of watershed
Topography Highest elevation = 826 feet MSL. Lowest Elevation = 548 feet MSL.
Generally, watershed topographic features have moderate slopes of 0-10%,
with some slopes exceeding 20%. Overall, general aspect of existing
topographic features is south to southwest.
Vegetation Vegetation is a mix of hardwood forested areas, scrub shrub understory,
with warm season grasses associated with open areas and suburban type
development.
Climate Monthly mean temperatures range from 40.1°F to 78.5°F, with
approximately 237 days of growing season (above 32°F); including a
yearly annual mean total precipitation of 42 inches.
Hydrology Hydrology follows a typical dendritic drainage pattern typified by most
piedmont areas.
Geology Watershed is underlain primarily by Metamorphosed Mafic Rock (38 sq.
miles) (Paleozoic/Late Proterzoic Age). The remaining geologic
formations consist of Granitic Rock (4.5 sq. miles) (Devonian/Ordovician
Age) and Gabbro of Concord Plutonic Suite (3.9 sq. miles)
(Devonian/Ordovician Age).
NPDES Discharges Mariners Watch WWTP – (<1mgd)
The Hideaways WWTP – (<1mgd)
Queens Harbor WWTP – (<1mgd)
Riverpointe WWTP – (<1mgd)
Harbor Estates WWTP – (<1mgd)
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Truetzschler Remediation Site – (Goundwater Remediation Discharge)
Berryhill Elementary School WWTP – (<1mgd)
Gough Econ WWTP – (<1mgd)
Charlotte/Paw Creek Terminal #1 – (Industrial Process & Commercial
Wastewater Discharge)
Charlotte Terminal (Outfall 009) – (Industrial Process & Commercial
Wastewater Discharge)
Charlotte Terminal 3 – (Industrial Process & Commercial Wastewater
Discharge)
Charlotte/Southern Facilities Terminal – (Industrial Process & Commercial
Wastewater Discharge)
City of Charlotte – (Stormwater Discharge)
Mecklenburg County – (Stormwater Discharge)
Soils Cecil sandy clay loam 2 to 8 percent slopes, moderately eroded and Cecil
sandy clay loam 8 to 15 percent slopes are the primary soil type within the
watershed. Other major soil types include: Mecklenburg fine sandy loam 2
to 8 percent slopes, Pacolet sandy loam 15 to 25 percent slopes, and
Monacan loam 0 to 2 percent slopes frequently flooded.
Population 2010 U.S. Census Data identified the watershed population to be 34,444.
The majority of the watershed consisted of 11 Census tracts and 19 Block
Groups.
Aquatic Species Typical piedmont aquatic species including several varieties of caddisflies,
mayflies and stoneflies, terrestrial insects, fish, amphibians, mussels, snails
and other species.
# Stormwater
Outfalls
233
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Figure 20: Location of Lake Wylie Watershed in Mecklenburg County
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Figure 21: TMDL Waters, Outfalls and Monitoring Sites in the Lake Wylie Watershed in
Mecklenburg County
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Figure 22: Landuses in the Lake Wylie TMDL Watershed in Mecklenburg County
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11.5 Public Information and Notification
The Public Information and Notification component is designed to provide citizens and
businesses with access to information about TMDLs that affect the City of Charlotte and
Mecklenburg County and the methods that will be used to reduce the TMDL pollutants of
concern. The public is notified about the TMDLs and the TMDL compliance efforts in
Mecklenburg County as follows:
• The CMSWS website contains information about the City and County’s TMDLs, the
TMDL pollutants of concern, TMDL compliance efforts, and how the public can report
water pollution problems and become engaged in volunteer opportunities.
• The County’s Phase II annual report is posted on the CMSWS website and will provide a
summary of the activities conducted under the TMDL watershed plan.
11.6 Implementation Team
City and County staff from CMSWS will serve as the primary implementation team for TMDL
compliance efforts. Staff from other affected agencies that conduct activities in the TMDL
watershed will also be included as necessary. The following staff positions with CMSWS were
identified as key members of the TMDL team:
• County Environmental Manager
• County Environmental Supervisor
• County Environmental Analyst
• County Senior Environmental Specialist
• County Environmental Specialist
• City Environmental Manager
• City Water Quality NPDES Supervisor
• City Water Quality NPDES Administrator
• City Land Development Erosion Control Administrator
• City Water Quality Public Information Specialist
• City Water Quality Modeler
• City Water Quality Planner
• City Water Quality Senior Specialist
• City Water Quality Post-Construction Administrator
• City Stormwater MS4 Inventory Supervisor
• City Utility Department Sanitary Sewer System Administrator
11.7 MS4 Major Stormwater Outfalls in the TMDL Watersheds
The major stormwater outfalls in the TMDL watersheds where Mecklenburg County is the lead,
including portions of the Rocky River, Goose Creek and Lake Wylie, have been identified
through MS4 inventory collection activities and are illustrated in Figures 15, 18 and 21,
respectively. The number of outfalls recorded in each watershed is shown in Table 35. These
outfalls are available in a GIS layer in CMSWS’s Cityworks database along with stormwater
inlets. The schedule to discover additional major outfalls is described in Section 7.4 of this
document. The major stormwater outfalls in the TMDL watersheds where the City of Charlotte
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is the lead are described in their NPDES MS4 TMDL Watershed Plan, which is available
through their Phase I contact.
Table 35: Number of Outfalls in each TMDL Watershed
Watershed Number of Outfalls
Rocky River 4
Goose Creek 183
Lake Wylie 233
Total 420
11.8 Existing BMP Measures
As discussed in Section 11.3, the primary pollutants of concern for the TMDL watersheds where
Mecklenburg County is the lead are fecal coliform bacteria, chlorophyll-a and mercury. Since
the Statewide mercury TMDL does not have a WLA assigned to stormwater there is not an
NPDES MS4 Permit obligation to reduce non-point source pollutant loading. For this reason,
TMDL compliance measures for this TMDL are not included in this SWMP. For fecal coliform
bacteria and chlorophyll-a, CMSWS has reviewed existing strategies and BMPs within the scope
of the six (6) minimum Phase II Permit compliance measures and has identified those BMPs
identified in the following subsections as suitable for best addressing those waters impaired due
to these pollutants of concern. All the strategies and BMPs described below are currently being
implemented in the Phase I and Phase II jurisdictions in Mecklenburg County.
11.8.1 Public Education & Outreach
The following existing public education and outreach activities have been identified as suitable
for addressing the pollutants of concern in the TMDL watersheds. These BMPs will address
impaired waters by inf orming the community of the impacts of the pollutants of concern on
water bodies and the steps that the public can take to reduce these pollutants. Previous sections
of this document ar e referenced below for additional information regarding each activity.
1. Utility Bill Inserts (see Section 5.4.1)
2. Brochures, Environmental Notices and Newsletters (see Section 5.4.2)
3. Print Ads (see Section 5.4.3)
4. Media Campaign (see Section 5.4.4)
5. Social Media (see Section 5.4.5)
6. Targeted Outreach (see Section 5.4.6)
7. Workshops and Video Taped Messages (see Section 5.4.7)
8. Web Pages (see Section 5.4.8)
9. Educational Presentations and Public Events (see Section 5.4.9)
10. Regional Stormwater Partnership (see Section 5.4.10)
11. Stormwater Helpline (see Section 5.3)
11.8.2 Fats, Oils and Grease Program
The City’s water and sewer utility department (Charlotte Water) maintains a public education
program focused on keeping food related fats, oils, and grease from being discharged to the
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sanitary sewer system. This effort helps to reduce clogging and blockages in the system and
prevent SSOs, which can introduce fecal coliform and other pollutants to water bodies.
11.8.3 Public Involvement and Participation
The following existing public involvement and participation activities have been identified as
suitable for addressing the pollutants of concern in the TMDL watersheds. These BMPs will
address impaired waters by involving the public in program development and implementation to
reduce the pollutants of concern. Previous sections of this document are referenced below for
additional information regarding each activity.
1. Adopt-A-Stream (see Section 6.4.3)
2. Storm Drain Marking (see Section 6.4.4)
3. Surface Water Clean Up Event (see Section 6.4.5)
11.8.4 Illicit Discharge Detection and Elimination (IDDE)
The following existing IDDE activities have been identified as suitable for addressing the
pollutants of concern in the TMDL watersheds. These BMPs will address impaired waters by
identifying and eliminating sources of the pollutants of concern. Previous sections of this
document are referenced below for additional information regarding each activity.
1. Storm Sewer System Mapping (see Section 7.4)
2. Pollution Control Ordinance (see Section 7.5)
3. Enforcement (see Section 7.6)
4. Citizen Requests for Service (see Section 7.7.1.1)
5. Routine Water Quality Monitoring Activities (see Section 7.7.1.2)
6. Volunteer Activities (see Section 7.7.1.3)
7. GIS Mapping (see Section 7.7.1.4)
8. Illicit Discharge Elimination Program (IDEP) (see Section 7.7.2.1)
9. Short Term Monitoring (see Section 7.7.2.2)
10. Hot Spot Investigations (see Section 7.7.2.3)
11. Stream Walks (see Section 7.7.2.4)
12. Facility Inspections (see Section 7.7.2.5)
13. Dry Weather Flow Investigations (see Section 7.7.2.6)
11.8.5 Sewer Use Ordinance
Implementation and enforcement of the Sewer Use Ordinance by Charlotte Water provides the
legal mechanism to ensure proper use and connection to the sanitary sewer system and correction
of problems and illegal practices. Ensuring that the system is used properly will help prevent
leaks and overflows as well as upsets at wastewater treatment plants thus helping control the
TMDL pollutants of concern.
11.8.6 Sanitary Sewer System Inspections and Maintenance
Charlotte Water conducts inspections and maintenance of various components of
the sanitary sewer system to ensure proper operating function and prevent leaks and overflows.
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These include food service grease trap inspections, commercial oil/water separator inspections,
sanitary sewer line root control and cleaning, sewer line right-of-way clearing and maintenance,
and lift station inspection and maintenance. Ensuring that the system is used properly inspected
and maintained will help prevent leaks and overflows as well as upsets at wastewater treatment
plants thus helping control the TMDL pollutants of concern.
11.8.7 SSO Rapid Response
Charlotte Water maintains a rapid response program designed to quickly and efficiently respond
to sanitary sewer overflows, thus reducing the discharge of pollutants to the MEP and helping
control the TMDL pollutants of concern.
