NCS000421_Renewal Application and Draft SWMPP_20210803

Public Services Department
Stormwater Services Division
July 29, 2021
VIA EMAIL and FEDERAL EXPRESS
DEQ-DEMLR Stormwater Program
Attn: Jeanette Powell
1612 Mail Service Center
Raleigh, NC 27699-1612
.� - ,
NORTH CAROLINA'S INTERNATIONAL CIW
RECEIVED
AUG 0 3 2021
DENR-LAND QUALITY
STORMWATER PERMITTING
RE: City of High Point Permit No. NCS000421
NPDES MS4 Permit Renewal Application Form
Dear Jeanette:
Enclosed please find the NPDES MS4 Permit Renewal Application Form and Final Draft
of the Stormwater Management Program Plan for the City of High Point.
Due to the unresolvable formatting issues within the previously submitted Word
document, it was necessary for us to prepare a new SWMP using DEQ's updated SWMP
Template in order to address all comments and concerns pertaining to the Final Draft
submission.
If you have any questions or concerns, please do not hesitate to contact me.
Respectfully,
Justin T. Gray
Public Services Manager
Enclosures
cc: Randy McCasl1n, Deputy City Manager
Terry Houk, Public Services Director
Robby Stone, PE, Deputy Public Services Director
Anita Simpson, Stormwater Operations Analyst
City of High Point, P.O. Box 230, 211 South Hamilton Street, High Point, NC 27261 USA
Fax:[phone] Phone:[phone] TDD:336.883.8517

D E Q�� NPDES MS4 Permit Renewal Application Form
National Pollutant Discharge Elimination System (NPDES)
�:���'� Municipal Separate Storm Sewer System (MS4)
Please complete the information below and submit this form along with the required supplemental information
to the address indicated. t�
Part I: Permittee Information RECEIVED
Current Permit No.
NCS 000421 AUG 0 3 "
MS4 Name
City of High Point
Owner Name*
Randy E. McCaslin STORMWATER PERMITTI
Owner Title
Interim City Manager
Street Address
211 S. Hamilton Street
City,State Zip
High Point NC 27260
Phone Number
336-883-3291
E-mail Address
[e-mail]
* The owner must be a principal executive officer or ranking elected official for the city/town/entity that
owns/operates the permitted MS4. Any permit enforcement actions will be sent to the owner on record.
Part II: Primary Contact**
Contact Name
Terry Houk
Contact Title
Public Services Director
Employer
City of High Point
Street Address
211 S. Hamilton Street
City,State Zip
High Point NC 27260
Phone Number
336-883-3218
E-mail Address
terry. houk@hih ointnc. ov
** The primary contact is the responsible party who will oversee the day-to-day permit compliance and
Stormwater Management Program implementation. With the exception of enforcement actions, permit
communications originating from NCDEQ will be sent to the primary contact and will be copied to the other
contacts listed below.
Part III: Other Contacts
Contact Name
Robby Stone
E-mail Address
[e-mail]
Contact Name
Justin Gray
E-mail Address
[e-mail]
Contact Name
Anita Simpson
E-mail Address
[e-mail]
Page 1 of 2

Part IV: Required Supplemental Information
Submit one (1) hard copy and one (1) electronic copy of a Draft Stormwater Management Plan (SWMP)
with this permit renewal application. The Draft SWMP must be in the current NCDEQ SWMP Template
format and shall include all required information in order for the permit renewal application to be
considered complete.
Part V: 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 incomplete permit renewal
applications, inclusive of the required Draft SWMP, will not be processed and will be returned to the
permittee.
❑ I am a ranking elected official for the permitted MS4.
❑ I am a principal executive officer for the permitted MS4.
❑ I am a duly authorized representative for the permitted MS4 and have attached the authorization
made in writing by the permit owner listed in Part I of this application, which specifies me as (check
one) :
❑ A specific individual having overall responsibility for the stormwater permit.
❑ A specific position having overall responsibility for the stormwater permit.
Signature:*
�®
Print Name:
Randy E. McCaslin
Title:
Interim City Manager
Signed this A day of , 2021.
* Please note that an original signature is required on this form, any required supplemental information, and any
representative authorization. Photocopies cannot be accepted.
Return this completed form along with the required supplemental information to:
DEQ-DEMLR Stormwater Program
Attn: MS4 Permitting
1612 Mail Service Center
Raleigh, NC 27699-1612
Page 2of2

Draft Final Stormwater Management Plan
City of High Point
NCS000421
July 29, 2021
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NORTH CAROLINA S INTERNATIONAL CITY—
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DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021

Table of Contents
PART1: INTRODUCTION........................................................................................................................ 1
PART2: CERTIFICATION........................................................................................................................ 2
PART 3: MS4 INFORMATION...........................................................
3.1 Permitted MS4 Area..............................................................
3.2 Existing MS4 Mapping..........................................................
3.3 Receiving Waters...................................................................
3.4 MS4 Interconnection..............................................................
3.5 Total Maximum Daily Loads (TMDLs)................................
3.6 Endangered and Threatened Species and Critical Habitat .....
3.7 Industrial Facility Discharges ................................................
3.8 Non-Stormwater Discharges ..................................................
3.9 Target Pollutants and Sources ................................................
3
3
4
4
5
5
6
6
9
PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION ................................... 10
4.1 Organizational Structure.............................................................................................................10
4.2 Program Funding and Budget..................................................................................................... 11
4.3 Shared Responsibility................................................................................................................. 12
4.4 Co-Permittees..............................................................................................................................12
4.5 Measurable Goals for Program Administration..........................................................................12
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM.........................................................14
PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM ........................................... 19
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM..............................21
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM...................................................25
PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ......
27
PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ......................32
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page ii

List of Tables
Table 1: Summary of MS4 Mapping
Table 2: Summary of MS4 Receiving Waters
Table 3: Summary of Approved TMDLs
Table 4: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality
Table 5: NPDES Stormwater Permitted Industrial Facilities
Table 6: Non-Stormwater Discharges
Table 7: Summary of Target Pollutants and Sources
Table 8: Summary of Responsible Parties
Table 9: Shared Responsibilities
Table 10: Co-Permittee Contact Information
Table 11: Program Administration BMPs
Table 12: Summary of Target Pollutants & Audiences
Table 13: Public Education and Outreach BMPs
Table 14: Public Involvement and Participation BMPs
Table 15: Illicit Discharge Detection and Elimination BMPs
Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program
Table 17: Construction Site Runoff Control BMPs
Table 18: Qualifying Alternative Program(s) for Post -Construction Site Runoff Control Program
Table 19: Summary of Existing Post -Construction Program Elements
Table 20: Post Construction Site Runoff Control BMPs
Table 21: Pollution Prevention and Good Housekeeping BMPs
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page iii

PART 1: INTRODUCTION
The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which
the City of High Point will comply with its National Pollutant Discharge Elimination System (NPDES)
Municipal Separate Storm Sewer System (MS4) Permit 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.
This SWMP identifies the specific elements and minimum measures that the City of High Point 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 NCS000421, as issued by NCDEQ. This permit covers activities associated with
the discharge of stormwater from the MS4 as owned and operated by the City of High Point and located
within the corporate limits of the City of High Point.
In preparing this SWMP, the City of High Point has evaluated its MS4 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 parts of the permit. Any major changes to the approved SWMP will require resubmittal,
review, and approval by NCDEQ, and may require a new public comment period depending on the nature
of the changes.
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 1

PART 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 part 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.
❑ 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):
❑ A specific individual having overall responsibility for stormwater matters.
❑ A specific position having overall responsibility for stormwater matters.
Signature:
�d4
Print
Name:
Randy McC slin
Title:
Deputy City Manager
Signed this dda of July, 2021.
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 2

PART 3: MS4 INFORMATION
3.1 Permitted MS4 Area
This SWMP applies throughout the corporate limits of the City of High Point, including all regulated
activities associated with the discharge of stormwater from the MS4. The map below shows the corporate
limits of City of High Point as of the date of this document.
As of January 2020, the jurisdictional and MS4 service area for the City of High Point is 57.8
square miles. The source of this information is the City of High Point, Public Services Department
and Planning & Development Department, which updates jurisdictional and geographical
boundaries as changes occur.
s-
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 3

