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Home My WebLink AboutNCS000421_High Point Draft Final SWMP_20210803Draft Final Stormwater Management Plan City of High Point NCS000421 July 29, 2021 NORTH CAROLINAS INTERNATIONALCITT"" DRAFT FINAL NCS000421 SWMP City of High Point July 29, 2021 Table of Contents PART1: INTRODUCTION........................................................................................................................ 1 PART2: CERTIFICATION........................................................................................................................ 2 PART3: MS4 INFORMATION..................................................................................................................3 3.1 Permitted MS4 Area..................................................................................................................... 3 3.2 Existing MS4 Mapping.................................................................................................................4 3.3 Receiving Waters.......................................................................................................................... 4 3.4 MS4 Interconnection.....................................................................................................................5 3.5 Total Maximum Daily Loads (TMDLs)....................................................................................... 5 3.6 Endangered and Threatened Species and Critical Habitat............................................................ 6 3.7 Industrial Facility Discharges....................................................................................................... 6 3.8 Non-Stormwater Discharges......................................................................................................... 8 3.9 Target Pollutants and Sources.......................................................................................................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: ,A ,s ' �d4 Print Randy McCilslin Name: Title: Deputy City Manager Signed this ol—�day 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. 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://giswebI O.hig_hpointnc.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 Map 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 Corn EcoBiolo ical 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 Corn 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 Corn West Fork of Deep River 17-3- 0.7 WS-IV;CA:* Eco/Biolo ical Integrity Fish Corn 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) 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' Yl : Outfall monitoring program only YZ : 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 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, 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 Iogperch 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 Mannington 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 HighPoint 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 Irrigation 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 S WMP 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, I 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 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 (YN) 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. BMP 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 package). -application 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 ermit ex iration. 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 Phos horus/Nitro en 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 wastes/automotive 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 1 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 SWMP. The web page shall also provide developers with all relevant post -construction requirements, design standards, checklists and/or other materials. A B C D 13MP o. 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 2. Add a link on the 2. Permit Year 1 2. Yes/No/Status reporting/contact information. 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 2. Advertise 2. Continuously _ 2. Yes/No/Status magnates, etc.) 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 Ref. 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 1 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 FY21122 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 lter. 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 Rer. 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. 13�IP 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 connections. 2. Maintain equipment 2. Continuously 2. Yes/No/Status 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 Annual Reporting Implementation 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 8: 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 I 1 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 Ref. 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 FY222/2/233 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 State QAP Name State Requirements Local Ordinance / Regulatory 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 Implementation 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 FY22/23 stormwater. 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 FY22/23 have a negative impact 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. FY22/23 Municipal facilities with industrial 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 requiring a Spill FY22/23 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.Perform 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 DRAFT FINAL NCS000421 SWMP City of High Point July 29, 2021 Page 36 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 WE 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 permits 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 Page 37 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 FY21/22 stormwater permitted needed. FY22/23 facilities 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 permit. 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 Page 38 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 � � Al Z LLJ � a \ % / \ \ a/( / / D \ \ L \ .\ \ � \ \ \ \ \ \ ) / \ \ 6 G G / \ m ■ \