11.8.8 Construction Site Stormwater Runoff Control
The following existing construction site stormwater runoff control activities have been identified
as suitable for addressing the pollutants of concern in the TMDL watersheds. These BMPs will
address impaired waters by reducing discharges of pollutants of concern from construction sites.
Previous sections of this document are referenced below for additional information regarding
each activity.
1. Erosion Control Ordinance (see Section 8.3)
2. Erosion Control Plan Reviews (see Section 8.4)
3. Enforcement (see Section 8.5)
4. Inspections (see Section 8.6)
5. Erosion Control Hotline (see Section 8.7)
6. Erosion Control Education (see Section 8.8)
7. Government Projects (see Section 8.9)
11.8.9 Post-Construction Site Runoff Control
The following existing post-construction site runoff control activities have been identified as
suitable for addressing the pollutants of concern in the TMDL watersheds. These BMPs will
address impaired waters by reducing discharges of pollutants of concern from new development
and redevelopment projects. Previous sections of this document are referenced below for
additional information regarding each activity.
1. Post-Construction Stormwater Ordinance (see Section 9.3)
2. Compliance by Co-Permittees with Post-Construction Ordinance Requirements (see
Section 9.4)
3. Requirements for Non-Structural BMPs (see Section 9.5)
4. Requirements for Structural BMPs (see Section 9.6)
5. Natural Resource Protection (see Section 9.7)
6. Open Space Protection (see Section 9.8)
7. Tree Preservation (see Section 9.9)
8. Green Infrastructure Practices (see Section 9.10)
9. Operation and Maintenance (see Section 9.11)
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11.8.10 Pollution Prevention and Good Housekeeping
The following existing pollution prevention and good housekeeping activities have been
identified as suitable for addressing the pollutants of concern in the TMDL watersheds. These
BMPs will address impaired waters by reducing discharges of pollutants of concern from
municipal facilities and operations. Previous sections of this document are referenced below for
additional information regarding each activity.
1. Inventory of Municipal Operations (see Section 10.3)
2. Training (see Section 10.4)
3. Operation and Maintenance Programs, Spill Prevention and Spill Response (see Section
10.5)
4. Minimizing Pollution from Municipally Owned Streets, Roads and Parking Lots (see
Section 10.7)
5. Operation and Maintenance of Municipally Owned Storm Sewer System (see Section
10.8)
6. Management of Pesticide, Herbicide and Fertilizer Application (see Section 10.11)
7. Preventing or Minimizing Pollution from Vehicle and Equipment Cleaning Areas (see
Section 10.12)
8. Waste Disposal (see Section 10.13)
9. Flood Management Projects (see Section 10.14)
11.9 Water Quality Monitoring and Data Assessment
CMSWS conducts fixed interval stream monitoring (see Section 7.7.1.2) at identified locations
in or immediately downstream of the TMDL watersheds on a monthly basis as indicated in
Figures 15, 18 and 21. This monitoring is primarily used to determine water quality trends, but
is also used as a tool to detect pollution problems in surface waters. Monitoring results that
exceed threshold values are referred for follow-up under the IDDE program. CMSWS also
conducts routine lake monitoring every other month during the calendar year as follows: January,
March, May, July, September, and November. Monitoring for fecal coliform bacteria is
performed monthly during the summer months from May through September. Data from this
lake monitoring is used to identify trends and to initiate watershed management strategies for
restoring degraded water quality conditions. CMSWS also maintains a Continuous Monitoring
and Alert Notif ication Network or CMANN that monitors surface waters at select sites in
streams and lakes for tur bidity, dissolved oxygen, temperature, conductivity, and pH. All
monitoring results that exceed threshold values are referred for follow-up under the IDDE
program.
11.9.1 Fecal Coliform Monitoring and Data Assessment for the Rocky River
As identified in Table 3, a section of the Rocky River in Mecklenburg County (AU Number 13-
17a) is subject to a fecal coliform TMDL with a WLA assigned to stormwater that was approved
on September 19, 2002. Mecklenburg County has been assigned responsibility for compliance
with this TMDL on behalf of the Phase I and Phase II jurisdictions in Charlotte-Mecklenburg.
Phase II Permit conditions required that a monitoring plan be developed for the Fecal Coliform
TMDL in the Rocky River Watershed unless a waiver was obtained from NCDEQ. Such a
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waiver was obtained on June 26, 2014, based on the condition that Mecklenburg County
continue to evaluate the land use and development within the watershed on an annual basis and if
additional stormwater infrastructure is installed or higher intensity land uses are constructed a
Monitoring Plan would be reconsidered. In response to this condition, CMSWS has obtained
impervious area and landuse data from the County GIS Department back to 2011 and continues
to update this data annually (see Table 36). To date, changes in the watershed are not significant
enough to warrant the establishment of a Monitoring Plan.
Table 36: Annual Analysis of the Rocky River Watershed for the Monitoring Plan
Watershed
Measure 2011 2012 2013 2014 2015 2016 2017 2018 2019
#
Increase
from
2011
%
Increase
from
2011
Residential
Impervious
Cover (acres)
14.22 14.22 14.55 14.88 15.00 15.10 15.20 15.69
15.72 1.5 10.55%
Commercial
Impervious
Cover (acres)
0.33 0.33 0.33 0.33 0.33 0.33 0.33 0.33
0.33 0.00 0.00%
Total
Impervious
Cover (acres)
14.55 14.55 14.88 15.21 15.33 15.43 15.53 16.02 16.05 1.50 10.31%
Storm Water
Outfalls
(number)
1 1 3 3 4 4 4 4
4 3 300%
Although CMSWS does not perform monitoring in the Rocky River TMDL watershed, it obtains
monthly monitoring data collected by the NCDEQ, Division of Water Quality at Q7330000,
which is the specific monitoring location for this TMDL. CMSWS completed an analysis of the
fecal coliform data collected by the State in calendar year 2019, which is the most current data
available. The geometric mean concentration of these samples was 357.17 CFU/100 ml. This
represents an approximate 46% decrease from the geometric mean concentration observed in
calendar year 2018 at 663.46 CFU/100 ml. Additionally, out of the 12 samples collected in
2019, eight (67%) exhibited concentrations below 400 CFU/100 ml. The North Carolina
Administrative Code (NCAC) 02B Fresh Surface Water Quality Standards dictate that fecal
coliform “shall not exceed a geometric mean of 200 [CFU]/100 ml…nor exceed 400 [CFU]/100
ml in more than 20 percent of the samples examined…”.
11.9.2 Fecal Coliform Monitoring and Data Assessment for Goose Creek
As identified in Table 3, two (2) sections of Goose Creek in Mecklenburg County (AU Numbers
13-17-18a and 13-17-18b) are subject to a fecal coliform TMDL with a WLA assigned to
stormwater that was approved on July 8, 2005. According to the approved NC 2018 305(b)
report, the two (2) TMDL segments of Goose Creek are currently meeting the fecal coliform
criteria. Mecklenburg County has been assigned responsibility for compliance with this TMDL
on behalf of the Phase I and Phase II jurisdictions in Charlotte-Mecklenburg. CMSWS
maintains a fixed inter val monitoring site (MY9) located where Stevens Mill Road crosses
Goose Creek in Union County. In calendar year 2019, fecal coliform counts at this station
ranged from 93 to 5,050 CFU/100 ml. with a geometric mean of 427.19 CFU/100 ml. Eleven of
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the 19 samples collected in 2019 (58%) exhibited concentrations at or below 400 CFU/100 ml.
No pollution sources were identified as a result of the water quality monitoring in the Goose
Creek TMDL watershed in 2019. Based on this analysis, there continues to be improvement in
fecal coliform concentrations in Goose Creek.
11.9.3 Chlorophyll-A Monitoring and Data Assessment for Lake Wylie
As identified in Table 3, two (2) sections of Lake Wylie in Mecklenburg County (AU Numbers
11-122 and 11-(123.5)a) are subject to a chlorophyll-a TMDL approved on February 5, 1996 that
does not include a WLA assigned to stormwater. Mecklenburg County has been assigned
responsibility for compliance with this TMDL on behalf of the Phase I and Phase II jurisdictions
in Charlotte-Mecklenburg. Surface Water Quality Standards have not been established for
nitrogen and phosphorus. As a result, CMSWS utilizes Chlorophyll-a concentration as a proxy
parameter for monitoring nutrient levels in Lake Wylie. According to the approved NC 2018
305(b) report, the two TMDL segments of Lake Wylie are currently meeting the Chlorophyll-a
criterion of 40 micrograms per liter (µg/L). All 63 Chlorophyll-a samples collected by CMSWS
in Lake Wylie in 2019 were below 40 µg/l.
11.9.4 Mercury Monitoring and Data Assessment Statewide
As stated in sub-section 11.3.3, the State did not include an MS4 NPDES WLA for mercury in
their statewide TMDL; therefore, an analysis of mercury data is not included in this document.
11.9.5 Effectiveness of BMPs Based on Data Analysis
Every year in an annual report, CMSWS will report on the effectiveness of BMPs based on an
analysis of available water quality data. Based on data collected through the end of calendar
year 2019, a general improvement in water quality is identified; therefore, it is determined that
the current BMPs are effective at identifying and eliminating pollution sources in compliance
with TMDL requirements and that these BMPs will continue to be implemented in FY2021.
Additional structural and/or non-structural BMPs will be implemented as described in Section
11.10 to further enhance TMDL compliance.
11.10 Additional BMP Measures
Over the past several years CMSWS has developed and implemented numerous BMP measures
in addition to those described in Section 11.8 in order to improve water quality conditions in the
TMDL watersheds by identifying and eliminating sources of the pollutant of concern. These
historic additional measures along with new measures proposed beginning in FY2021 are
described in the following subsections by TMDL watershed.
11.10.1 Additional BMP Measures in the Rocky River Watershed
During the fiscal years (FY) indicated below (July 1 through June 30), the following actions
were completed to reduce fecal coliform bacteria levels and enhance water quality in the Rocky
River Watershed.
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FY2015
1. In November 2014, approximately 250 trees were planted in the buffer at the Rocky
River Bluff Nature Preserve (Parcel Number 00307115) by a total of 31 volunteers
through a partnership between CMSWS, Mecklenburg County Park & Recreation
Department, and the Davidson Lands Conservancy. partial funding for the event was
provided through an Urban Cost Share Grant. This enhanced buffer will provide
additional filtering for nonpoint source pollutants that will assist with TMDL pollutant
removal.