3.2 Existing MS4 Mapping
The current MS4 mapping includes pipes, flow direction, ditches, inlets, catch basins, manholes, outfalls,
sizes, condition, etc., and is contained in our GIS mapping program and in a secure layer of ThePoint, an
interactive map which allows searches for property information as well as many other types of
information related to areas of High Point. The City of High Point does not provide access to stormwater
structural layers to the general public, however.
Go to https:Hgiswebl0.hi vointnc.gov/JS/ThePoint/ to access the Interactive GIS Data Viewer.
Table 1: Summary of Current MS4 Mapping
Percent of MS4 Area Mapped
99%
No. of Major Outfalls* Mapped
1,203 as of 7-14-2021
*An outfall is a point where the MS4 discharges from a pipe or other conveyance (e.g., a ditch) directly
into surface waters. Major outfalls are required to be mapped to meet permit requirements. A major
outfall is a 36-inch diameter pipe or discharge from a drainage area > 50-acres; and for industrial zoned
areas a 12-inch diameter pipe or a drainage area > 2-acres.
3.3 Receiving Waters
The City of High Point MS4 is located within the Cape Fear and Yadkin River Basins and discharges
directly into receiving waters as listed in Table 2 below. Applicable water quality standards listed below
are compiled from the following NCDEQ sources:
o Waterbody Classification Map
o Impaired Waters and TMDL Mao
o Most recent NCDEQ Final 303(d) List
Table 2: Summary of MS4 Receiving Waters
Receiving Water Name
Stream
Index / AU
Number
Water
Quality
Classification
303(d) Listed Parameter(s)
of Interest
Cape Fear River Basin
Boulding Branch
17-3-2
WS-IV:*
Deep River (including High Point
Lake at normal pool elevation
17-(1)
WS-IV;CA:*
East Fork of Deep River
17-2- 0.3
WS-IV
Fecal Coliform; Turbidity
East Fork of Deep River
17-2- 0.7
WS-IV;CA:*
Fecal Coliform; Turbidity
Hiatt Branch
17-3-1- 1
WS-IV:*
High Point City Lake
17- 1
WS-IV;CA:*
Long Branch
17-2-1- 1
WS-IV
EcoBiological Integrity Fish Com
EcoBiolo 'cal Integrity Benthos
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 4

Long Branch
17-2-1- 2
WS-IV;CA:*
EcoBiological Integrity Fish Com
EcoBiolo ical Integrity Benthos
Mile Branch (Two Mile Branch /
Jackson Lake)
17-7-3
WS-IV:*
Oak Hollow Lake
17-3- 0.7
WS-IV;CA:*
West Fork of Deep River
17-3- 0.3
WS-IV:*
Eco/Biolo ical Integrity Fish Com
West Fork of Deep River
17-3- 0.7
WS-IV;CA:*
Eco/Biolo ical Integrity Fish Com
Richland Creek
17-7- 0.5
WS-IV:*
Fecal Coliform
Richland Creek
17-7- 4
WS-IV;CA:*
Fecal Coliform
Unnamed tributaries within the
Cape Fear River Basin
Yadkin
River Basin
Rich Fork Creek
12-119-7
C
Fecal Coliform
Payne Creek
12-119-7
C
Kennedy Mill Creek
12-119-7
C
Unnamed tributaries within the
Yadkin River Basin
3.4 MS4 Interconnection
The City of High Point MS4 is not interconnected with another regulated MS4 and directly discharges to
the receiving waters as listed in Table 2 above.
The MS4 does not interconnect with the statewide NCDOT MS4 and includes:
a. The interconnection is not receiving stormwater from the NCDOT MS4. The number of
interconnections is known/estimated/unknown. (N/A)
b. The interconnection is not discharging stormwater into the NCDOT MS4. The number of
interconnections is known/estimated/unknown. (N/A)
c. The City of High Point MS4 mapping does not identify interconnections with the NCDOT
MS4.
d. The City of High Point MS4 mapping does not include NCDOT MS4 outfalls.
3.5 Total Maximum Daily Loads (TMDLs)
The TMDL(s) listed in Table 3 below have been approved within the MS4 area, as determined by the map
and list provided on the NCDEO Modeling & Assessment Unit web page. The table also indicates
whether the approved TMDL has a specific stormwater Waste Load Allocation (WLA) for any watershed
directly receiving discharges from the permitted MS4, and whether a Water Quality Recovery Program
has been implemented to address the WLA.
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 5

Table 3: Summary of Approved TMDLs
Water Body Name
TMDL Pollutant(s) of Concern
Stormwater
Water
Waste
Quality
Load
Recovery
Allocation
Program
(Y/N)
Y/N
E. Fork Deep River
Fecal Coliform
Y
Y'
Richland Creek
Fecal Coliform
Y
Y2
Rich Fork Creek
Fecal Coliform
Y
Y'
Y, : Outfall monitoring program only
Y2 : TMDL water quality monitoring plan (2015)
3.6 Endangered and Threatened Species and Critical Habitat
Significant populations of threatened or endangered species and/or critical habitat are identified within the
regulated MS4 urbanized area. Based upon a review of the Endangered and Threatened Species and
Species of Concern by Cooty 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, the species listed in Table 4 have
the potential to occur within the regulated MS4 urbanized area. Of those species listed, Table 4
summarizes the species that may be significantly impacted by the quality of surface waters within their
habitat.
Table 4: Potential Federally Listed Species/Habitat Impacted by Surface Water Quality
Scientific Name
Common name
Species Group
Federal Listing Status
Fusconaia masoni
Atlantic pigtoe
Clams
Proposed Threatened
Notro is mekistocholas
Cape Fear Shiner
Fish
Endangered
Percina rex
Roanoke logperch
Fish
Endangered
Isotria medeoloides
Small whorled pogonia
Flowering Plants
Threatened
Helianthus schweinitzii
Schweinitz's sunflower
Flowering Plants
Endangered
Perim otis subflavus
Tricolored bat
Mammals
Under Review
Clemm s muhlenber ii
Bog Turtle
Reptiles
Threatened
Fusconaia masoni
Atlantic pigtoe
Clams
Proposed Threatened
3.7 Industrial Facility Discharges
The City of High Point MS4 jurisdictional area includes the following industrial facilities which hold
NPDES Industrial Stormwater Permits, as determined from the NCDEO Maps & Permit Data web page.
Table 5: NPDES Stormwater Permitted Industrial Facilities
Permit Number
Facility Name
NCG030009
Thomas Built Buses Inc - High Point
NCG030010
Thomas Built Buses Incorporated (Cape Fear River Basin
NCG030010
Thomas Built Buses Incorporated Yadkin River Basin
NCG030517
Mickey Truck Body Inc - High Point
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 6

NCG050370
Innocor Foam Technologies - ACP, Inc.
NCG060003
Kao Specialties Americas LLC
NCG060041
Piedmont Chemical Ind I LLC
NCG060205
Custom Finishers Incorporated
NCG060244
Hunter Farms Dairy
NCG060359
Innos ec Performance Chemicals
NCG060381
Cambrex High Point Inc.
NCG070029
Glass Unlimited -High Point Inc
NCG080683
High Point City -Fleet Maintenance Facility
NCG080702
High Point City Transit
NCG090020
Axalta Coating Systems U.S.A., LLC (High Point
NCG090021
Akzo Nobel Coatings Incorporated
NCG120105
Kersey Valley MSW Landfill
NCG 140003
Childers Concrete
NCG140215
ARGOS USA - High Point Concrete Facility (previously Ready Mixed Concrete
Plant 75
NCG160041
Larco Construction Co - High Point
NCG170388
Chambers Fabrics Incorporated
NCG180036
Haworth Inc -Wood Seating Plant
NCG 180220
High Point Furniture Industries
NCG180254
Marsh Furniture Co
NCG240007
City of High Point Ingleside Compost Facility
NCGNE0048
Premiere Cushion -Hickory Springs Mfg. Co.
NCGNE0104
Leggett & Platt Inc -Guilford
NCGNE0118
Patheon Softgels Inc.
NCGNE0134
Environmental Air Systems Inc
NCGNE0150
Patrician Furniture Co
NCGNE0166
Poly Pride, Inc.
NCGNE0241
Ultra -Flex
NCGNE0264
Carpenter Co - High Point
NCGNE0281
Henredon Furniture -Guilford
NCGNE0284
Carson's Hospitality
NCGNE0291
Novamelt Americas LLC
NCGNE0313
Sunrise Medical DC
NCGNE0325
Suiza Dairy Group, LLC dba Dairy Fresh, LLC)-High Point
NCGNE0482
V & E Components Inc
NCGNE0497
Triad Fabco Industries
NCGNE0498
Triad Fabco Industries -High Point
NCGNE0517
Leggett & Platt, Inc.
NCGNE0615
General Elastic Corp -Randolph
NCGNE0751
Baltek, Inc
NCGNE0758
Axalta Coating Systems U.S.A., LLC
NCGNE0766
Harriss & Covington Hosiery
NCGNE0791
M ington Wood Floors
NCGNE0839
Gotico Furniture and Accents
NCGNE0863
NC National Guard High Point Armory & FMS #8
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 7

NCGNE0951
Hancock & Moore, LLC
NCGNE0970
Baker Interiors Furniture Company - High Point
NCGNE0991
S ntec Seating Solutions LLC
NCGNE1022
High Point Furniture Industries
NCGNE1131
Fastenal Company
NCGNE1144
V&E Components, Inc.
NCGNE1208
Thomas Clyde Lamar ARC NCO28
NCGNE1227
Fortis Solutions Group
NCGNE1255
Ornamental Products LLC
NCGNE1323
Waste Industries LLC
NCGNE1384
Freud America - High Point - 218 Feld
NCGNE1385
Freud America - High Point - 220 Feld
NCS000421
High Point city - Small MS4
NCS000582
Ennis Flint
3.8 Non-Stormwater Discharges
The water quality impacts of non-stormwater discharges have been evaluated by the City of High Point as
summarized in Table 6 below. The unpermitted non-stormwater flows listed as incidental do not
significantly impact water quality. The City of High Point has evaluated residential and charity car
washing and street washing for possible significant water quality impacts.
Street washing discharges are addressed under the Pavement Management Program in Part 10 of this
SWMP. The Division has not required that other non-stormwater flows be specifically controlled by the
City of High Point.
Wash water associated with car washing that does not contain detergents or does not discharge directly
into the MS4 is considered incidental. However, these types of non-stormwater discharges that do contain
detergents have not been evaluated by the City of High Point to determine whether they may significantly
impact water quality. However, the City of High Point will continue to educate the general public on the
hazards associated with car washing. Measures to address these target pollutants are provided in Part 5 of
this SWMP.
Table 6: Non-Stormwater Discharges
Non-Stormwater Discharge
Water Quality Impacts
Water line and fire hydrant flushing
Incidental
Landscape irrigation
Incidental
Diverted stream flows
Incidental
Rising groundwater
Incidental
Uncontaminated groundwater infiltration
Incidental
Uncontaminated pumped groundwater
Incidental
Uncontaminated potable water sources
Incidental
Foundation drains
Incidental
Air conditioning condensate
Incidental
Irri ation waters
Incidental
Springs
Incidental
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 8

