HomeMy WebLinkAboutNCS000421_High Point APPROVED SWMP_20211220NCS000421 SWMP
City of High Point
November 15th, 2021
Stormwater Management Plan
City of High Point
NCS000421
November 15th, 2021
NCS000421 SWMP
City of High Point
November 15th, 2021
Page ii
Table of Contents
PART 1: INTRODUCTION ........................................................................................................................ 1
PART 2: CERTIFICATION ........................................................................................................................ 2
PART 3: 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
NCS000421 SWMP
City of High Point
November 15th, 2021
Page iii
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
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 1
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.
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 2
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 enforceab le 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:
Print
Name: Tasha Logan Ford
Title: City Manager
Signed this day of November, 2021.
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 3
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.
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 4
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://gisweb10.highpointnc.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
Eco/Biological Integrity Fish Com
Eco/Biological Integrity Benthos
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 5
Long Branch
17-2-1-(2)
WS-IV;CA:*
Eco/Biological Integrity Fish Com
Eco/Biological 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/Biological Integrity Fish Com
West Fork of Deep River 17-3-(0.7) WS-IV;CA:* Eco/Biological 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 NCDEQ 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.
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 6
Table 3: Summary of Approved TMDLs
Water Body Name TMDL Pollutant(s) of Concern Stormwater
Waste
Load
Allocation
(Y/N)
Water
Quality
Recovery
Program
(Y/N)
E. Fork Deep River Fecal Coliform Y Y1
Richland Creek Fecal Coliform Y Y2
Rich Fork Creek Fecal Coliform Y Y1
Y1 : 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 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
Notropis 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
Perimyotis subflavus Tricolored bat Mammals Under Review
Clemmys muhlenbergii 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 NCDEQ 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
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 7
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 Innospec 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
NCG140003 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
NCG180220 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
NCGNE0951 Hancock & Moore, LLC
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 8
NCGNE0970 Baker Interiors Furniture Company - High Point
NCGNE0991 Syntec Seating Solutions LLC
NCGNE1022 High Point Furniture Industries
NCGNE1131 Fastenal Company
NCGNE1144 V&E Components, Inc.
NCGNE1208 Thomas Clyde Lamar ARC NC028
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
Irrigation waters Incidental
Springs Incidental
Water from crawl space pumps Incidental
Footing drains Incidental
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 9
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
Pollutant(s)
Likely Source(s)/Target Audience(s) SWMP Program Addressing Target
Pollutant(s)/Audience(s)
Litter General Public, Businesses, Schools Public Education & Outreach, Public
Participation
Pet Waste/Fecal
Coliform
General Public, Parks, Greenways,
Sewer Overflows, Failing Septic
Systems
Public Education & Outreach, Illicit
Discharge Detection & Elimination
Sediment Construction Erosion, Stream Bank
Erosion
Construction Site Runoff Control
Illicit Discharges General Public, Businesses,
Municipal Employees
Public Education & Outreach, Illicit
Discharge Detection & Elimination, Public
Involvement
Illegal Dumping General Public, Businesses,
Municipal Employees
Public Education & Outreach, Illicit
Discharge Detection & Elimination,
Pollution Prevention & Good Housekeeping
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 10
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
Administration
Dep. Public Services Director Robby Stone Public Services
Administration
SWMP Management Public Services Manager
Operations Analyst
Justin Gray
Vacant
Public Services
Stormwater Division
Public Education &
Outreach
Stormwater Specialists Robbie Baker
Kelsie Burgess
Abigail Rosendale
Public Services
Stormwater Division
Public Involvement &
Participation
Stormwater Specialists Robbie Baker
Kelsie Burgess
Abigail Rosendale
Public Services
Stormwater Division
Illicit Discharge
Detection & Elimination
Stormwater Specialists Robbie Baker
Kelsie Burgess
Abigail Rosendale
Public Services
Stormwater Division
Construction Site Runoff