2. CMSWS completed a review of historic aerial imagery from the Rocky River Watershed,
which revealed that since 1993 an equestrian area had been located approximately one-
half mile upstream of monitoring site Q733 on the Mecklenburg County side of the
Rocky River. In recent years, a septic system was installed to treat wash water from a
stable located in this area. CMSWS performed monitoring upstream and downstream of
this potential source. Results indicate that the septic system was not a source of fecal
coliform bacteria.
FY2016
1. High resolution aerial imagery was evaluated, and no sources of fecal coliform bacteria
were identified.
2. Agricultural operations in the watershed, which are mainly horse farms, were evaluated
and no sources of fecal coliform bacteria were identified.
3. Health Department records were reviewed and only two (2) failed septic systems were
identified in the watershed between FY2009 and FY2016, which suggest that failing
septic systems are not a chronic problem in this area. Inspections were conducted where
these failing systems had been detected and no sources of fecal coliform bacteria were
identified.
4. The four (4) outfalls in the watershed were inspected and no evidence of dry weather
flows was observed. These inspections were documented in GIS using the ESRI app for
iPhone.
5. The Mecklenburg County Soil & Water Conservation District worked with the property
owner at 18005 Callaway Hills Lane in Davidson, N.C. to complete a stream bank
stabilization project immediately upstream of the first stormwater outfall shown in Figure
15. The cost of the project was $42,000 with the NC Ag Cost Share Program reimburse
the landowner $32,000, leaving the landowner portion at $10,000. The completion of
this project will reduce the sediment load in the stream, which will in-turn reduce fecal
coliform bacteria levels.
FY2017
1. The four (4) outfalls in the watershed were inspected and no evidence of dry weather
flows was observed. These inspections were documented in Cityworks.
2. On June 27, 2017, fecal coliform samples were collected from the Rocky River where it
enters and exits Mecklenburg County. Results indicated fecal coliform levels at 980 and
1020 colonies/100ml, respectively. This represents an insignificant increase.
3. Health Department records were reviewed, and no failed septic systems were identified.
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FY2018
1. Monthly water quality monitoring, including sampling for fecal coliform bacteria
continued at site MY1B (West Branch of the Rocky River at River Ford Drive) located
upstream of the TMDL watershed in Mecklenburg County. One Watch Level
exceedance for fecal coliform bacteria at 370 CFU/100 ml was detected on 12/12/17. No
pollution sources were identified as a result of this monitoring.
2. Health Department records were reviewed, and no failed septic systems were identified.
3. Major outfalls were inspected. No dry weather flows or pollution sources were detected.
4. Design plans are 100% complete for the restoration of a section of the Rocky River in the
TMDL water in Mecklenburg County. Construction is planned to begin in October 2018.
FY2019
1. Monthly water quality monitoring, including sampling for fecal coliform bacteria
continued at #MY1B located upstream of the Rocky River TMDL watershed. Sampling
results are described in Section 9.11.2.
2. Health Department records were reviewed, and no failed septic systems were identified.
FY2020
1. Monthly water quality monitoring, including sampling for fecal coliform bacteria,
continued at site MY1B (West Branch of the Rocky River at River Ford Drive) located
upstream of the TMDL watershed in Mecklenburg County. Monitoring results are
described in Section 11.9.1.
2. On January 3, 2020, Health Department records were reviewed, and no failed septic
systems were identified.
3. On December 29, 2019, the four (4) major outfalls in the Rocky River TMDL watershed
in Mecklenburg County were inspected. No dry weather flows or pollution sources were
detected.
4. In December 2019, design plans for the restoration of a two-mile section of West Branch
Rocky River were completed. Permitting activities for the restoration were subsequently
completed in June 2020. Construction activities are scheduled to begin in Fall 2020.
11.10.2 Additional BMP Measures in the Goose Creek Watershed
During the fiscal years indicated below (July 1 through June 30), the following actions were
completed to reduce fecal coliform bacteria levels and enhance water quality in the Goose Creek
Watershed:
FY2012
1. Routine fixed interval monitoring was conducted monthly at sites MY-9 (Goose Creek –
Stevens Mill Road) and MY-14 (Duck Creek – Tara Oaks Lane). Monthly samples were
analyzed for 16 parameters including fecal coliform, E. Coli, and Enterococcus bacteria.
2. Continuous automated monitoring was conducted at site MY-9 for dissolved oxygen,
temperature, pH, conductivity, and turbidity. These measurements are collected every
hour 365 days per year.
3. Two (2) citizen requests for service were responded to in the watershed.
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FY2013
1. Conducted feasibility study for a potential stream restoration project on Stevens Creek.
2. Routine fixed interval monitoring was conducted monthly at sites MY-9 (Goose Creek –
Stevens Mill Road) and MY-14 (Duck Creek – Tara Oaks Lane). Monthly samples were
analyzed for 16 parameters including fecal coliform, E. Coli, and Enterococcus bacteria.
3. Continuous automated monitoring was conducted at site MY-9 for dissolved oxygen,
temperature, pH, conductivity, and turbidity. These measurements are collected every
hour 365 days per year.
4. One (1) citizen request for service was responded to in the watershed.
FY2014
1. Property easement acquisition began to facilitate a stream restoration project on Stevens
Creek from I-485 to Thompson Road and an unnamed tributary from Stevens Creek
mainstem to Cheval Lane.
2. Routine fixed interval monitoring was conducted monthly at sites MY-9 (Goose Creek –
Stevens Mill Road) and MY-14 (Duck Creek – Tara Oaks Lane). Monthly samples were
analyzed for 16 parameters including fecal coliform, E. Coli, and Enterococcus bacteria.
3. Continuous automated monitoring was conducted at site MY-9 for dissolved oxygen,
temperature, pH, conductivity, and turbidity. These measurements are collected every
hour 365 days per year.
4. Three (3) citizen requests for service were responded to in the watershed.
FY2015
1. Property easement acquisition continued to facilitate a stream restoration project on
Stevens Creek from I-485 to Thompson Road and an unnamed tributary from Stevens
Creek mainstem to Cheval Lane.
2. Stantec Engineering retained to begin design of the Stevens Creek stream restoration
project.
3. Routine fixed interval monitoring was conducted monthly at sites MY-9 (Goose Creek –
Stevens Mill Road) and MY-14 (Duck Creek – Tara Oaks Lane). Monthly samples were
analyzed for 16 parameters including fecal coliform, E. Coli, and Enterococcus bacteria.
4. Continuous automated monitoring was conducted at site MY-9 for dissolved oxygen,
temperature, pH, conductivity, and turbidity. These measurements are collected every
hour 365 days per year.
5. Four (4) citizen requests for service were responded to in the watershed.
FY2016
1. Two (2) animal operations with direct access to surface waters were located during the
assessments. Bacteria samples collected at these sites were below action thresholds.
2. Routine fixed interval monitoring was conducted monthly at sites MY-9 (Goose Creek –
Stevens Mill Road) and MY-14 (Duck Creek – Tara Oaks Lane). Monthly samples were
analyzed for 16 parameters including fecal coliform, E. Coli, and Enterococcus bacteria.
3. Continuous automated monitoring was conducted at site MY-9 for dissolved oxygen,
temperature, pH, conductivity, and turbidity. These measurements are collected every
hour 365 days per year.
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4. Two (2) NPDES wastewater Permits (Oxford Glen – Stevens Creek and Ashe Plantation
– Duck Creek) in the Goose Creek watershed came up for renewal during FY16. County
staff reviewed and provided comments to State staff on the draft Permits.
5. Sediment toxicity monitoring was conducted at one (1) location on Stevens Creek and
two locations on Duck Creek.
6. Design and permitting are underway for the restoration of 2.3 miles of Stevens Creek
from I-485 to Thompson Road and an unnamed tributary from Stevens Creek to Cheval
Lane.
7. Four (4) citizen requests for service were responded to in the watershed.
FY2017
1. 28.03 stream miles were physically assessed in the watershed to identify sources of fecal
coliform bacteria. During these assessments, 88 stormwater outfalls were inspected, and
168 fecal coliform bacteria samples were collected and analyzed. 15 of the samples
collected had elevated concentrations of bacteria which initiated follow-up investigations.
No direct sources of fecal coliform bacteria could be determined. As a result, genetic
microbial source analysis (MST) was conducted at four (4) locations. One (1) location
indicated the presence of human sourced bacteria and one location indicated the presence
of canine sourced bacteria. Trace amounts of bird and ruminant sourced bacteria were
observed in three (3) of the four (4) sample locations. Follow up investigations for the
human sourced bacteria did not reveal any pollution sources.
2. Routine fixed interval monitoring was conducted monthly at sites MY-9 (Goose Creek –
Stevens Mill Road) and MY-14 (Duck Creek – Tara Oaks Lane). Monthly samples were
analyzed for 16 parameters including fecal coliform, E. Coli, and Enterococcus bacteria.
3. Continuous automated monitoring was conducted at site MY-9 for dissolved oxygen,
temperature, pH, conductivity, and turbidity. These measurements are collected every
hour 365 days per year.
4. Health Department records were reviewed, and no failed septic systems were identified.
5. Design and permitting are underway for the restoration of 2.3 miles of Stevens Creek
from I-485 to Thompson Road and an unnamed tributary from Stevens Creek to Cheval
Lane.
6. Three (3) citizen requests for service were responded to in the watershed.
FY2018
1. Routine fixed interval monitoring was conducted monthly at sites MY-9 (Goose Creek –
Stevens Mill Road) and MY-14 (Duck Creek – Tara Oaks Lane). Monthly samples were
analyzed for 16 parameters including fecal coliform, E. Coli, and Enterococcus bacteria.
2. Continuous automated monitoring was conducted at site MY-9 for dissolved oxygen,
temperature, pH, conductivity, and turbidity. These measurements are collected every
hour 365 days per year.
3. Health Department records were reviewed, and no failed septic systems were identified.
4. On October 3, 2017 and February 28, 2018, a high-resolution aerial infrared survey was
completed of 192 acres in the Goose Creek watershed off of Fairington Oaks Drive in
Mint Hill. The purpose of this survey was to identified heat signatures indicating
potential failing septic systems as a source of fecal coliform bacteria. Results from the
survey were inconclusive. No pollution sources were detected.
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FY2019
1. Routine fixed interval monitoring was conducted monthly at sites MY-9 (Goose Creek –
Stevens Mill Road) and MY-14 (Duck Creek – Tara Oaks Lane). Monthly samples were
analyzed for 16 parameters including fecal coliform, E. Coli, and Enterococcus bacteria.
Monitoring results are described in Section 11.9.2.
2. Continuous automated monitoring was conducted at site MY-9 for dissolved oxygen,
temperature, pH, conductivity, and turbidity. These measurements are collected every
hour 365 days per year.