Water from crawls ace pumps
Incidental
Footing drains
Incidental
Lawn watering
Incidental
Residential and charity car washing
Possible
Flows from riparian habitats and wetlands
Incidental
Dechlorinated swimming pool discharges
Incidental
Street wash water
Possible
Flows from firefighting activities
Incidental
3.9 Target Pollutants and Sources
In addition to those target pollutants identified above, the City of High Point is aware of other significant
water quality issues within the permitted MS4 area.
Table 7 below summarizes the water quality pollutants identified throughout Part 3 of this SWMP, the
likely activities/sources/targeted audiences attributed to each pollutant and identifies the associated
SWMP program(s) that address each. In addition, the City of High Point has evaluated schools,
homeowners and businesses as target audiences that are likely to have significant stormwater impacts.
Table 7: Summary of Target Pollutants and Sources
Target
Likely Source(s)/Target Audience(s)
SWMP Program Addressing Target
Pollutants
Pollutant s /Audience s
Litter
General Public, Businesses, Schools
Public Education & Outreach, Public
Participation
Pet Waste/Fecal
General Public, Parks, Greenways,
Public Education & Outreach, Illicit
Coliform
Sewer Overflows, Failing Septic
Discharge Detection & Elimination
Systems
Sediment
Construction Erosion, Stream Bank
Construction Site Runoff Control
Erosion
Illicit Discharges
General Public, Businesses,
Public Education & Outreach, Illicit
Municipal Employees
Discharge Detection & Elimination, Public
Involvement
Illegal Dumping
General Public, Businesses,
Public Education & Outreach, Illicit
Municipal Employees
Discharge Detection & Elimination,
Pollution Prevention & Good Housekeeping
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 9

PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION
4.1 Organizational Structure
The Stormwater Division is responsible for compliance of the City of High Point's NPDES
Permit. All related activities/requirements/etc. for compliance are the responsibility of the Stormwater
Division, with the exception of Engineering Services, which oversees the Construction Runoff portion of
the Permit.
See Appendix A for Organizational Chart.
Table 8: Summary of Responsible Parties
SWMP Component
Responsible Position
Staff Name
Department
Stormwater Program
Dep. Public Services Director
Robby Stone
Public Services
Administration
Administration
SWMP Management
Public Services Manager
Justin Gray
Public Services
Stormwater Division
Operations Analyst
Anita Simpson
Public Education &
Stormwater Specialists
Robbie Baker
Public Services
Outreach
Kelsie Burgess
Stormwater Division
Abigail Rosendale
Public Involvement &
Stormwater Specialists
Robbie Baker
Public Services
Participation
Kelsie Burgess
Stormwater Division
Abigail Rosendale
Illicit Discharge
Stormwater Specialists
Robbie Baker
Public Services
Detection & Elimination
Kelsie Burgess
Stormwater Division
Abigail Rosendale
Construction Site Runoff
Engineering Services Director
Trevor Spencer
Engineering
Control
Services Division
Civil Engineer II
Aspasia Vlachou
Erosion Control Inspectors
Scott Ford
Kathy Blake
Post -Construction
Operations Analyst
Anita Simpson
Public Services
Stormwater Management
Stormwater Division
Pollution Prevention /
Stormwater Specialists
Robbie Baker
Public Services
Good Housekeeping for
Kelsie Burgess
Stormwater Division
Municipal Operations
Abigail Rosendale
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 10

Municipal Facilities
Stormwater Specialists
Robbie Baker
Public Services
Operation & Maintenance
Kelsie Burgess
Stormwater Division
Program
Abigail Rosendale
Spill Response Program
All Stormwater Division Staff
All Stormwater
Public Services
Division Staff
Stormwater Division
MS4 Operation &
Public Services Manager
Justin Gray
Public Services
Maintenance Program
Stormwater Division
Street Maint. Superintendent
Ken Sult
Municipal SCM
Public Services Manager
Justin Gray
Public Services
Operation & Maintenance
Stormwater Division
Program
Pesticide, Herbicide &
Safety Officer
Jim Gwynn
Public Services
Fertilizer Management
Administration
Program
Vehicle & Equipment
Public Services Manager
Justin Gray
Public Services
Cleaning Program
Stormwater Division
Pavement Management
Public Services Manager
Justin Gray
Public Services
Program
Stormwater Division
Street Maint. Superintendent
Ken Sult
(Streets Department)
Total Maximum Daily
Operations Analyst
Anita Simpson
Public Services
Load (TMDL)
Stormwater Division
Requirements
Stormwater Specialists
Robbie Baker
Kelsie Burgess
Abigail Rosendale
4.2 Program Funding and Budget
In accordance with the issued permit, the City of High Point shall maintain adequate funding and staffing
to implement and manage the provisions of the SWMP and comply with the requirements of the NPDES
MS4 Permit. The budget includes the permit administering and compliance fee, which is billed by the
Division annually.
The stormwater program is funded through a stormwater utility fee charged to property owners within
city limits. Residential customers are charged 1 Equivalent Residential Unit (ERU) of $4 per month.
All commercial and industrial properties are charged based on the total amount of impervious area on a
property divided by the ERU (Equivalent Residential Unit) of 2,588 square feet multiplied by $4 per
month. Example: 100,000 sq. ft. / 2588 sq. ft. = 38.64 ERU, 38.64 ERU X
$4 per month = $154.56 per month for the stormwater utility fee.
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 11

The stormwater utility fee sufficiently funds program needs and services, and a staff of 26 employees.
The staff consists of 1 Public Services Manager, 1 Operations Analyst, 1 GIS Analyst, 2 Administrative
Associates, 3 Stormwater Specialists, 2 Stormwater Supervisors for field service crews, 1 Stormwater
Technician (camera truck operator), and 15 Motor Equipment Operators for field service crews. The
stormwater utility fee collects revenue in excess of $5.45 million annually, while the Stormwater Division
has a total operating budget of approximately $2.9 million.
4.3 Shared Responsibility
The City of High Point does not share the responsibility to implement any of the six minimum
control measures.
Table 9: Shared Responsibilities
SWMP BMP or
Permit Requirement
Implementing Entity & Program Name
Legal
Agreement
Y
N/A
4.4 Co-Permittees
The are no other entities applying for co-permittee status under the NPDES MS4 permit number
NCS000421 for the City of High Point.
Table 10: Co-Permittee Contact Information
Co-Permittee MS4
Contact Person
Phone & E-Mail
Interlocal
Name
Agreement
(Y/N
N/A
4.5 Measurable Goals for Program Administration
The City of High Point will manage and report the following Best Management Practices (BMPs) for the
administration of the Stormwater Management Program.
Table 11: Program Administration BMPs
Permit
2.1.2 and Part 4: Annual Self -Assessment
Ref.
Measures to evaluate the performance and effectiveness of the SWMP program components at least annually.
Results shall be used by the permittee to modify the program components as necessary to accomplish the intent
of the Stormwater Program. The self -assessment reporting eriod is the fiscal year (Jul 1 — June 30).
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 12

BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
1.
Annual Self -Assessment
Perform an annual evaluation of
1. Prepare, certify, and
1. Annually
1. Yes/No
SWMP implementation, suitability of
submit the Annual Self-
Permit Years 1 — 4
SWMP commitments and any
Assessment to NCDEQ
FY21/22
proposed changes to the SWMP
prior to August 31 each
FY22/23
utilizing the NCDEQ Annual Self-
year.
FY23/24
Assessment Template.
FY24/25
Permit
1.6: Permit Renewal Application
Ref.
Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the
NPDES MS4 permit.
13MP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
2.
Permit Renewal Application
Audit stormwater program
1. Participate in an
1. TBD — Typically
1. Yes/No
implementation for compliance with
NPDES MS4 Permit
Permit Year 4
the permit and approved SWMP and
Compliance Audit, as
FY24/25
utilize the results to prepare and
scheduled and performed
submit a permit renewal application
by EPA or NCDEQ.
package.
2. Self -audit and
2. Permit Year 5
2. Yes/No/Partial
document any
FY25/26
stormwater program
components not audited
by EPA or NCDEQ
utilizing the DEQ Audit
Template. Submit Self -
Audit to DEMLR
(required component of
permit renewal
application package).
3. Certify the stormwater
3. Permit Year 5
3. Date of permit renewal
permit renewal
FY25/26
application submittal
application (Permit
renewal application
form, Self -Audit, and
Draft SWMP for the next
5-year permit cycle) and
submit to NCDEQ at
least 180 days prior to
permit expiration.
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 13

PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM
The City of High Point will implement a Public Education and Outreach Program to distribute
educational materials to the community or conduct equivalent outreach activities about the impacts of
storm water discharges on water bodies and steps the public can take to reduce pollutants in storm water
runoff.
The target audiences and identified pollutants listed in Part 3.9 of this SWMP, which will be addressed by
the Public Education and Outreach Program, are summarized in Table 12 below. In addition, the City of
High Point is required to inform businesses and the general public of the hazards associated with illicit
discharges, illegal dumping, and improper disposal of waste.
Table 12: Summary of Target Pollutants & Audiences
Target Pollutants/Sources
Target Audience(s)
Litter/Household Waste
General Public
Pet Waste/Fecal Coliform
General Public Public/Private Sanitary Sewer Infrastructure
Sediment
Developers, Contractors, Homeowners, Landscapers
Fats, Oils & Grease
General Public, Commercial, Industrial, Food Industries
Nutrients (Phosphorus/Nitrogen)
General Public, Commercial, Landscaping
Illicit Discharges
General Public, Businesses, Municipal Employees
Illegal Dumping
General Public, Businesses, Municipal Employees
Improper Disposal of Waste
General Public, Businesses, Municipal Employees
The City of High Point will manage, implement, and report the following public education and outreach
BMPs.
Table 13: Public Education and Outreach BMPs
Permit
3.2.2 and 3.2.4: Outreach to Targeted Audiences
Ref.
Measures to identify the specific elements and implementation of a Public Education and Outreach Program to
share educational materials to the community or conduct equivalent outreach activities about the impacts of
stormwater discharges on water bodies and how the public can reduce pollutants in stormwater runoff. The
permittee shall provide educational information to identified target audiences on pollutants/sources identified in
table 12 above and shall document the extent of exposure of each media, event, or activity, including those
elements implemented locally or through a cooperative agreement.
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 14

BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
3.
School Outreach
Develop age -specific educational
1. Provide age -specific
1. Continuously
1. Number of students
information for use in schools and
stormwater presentations
Permit Years 1-5
reached
for presentations to school age
upon request.
FY21/22
children. Will present information
FY22/23
in appropriate format.
FY23/24
FY24/25
FY25/26
2. Reach out to Guilford
2. Annually
2. Yes/No/Status
County Schools and
Permit Years 1-5
Private schools to remind
FY21/22
them of the programs
FY22/23
offered.
FY23/24
FY24/25
FY25/26
3. Organize stream
3. Continuously
3. Number of
habitat events for schools
Permit Years 1-5
participants
and/or summer camps as
FY21/22
requested
FY22/23
FY23/24
FY24/25
FY25/26
4.
Public Event Tabling
Set up public education table at a
1. Monthly Library Table
1. Continuously
1. Number of
variety of public events and locations
Permit Years 1-5
interactions at the table
in order to reach diverse groups,
FY21/22
minorities ,and underserved
FY22/23
populations. Educational topics will
FY23/24
vary and may include general
FY24/25
stormwater awareness and the
FY25/26
pollutants/sources listed in Table 12
2. Monthly Farmer's
2. Continuously
2. Number of
above for the general public target
Market Table
Permit Years 1-5
interactions at the table
audience (litter, pet waste, septic tank
FY21/22
systems, FOG, nutrients, illicit
FY22/23
discharges, illegal dumping).
FY23/24
FY24/25
FY25/26
3. Attend at least 3 other
3. Continuously
3. Number of events held
City of High Point Public
Permit Years 1-5
and number of
events.
FY21/22
interactions
FY22/23
FY23/24
FY24/25
FY25/26
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 15

4. Coordinate and attend
4. Annually
4. Number of attendees
the annual Public
Permit years 1-5
Services Day event.
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
5. Coordinate and attend
5. Annually
5. Number of attendees
one event in High Point
Permit years 1-5
for Guilford Creek
FY21/22
Week.
FY22/23
FY23/24
FY24/25
FY25/26
5.
Utility Bill Inserts
Stormwater bill inserts will continue
1. Develop and distribute
1. Semi -Annually
1. Number of flyers
to be inserted into combined utility
a stormwater flyer for
Permit Year 1
mailed
bill statements and distributed to all
general stormwater
FY21/22
City residents and businesses
information/pet waste/
receiving a utility bill on at least a
septic tanks stems.
semi- annual schedule.
2. Develop and distribute
2. Semi -Annually
2. Number of flyers
a stormwater flyer for
Permit Year 2
mailed
illicit discharges/illegal
FY22/23
dumping and general
stormwater information
3. Develop and distribute
3. Semi -Annually
3. Number of flyers
a stormwater flyer for
Permit Year 3
mailed
litter/household
FY23/24
wastestautomotive care
and leaf pick
4. Develop and distribute
4. Semi -Annually
4. Number of flyers
a stormwater flyer for
Permit Year 4
mailed
general stormwater
FY24/25
information and fats,
oils, and grease(FOG)
5. Develop and distribute
5. Semi -Annually
5. Number of flyers
a stormwater flyer for
Permit Year 5
mailed
illicit discharge/illegal
FY25/26
dumping and yard
waste/leaf pickup.
6.
Stormwater Information Documents
Informational pamphlets, brochures,
1. Develop a list of target
1. Annually
1. Yes/No/Status
and giveaways with specific
audiences, groups, and/or
Permit Years 1-5
stormwater topics, as well as general
businesses for each
FY21/22
information to be handed out to
informational document.
FY22/23
targeted groups and be available at all
FY23/24
tabling events.
FY24/25
FY25/26
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 16

2. Develop a schedule for
2. Annually
2. Number of documents
inventory of all
Permit Years 1-5
of each topic distributed
informational documents
FY21/22
and giveaways.
FY22/23
FY23/24
FY24/25
FY25/26
7.
Information Kiosks
Multiple stormwater documents will
1. Develop a location list
1. Annually
1. Yes/No/Status
be displayed at locations throughout
and schedule to regularly
Permit Year I FY21/22
the City including City Hall
check kiosks
2. Check kiosks to ensure
2. Quarterly
2. Number of documents
(Customer Service), Public Services
Department, the City of High Point
documents are available
Permit Years 2-5
of each topic distributed
Visitors Center, Public Library,
and replenished
FY22/23
Piedmont Environmental Center, and
FY23/24
other city -maintained recreational
FY24/25
facilities.
FY25/26
8.
Social Media
Work with the City of High Point's
1. Post at least three
1. Annually
1. Number of views per
Public Information Office to promote
stormwater specific
Permit Years 1-5
post and topic
information about upcoming events
informational social
FY21/22
and other stormwater- related
media posts per year.
FY22/23
educational information using
FY23/24
multiple social media outlets
FY24/25
(Facebook, Next Door, Twitter,
FY25/26
Insta ram
9.
Advertisements, Media, Etc.
Utilize additional physical or digital
1. At least once per year,
1. Annually
1. Yes/No/Status, and
advertising spaces to increase
use non -municipal
Permit Years 1-5
topic(s) displayed
visibility of the stormwater message.
website or outdoor
FY21/22
advertisement space
FY22/23
(e.g., La Noticia print
FY23/24
and website, using ad
FY24/25
space inside and outside
FY25/26
of High Point Transit
Buses, billboards,
shopping carts, etc.) to
display an informational
stormwater message.
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 17

Permit
2.1.7, 3.2.3 and 3.6.5(c): Web Site
Ref.
Measures to provide a web site designed to convey the program's message(s) and provide online materials
including ordinances, or other regulatory mechanisms, or a list identifying the ordinances or other regulatory
mechanisms, providing the legal authority necessary to implement and enforce the requirements of the permit
and S WMP. The web page shall also provide developers with all relevant post -construction requirements,
design standards, checklists and/or other materials.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
10.
Informational Web Site
The Stormwater Services Division
1. Maintain the
1. Continuously Permit
1. Yes/No/Status
will maintain an internet web site that
stormwater web page and
Years 1-5
contains detailed information
update any changes as
FY21/22
regarding all aspects of the
needed.
FY22/23
stormwater permit requirements,
FY23/24
services offered, educational
FY24/25
brochures/fliers, and
FY25/26
reporting/contact information.
2. Add a link on the
2. Permit Year 1
2. Yes/No/Status
Stormwater webpage to
FY21/22
the NCDEQ Stormwater
web a e
Permit
3.2.5: Stormwater Hotline
Ref.
Measures for a stormwater hotline/helpline for the purpose of public education and outreach.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
11.
Stormwater Hotline
Dedicated Customer Service number
1. Respond to calls and
1. Continuously
1. Number of calls
for all Public Services has been
inquiries within one
Permit Years 1-5
received and number of
established where citizens can call to
business day (for non-
FY21/22
resolutions
report stormwater pollution
emergencies), and
FY22/23
violations. This number is publicized
immediately to an IDDE.
FY23/24
on the website, stormwater flyers
FY24/25
and give-away items (pens, pencils,
FY25/26
magnates, etc.)
2. Advertise
2. Continuously
2. Yes/No/Status
hotline/helpline in all
Permit Years 1-5
ads, printed materials,
FY21/22
social media, and
FY22/23
website.
FY23/24
FY24/25
FY25/26
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 18

PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM
This SWMP identifies the minimum elements and implementation of a Public Involvement and
Participation Program that complies with applicable State, Tribal and local public notice requirements.
The City of High Point will manage, implement, and report the following public involvement and
participation BMPs.
Table 14: Public Involvement and Participation BMPs
Permit
3.3.1: Public Input
Ref.
Mechanisms for public involvement that provide for input on stormwater issues and the stormwater program.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
12.
Stormwater Hotline
Dedicated Customer Service number
1. See BMP 11
1. See BMP 11
1. See BMP 11
for all Public Services has been
established where citizens can call to
report stormwater pollution violations
See BMP 11).
Permit
3.3.2: Volunteer Opportunities
lZef.
Measures to provide volunteer opportunities designed to promote ongoing citizen participation.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
13.
Adopt -a -Street Program
Provide public and private
1. Check in with Keep
1. Annually
1. Pounds of trash and
organizations the opportunity for
High Point Beautiful
Permit Years 1-5
recycling collected, date
volunteers to participate in cleaning
President for Adopt -a-
FY21/22
and number of
up local streams.
Street results
FY22/23
participants
FY23/24
FY24/25
FY25/26
_
14.
Adopt -a -Stream Program
Provide public and private
1. Partner and coordinate
1. Annually
1. Pounds of trash and
organizations the opportunity for
with organizations in
Permit Years 1-5
recycling collected, date
volunteers to participate in cleaning
efforts to clean up
FY21/22
and number of
up local streams.
adopted stream.
FY22/23
participants
FY23/24
FY24/25
FY25/26
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 19

Table 14: Public Involvement and Participation BMPs
2. Recruit at least one
2. Annually
2. Number of new groups
new Adopt -A -Stream
Permit Years 1-5
group per year.
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
15.
Storm Drain Marking Program
Volunteers place drain markers on
1. Recruit at least one
1. Annually
1. Yes/No/Status
storm drains to assist in stormwater
new storm drain marking
Permit Years 1-5
and watershed education within
volunteer group per year.
FY21/22
neighborhoods and public streets.
FY22/23
FY23/24
FY24/25
FY25/26
2. Coordinate storm
2. Annually
2. Number of storm
drain marking and track
Permit Years 1-5
drains marked, number
marked drains
FY21/22
of participants
FY22/23
FY23/24
FY24/25
FY25/26
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 20

PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM
The City of High Point will develop, manage, implement, document, report and enforce an Illicit
Discharge Detection and Elimination Program which shall, at a minimum, include the following illicit
discharge detection and elimination BMPs.
Table 15: Illicit Discharge Detection and Elimination BMPs
Permit
3.4.1: MS4 Map
Ref.
Measures to develop, update and maintain a municipal storm sewer system map including stormwater
conveyances, flow direction, major outfalls and waters of the United States receiving stormwater discharges.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
16.
Storm Sewer System Inventory
Provide dedicated field staff to
1. Add pertinent data for
1. Continuously
1. Yes/No/Status
collect and update stormwater
new stormwater
Permit Years 1-5
infrastructure data.
infrastructure (pipes,
FY21/22
junctions, structures,
FY22/23
outfalls) to our
FY23/24
Stormwater GIS system
FY24/25
for new construction
FY25/26
2. Maintain storm sewer
2. Continuously
2. Yes/No/Status
system map including
Permit Years 1-5
Total number of mapped
stormwater conveyances,
FY21/22
outfalls
flow direction, major
FY22/23
outfalls, and surface
FY23/24
waters.
FY24/25
FY25/26
17.
Stormwater Web Map
All SCMs within the City of High
1. Add new SCMs to
1. Continuously
1. Yes/No/Status
Point are identified and added to the
mapping database once
Permit Years 1-5
current SCM Stormwater Web Map.
construction and/or
FY21/22
conversion from erosion
FY22/23
control basin
FY23/24
FY24/25
FY25/26
18.
Camera Crew
In-house staff collects stormwater
1. Maintain process for
1. Continuously
1. Yes/No/Status
infrastructure data for existing
collecting data and
Permit Years 1-5
systems using pipe camera.
incorporating pertinent
FY21/22
information into GIS
FY22/23
database
FY23/24
FY24/25
FY25/26
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 21

Table 15: Illicit Discharge Detection and Elimination BMPs
Permit
3.4.2: Regulatory Mechanism
Ref.
Measures to provide an IDDE ordinance or other regulatory mechanism that provides legal authority to prohibit,
detect, and eliminate illicit connections and discharges, illegal dumping, and spills into the MS4, including
enforcement procedures and actions.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
19.
Enforcement
The Illicit Discharge Control
1. Maintain illicit
1. Continuously
1. Yes/No/Status
Ordinance will charge the Public
discharge ordinance,
Permit Years 1-5
Services Director or designee with
administration, and
FY21/22
implementing the Illicit Discharge
enforcement procedures.
FY22/23
Detection and Elimination program.
FY23/24
The ordinance does specify legal
FY24/25
penalties to be implemented in cases
FY25/26
of non-compliance.
(Code of Ordinances, Title 12,
Chapter 3 - Public Nuisances).
Permit
3.4.3: IDDE Plan
Ref.
Measures to maintain and implement a written IDDE Plan to detect and address illicit discharges, illegal dumping
and any non-stormwater discharges identified as significant contributors of pollutants to the MS4. The plan shall
provide standard procedures and documentation to:
a) Locate priority areas likely to have illicit discharges,
b) Conduct routine dry weather outfall inspections,
c) Identify illicit discharges and trace sources,
d) Eliminate the source(s) of an illicit discharge, and
e) Evaluate and assess the IDDE Program.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
20.
Written IDDE Plan
Maintain and implement a written
1. Continue to update the
1. Continuously
1. Yes/No/Status
IDDE Plan.
IDDE Plan as required
Permit Years 1-5
by any change in
FY21/22
ordinance, state statute
FY22/23
or other federal
FY23/24
regulation than is
FY24/25
specific to IDDE
FY25/26
incidents
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 22

Table 15: Illicit Discharge Detection and Elimination BMPs
21.
Outfall Inspections
Perform regular dry weather (no rain
1. Inspect 25% of all
1. Continuously
1. Yes/No/Status
in previous 72 hours) outfall
major outfalls within the
Permit Years 1-5
inspections to proactively identify
City limits every year.
FY21/22
illicit discharges and illicit
FY22/23
connections.
FY23/24
FY24/25
FY25/26
22.
Detection and Elimination
Detect and identify illicit discharges
1. Continue to respond to
1. Continuously
1. Yes/No/Status
and connections; conduct dry-
IDDEs, train employees,
Permit Years 1-5
weather outfall monitoring; respond
and conduct outfall
FY21/22
to citizen concerns made via the
monitoring
FY22/23
Customer Service line; train City
FY23/24
personnel on recognizing and
FY24/25
reporting illicit discharges or
FY25/26
2. Maintain equipment
2. Continuously
2. Yes/No/Status
connections.
and materials to detect
Permit Years 1-5
IDDEs and analyze
FY21/22
stormwater samples.
FY22/23
FY23/24
FY24/25
FY25/26
Permit
3.4.4: IDDE Tracking
Ref.
Measures for tracking and documenting the date(s) an illicit discharge, illicit connection or illegal dumping was
observed, the results of the investigation, any follow-up of the investigation, the date the investigation was
closed, the issuance of enforcement actions, and the ability to identify chronic violators.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
23.
Notice of Violation (NOV) Letters
NOVs with a detailed description of
1. Continue to update
1. Continuously
1. Yes/No/Status
the incident along with date/time
system processing of
Permit Years 1-5
stamped photos are sent certified
IDDE records and
FY21/22
mail to the violator or representative.
implement procedures
FY22/23
Follow-up occurs when the time
that may increase
FY23/24
allotted for compliance has expired.
efficiency of handling
FY24/25
these incidents
FY25/26
2. Store illicit discharge
2. Continuously
2. Yes/No/Number of
information in database
Permit Years 1-5
enforcement actions
and Excel spreadsheet;
FY21/22
issued
maintain hard copies of
FY22/23
NOV letters, photos,
FY23/24
and other pertinent
FY24/25
information in physical
FY25/26
files
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 23

Table 15: Illicit Discharge Detection and Elimination BMPs
Permit
3.4.5: Staff IDDE Training
Ref.
Measures to provide training for municipal staff and contractors who, as part of their normal job responsibilities,
may observe an illicit discharge, illicit connection, illegal dumping, or spills. Training shall include how to
identify and report illicit discharges, illicit connections, illegal dumping, and spills. Each staff training event
shall be documented, including the agenda/materials, date, and number of staff participatin .
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
24.
Staff Training
Provide stormwater training to all
1. Maintain an employee
1. Annually
1. Yes/No/Status,
groups of municipal staff and/or
training program on
Permit Years 1-5
Number trained
contractors each year.
detecting and reporting
FY21/22
Training shall include how to
illicit discharges, illicit
FY22/23
identify and report illicit
connections, illegal
FY23/24
discharges, illicit connections, illegal
dumping, and spills.
FY24/25
dumping, ands ills.
FY25/26
Permit
3.4.6: IDDE Reporting
Ref.
Measures for the public and staff to report illicit discharges, illegal dumping, and spills. The mechanism shall be
publicized to facilitate reporting and shall be managed to provide rapid response by appropriately trained
personnel.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
25.
Stormwater Hotline
Dedicated Customer Service number
1. Promote and
1. Continuously
1. Number of IDDEs
for all Public Services has been
publicize phone number
Permit Years 1-5
reported each year.
established where citizens can call to
to receive reports
FY21/22
report stormwater pollution
related to illicit
FY22/23
violations.
discharges.
FY23/24
FY24/25
FY25/26
26.
On -Call Duty Officer
On -Call duty officer to be available
1. Promote and
1. Continuously
1. Number of IDDEs
after normal business hours to
publicize phone number
Permit Years 1-5
reported each year.
investigate illicit discharges, illegal
to receive reports
FY21/22
dumping and spills if reported.
related to illicit
FY22/23
discharges.
FY23/24
FY24/25
FY25/26
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 24