Control
Engineering Services Director
Civil Engineer II
Erosion Control Inspectors
Trevor Spencer
Aspasia Vlachou
Scott Ford
Kathy Blake
Engineering
Services Division
Post-Construction
Stormwater Management
Operations Analyst Vacant Public Services
Stormwater Division
Pollution Prevention /
Good Housekeeping for
Municipal Operations
Stormwater Specialists Robbie Baker
Kelsie Burgess
Abigail Rosendale
Public Services
Stormwater Division
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 11
Municipal Facilities
Operation & Maintenance
Program
Stormwater Specialists Robbie Baker
Kelsie Burgess
Abigail Rosendale
Public Services
Stormwater Division
Spill Response Program All Stormwater Division Staff All Stormwater
Division Staff
Public Services
Stormwater Division
MS4 Operation &
Maintenance Program
Public Services Manager
Street Maint. Superintendent
Justin Gray
Ken Sult
Public Services
Stormwater Division
Municipal SCM
Operation & Maintenance
Program
Public Services Manager Justin Gray
Public Services
Stormwater Division
Pesticide, Herbicide &
Fertilizer Management
Program
Safety Officer Jim Gwynn Public Services
Administration
Vehicle & Equipment
Cleaning Program
Public Services Manager Justin Gray
Public Services
Stormwater Division
Pavement Management
Program
Public Services Manager
Street Maint. Superintendent
Justin Gray
Ken Sult
Public Services
Stormwater Division
(Streets Department)
Total Maximum Daily
Load (TMDL)
Requirements
Operations Analyst
Stormwater Specialists
Vacant
Robbie Baker
Kelsie Burgess
Abigail Rosendale
Public Services
Stormwater Division
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.
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 12
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
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
Name
Contact Person Phone & E-Mail Interlocal
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
Ref.
2.1.2 and Part 4: Annual Self-Assessment
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 period is the fiscal year (July 1 – June 30).
SWMP BMP or
Permit Requirement Implementing Entity & Program Name
Legal
Agreement
(Y/N)
N/A
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 13
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
1. Annual Self-Assessment
Perform an annual evaluation of
SWMP implementation, suitability of
SWMP commitments and any
proposed changes to the SWMP
utilizing the NCDEQ Annual Self-
Assessment Template.
1. Prepare, certify, and
submit the Annual Self-
Assessment to NCDEQ
prior to August 31 each
year.
1. Annually
Permit Years 1 – 4
FY21/22
FY22/23
FY23/24
FY24/25
1. Yes/No
Permit
Ref.
1.6: Permit Renewal Application
Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the
NPDES MS4 permit.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
2. Permit Renewal Application
Audit stormwater program
implementation for compliance with
the permit and approved SWMP and
utilize the results to prepare and
submit a permit renewal application
package.
1. Participate in an
NPDES MS4 Permit
Compliance Audit, as
scheduled and performed
by EPA or NCDEQ.
1. TBD – Typically
Permit Year 4
FY24/25
1. Yes/No
2. Self-audit and
document any
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).
2. Permit Year 5
FY25/26
2. Yes/No/Partial
3. Certify the stormwater
permit renewal
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.
3. Permit Year 5
FY25/26
3. Date of permit renewal
application submittal
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 14
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 Colifor m 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, Commerci al, 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
Ref.
3.2.2 and 3.2.4: Outreach to Targeted Audiences
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.
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 15
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
3. School Outreach
Develop age-specific educational
information for use in schools and
for presentations to school age
children. Will present information
in appropriate format.
1. Provide age-specific
stormwater presentations
upon request.
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Number of students
reached
2. Reach out to Guilford
County Schools and
Private schools to remind
them of the programs
offered.
2. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Yes/No/Status
3. Organize stream
habitat events for schools
and/or summer camps as
requested
3. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
3. Number of
participants
4. Public Event Tabling
Set up public education table at a
variety of public events and locations
in order to reach diverse groups,
minorities ,and underserved
populations. Educational topics will
vary and may include general
stormwater awareness and the
pollutants/sources listed in Table 12
above for the general public target
audience (litter, pet waste, septic tank
systems, FOG, nutrients, illicit
discharges, illegal dumping).