3. Health Department records were reviewed, and no failed septic systems were identified.
4. Beginning on November 1, 2018 and concluding on May 16, 2019, stream walk activities
were completed in the Goose Creek TMDL watershed, including extensive monitoring
for fecal coliform bacteria. No pollution sources were detected.
FY2020
1. Routine fixed interval monitoring was conducted monthly at sites MY-9 (Goose Creek –
Stevens Mill Road) and MY-14 (Duck Creek – Tara Oaks Lane). Monthly samples were
analyzed for 16 parameters including fecal coliform and E. coli. Monitoring results are
described in Section 11.9.2.
2. Beginning on November 1, 2019 and concluding on April 28, 2020, CMSWS staff
walked approximately 60.97 stream miles in the Phase II jurisdictions, including 21.57 in
the Towns and 39.4 miles in the ETJ areas located in the County. In all, 34 points or
features, 18 outfalls inspected, 13 new outfalls, and two dry weather flow samples were
collected. No exceedances above the fecal coliform action level (>3000 col/100ml) were
identified. One sample exhibited a total phosphorus level in exceedance of the action
level of 0.50 ppm. Three significant problems and 15 stream blockages were identified
and reported to Mecklenburg County Storm Water Operations. No illicit discharges of
pollution sources were observed during 2020 Phase II stream walk activities.
3. On January 3, 2020, Health Department records were reviewed, and no failed septic
systems were identified.
11.10.3 Additional BMP Measures in the Lake Wylie Watershed
During the fiscal years (FY) indicated below (July 1 through June 30), the following actions
were completed to reduce fecal coliform bacteria levels and enhance water quality in the Lake
Wylie Watershed:
FY2009
1. On March 23, 2009, high levels of Chlorophyll-a were observed in Wither’s Cove that
exceeded the State standard. In response, CMSWS completed a full assessment of the
cove and watershed, including a windshield survey to identify potential pollution
sources. The Siemens facility that discharges directly to the cove was inspected and
sampled. Elevated copper levels were detected in the intake filter backwash from the
facility. Consultation with NCDEQ revealed that annual sampling was required of the
backwash but there were no Permit limits. On April 8, 2009, additional sampling was
performed at 10 sites in the cove and tributaries draining to the cove. No nutrient sources
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were detected. All Chlorophyll-a levels had returned to normal. The March 2009 event
appears to have been an algae bloom.
During FY2020, FY2021 and FY2022, physical assessments (Stream Walks) are planned for all
the tributaries draining into Lake Wylie in Mecklenburg County, including all of Long Creek and
Paw creek. These assessments will include, stormwater outfall inventory and inspection,
bacteria sampling both instream and any dry weather flows, as well as visual inspection for
sources of fecal coliform bacteria.
11.10.4 Additional BMP Measures Planned for TMDL Watersheds in FY2021
As discussed in Section 11.9.5, existing BMPs were found to be effective and will therefore
continue to be implemented in FY2021. Additional BMPs to be implemented and associated
schedules for FY2021 are provided below.
1. Routine fixed interval monitoring will continue to be performed monthly at MY-9 on
Goose Creek at Stevens Mill Road, MY-14 on Duck Creek at Tara Oaks Lane, and at
MY1B located upstream of the Rocky River TMDL watershed. Monthly samples will be
analyzed for 16 parameters including fecal coliform and E. Coli bacteria. Exceedances of
established water quality watch and action levels will be identified and follow up actions
conducted as necessary for the identification and elimination of pollution sources.
2. By June 30, 2021, CMSWS will complete a review of Health Department records to
determine where failed septic systems have been identified in both the Rocky River and
Goose Creek TMDL watersheds. Follow up inspections and monitoring will be
performed as necessary to ensure the elimination of sources of fecal coliform bacteria
associated with failed septic systems thereby addressing impaired waters.
3. By June 30, 2021, major outfalls will be inspected in the Rocky River TMDL watershed.
Dry weather flows will be identified, and pollution sources eliminated thereby addressing
impaired waters.
4. In Fall 2020, construction activities will begin for the restoration of a two-mile section of
West Branch Rocky River. Currently, West Branch Rocky River is severely degraded by
storm water flows that erode the stream banks. The restoration project will stabilize the
stream banks to reduce erosion and improve water quality.
11.11 Tracking and Reporting Success
The overall success of the TMDL Program is evaluated through the successful achievement of
these measurable goals as reported with each NPDES MS4 annual assessment report. At a
minimum, the following metrics are included in this annual report:
• Number of BMP compliance activities completed by TMDL watershed;
• Effectiveness of BMPs based on an assessment of applicable monitoring data; and
• Future BMPs to be implemented to improve water quality and satisfy TMDL
requirements.
CMSWS will document all activities completed for the identification and elimination of
pollution sources in the TMDL watersheds, including all inspections conducted and corrective
actions implemented. All confirmed pollution sources will be mapped in GIS and where
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possible pollutant loads will be estimated. This data will be tracked over time as a measure of
the success of program activities.
11.12 Reporting
CMSWS will prepare an annual report for activities relating to the implementation of the water
quality restoration activities for the TMDL watersheds where Mecklenburg County has been
assigned responsibility, including Rocky River, Goose Creek and Lake Wylie. The report will
be submitted to NCDEQ by October 1 of each calendar year. The report will at a minimum
include the following information:
1. Description of water quality restoration activities completed during the past fiscal year.
2. Description of water quality restoration activities expected to occur next fiscal year.
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Appendix A: BMP Summary Table
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147
148
149
150
151
152
153
154
155
156
157
158
159
160
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Appendix B: Mecklenburg County Phase II Jurisdictions/Entities Organizational Charts
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163
164
165
166
167
168
169
170
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Appendix C: Post-Construction Policy for Transportation Projects
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Post-Construction Policy for Transportation Projects in the Phase II Jurisdictions
Program Purpose and Background
The purpose of the Post-Construction Policy for Transportation Projects within the Phase II
jurisdictional areas (including Mecklenburg County and the Towns of Cornelius, Davidson,
Huntersville, Matthews, Mint Hill and Pineville) is to ensure that these projects meet all federal,
state, and local requirements. Specifically, this policy is written for public transportation projects that
involve roadway construction not associated with a subdivision or development. Please note that this
policy document does not apply to:
• Roadway projects associated with development – These projects (such as road widening or
turn lane addition) are treated as part of the development and the right-of-way area and built-
upon area should be included in stormwater calculations for the development.
• Roadway projects constructed by the North Carolina Department of Transportation
(NCDOT) - These projects are subject to NCDOT’s Post-Construction program; therefore,
these projects are not subject to local Post-Construction ordinances.
The North Carolina Division of Water Quality (NCNCDEQ) suggests that regulated public entities
use BMPs in the North Carolina Department of Transportation’s (NCDOT’s) "Best Management
Practices Toolbox” developed for linear systems, which has been approved by NCDEQ to meet post-
construction requirements for linear roadway systems.
Applicability
Public roadway projects are subject to the applicability criteria of the applicable jurisdiction’s Post-
Construction ordinance in which the project is located. For post-construction purposes, public
roadway projects will be considered commercial/industrial development or redevelopment. The post-
construction applicability criteria are found in Section 105 of the Post-Construction ordinances for all
Phase II jurisdictions with the exception of the Town of Huntersville, where the applicability criteria
are contained within Section 8.17.3 of the ordinance and the Town of Matthews where the
applicab ility criteria are found in Section 154.005. The grandfathering (or exemption) of public
projects is consistent with the rights given to private developers under applicability and exceptions
provisions of the Post-Construction ordinances. In the event that Post-Construction ordinance
requirements apply to a public roadway project, the responsible public entity shall work with the staff
of Charlotte Mecklenburg Stormwater Services’ Water Quality Program to ensure compliance.
BMPs for Public Linear Roadway Projects
The North Carolina Department of Transportation (NCDOT) developed a list of structural BMPs
suitable for linear projects published in NCDOT’s Stormwater Best Management Practices Toolbox.
NCDOT’s BMP Toolbox has been approved for use by NCNCDEQ for linear roadway projects. To
the extent practicable, the jurisdictions shall use BMPs from the North Carolina Department of
Transportation’s "Best Management Practices Toolbox” developed for linear systems, which has
been approved by NCNCDEQ to meet post-construction requirements for linear roadway systems.
The designs in the Charlotte-Mecklenburg BMP Design Manual are also used where practicable. In
addition, when public linear roadway projects use bridges over surface waters, bridge drainage
systems that eliminate or minimize direct discharge to surface waters are required. More information
on bridge drainage systems can be found in Chapter 9 of NCDOT’s BMP Toolbox. A copy of
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NCDOT’s BMP Toolbox can be found at the following website:
https://connect.ncdot.gov/resources/hydro/HSPDocuments/2014_BMP_Toolbox.pdf.
BMP Maintenance
Perpetual maintenance is required on all public-owned BMPs by the jurisdiction constructing the
roadway. Each BMP shall be recorded in the Charlotte-Mecklenburg Stormwater Services –
County Water Quality Program BMP database and will be subject to annual compliance inspections
and periodic mainten ance.
The only excep tion to th is is when roadway projects are constructed to NCDOT standards that are to
be turned over for main tenance to NCDOT following construction. These BMPs shall be maintained
in accordance with NCDOT requirements and shall not be subject to the local post-construction
ordinance maintenance requirements.
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Appendix D: Phase II Municipal Facility Inventory Procedures
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Phase II Municipal Facility Inventory Standard Operating Procedures (SOPs)
(PP-5)
September 2020
Purpose
The purpose of this document is to describe how Charlotte-Mecklenburg Storm Water Services
(CMSWS) will fulfill Section G.2.a. of Permit NCS000395 in that requires the development of
an inventory of all the Phase II municipal facilities and operations owned and/or operated by the
County, Towns, CPCC and CMS that have significant potential for generating polluted
stormwater runoff. This document further describes what actions will be taken by CMSWS to
address this pollution potential in compliance with Permit requirements. This is under the
section of the Permit entitled Pollution Prevention and Good Housekeeping for Municipal
Operations.
Procedure for Evaluation of Facilities
During the first Permit term, the following language was contained in Section G regarding
Pollution Prevention and Good Housekeeping for Municipal Operations: “Develop an inventory
of all facilities and operations owned and operated by the permittee with the potential for
generating polluted stormwater runoff. Specifically inspect the potential sources of polluted
runoff, the stormwater controls, and conveyance systems. Evaluate the sources, document
deficiencies, plan corrective actions, and document the accomplishment of corrective actions.”