PART S: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
In accordance with 15A NCAC 02H .0153, the City of High Point relies upon the North Carolina
Sedimentation Pollution Control Act (SPCA) of 1973 as a qualifying alternative program to meet a
portion of the NPDES MS4 Permit requirements for construction site runoff control measures. The
SPCA requirements include reducing pollutants in stormwater runoff from construction activities that
result in land disturbance of greater than or equal to one acre and includes any construction activity that is
part of a larger common plan of development that would disturb one acre or more. The state SPCA
Program is either delegated to a city/town, delegated to a county, or implemented by NCDEQ in non -
delegated areas.
Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program
Permit
Reference
State or Local Program Name
Legal Authority
Implementing
Entity
3.5.1 -
City of High Point Delegated
15A NCAC Chapter 04
City of High Point
3.5.4
SPCA Program*
NCDEQ Approved Delegation
* The local delegated SPCA Program ordinance(s)/regulatory mechanism(s) can be found in the City of
High Point Development Ordinance, Chapter 6, Section 6.3 - Soil Erosion and Sedimentation; and
Chapter 9, Sections 9.5. — Enforcement, 9.6. - Enforcement Procedure , 9.7. — Remedies, and 9.9. -
Assessment of Civil Penalties.
The City of High Point also implements the following BMPs to meet NPDES MS4 Permit requirements.
Table 17: Construction Site Runoff Control BMPs
Permit
3.5.6: Public Input
Ref.
Measures to provide and promote a means for the public to notify the appropriate authorities of observed
erosion and sedimentation problems.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
27.
Municipal Staff Training
Train municipal staff who receive
1. Train municipal staff
1. Annually
1. Number of staff
calls from the public on the protocols
on proper handling of
Permit Years 1-5
trained
for referral and tracking of
construction site runoff
FY21/22
construction site runoff control
control complaints.
FY22/23
complaints.
FY23/24
FY24/25
FY25/26
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 25

28.
Stormwater Hotline
Dedicated Customer Service number
1. See BMP 11
1. See BMP 11
1. See BMP 11
for all Public Services has been
established where citizens can call to
report stormwater pollution
violations. This number is publicized
on the website, stormwater flyers
and give-away items (pens, pencils,
magnates, etc.) (See BMP 11).
Permit
3.5.5: Waste Management
Itef.
Measures to require construction site operators to control waste such as discarded building materials, concrete
truck washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impact to
water quality
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
29.
Establish and Maintain Legal Authority
Provide ordinance to require
1. Develop, adopt and/or
1. Permit Year 1
1. Yes/No/Status, date
construction site operators to control
update the ordinance
FY21/22
of adoption
waste
2. Maintain Legal
2. Continuously
2. Yes/No/Summary
Authority
Permit Years 2-5
FY22/23
FY23/24
FY24/25
FY25/26
30.
Pre -Construction Conference
Conduct project conferences with
1. Conduct Pre-
1. Continuously
1. Document and
contractors, engineers, plan
Construction Meetings
Permit Years 1-5
report number of
reviewers and site construction
FY21/22
preconstruction
inspectors for all projects with
conferences
land disturbing activities
FY22/23
/23
requiring an E&SC plan
FY23/24
FY24/25
FY25/26
2. Develop and
2. Continuously
2. Yes/No/Status
distribute informational
Permit Years 1-5
Number of Fact Sheets
Fact Sheet at pre-
FY21/22
distributed
construction
FY22/23
conferences
FY23/24
FY24/25
FY25/26
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 26

PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
This SWMP identifies the minimum elements to develop, implement and enforce a program to address
stormwater runoff from new development and redevelopment projects 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 are located within the City of High Point and discharge into the MS4. These elements are
designed to minimize water quality impacts utilizing a combination of structural Stormwater Control
Measures (SCMs) and/or non-structural BMPs appropriate for the community and ensure adequate long-
term operation and maintenance of SCMs.
In accordance with 15A NCAC 02H .0153 and .1017, the City of High Point implements the following
State post -construction program requirements, which satisfy the NPDES Phase II MS4 post -construction
site runoff control requirements as Qualifying Alternative Programs (QAPs) in the MS4 area(s) where
they are implemented.
Table 18: Qualifying Alternative Program(s) for Post -Construction Site Runoff Control Program
Local Ordinance / Regulatory
State QAP Name
State Requirements
Mechanism Reference
None
N/A
N/A
The City of High Point has existing requirements other than Qualifying Alternative Program(s) for
implementation of the NPDES Phase II MS4 post -construction program requirements. These existing
requirements are codified in local ordinance(s), and implementation is further defined in guidance,
manuals and/or standard operating procedure(s) as summarized in Table 19 below.
Table 19: Summary of Existing Post -Construction Program Elements
Permit Requirements for
Municipal Ordinance/Code
Date Adopted
Plan Review and Approval
Reference(s)
and/or Document Title(s)
3.6.2(a) Authority
City of High Point Development
Ord. No. 7266/17-08, § 2, 1-17-
Ordinance Chapter 2-2
2017; Ord. No. 7476/18-105, §
2.13, 12-3- 2018
3.6.3(a) & 15A NCAC
City of High Point Development
Ord. No. 7266/17-08, § 27, 1-17-
02H.0153(c) Federal, State &
Ordinance Chapter 6-2
2017; Ord. No. 7287/17-29, §
Local Projects
12, 4-3-2017
3.6.3(b) Plan Review
City of High Point Development
Ord. No. 7266/17-08, § 2, 1-17-
Ordinance Chapter 2-2
2017; Ord. No. 7476/18-105, §
2.13, 12-3-2018
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 27

3.6.3(c) O&M Agreement
City of High Point Development
Ord. No. 7266/17-08, § 27, 1-17-
Ordinance Chapter 6-2-11
2017; Ord. No. 7287/17-29, §§
12, 13, 4-3-2017; Ord. No.
7365/17-108, § 1, 11-20-2017
3.6.3(d) O&M Plan
City of High Point Development
Ord. No. 7266/17-08, § 27, 1-17-
Ordinance Chapter 6-2-11
2017; Ord. No. 7287/17-29, §§
12, 13, 4-3-2017; Ord. No.
7365/17-108, § 1, 11-20-2017
3.6.3(e) Deed
City of High Point Development
Ord. No. 7266/17-08, § 27, 1-17-
Restrictions/Covenants
Ordinance Chapter 6-2-11
2017; Ord. No. 7287/17-29, §§
12, 13, 4-3-2017; Ord. No.
7365/17-108, § 1, 11-20-2017
3.6.3(f) Access Easements
City of High Point Development
Ord. No. 7266/17-08, § 27, 1-17-
Ordinance Chapter 6-2-11
2017; Ord. No. 7287/17-29, §§ 12,
13, 4-3-2017; Ord. No. 7365/17-
108, § 1, 11-20-2017
Permit Requirements for
Municipal Ordinance/Code
Date Adopted
Inspections and
Reference(s)
Enforcement
and/or Document Title(s)
3.6.2(b) Documentation
City of High Point Development
Ord. No. 7266/17-08, § 27, 1-17-
Ordinance Chapter 6-2-11
2017; Ord. No. 7287/17-29, §§ 12,
13, 4-3-2017; Ord. No. 7365/17-
108, § 1, 11-20-2017
3.6.2(c) Right of Entry
City of High Point Development
Ord. No. 7266/17-08, § 27, 1-17-
Ordinance Chapter 6-2-11
2017; Ord. No. 7287/17-29, §§ 12,
13, 4-3-2017; Ord. No. 7365/17-
108 § 1 11-20-2017
3.6.4(a) Pre -CO Inspections
City of High Point Development
Ord. No. 7266/17-08, § 27, 1-17-
Ordinance Chapter 6-2-11
2017; Ord. No. 7287/17-29, §§ 12,
13, 4-3-2017; Ord. No. 7365/17-
108 § 1, 11-20-2017
3.6.4(b) Compliance with
City of High Point Development
Ord. No. 7266/17-08, § 27, 1-17-
Plans
Ordinance Chapter 6-2-11
2017; Ord. No. 7287/17-29, §§ 12,
13, 4-3-2017; Ord. No. 7365/17-
108 § 1, 11-20-2017
3.6.4(c) Annual SCM
City of High Point Development
Ord. No. 7266/17-08, § 27, 1-17-
Inspections
Ordinance Chapter 6-2-11
2017; Ord. No. 7287/17-29, §§ 12,
13, 4-3-2017; Ord. No. 7365/17-
108 § 1, 11-20-2017
3.6.4(d) Low Density
City of High Point Development
Ord. No. 7266/17-08, § 27, 1-17-
Inspections
Ordinance Chapter 6-2-11
2017; Ord. No. 7287/17-29, §§ 12,
13, 4-3-2017; Ord. No. 7365/17-
108 § 1, 11-20-2017
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 28