1. Monthly Library Table 1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Number of
interactions at the table
2. Monthly Farmer’s
Market Table
2. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Number of
interactions at the table
3. Attend at least 3 other
City of High Point Public
events.
3. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
3. Number of events held
and number of
interactions
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 16
4. Coordinate and attend
the annual Public
Services Day event.
4. Annually
Permit years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
4. Number of attendees
5. Coordinate and attend
one event in High Point
for Guilford Creek
Week.
5. Annually
Permit years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
5. Number of attendees
5. Utility Bill Inserts
Stormwater bill inserts will continue
to be inserted into combined utility
bill statements and distributed to all
City residents and businesses
receiving a utility bill on at least a
semi- annual schedule.
1. Develop and distribute
a stormwater flyer for
general stormwater
information/pet waste/
septic tank systems.
1. Semi-Annually
Permit Year 1
FY21/22
1. Number of flyers
mailed
2. Develop and distribute
a stormwater flyer for
illicit discharges/illegal
dumping and general
stormwater information
2. Semi-Annually
Permit Year 2
FY22/23
2. Number of flyers
mailed
3. Develop and distribute
a stormwater flyer for
litter/household
wastes/automotive care
and leaf pick
3. Semi-Annually
Permit Year 3
FY23/24
3. Number of flyers
mailed
4. Develop and distribute
a stormwater flyer for
general stormwater
information and fats,
oils, and grease (FOG)
4. Semi-Annually
Permit Year 4
FY24/25
4. Number of flyers
mailed
5. Develop and distribute
a stormwater flyer for
illicit discharge/illegal
dumping and yard
waste/leaf pickup.
5. Semi-Annually
Permit Year 5
FY25/26
5. Number of flyers
mailed
6. Stormwater Information Documents
Informational pamphlets, brochures,
and giveaways with specific
stormwater topics, as well as general
information to be handed out to
targeted groups and be available at all
tabling events.
1. Develop a list of target
audiences, groups, and/or
businesses for each
informational document.
1. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 17
2. Develop a schedule for
inventory of all
informational documents
and giveaways.
2. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Number of documents
of each topic distributed
7. Information Kiosks
Multiple stormwater documents will
be displayed at locations throughout
the City including City Hall
(Customer Service), Public Services
Department, the City of High Point
Visitors Center, Public Library,
Piedmont Environmental Center, and
other city-maintained recreational
facilities.
1. Develop a location list
and schedule to regularly
check kiosks
1. Annually
Permit Year 1 FY21/22
1. Yes/No/Status
2. Check kiosks to ensure
documents are available
and replenished
2. Quarterly
Permit Years 2-5
FY22/23
FY23/24
FY24/25
FY25/26
2. Number of documents
of each topic distributed
8. Social Media
Work with the City of High Point’s
Public Information Office to promote
information about upcoming events
and other stormwater- related
educational information using
multiple social media outlets
(Facebook, Next Door, Twitter,
Instagram)
1. Post at least three
stormwater specific
informational social
media posts per year.
1. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Number of views per
post and topic
9. Advertisements, Media, Etc.
Utilize additional physical or digital
advertising spaces to increase
visibility of the stormwater message.
1. At least once per year,
use non-municipal
website or outdoor
advertisement space
(e.g., La Noticia print
and website, using ad
space inside and outside
of High Point Transit
Buses, billboards,
shopping carts, etc.) to
display an informational
stormwater message.
1. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status, and
topic(s) displayed
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 18
Permit
Ref.
2.1.7, 3.2.3 and 3.6.5(c): Web Site
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.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
10. Informational Web Site
The Stormwater Services Division
will maintain an internet web site that
contains detailed information
regarding all aspects of the
stormwater permit requirements,
services offered, educational
brochures/fliers, and
reporting/contact information.
1. Maintain the
stormwater web page and
update any changes as
needed.
1. Continuously Permit
Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
2. Add a link on the
Stormwater webpage to
the NCDEQ Stormwater
webpage
2. Permit Year 1
FY21/22
2. Yes/No/Status
Permit
Ref.