CMSWS updated its Stormwater Quality Management Program Plan (SWMP) effective July 1,
2005 to include procedures to evaluate 20 percent of the municipal operations each year of the 5-
year Permit ending June 30, 2010 in order to identify the facilities and operations owned and/or
operated by the County, Towns, CPCC and CMS that have significant potential for generating
polluted stormwater runoff and are therefore required to comply with this part of the Permit. The
program element for this requirement was PP-5. CMSWS used the phased approach described in
“A” below to conduct this evaluation. This evaluation was completed by the end of the Permit
term on June 30, 2010, resulting in the development of the Tables 17, 18, 19, and 20 of the
FY2021 version of the SWMP.
Mecklenburg County’s Phase II Permit was renewed on November 11, 2011. This new Permit
changed Section G from applying to facilities with the “potential for generating polluted
stormwater runoff” to applying to facilities with the “significant potential for generating polluted
stormwater runoff.” This change resulted in CMSWS changing its evaluation procedures to
those described in “B” below. This evaluation was completed at the end of the Permit term on
June 30, 2015.
A. FIRST PERMIT TERM
1. Accumulate a listing of all county and town-owned properties in a spreadsheet format.
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2. Determine if the properties are located in an urbanizing area (UA). All properties in
Mecklenburg County have been deemed to be an urbanizing area by the State of North
Carolina.
3. Determine which properties do not contain building improvements (i.e. vacant parcels).
Properties containing no building improvements are deemed to have no potential to
pollute stormwater and will not likely have a stormwater conveyance system. To conduct
this evaluation, CMSWS will:
a. Use the attached spreadsheet format to collect data from each jurisdiction
including the County (spreadsheet already completed) and each of the Towns,
CMS and CPCC. The spreadsheets are located in the following directory:
G:\WQxfer\WQ\Phase II Inventory.
b. Sort the parcels in the spreadsheet by ascending size and start the evaluation with
the smaller parcels first. After sorting, each parcel will be assigned a database
number in the first column in the spreadsheet starting with the number one (1) for
the smallest parcel.
c. Review aerial photographs of the properties on-line through use of Polaris with
the “parcel number labels”, “streams”, “SWIM buffer”, “10-ft Contours” and
“aerial photography” layers turned on. The parcel will also be highlighted by
using the “ID parcel” tool.
d. CMSWS staff will print out copies of the map and the ownership information for
documentation. The database number for that file will be handwritten on the
upper right-hand side of the map and the ownership record stapled behind the
map. The hard copies will be filed in a three-ring binder by database number.
e. Mark the number of buildings in the appropriate column of the spreadsheet for
each parcel.
f. Properties with no buildings or a single building are not included in the Phase II
process at this time. CMSWS staff will mark the “Applicable” column with “N”
and add a comment as to why the property is not applicable to Phase II (i.e. – no
building structures).
4. Other parcels containing 2 or more buildings will require further evaluation to determine
if applicable to the Phase II process:
a. By reviewing the aerial photographs and contours, determine if the property
discharges directly into a stream without going through a MS4 system (system
maintained by City and County). CMSWS staff can use Mecklenburg County
Stormwater Ser vices Interactive Mapping site
athttp://www.704336rain.com/disclaimer.html to view storm drain inlets and
piping to assist in this evaluation. If the storm drain system meets these criteria,
Phase II is applicable to this property. CMSWS staff will mark the “Applicable”
column as “Y” and add a comment as to why the property is applicable to Phase II
(i.e. storm drainage system discharges directly to a stream). If it is unclear the
property drains directly to the surface water, do not mark anything on the
spreadsheet.
b. Field evaluations will be required for all remaining properties without a “Y” or an
“N” in the “Applicable” column. Field evaluations will be conducted in the
following manner:
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i. The Phase II Parcel Evaluation Sheet will be used to document
applicability. Each step of the flow chart will be circled as evaluated as
well as notes related to applicability or non-applicability.
ii. The operations or activities that have the potential to pollute stormwater
will be noted as well. Photographs will be taken if staff is unclear of
applicability.
iii. The Phase II Parcel Evaluation Sheet will be stapled behind the
ownership records page and re-filed in the appropriate three-ring binder.
iv. CMSWS staff will update the spreadsheet with a “Y” or “N” in the
“Applicability” column as appropriate.
B. SECOND PERMIT TERM
CMSWS changed its evaluation procedures for the second Permit term to include facilities with
the “significant potential for generating polluted stormwater runoff” in the Pollution Prevention
and Good Housekeeping Program described in Section II, Section G.2.a of the Permit. These
new procedures are less inclusive than those applied during the first Permit term; therefore,
facilities and operations identified for coverage prior to 2011 were left in the program thus going
beyond minimum Permit requirements. For the purposes of this Permit, “significant potential for
generating polluted stormwater runoff” shall mean that the facility meets both of the following
criteria:
1. Exposure of significant materials based on the “Exposure Checklist” included in numbers
12 through 14 of NCDEQ’s “No Exposure Certification Form” (NCGNE0000) (see
attached Form for Evaluating Exposure of Significant Materials), and
2. No written procedures or controls in place to prevent pollution.
Facilities that meet the above criteria are added to the Pollution Prevention/Good Housekeeping
Program and the co-permittees that own and/or operate these facilities are required to implement
long-term pollution prevention measures to reduce the potential for polluted stormwater runoff,
including (but not limited to) the following:
1. Development of a full Stormwater Pollution Prevention Plan.
2. Development of written Standard Operating Procedures (SOPs) for activities on-site that
have a significant potential to pollute stormwater.
3. Completion of required inspections.
4. Completion of required pollution prevention training for on-site staff.
Based upon guidance documents provided by NCDEQ in the BIMS database, jurisdictions will
review several types of municipal operations in their evaluation. Below is a listing of these
municipal operation types along with a summary of how each has currently been addressed or
will be addressed by CMSWS.
1. Transfer stations – The County operates a total of five (5) solid waste recycling centers,
which are currently included in the Pollution Prevention and Good Housekeeping
Program. One of these, the Old Compost Central, is no longer open to the public and
only receives materials from City operations. It is planned to close in late 2021.
2. Fleet maintenance – All fleet maintenance that is performed by the co-permittees is
conducted at the facilities that are currently inspected under the Pollution Prevention and
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Good Housekeeping Program. Fleet maintenance not performed at currently inspected
sites is contracted to outside vendors. This was verified via emails to co-permittee staff
during the week of 9/28/2020 and correspondence can be found on the LAN as follows:
Z:\20-21 City Works Server Attachments\PP-5\Emails on vehicle maintenance from Co
permittees.
3. Airports – None of the co-permittees operate airports.
4. Animal shelters – The Town of Cornelius is the only Mecklenburg County Phase II
jurisdiction that operates an animal shelter. This facility will be evaluated in FY2021
utilizing the Facility Exposure Form to determine if it has a significant potential to
pollute. Appropriate measures will be implemented to minimize storm water pollution
issues based on this evaluation.
5. Wastewater Treatment Plants - None of the co-permittees operate wastewater treatment
plants.
6. Water plants – None of the co-permittees operate water treatment plants.
7. Construction debris sites – Mecklenburg County operates the Foxhole Landfill, which
accepts construction and demolition waste. This facility is currently inspected under the
Pollution Prevention and Good Housekeeping Program.
8. Transit authority - None of the co-permittees operate public transit systems.
9. Public works operations – Public Works facilities have been evaluated and are currently
included in the Pollution Prevention and Good Housekeeping Program.
10. Prisons – None of the co-permittees operate prisons; however, Mecklenburg County does
operate two jails (Mecklenburg County Jail Central and Mecklenburg County Jail North),
which were evaluated in FY14. It was determined that they do not have a significant
potential for stormwater pollution and were not be included in the Pollution Prevention
and Good Housekeeping Program. The contact for these jails is Captain Mike Greer (704-
336-8544).
11. Emergency service facilities – Emergency service facilities have been evaluated.
Mecklenburg County operates the Mecklenburg County Medic facility, which is currently
included in the Pollution Prevention and Good Housekeeping Program. The Towns’ fire
departments operate emergency services along with the individual fire stations. All fire
stations owned and operated by the Towns, as well as volunteer fire departments that
operate within a co-permittee jurisdiction, were evaluated in FY2020, and were
determined not to have a significant potential to pollute. Therefore, these facilities will
not be included in the Pollution Prevention and Good Housekeeping Program.
12. Fire stations – All of the co-permittees operate one or more fire stations. All fire stations
operated in the Towns are owned by the Towns except one of the four (4) stations in
Huntersville and both stations in Mint Hill, which are owned by independent volunteer
fire departments (VFDs). All fire stations located in the Towns, as well as several VFD
owned and operated fire stations in the County, were evaluated in FY2020 utilizing the
Facility Exposure form and were determined not to have a significant potential to pollute.
Therefore, these facilities will not be included in the Pollution Prevention and Good
Housekeeping Program.
13. Landfills – Mecklenburg County operates one active landfill (Foxhole) and one inactive
landfill (Harrisburg Rd.). The inactive site is now the location of the CT Meyers golf
course where Mecklenburg County Solid Waste still performs ground water monitoring.
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The Foxhole landfill and the CT Meyers golf course are included in the Pollution
Prevention and Good Housekeeping Program.
14. Schools – CMS and CPCC school facilities have been evaluated and are included in the
Pollution Prevention and Good Housekeeping Program. Newly added CMS and CPCC
schools are identified through the municipal inventory process. All new CMS schools are
added to the Pollution Prevention and Good Housekeeping Program for CMS. New CMS
schools are inspected as they are added and then are inspected on a rotational basis with
all other schools going forward. All new CPCC school facilities to date have been
additions to existing campuses which are already included in the Pollution Prevention and
Good Housekeeping Program.
15. Parks – On 9/30/2020, the Park and Recreation Director with each co-permittee was
contacted and informed that CMSWS wanted to ensure that all park properties with a
potential to pollute have been evaluated. They were asked if their parks included
facilities with vehicle or equipment maintenance or storage and/or chemical or fuel
storage. Mint Hill, Matthews, Davidson, and Huntersville stated that they did not have
any such facilities. Cornelius stated that most of their larger parks have a small fuel
cabinet where a couple gallons of gas or diesel fuel for equipment and gators is kept.
They also keep gators at several parks but do not service vehicles in-house. Based on this
information, these facilities do not rise to the level of a significant potential to pollute and
will not be included in the Pollution Prevention and Good Housekeeping Program.