3.6.4(e) Qualified
City of High Point Development
Ord. No. 7266/17-08, § 27, 1-17-
Professional
Ordinance Chapter 6-2-11
2017; Ord. No. 7287/17-29, §§ 12,
13, 4-3-2017; Ord. No. 7365/17-
108 § 1, 11-20-2017
Permit Requirements for
Municipal Ordinance/Code
Date Adopted
Fecal Coliform Reduction
Reference(s)
and/or Document Title(s)
3.6.6(a) Pet Waste
City of High Point Code of
Ord. No. 6168/04-65, § 1, 9-7-04;
Ordinances, Title 12, Chapter 3,
Ord. No. 6541/08-26, 5-19-08;
Sec. 12-3-1
Ord. No. 6573/08-58, § 2, 8-18-
2008
3.6.6(b) On -Site Domestic
City of High Point Code of
(Ord. No. 6168/04-65, § 1, 9-7-04;
Wastewater Treatment
Ordinances, Title 12,
Ord. No. 6541/08-26, 5-19-08;
Chapter 3, Sec. 12-3-1
Ord. No. 6573/08-58, § 2, 8-18-
2008
The annual reporting metrics for the post construction program are provided in Table 20: Post
Construction Site Runoff Control BMPs below.
Table 20: Post Construction Site Runoff Control BMPs
Permit
3.6.5(a), 3.6.5(b), and 4.1.3: Minimum Post -Construction Reporting Requirements
Ref.
Measures to document activities over the course of the fiscal year (July 1 — June 30) including appropriate
information to accurately describe ogress, status, and results.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
31.
Standard Reporting
Implement standardized tracking,
1. Track number of low
1. Continuously
1. Number of plan
documentation, inspections, and
density and high density
Permit Years 1-5
reviews performed for
reporting mechanisms to compile
plan reviews performed.
FY21/22
low density and high
appropriate data for the annual self-
FY22/23
density.
assessment process. Data shall be
FY23/24
provided for each Post -Construction/
FY24/25
Qualifying Alternative Program
FY25/26
2. Track number of low
2. Continuously
2. Number of plan
being implemented as listed in Tables
18 and 19.
density and high density
Permit Years 1-5
approvals issued for low
plans approved.
FY21/22
density and high density.
FY22/23
FY23/24
FY24/25
FY25/26
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 29

Table 20: Post Construction Site Runoff Control BMPs
3. Maintain a current
3. Continuously
3. Summary of number
inventory of low density
Permit Years 1-5
and type of SCMs added
projects and constructed
FY21/22
to the inventory; and
SCMs including SCM
FY22/23
number and acreage of
type or low density
FY23/24
low density projects
acreage, location, and
FY24/25
constructed.
last inspection date.
FY25/26
4. Track number of SCM
4. Continuously
4. Number of SCM
inspections performed.
Permit Years 1-5
inspections.
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
5. Track number of low
5. Continuously
5. Number of low density
density inspections
Permit Years 1-5
projects inspected.
performed.
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
6. Track number and
6. Continuously
6. Number of
type of enforcement
Permit Years 1-5
enforcement actions
actions taken.
FY21/22
issued.
FY22/23
FY23/24
FY24/25
FY25/26
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
Permit
3.6.3: Plan Review and Approval
Ref.
Measures to maintain plan review and approval authority, standards and procedures to: (a) Require Federal,
State, and local government projects to comply with Post -Construction Program requirements throughout the
entire MS4 permitted area, unless the entity is subject to its own NPDES MS4 permit or a qualifying alternative
program, (b) Conduct site plan reviews of all new development and redeveloped sites that disturb greater than
or equal to one acre, and sites that disturb less than one acre that are part of a larger common plan of
development or sale for compliance with 15A NCAC 02H. 1017 and the qualifying alternative programs that
apply within your jurisdiction, (c) Ensure that each project has an Operation and Maintenance Agreement that
complies with 15A NCAC 02H .1050(12), (d) Ensure that each project has an Operation and Maintenance Plan
that complies with 15A NCAC 02H .1050(13), (e) Ensure that each project has recorded deed restrictions and
protective covenants, that require the project to be maintained consistent with approved plans, and (f) Ensure
that each SCM and associated maintenance accesses be protected in a permanent recorded easement per 15A
NCAC 02H 1050 (9) and (10). This permit requirement is fully met by the existing post -construction program,
see references provided in Table 19.
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 30

BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
lm lcmentation
Annual Reporting
Metric
Permit
3.6.4: Inspections and Enforcement
Ref.
Measures to maintain inspection and enforcement authority, standards, and procedures to: (a) Conduct post -
construction inspections prior to issuing a Certificate of Occupancy or a Temporary Certificate of Occupancy.
Alternatively, the project owner may provide a surety bond to guarantee compliance with the approved plan(s),
(b) Ensure that the project has been constructed in accordance with the approved plan(s), (c) Ensure annual
inspection of each permitted SCM to ensure compliance with the approved Operation and Maintenance
Agreement, (d) Ensure inspection of low density projects at least once during the permit term, and (e) Require
that inspections be conducted by a qualified professional. This permit requirement is fully met by the existing
post -construction program, see references provided in Table 19.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
Permit
3.6.6: Fecal Coliform Reduction
Ref.
Measures to control, to the maximum extent practicable, sources of fecal coliform per 15A NCAC 02H
.1017(7). At a minimum, the program shall include: (a) A pet waste management component, which may be
achieved by revising an existing litter ordinance, and (b) An on -site domestic wastewater treatment system
component, if applicable, which may be coordinated with local county health department, to ensure proper
operation and maintenance of such systems. This permit requirement is fully met by the existing post -
construction program, see references provided in Table 19.
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 31

PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS
This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the City
of High Point municipal facilities and operations. Pollution prevention and good housekeeping is
accomplished through the implementation of seven required programs, which collectively address the
ultimate goal of preventing or reducing pollutant runoff from municipal operations such as parks and
open space maintenance, fleet and building maintenance, new construction and land disturbances, and
municipal storm sewer system maintenance.
Pollution prevention and good housekeeping for municipal operations includes the following programs:
1. Municipal Facilities Operation and Maintenance Program
2. Spill Response Program
3. MS4 Operation and Maintenance Program
4. Municipal SCM Operation and Maintenance Program
5. Pesticide, Herbicide and Fertilizer Management Program
6. Vehicle and Equipment Maintenance Program
7. Pavement Management Program
The City of High Point will manage, implement, and report the pollution prevention and good
housekeeping BMPs as specified in Table 21 below for each required program.
Table 21: Pollution Prevention and Good Housekeeping BMPs
Permit
3.7.1: Municipal Facilities Operation and Maintenance Program
Ref.
Measures to manage facilities that are owned and operated by the permittee and have the potential for
generating polluted stormwater runoff. The permittee shall maintain a current inventory of municipal facilities;
perform facility inspections and routine maintenance; establish specific frequencies, schedules, and standard
documentation; provide staff training on general stormwater awareness and implementing pollution prevention
and good housekeeping ractices.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
33.
Operation and Maintenance Plan
Maintain and update the written
1. Implement all aspects
1. Continuously
1. Yes/No/Status
Operation and Maintenance Plan.
of the O&M Plan
Permit Years 1-5
Summary
FY21 /22
FY22/23
FY23/24
FY24/25
FY25/26
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 32

2. Update plan on an
2. Annually
1. Yes/No/Status
annual basis.
Permit Years 1-5
Summary
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
34.
Inventory of Municipal Facilities
Update and maintain inventory of
1. Review and update list
1. Annually
1. Yes/No/Date
municipal facilities that have the
of municipal facilities.
Permit Years 1-5
updated
potential to generate polluted
FY21/22
stormwater runoff.
FY22/23
FY23/24
FY24/25
FY25/26
35.
Municipal Facility Inspections
Inspect municipal facilities deemed to
1. Review and update
1. Annually
2. Yes/No/Status
have the potential to generate
municipal inspection
Permit Years 1-5
polluted stormwater runoff.
forms.
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Perform municipal
2. Annually
2. Yes/No/Status,
facility inspections on
Permit Years 1-5
number of inspections
those facilities that have
FY21/22
the potential to pollute
stormwater.
FY22/23
FY23/24
FY24/25
FY25/26
36.
Municipal Employee Training
Conduct annual stormwater training
1. Perform employee
1. Annually
1. Yes/No/Status,
that covers general stormwater
training at Facilities that
Permit Years 1-5
Number trained
awareness, pollution prevention and
have been identified as
FY21/22
spill response, and IDDE reporting
having the possibility to
have a negative impact
FY22/23
on stormwater.
FY23/24
FY24/25
FY25/26
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 33