3.2.5: Stormwater Hotline
Measures for a stormwater hotline/helpline for the purpose of public education and outreach.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
11. Stormwater Hotline
Dedicated Customer Service number
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.)
1. Respond to calls and
inquiries within one
business day (for non-
emergencies), and
immediately to an IDDE.
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Number of calls
received and number of
resolutions
2. Advertise
hotline/helpline in all
ads, printed materials,
social media, and
website.
2. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Yes/No/Status
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 19
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
Ref.
3.3.1: Public Input
Mechanisms for public involvement that provide for input on stormwater issues and the stormwater program.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
12. Stormwater Hotline
Dedicated Customer Service number
for all Public Services has been
established where citizens can call to
report stormwater pollution violations
(See BMP 11).
1. See BMP 11 1. See BMP 11 1. See BMP 11
Permit
Ref.
3.3.2: Volunteer Opportunities
Measures to provide volunteer opportunities designed to promote ongoing citizen participation.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
13. Adopt-a-Street Program
Provide public and private
organizations the opportunity for
volunteers to participate in cleaning
up local streams.
1. Check in with Keep
High Point Beautiful
President for Adopt-a-
Street results
1. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Pounds of trash and
recycling collected, date
and number of
participants
14. Adopt-a-Stream Program
Provide public and private
organizations the opportunity for
volunteers to participate in cleaning
up local streams.
1. Partner and coordinate
with organizations in
efforts to clean up
adopted stream.
1. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Pounds of trash and
recycling collected, date
and number of
participants
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 20
Table 14: Public Involvement and Participation BMPs
2. Recruit at least one
new Adopt-A-Stream
group per year.
2. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Number of new groups
15. Storm Drain Marking Program
Volunteers place drain markers on
storm drains to assist in stormwater
and watershed education within
neighborhoods and public streets.
1. Recruit at least one
new storm drain marking
volunteer group per year.
1. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
2. Coordinate storm
drain marking and track
marked drains
2. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Number of storm
drains marked, number
of participants
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 21
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
Ref.
3.4.1: MS4 Map
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.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
16. Storm Sewer System Inventory
Provide dedicated field staff to
collect and update stormwater
infrastructure data.
1. Add pertinent data for
new stormwater
infrastructure (pipes,
junctions, structures,
outfalls) to our
Stormwater GIS system
for new construction
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
2. Maintain storm sewer
system map including
stormwater conveyances,
flow direction, major
outfalls, and surface
waters.
2. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Yes/No/Status
Total number of mapped
outfalls
17. Stormwater Web Map
All SCMs within the City of High
Point are identified and added to the
current SCM Stormwater Web Map.
1. Add new SCMs to
mapping database once
construction and/or
conversion from erosion
control basin
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
18. Camera Crew
In-house staff collects stormwater
infrastructure data for existing
systems using pipe camera.
1. Maintain process for
collecting data and
incorporating pertinent
information into GIS
database
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 22
Table 15: Illicit Discharge Detection and Elimination BMPs
Permit
Ref.
3.4.2: Regulatory Mechanism
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
19. Enforcement
The Illicit Discharge Control
Ordinance will charge the Public
Services Director or designee with
implementing the Illicit Discharge
Detection and Elimination program.
The ordinance does specify legal
penalties to be implemented in cases
of non-compliance.
(Code of Ordinances, Title 12,
Chapter 3 - Public Nuisances).
1. Maintain illicit
discharge ordinance,
administration, and
enforcement procedures.
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
Permit
Ref.
3.4.3: IDDE Plan
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
20. Written IDDE Plan
Maintain and implement a written
IDDE Plan.
1. Continue to update the
IDDE Plan as required
by any change in
ordinance, state statute
or other federal
regulation than is
specific to IDDE
incidents
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
21. Outfall Inspections
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 23
Table 15: Illicit Discharge Detection and Elimination BMPs
Perform regular dry weather (no rain
in previous 72 hours) outfall
inspections to proactively identify
illicit discharges and illicit
connections.
1. Inspect 25% of all
major outfalls within the
City limits every year.