Pineville reported that they have a Park Maintenance Facility that has vehicle/equipment
storage and maintenance as well a chemical storage and diesel fuel tank. This facility
will be evaluated in FY2021 utilizing the Facility Exposure Form to determine if it has a
significant potential to pollute. Appropriate measures will be implemented to minimize
storm water pollution issues based on this evaluation. All email correspondence with co-
permittee staff can be found on the LAN as follows: Z:\20-21 City Works Server
Attachments\PP-5\Park and Rec emails on facilities. Contact information for Parks:
o County Parks – Peter Cook, Deputy Director (980-314-1041Cornelius – John
DeKemper, Asst. Director (704-892-6031)
o Davidson – Jesse Bouk (704-892-7591)
o Huntersville – Michael Jaycocks, Director (704-766-2220)
o Matthews – Corey King, Director (704-708-1263)
o Mint Hill – Steve Frye, Director (704-545-9726)
o Pineville – Kr isty Detwiler, Director (704-889-2291)
16. Police Departments – The six (6) Towns operate Police Departments, but the County
does not. The police stations include offices with no significant potential to pollute;
therefore, they are not included in the Pollution Prevention and Good Housekeeping
Program.
17. Waste recycling centers – The County operates a total of five (5) solid waste recycling
centers, which are currently included in the Pollution Prevention and Good Housekeeping
Program. One of these, the Old Compost Central, is no longer open to the public and
only receives materials from City operations. Plans are to close the facility in late 2021.
18. Vehicle maintenance operations – None of the co-permittees operate vehicle maintenance
facilities as dedicated municipal operations. All fleet maintenance that is performed by
the co-permittees is conducted at their municipal facilities that are currently inspected
under the Pollution Prevention and Good Housekeeping Program. Fleet maintenance that
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is not performed by the co-permittee is contracted to outside vendors. This was verified
via emails to co-permittee staff during the week of 9/28/2020 and correspondence can be
found on the LAN as follows: Z:\20-21 City Works Server Attachments\PP-5\Emails on
vehicle maintenance from Co permittees
19. Vehicle wash operations - None of the co-permittees operate Vehicle Wash Operation
facilities as dedicated municipal operations. Three (3) Phase II municipal facilities
include areas where they wash vehicles and/or equipment as part of their standard
operations, including the Towns of Cornelius, Matthews and Huntersville. These
operations are inspected annually as part of the inspection of the municipal facility under
the Pollution Prevention and Good Housekeeping Program.
20. Pump stations or lift stations - None of the co-permittees operate Pump Station or Lift
Station facilities as dedicated municipal operations.
Based on the above summary, in FY2021 field evaluations will be performed at the following
facilities:
1. Town of Cornelis Animal Shelter
2. Town of Pineville Park Maintenance Facility that has vehicle/equipment storage and
maintenance as well a chemical storage and diesel fuel tank.
The Facility Exposure Form will be used during this evaluation to determine if the facilities have
a significant potential to pollute. Appropriate measures will be implemented to minimize storm
water pollution issues based on this evaluation, including adding the facilities to the Program as
necessary. All field evaluations and follow up actions will be document in Cityworks using the
Activity Report form.
Co-permittees purchase, and in some case sell, properties necessitating that the inventory be
updated on an annual basis. The process for updating the inventory is described below.
1. Prior to January 31st of every year, staff with CMSWS will use the Mecklenburg County
Open Mapping system to obtain an updated inventory of all properties that are owned by
the co-permittees, including the County, six (6) Towns, CPCC and CMS.
2. Prior to March 31st of every year, staff will complete a comparison of the updated
inventory to the inventory on file from the previous fiscal year. The inventory will be
updated with all new co-permittee properties.
3. Prior to May 31st of every year, staff will evaluate the new properties added to the
inventory to determine if the properties have a significant potential to pollute as defined
above. This process is as follows:
a. The most current aerial imagery available will be used to determine if no
buildings are located on the property in which case the property will be identified
as not having a significant potential to pollute and will not be included in the
Pollution Prevention and Good Housekeeping Program.
b. The inventory will be updated to indicate that the property was not included in the
Program by placing an “N” in the column entitled “Significant Potential to
Pollute” and a “N” in the column entitled “Pollution Prevented or Eliminated.” A
comment as to why (i.e. – no building on property) will be added to the inventory.
An Activity Report will be completed in Cityworks to document the identification
process for properties with no significant potential to pollute. Staff will email
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their supervisor regarding completion of this evaluation and indicate the Activity
Report number.
c. Properties with one or more buildings (excluding single family homes) will be
field evaluated and the Form for “Evaluating Exposure of Significant Materials”
(see Attachment 2) will be completed. The form is divided into three (3) sections,
including Exposure to Precipitation, Above Ground Storage Tanks, and
Secondary Containment. If the answer is “Yes” to any of the questions under
Exposure to Precipitation or “No” to any of the questions under Above Ground
Storage Tanks and Secondary Containment, then the facility has a significant
potential to pollute unless:
i. Written procedures or controls are in place to prevent pollution; or
ii. The source(s) of pollution can be permanently eliminated.
If either of these two (2) conditions for exclusion from having a significant
potential to pollute currently exist or can be developed, then staff will select the
appropriate “Yes” or “No” box on the form and indicate under “Comments” at the
end of each section the appropriate exclusion option and whether it currently
exists or needs to be developed. If no exclusion option exists, then the
appropriate box is selected, and no comment provided.
d. If the answer is “No” to all the questions under Exposure to Precipitation and
“Yes” to all the questions under Above Ground Storage Tanks and Secondary
Containment, then the facility does not have a significant potential to pollute.
However, there may be pollution sources that are not listed on the form, such as
vehicle washing outside or a leaking drum. In such cases, staff will note this
under “General Comments” at the bottom of the form. In all such situations, staff
must implement immediate actions to remove the pollution source, including
issuing a Notice of Violation and/or requiring that SOPs be implemented to
eliminate/control the source.
e. Staff will complete an Activity Report in Cityworks to document the field
evaluation and the Form will be attached. Staff will indicate in the Activity
Report whether the property has a significant potential to pollute and recommend
a course of action. Staff will submit the Activity Report documenting the
completion of the field evaluation to their supervisor for review and follow up.
f. The supervisor will review the Activity Report and discuss with staff as
necessary. The supervisor will decide the appropriate course of action and the
Activity Report will include a description of that action and document when it is
completed. For example, if it is decided that there is no significant potential to
pollute, the lead staff will explain this in the Activity Report and update the
inventory by placing an “N” in the column entitled “Significant Potential to
Pollute” and a “N” in the column entitled “Pollution Prevented or Eliminated.”
The Activity Report number will be indicated in the inventory and then closed.
No further action is required.
g. If it is decided that there is a significant potential to pollute, but that one of the
two (2) exclusion options described above can be implemented, then the
supervisor will assign this work to staff and follow up to ensure completion at
which point the Activity Report will be updated with a description of the actions
taken and the inventory updated by placing a “Y” in the column entitled
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“Significant Potential to Pollute” and a “Y” in the column entitled “Pollution
Prevented or Eliminated.” A brief description of the actions completed will be
provided in the comment column of the inventory. The Activity Report number
will be indicated in the inventory and then closed. No further action is required.
h. If it is decided that there is a significant potential to pollute and the two (2)
exclusion options cannot be implemented, then the supervisor will explain this in
the Activity Report and update the inventory by placing a “Y” in the column
entitled “Significant Potential to Pollute” and a “N” in the column entitled
“Pollution Prevented or Eliminated.” A comment will also be added to the
inventory explaining why. The Activity Report number will be indicated in the
inventory and then closed. The facility will be added to the Pollution Prevention
and Good Housekeeping Program and the four (4) long-term pollution prevention
measures will be implemented as described in this document.
i. If it is decided that there is no significant potential to pollute but pollution sources
are present at the facility that are not listed on the form, then the supervisor will
ensure that staff complete the necessary follow up actions to eliminate the
source(s). The Activity Report will be updated with a description of the actions
taken and the inventory updated by placing a “N” in the column entitled
“Significant Potential to Pollute” and a “Y” in the column entitled “Pollution
Prevented or Eliminated.” A brief description of the actions completed will be
provided in the comment column of the inventory. The Activity Report number
will be indicated in the inventory and then closed. No further action is required.
j. In some situations, the supervisor may decide that even though a significant
potential to pollute does not exist there is a potential to cause negative water
quality impacts and sources cannot be effectively eliminated or controlled. In
such cases, the supervisor may elect to implement one (1) or more of the four (4)
long-term pollution prevention measures described in this document. A brief
description of the actions to be undertaken will be provided in the comment
column of the inventory. The Activity Report will be updated with a description
of the actions taken and the inventory updated by placing a “N” in the column
entitled “Significant Potential to Pollute” and a “Y” in the column entitled
“Pollution Prevented or Eliminated.” A brief description of the actions completed
will be provided in the comment column of the inventory. The Activity Report
number will be indicated in the inventory and then closed. No further action is
required.
4. Prior to June 30th of every year, staff will contact all co-permittees either by email or
letter providing a list of all their facilities and/or operations that have been determined to
have a significant potential to pollute and are therefore subject to the Pollution Prevention
and Good Housekeeping Program. Co-permittees will be asked to respond back with any
additional facilities and/or operations that should be added to the list or indicate that the
list is complete. The supervisor may assign field evaluations or other follow up actions
as necessary based on these responses to ensure that the inventory is updated as
necessary. All the above actions will be documented in an Activity Report in Cityworks
with all correspondences attached. The end result will be the completion of the updated
inventory prior to June 30th of every year that has been verified in writing by each co-
permittee.
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5. The inventory must be completed by June 30th of every year.
6. If follow up actions are deemed necessary for future fiscal years, the supervisor will be
responsible for incorporating these actions into annual Work Plans.
7. The supervisor will work with the Program Manager to update the SWMP to include new
properties into the Pollution Prevention and Good Housekeeping Program.
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Phase II Municipal Facility Inventory (PP-5)
CMS, CPCC, County or Town of XXXX
PID Physical Address Property
Use
No. of
Buildings
Total
Acres
Date
Evaluated
Staff
Performing
Evaluation
Significant
Potential to
Pollute (Y/N)
Pollution
Prevented or
Eliminated
(Y/N)
Activity
Report #
Comment /
Justification
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Form for Evaluating Exposure of Significant Materials
Facility Name (PID): Facility DB#:
Inspector: Date: Town:
NA Yes No
Exposure to Precipitation: Are any of the following materials
or activities exposed to precipitation, now or in the
foreseeable future? (Please check either “Yes” or “No.”) If
you answer “Yes” to any of these items, the facility is
determined to have a significant potential for generating
polluted stormwater runoff and is to be incorporated into
CMSWS’s Pollution Prevention and Good Housekeeping
Program unless written procedures or controls are in place to
prevent pollution.