Permit
3.7.2: Spill Response Program
Ref.
Measures for facilities and operations that store and/or use materials that have the potential to contaminate
stormwater runoff if spilled. The permittee shall maintain written spill response procedures and train staff on
spill response procedures.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
37.
Spill Response Plan
A written spill response plan has been
1. Review and update
1. Annually
1. Yes/No/Status
developed for municipal facilities that
Spill Response Plan
Permit Years 1-5
store or use materials that could
annually to ensure plan is
FY21/22
contaminate stormwater runoff.
effective.
Municipal facilities with industrial
FY22/23
permits have a spill response plan as
FY23/24
part of their Stormwater Pollution
FY24/25
Prevention Plan or SPCC Plan.
FY25/26
2. Perform spill
2. Annually
2. Yes/No/Status,
response training for
Permit Years 1-5
Number trained
municipal employees
FY21/22
annually.
FY22/23
FY23/24
FY24/25
FY25/26
3. Evaluate municipal
3. Annually
3. Yes/No/Status
facilities to determine if
Permit Years 1-5
any need to be added or
FY21/22
removed from those
FY22/23
requiring a Spill
Response Plan.
FY23/24
FY24/25
FY25/26
38.
Maintain Inventory of Facilities with a Spill Response Plan
Maintain a list of city facilities that
1. Update list of city
1. Annually
1. Yes/No/Status
have a SPCC Plan, SWPPP, or Spill
facilities with the
Permit Years 1-5
Response Plan.
potential to pollute
FY21/22
stormwater.
FY22/23
FY23/24
FY24/25
FY25/26
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 34

Permit
3.7.3: MS4 Operation and Maintenance Program
Ref.
Measures to minimize pollutants in the stormwater collection system. The permittee shall provide operation
and maintenance staff training on stormwater awareness and pollution prevention, perform MS4 inspections,
maintain the collection system including catch basins and conveyances; and establish specific frequencies,
schedules, and standard documentation.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
39.
Inspections and Maintenance of Stormwater Conveyances
Inspection and Maintenance Plan for
1. Develop an SOP that
1. Permit Year 1
1. Yes/No/Status
stormwater infrastructure inspections.
identifies frequencies
FY21/22
and documentation for
maintenance.
2.Perfor n inspections in
2. Annually
2. Yes/No/Status
accordance with SOP
Permit Years 1-5
Number of MS4
FY21/22
inspections performed
FY22/23
FY23/24
FY24/25
FY25/26
3. Maintain a
3. Continuously
3. Yes/No/Status
prioritized Capital
Permit Years 1-5
Number of CIPs on list.
Improvement Project
FY21/22
Number of CIPs
(CIP) list.
FY22/23
completed.
FY23/24
FY24/25
FY25/26
40.
Employee Training
Continue stormwater training to
1. See BMP 36
1. See BMP 36
1. See BMP 36
employees within the Public Services
Department (See BMP 36).
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 35

Permit
3.7.4: Municipal SCM Operation and Maintenance Program
Ref.
Measures to manage municipally -owned, operated, and/or maintained structural stormwater control measures
(SCMs) that are installed for compliance with the permittee's post -construction program. The permittee shall
maintain a current inventory of SCMs, perform SCM inspections and maintenance, and shall establish specific
frequencies, schedules, and documentation.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
41.
Municipal SCM Inventory
Maintain inventory of municipally
1. Maintain Operation
1. Continuously
1. Yes/No/Status
owned structural SCMs.
and Maintenance plans
Permit Years 1-5
for all City -owned
FY21/22
SCMs.
FY22/23
FY23/24
FY24/25
FY25/26
2. Update inventory of
2. Continuously
2. Yes/No/Date
City -owned SCMs.
Permit Years 1-5
updated; total
FY21/22
number of SCMs
FY22/23
inventoried
FY23/24
FY24/25
FY25/26
42.
SCM Inspection and Maintenance
Perform regular inspections and
1. NC SCM Certification
1. Continuously
1. Yes/No/Status
maintenance of municipal SCMs and
is maintained by
Permit Years 1-5
Number of certified staff
document on an annual basis with all
Stormwater Staff
FY21/22
related documentation stored in a
conducting SCM
tracking database.
inspections.
FY22/23
FY23/24
FY24/25
FY25/26
2. Conduct annual SCM
2. Annually
2. Number of inspections
inspections per the SCM
Permit Years 1-5
performed
Inspection SOP.
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
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City of High Point
July 29, 2021
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3. Perform needed
3. Continuously
3. Number of SCMs
maintenance identified
Permit Years 1-5
maintained
during the inspections.
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
4. Update the tracking
4. Continuously
4. Yes/No/Status
data base with inspection
Permit Years 1-5
status and documents.
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
Permit
3.7.5: Pesticide, Herbicide and Fertilizer Management Program
Ref.
Measures to minimize water quality impacts from the use of landscape chemicals. The permittee shall provide
routine pollution prevention and chemical use, storage, and handling training, and shall ensure compliance with
pen -nits and applicator certifications.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
43.
_
Applicator Training for Pesticides, Herbicides and Fertilizer
Training of city staff who apply
1. Maintain proper
1. Continuously
1. Yes/No/Status
chemicals to help prevent
licenses or
Permit Years 1-5
Number of licensed
negative water quality impacts
certification for
FY21/22
staff
from pesticides, herbicides, and
applying pesticides,
FY22/23
fertilizers.
herbicides, and
FY23/24
fertilizers.
FY24/25
FY25/26
2. Yes/No/Status,
2. Provide staff training
2. Continuously
in pollution prevention
Permit Years 1-5
Number trained
and applying chemicals.
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
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Permit
3.7.6: Vehicle and Equipment Maintenance Program
Ref.
Measures to prevent and minimize contamination of stormwater runoff from areas used for municipal vehicle
and equipment maintenance and/or cleaning. The permittee shall ensure that municipal industrial facilities
subject to NPDES industrial permitting comply with those permit requirements, provide routine pollution
prevention training to staff, perform routine inspections, and establish specific frequencies, schedules, and
documentation.
BMP
A
B
C
D
No.
44.
NPDES Industrial Permit Compliance
Ensure that municipal facilities
1. Update municipal
1. Annually
1. Yes/No/Status
covered under an NPDES industrial
facility inventory with
Permit Years 1-5
permit are maintaining compliance.
NPDES permit status.
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Ensure that all NPDES
2. Annually
2. Yes/No/Status;
Permits for municipal
Permit Years 1-5
number of industrial
facilities are renewed as
FY21/22stormwater
permitted
needed.
facilities
FY222/23
FY23/24
FY24/25
FY25/26
3. Use industrial
3. Annually
3. Yes/No/Status;
facility inspection
Permit Years 1-5
number of industrial
form when
FY21/22
facility inspections
conducting annual
performed
inspections at
FY22/23
municipal facilities
FY23/24
covered under a
FY24/25
NPDES ermit.
FY25/26
4. See BMP 36
4. See BMP 36
4. See BMP 36
45.
Vehicle and Equipment Cleaning and Maintenance Facility Inspections
Vehicle and equipment cleaning and
1. Perform annual
1. Annually
1. Yes/No/Status
maintenance is included as part of the
inspections and notify
Permit Years 1-5
Number of inspections
annual facility inspection.
responsible person of any
FY21/22
performed
corrective actions
required.
FY22/23
FY23/24
FY24/25
FY25/26
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
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2. Ensure any corrective
2. Continuously
2. Yes/No/Status
actions are made by
Permit Years 1-5
Number of follow-up
conducting a follow-up
FY21/22
inspections performed
inspection and/or
contacting the
FY22/23
responsible person.
FY23/24
FY24/25
FY25/26
Permit
3.7.7: Pavement Management Program
Ref.
Measures to reduce pollutants in stormwater runoff from municipally -owned streets, roads, and parking lots
within the permittee's corporate limits. The permittee shall implement measures to control litter, leaves, debris,
particulate, and fluid pollutants associated with vehicles, and establish specific frequencies, schedules, and
documentation.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
46.
Street Sweeping
Street sweeping following a regular
1. Develop a standard
1. Permit Year 1
1. Yes/No/Status
schedule in order to reduce
operating procedure,
FY21/22
pollutants from City owned and
including schedules,
maintained streets.
zones/locations, and
proper disposal of
collected wash waters
and solids.
2. Implement SOP and
2. Annually
2. Number of street
documentation.
Permit Years 1-5
miles swept
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
47.
Loose Leaf Collection
Provide seasonal loose leaf collection
1. Publicize/establish
1. Annually
1. Yes/No/Status
in residential areas and compost the
protocols for residential
Permit Years 1-5
collected material at the city operated
brush and bagged leaf
FY21/22
composting center for use by the city
collections.
and residents.
FY22/23
FY23/24
FY24/25
FY25/26
2. Collect brush and
2. Annually
2. Total weight of brush
bagged leaves
Permit Years 1-5
collected
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
DRAFT FINAL NCS000421 SWMP
City of High Point
July 29, 2021
Page 39

Trevor Spencer
Engineering Services Director
Material Recycling Facility
Melanie Bruton
MRF Superintendent
APPENDIX A
Jay Wagner
Mayor
City Council
Tasha Logan Ford
City Manager
Terry Houk
Public Services Director
Robby Stone
Deputy Public Services Director
Stormwater Division
Justin Gray
Public Services Manager
Street Maintenance Division
Ken Sult
Street Maintenance Superintendent
Bob Martin
Customer Services Director
Environmental Services Division
Greg Holt
Environmental Services Superintendent
Rev. 6/28/2021