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
22. Detection and Elimination
Detect and identify illicit discharges
and connections; conduct dry-
weather outfall monitoring; respond
to citizen concerns made via the
Customer Service line; train City
personnel on recognizing and
reporting illicit discharges or
connections.
1. Continue to respond to
IDDEs, train employees,
and conduct outfall
monitoring
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
2. Maintain equipment
and materials to detect
IDDEs and analyze
stormwater samples.
2. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Yes/No/Status
Permit
Ref.
3.4.4: IDDE Tracking
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
23. Notice of Violation (NOV) Letters
NOVs with a detailed description of
the incident along with date/time
stamped photos are sent certified
mail to the violator or representative.
Follow-up occurs when the time
allotted for compliance has expired.
1. Continue to update
system processing of
IDDE records and
implement procedures
that may increase
efficiency of handling
these incidents
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
2. Store illicit discharge
information in database
and Excel spreadsheet;
maintain hard copies of
NOV letters, photos,
and other pertinent
information in physical
files
2. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Yes/No/Number of
enforcement actions
issued
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 24
Table 15: Illicit Discharge Detection and Elimination BMPs
Permit
Ref.
3.4.5: Staff IDDE Training
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 participating.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
24. Staff Training
Provide stormwater training to all
groups of municipal staff and/or
contractors each year.
Training shall include how to
identify and report illicit
discharges, illicit connections, illegal
dumping, and spills.
1. Maintain an employee
training program on
detecting and reporting
illicit discharges, illicit
connections, illegal
dumping, and spills.
1. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status,
Number trained
Permit
Ref.
3.4.6: IDDE Reporting
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
25. Stormwater Hotline
Dedicated Customer Service number
for all Public Services has been
established where citizens can call to
report stormwater pollution
violations.
1. Promote and
publicize phone number
to receive reports
related to illicit
discharges.
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Number of IDDEs
reported each year.
26. On-Call Duty Officer
On-Call duty officer to be available
after normal business hours to
investigate illicit discharges, illegal
dumping and spills if reported.
1. Promote and
publicize phone number
to receive reports
related to illicit
discharges.
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Number of IDDEs
reported each year.
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 25
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 -
3.5.4
City of High Point Delegated
SPCA Program*
15A NCAC Chapter 04
NCDEQ Approved Delegation
City of High Point
2
* 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
Ref.
3.5.6: Public Input
Measures to provide and promote a means for the public to notify the appropriate authorities of observed
erosion and sedimentation problems.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
27. Municipal Staff Training
Train municipal staff who receive
calls from the public on the protocols
for referral and tracking of
construction site runoff control
complaints.
1. Train municipal staff
on proper handling of
construction site runoff
control complaints.
1. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Number of staff
trained
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 26
28. Stormwater Hotline
Dedicated Customer Service number
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).
1. See BMP 11 1. See BMP 11 1. See BMP 11
Permit
Ref.
3.5.5: Waste Management
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
29. Establish and Maintain Legal Authority
Provide ordinance to require
construction site operators to control
waste
1. Develop, adopt and/or
update the ordinance
1. Permit Year 1
FY21/22
1. Yes/No/Status, date
of adoption
2. Maintain Legal
Authority
2. Continuously
Permit Years 2-5
FY22/23
FY23/24
FY24/25
FY25/26
2. Yes/No/Summary
30. Pre-Construction Conference
Conduct project conferences with
contractors, engineers, plan
reviewers and site construction