Using, storing, or cleaning industrial machinery or equipment,
and areas where residuals from using, storing or cleaning
industrial machinery or equipment remain and are exposed to
storm water.
Materials or residuals on the ground or in stormwater inlets from
spills/leaks
Materials or products from past industrial activity
Material handling equipment (except adequately maintained
vehicles)
Materials or products during loading/unloading or transporting
activities
Materials or products stored outdoors (except final products
intended for outside use [e.g., new cars] where exposure to
stormwater does not result in the discharge of pollutants)
Materials contained in open, deteriorated or leaking storage
drums, barrels, tanks, and similar containers
Materials or products handled/stored on roads or railways owned
or maintained by the discharger
Waste material (except waste in covered, non-leaking containers
[e.g., dumpsters])
Application or disposal of process wastewater (unless otherwise
permitted)
Particulate matter or visible deposits of residuals from roof stacks
and/or vents not otherwise regulated (i.e., under an air quality
control permit) and evident in the stormwater outflow
Empty containers that previously contained materials that are not
properly stored (i.e., not closed and stored upside down to
prevent precipitation accumulation)
For any exterior ASTs, as well as drums, barrels, tanks, and
similar containers stored outside, has the facility had any releases
in the past three (3) years?
Comments:
NA Yes No Above Ground Storage Tanks (ASTs): If you answer “No” to
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any of the following items, the facility is determined to have a
significant potential for generating polluted stormwater
runoff and is to be incorporated into CMSWS’s Pollution
Prevention and Good Housekeeping Program unless written
procedures or controls are in place to prevent pollution
Are exterior ASTs and piping free of rust, damaged or weathered
coating, pits, or deterioration, or evidence of leaks?
Is secondary containment provided for all exterior ASTs? If so,
is it free of any cracks, holes, or evidence of leaks, and are drain
valves maintained locked shut?
Comments:
NA Yes No
Secondary Containment: If you answer “No” to any of the
following items, the facility is determined to have a
significant potential for generating polluted stormwater
runoff and is to be incorporated into CMSWS’s Pollution
Prevention and Good Housekeeping Program unless written
procedures or controls are in place to prevent pollution.
Is secondary containment provided for all single above ground
storage containers (including drums, barrels, etc.) with a
capacity of more than 660-gallons?
Is secondary containment provided for above ground storage
containers stored in close proximity to each other with a
combined capacity of more than 1,320-gallons?
Is secondary containment provided for Title III Section 313
Superfund Amendments and Reauthorization Act (SARA) water
priority chemicals*?
Is secondary containment provided for hazardous substances**
designated in 40 CFR §116?
Are release valves on all secondary containment structures
locked in the closed position?
Is accumulated water within an open secondary containment
berm inspected prior to release (using a standard form)?
Is water that is contaminated disposed of properly, in accordance
with a SOP?
Comments:
General Comment:
Inspector: _____________________________
Inspector Signature: _______________________________
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Appendix E: Stormwater Inspection Checklist for Municipal Facilities
Stormwater Inspection Report/Checklist
188
Facility Name: Inspection Type:
MH-I PP-2
PP-2-CMS PP-2-CPCC
IN-I
Permit No.:
NCG
NCS0
Not Applicable
Permit Effective
Date (if applicable):
Permit Status
(If not currently
permitted):
Inspection
Date: Discharges to:
Inspector(s):
Facility Personnel
Assisting with Inspection
(Name/Phone Number):
Entry Time: Exit Time:
SIC Code: Facility Hours of
Operation:
Facility Description:
File Review/History:
Inspection Summary:
This form is a procedural guide for Inspectors to follow when conducting facility stormwater compliance inspections.
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189
I. Site Inspection
Were deficiencies observed with the following items?
(Inspector should comment on violations/deficiencies observed) Yes No NA Repeat Finding
1. Stormwater System: catch basins, open ditches, channels, pipes, outfalls, etc.
Comments:
2. Erosion Issues
Comments:
3. Structural Stormwater BMPs
Comments:
4. Illicit Discharges / Connections
Comments:
5. Aboveground Storage Tanks (ASTs): List size, material type, and if secondary
containment is provided
Comments:
6. Underground Storage Tank (UST) Fill Port Area
Comments:
7. Outdoor Material Storage Area(s)
Comments:
8. Outdoor Processing Area(s)
Comments:
9. Loading/Unloading Area(s)
Comments:
10. Vehicle/Equipment Area(s): fueling, washing, maintenance, storage
Comments:
11. Oil/Water Separator / Pretreatment
Comments:
12. Waste Storage / Disposal Area(s): scrap metal, dumpsters, grease bins, etc.
Comments:
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13. Food Service Area(s)
Comments:
14. Indoor Material Storage Area(s)
Comments:
15. Indoor Processing Area(s)
Comments:
I. Site Inspection (continued) Yes No NA Repeat
Finding
16. Floor drains – illicit connections
Comments:
17. Spill Response Equipment
Comments:
II. Stormwater Pollution Prevention Plan
Does the site have a Stormwater Pollution Prevention Plan (SPPP)?
If the site has a SPPP, then complete questions in Sections II and III.
1. Does the Plan include a General Location (USGS) map?
Facility location in relation to roads and surface waters. Includes: name of receiving stream or name of municipal storm sewer
system, and accurate lat. and long. of point of discharge.
2. Does the Plan include a “Narrative Description of Practices”?
Should cover storage practices, loading and unloading areas, outdoor process areas, dust or particulate generating or control
processes, waste disposal practices, etc.
3. Does the Plan include a detailed site map including outfall locations and
drainage areas?
Should show
Location of industrial activities (storage areas, disposal areas, process areas, unloading and loading areas)
The drainage structures
Drainage areas for each outfall and activities occurring in the drainage area
Building locations
Existing BMPs and impervious surfaces and the % of each drainage area that is impervious
For each outfall, a narrative description of the potential pollutants which could be expected to be present in the stormwater
discharge.
This forces permittee to analyze the site with relation to stormwater discharges. It is also a tool for the inspector to understand
if the site has changed over time, i.e. if site map does not match facility they must update their plan.
4. Does the Plan include a list of significant spills occurring during the past 3
years?
Needs to include corrective actions that were taken. The permittee needs to know what the reportable quantities are for
wastewater, oil pollution, and SARA Title III.
5. Have stormwater outfalls been evaluated for the presence of non-stormwater
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discharges?
Signature required:
Corporation - signed by Responsible Corporate Officer or assigned manager
Partnership or Sole Proprietorship – General Partner or the Proprietor
Municipality, State, Federal, or other public agency – either principal executive officer or ranking elected official
6. Has the facility evaluated feasible alternatives to current practices?
Provide a review of the technical and economic feasibility of changing the methods of operations and/or storage practices to
eliminate or reduce exposure of materials and processes to stormwater.
In areas where elimination of exposure is not practical, the stormwater management plan shall document the feasibility of
diverting the stormwater runoff away from areas of potential contamination.
7. Does the facility provide all necessary secondary containment?
Applies to liquid raw materials, manufactured products, waste materials, or by-products
Single AST capacity > 660 gallons
Multiple AS containers in close proximity to each other with a total combined capacity of > 1,320
II. Stormwater Pollution Prevention Plan (continued) Yes No NA Repeat
Finding
If connected to SW conveyance; controlled by manually activated valves or other similar devices? (Closed?)
Collected water observed for color, foam, outfall staining, visible sheens, and dry weather flow prior to release
Document individual making observation, description of water, date, and time of release
Retain record 5 years
8. Does the Plan include a BMP summary?
Narrative description of BMPs to be considered including oil and grease separation, debris control, vegetative filter strips,
infiltration and stormwater detention or retention, where necessary.
The need for structural BMPs shall be based on the assessment of potential sources to contribute significant quantities of
pollutants to stormwater discharges and data collected through monitoring of stormwater discharges.
9. Does the Plan include a Spill Prevention and Response Plan (SPRP)?
Assessment of potential pollutant sources based on materials inventory of the facility
Facility personnel responsible for implementing the SPRP shall be identified
Responsible person shall be on-site at all times during facility operations that have the potential to contaminate stormwater
runoff through spills or exposure of materials associated with the facility operations.
10. Does the Plan include a Preventative Maintenance and Good Housekeeping
Plan?
Document schedules of inspections and maintenance activities of stormwater control systems, plant equipment and systems
Inspect material handling areas
Regular cleaning schedules of these areas
11. Does the facility provide and document Employee Training?
Provide at a minimum, annual training for all personnel, including: proper spill response, cleanup procedures, preventative
maintenance activities for all personnel involved in any of the facility’s operations that have the potential to contaminate
stormwater runoff
Develop training schedule and identify facility personnel responsible for implementing the training
12. Does the Plan include a list of Responsible Parties?
Identify position responsible for the overall coordination, development, implementation, and revision of the SPPP
13. Is the Plan reviewed and updated annually?
Have there been any changes to the design, construction, operation, or maintenance of the facility, which would have a
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192
significant effect on the potential for the discharge of pollutants to surface waters? Does plan include changes?
14. Does the Plan include a Stormwater Facility Inspection Program?
Inspect semi-annually at a minimum - once in Fall and once in Spring
Inspection and subsequent maintenance activities performed shall be documented
Record date and time
Individual performing inspection
Narrative description of the stormwater outfall and plant equipment and systems
Records should be incorporated into the SPPP
Stormwater Pollution Prevention Plan Comments:
III. Qualitative and Analytical Monitoring Yes No NA Repeat
Finding
1. Has the facility conducted its Qualitative Monitoring semi-annually?
Color Odor Clarity Floating Solids
Suspended solids Foam Oil Sheen Other indica tors
2. Has the facility conducted its Analytical Monitoring?
3. Has the facility conducted its Analytical Monitoring from Vehicle Maintenance
areas?
Qualitative and Analytical Monitoring Comments:
IV. Permit and Outfalls
1. Is a copy of the Permit and the Certificate of Coverage available at the site?
2. Were all outfalls observed during the inspection?
3. If the facility has representative outfall status, has it been documented by the NC
Division of Water Quality?
4. If the facility has a No-Exposure Certificate, has the facility self-inspected and
documented this on an annual basis?
Stormwater Inspection Report/Checklist
193
Permit and Outfalls Comments:
V. Phase II Permit Requirements (See Attached Compliance Document)
1. Is the permittee properly disposing of wastes removed from the streets, parking
lots and the MS4 and documenting the quantity (lbs., cubic yards)? (inspector
should indicate the disposal method in the comments section).
2. Were any public transportation (roadway) projects constructed within the last
year? (list roadway projects in comments section)
3. Is the permittee implementing BMPs (and maintaining records) to reduce polluted
storm water runoff from the municipally-owned streets, roads, and public parking
lots?
4. Is the permittee implementing BMPs (and maintaining records) to reduce polluted
storm water runoff from the municipally owned or maintained storm water catch
basins and conveyance systems?
5. Did the Co-Permittee provide pesticide license numbers (indicate license #) for all
employees and contractors performing application activities and was license validity
verified through a search on the NC Dept. of Agriculture and Consumer Services
website (indicate Expiration date)?
6. Does the permittee document areas treated with pesticides/herbicides for
comparison to annual thresholds?
7. Did permittee comply with pesticide limitations specific to the Goose Creek
Watershed?
8. Is the permittee implementing BMPs to reduce polluted storm water runoff from
vehicle and equipment cleaning areas?
Phase II Permit Requirement Comments:
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Appendix F: Co-Permittee Responsibilities for Compliance with Phase Permit
Requirements
Stormwater Quality Management Program Plan - MS4 Permit No. NCS000395 - March 2021
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Co-Permittee Responsibilities for Compliance with Phase Permit Requirements
February 24, 2021
Provided below is a list of those activities that each co-permittee must complete to comply with
Permit requirements working in cooperation with Charlotte-Mecklenburg Storm Water Services
(CMSWS). According to the terms of the Permit, each co-permittee is responsible for
compliance within their respective jurisdiction.
1. Work with CMSWS to ensure an effective public outreach regarding stormwater quality
by making educational materials available in newsletters and/or other regular
communications by the co-permittee and by maintaining brochures in a location
available to the public as requested by CMSWS. Contact CMSWS if new educational
materials are needed.
2. Maintain a link from the co-permittee web site to the CMSWS web site.
3. Assist as requested with volunteer programs, including working with CMSWS to
maximize volunteer participation, schedule events, collect trash following events, etc.
4. Receive and respond as necessary to reported problems with the storm sewer system
within the co-permittee’s jurisdiction.
5. Work with CMSWS to update and adopt ordinances required for Permit compliance as
requested.
6. Notify CMSWS of any actions necessary to improve the effectiveness of the Phase II
Permit compliance program.
7. Ensure compliance with erosion and sediment control requirements at co-permittee
construction sites.
8. Ensure that all co-permittee projects comply with post-construction ordinance
requirements, including transportation projects. Guidance for ensuring compliance by
transportation projects is provided at the following link:
http://charlottenc.gov/StormWater/Regulations/Documents/PostConstructionPolicyforPu
blicTransportationProjects.pdf).
9. Maintain and implement an Operation and Maintenance (O&M) program for
municipally-owned or maintained structural stormwater controls installed for compliance
with the post-construction ordinances adopted by Mecklenburg County and the Towns of
Cornelius, Davidson, Huntersville, Matthews, Mint Hill, and Pineville on June 30, 2007
and by the City of Charlotte on July 1, 2008. At a minimum, the O&M program shall
specify that annual inspections are to be performed and the routine maintenance that is to
be performed.
10. CMSWS performs the required annual inspections of these stormwater control measures
and provides a written report to the co-permittee who is responsible for ensuring that all
deficiencies indicated in the report are properly resolved. The co-permittee is to submit
documentation of completion to CMSWS.
11. Ensure that co-permittee employees receive the training provided by CMSWS regarding
proper pollution prevention and good housekeeping practices at municipal facilities as
well as training on recognizing and reporting illicit discharges and improper waste
disposal. Keep records of employee training for a minimum of five (5) years.
12. CMSWS performs the required annual inspections of the co-permittee facilities
identified as having a significant potential to pollute and provides a written report to the
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co-permittee who is responsible for ensuring that all deficiencies indicated in the report
are properly resolved. The co-permittee is to submit documentation of completion to
CMSWS.
13. Implement the co-permittee’s Storm Water Pollution Prevention Plan, including (but not
limited to):
a. Perform semi-annual inspections of material storage areas.
b. Perform annual outfall inspections during dry conditions.
c. Keep records of inspections for a minimum of five (5) years.
d. Follow procedures when spills occur.
e. Keep records of spills for a minimum of five (5) years.
14. Inform CMSWS if properties are purchased or sold so that an inventory of the co -
permittee’s municipal facilities subject to Permit requirements can be maintained.
15. Implement the following to reduce polluted storm water runoff from the municipally
owned streets and public parking lots:
a. Continue enforcement of existing litter ordinances.
b. Continue existing solid waste collection and recycling services.
c. Continue public education to encourage the proper disposal and recycling of waste.
d. Sweep municipally owned streets and parking lots in identified problem areas.
These problem areas are identified by staff based on accumulations of leaves,
trash, debris, blockages, flooding, etc. Parking lot cleaning may also be
performed after special events and festivals where additional trash and other
pollutants are expected.
e. Continue providing trash receptacles at public parking lots and performing
scheduled trash pick-up.
f. Maintain written records documenting the location and number of parking lots and
streets swept and the pounds of pollutants removed as well as costs for a
minimum of five (5) years. Make these reports available to CMSWS by July 31st
of every year.
g. Ensure that waste collected from street sweeping and parking lot cleaning is
properly disposed of.
16. Implement the following to reduce polluted storm water runoff from the municipally
owned storm sewer systems:
a. Perform catch basin and conveyance system cleaning as well as make repairs to
the storm sewer system in identified problem areas. These problem areas are
identified by staff based on accumulations of leaves, trash, debris, blockages,
flooding, etc.
b. If catch basin and conveyance system cleaning reveals the presence of pollutants,
such as oil, paint, chemicals, etc., notify CMSWS immediately for the initiation
of follow up actions aimed at identifying and elimination pollution sources.
c. Maintain records documenting the number of inlets, outlets, and pipes cleaned
and the pounds of pollutants removed as well as costs for a minimum of five (5)
years. Make these reports available to CMSWS by July 31st of every year.
d. Ensure that waste collected from storm sewer system cleaning is properly
disposed of.
e. Receive and respond to information provided by CMSWS regarding potential
maintenance issues.
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f. Receive and respond to service requests from the public regarding storm drain
system maintenance issues.
17. Implement the following to ensure that municipal employees and contractors are
properly trained and all Permits, certifications, and other compliance measures for
pesticide applicators are followed:
a. Verify that employees and/or contractors that apply pesticides are properly licensed
and maintain copies of these licenses (update at least annually and within 30 days
of hire) and/or license numbers.
b. Comply with pesticide application thresholds described in Table 1 below. Each co-
permittee is responsible for maintaining a list of all locations treated with the
pesticides listed in this table and documenting the date and quantity of material
applied. To obtain guidance for compliance with Permit requirements, notify
Rusty Rozzelle with CMSWS at 980-314-3217 or at
rusty.rozzelle@mecklenburgcountync.gov when either or both of the following
conditions are met when applying the pesticides listed in Table 1:
• Co-permittee believes a treatment event may reasonably exceed an annual
applicable threshold quantity as described in the table below.
• Co-permittees discharges pesticide in response to a declared pest
emergency situation.
c. Comply with pesticide application limitations in the Goose Creek Watershed
specified in Table 2 below.
18. Implement the following to reduce polluted storm water runoff from vehicle and
equipment cleaning areas:
a. Vehicle washing areas should drain to a permitted sanitary sewer system, if
available.
b. If no sanitary sewer connection is available, the facility should either wash
vehicles at a car wash facility or designate an on-site vehicle washing area that is
not directly connected to a storm drain system, such as grassed areas, gravel
parking areas, or a water quality BMP. This washing area must be designated on
the Site Plan Map within the SWPPP. The following restrictions apply to these
designated washing areas not connected to the sanitary sewer system:
i. Only biodegradable detergents can be used with a pH between 4.0 and 9.0.
ii. Solvents cannot be used to clean vehicles in this area.
iii. Only vehicle exteriors should be washed. Engines or oily equipment /
parts cannot be washed in these areas.
iv. Water usage should be minimized to the extent practicable by using a
pressure washer or low flow nozzle.
Table 1: Pesticide Treatment Thresholds
Pesticide Use Annual Threshold
Mosquitoes and Other Flying Insect Pests 15,000 acres of treatment area (adulticide
applications only) (1)
Aquatic Weed and Algae Control - In
Water
1,000 acres of treatment area
Aquatic Weed and Algae Control - At 200 linear miles of treatment area at water’s
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Pesticide Use Annual Threshold
Water’s Edge edge (2)
Aquatic Nuisance Animal Control - In
Water
200 acres of treatment area
Aquatic Nuisance Animal Control - At
Water’s Edge
200 linear miles of treatment area at water’s
edge (2)
Forest Canopy Pest Control 10,000 acres of treatment area
Intrusive Vegetation Control 500 linear miles (3)
(1) Multiple applications to the same area are added together only for mosquito and other flying
insect pest control.
(2) Applications that occur at the water’s edge in a ditch or canal are counted only once when
one or both sides are treated.
(3) Applications to both sides of a road are added together for the total miles.
Table 2: Pesticide Application Limitations in the Goose Creek Watershed
Pesticide Active Ingredient Code/Limitations
Azinphos-methyl (2)
Benomyl (1)
Captan (1)
Carbaryl (2)
Carbofuran (1)
Chlorpyrifos (3)
Diazinon (2)
Dicofol (2)
Dimethoate (2)
Endosulfan (2)
Esfenvalerate (1)
Ethion (2)
Ethoprop (1)
Fenamiphos (2)
Fonofos (2)
Malathion (2)
Methidathion (2)
Methomyl (1)
Mevinphos (2)
Naled (1)
Parathion (ethyl) (2)
Pendimethalin (2)
Permethrin (1)
Phorate (1)
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Pesticide Active Ingredient Code/Limitations
Phosmet (1)
Phosphamidon (1)
Propiconazole (1)
Pyrethrins (2)
Terbufos (2)
Trichlorfon (2)
Code/Limitations:
(1) This pesticide shall not be applied within 20 yards from the edge of water for ground
applications and within 100 yards for aerial applications;
(2) This pesticide shall not be applied within 40 yards from the edge of water for ground
applications and within 200 yards for aerial applications;
(3) This pesticide shall not be applied within 100 yards from the edge of water for ground
applications and within one-fourth mile for aerial applications.