inspectors for all projects with
land disturbing activities
requiring an E&SC plan
1. Conduct Pre-
Construction Meetings
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Document and
report number of
preconstruction
conferences
2. Develop and
distribute informational
Fact Sheet at pre-
construction
conferences
2. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Yes/No/Status
Number of Fact Sheets
distributed
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 27
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
2
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
Plan Review and Approval
Municipal Ordinance/Code
Reference(s)
and/or Document Title(s)
Date Adopted
3.6.2(a) Authority City of High Point Development
Ordinance Chapter 2-2
Ord. No. 7266/17-08, § 2, 1-17-
2017; Ord. No. 7476/18-105, §
2.B, 12-3- 2018
3.6.3(a) & 15A NCAC
02H.0153(c) Federal, State &
Local Projects
City of High Point Development
Ordinance Chapter 6-2
Ord. No. 7266/17-08, § 27, 1-17-
2017; Ord. No. 7287/17-29, §
12, 4-3-2017
3.6.3(b) Plan Review City of High Point Development
Ordinance Chapter 2-2
Ord. No. 7266/17-08, § 2, 1-17-
2017; Ord. No. 7476/18-105, §
2.B, 12-3-2018
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 28
3.6.3(c) O&M Agreement City of High Point Development
Ordinance Chapter 6-2-11
Ord. No. 7266/17-08, § 27, 1-17-
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
Ordinance Chapter 6-2-11
Ord. No. 7266/17-08, § 27, 1-17-
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
Restrictions/Covenants
City of High Point Development
Ordinance Chapter 6-2-11
Ord. No. 7266/17-08, § 27, 1-17-
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
Ordinance Chapter 6-2-11
Ord. No. 7266/17-08, § 27, 1-17-
2017; Ord. No. 7287/17-29, §§ 12,
13, 4-3-2017; Ord. No. 7365/17-
108, § 1, 11-20-2017
Permit Requirements for
Inspections and
Enforcement
Municipal Ordinance/Code
Reference(s)
and/or Document Title(s)
Date Adopted
3.6.2(b) Documentation City of High Point Development
Ordinance Chapter 6-2-11
Ord. No. 7266/17-08, § 27, 1-17-
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
Ordinance Chapter 6-2-11
Ord. No. 7266/17-08, § 27, 1-17-
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
Ordinance Chapter 6-2-11
Ord. No. 7266/17-08, § 27, 1-17-
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
Plans
City of High Point Development
Ordinance Chapter 6-2-11
Ord. No. 7266/17-08, § 27, 1-17-
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
Inspections
City of High Point Development
Ordinance Chapter 6-2-11
Ord. No. 7266/17-08, § 27, 1-17-
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
Inspections
City of High Point Development
Ordinance Chapter 6-2-11
Ord. No. 7266/17-08, § 27, 1-17-
2017; Ord. No. 7287/17-29, §§ 12,
13, 4-3-2017; Ord. No. 7365/17-
108 § 1, 11-20-2017
3.6.4(e) Qualified
Professional
City of High Point Development
Ordinance Chapter 6-2-11
Ord. No. 7266/17-08, § 27, 1-17-
2017; Ord. No. 7287/17-29, §§ 12,
13, 4-3-2017; Ord. No. 7365/17-
108 § 1, 11-20-2017
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 29
Permit Requirements for
Fecal Coliform Reduction
Municipal Ordinance/Code
Reference(s)
and/or Document Title(s)
Date Adopted
3.6.6(a) Pet Waste City of High Point Code of
Ordinances, Title 12, Chapter 3,
Sec. 12-3-1
Ord. No. 6168/04-65, § 1, 9-7-04;
Ord. No. 6541/08-26, 5-19-08;
Ord. No. 6573/08-58, § 2, 8-18-
2008
3.6.6(b) On-Site Domestic
Wastewater Treatment
City of High Point Code of
Ordinances, Title 12,
Chapter 3, Sec. 12-3-1
(Ord. No. 6168/04-65, § 1, 9-7-04;
Ord. No. 6541/08-26, 5-19-08;
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
Ref.
3.6.5(a), 3.6.5(b), and 4.1.3: Minimum Post-Construction Reporting Requirements
Measures to document activities over the course of the fiscal year (July 1 – June 30) including appropriate
information to accurately describe progress, status, and results.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
31. Standard Reporting
Implement standardized tracking,
documentation, inspections, and
reporting mechanisms to compile
appropriate data for the annual self-
assessment process. Data shall be
provided for each Post-Construction/
Qualifying Alternative Program being
implemented as listed in Tables 18
and 19.
1. Track number of low
density and high density
plan reviews performed.
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Number of plan
reviews performed for
low density and high
density.
2. Track number of low
density and high density
plans approved.
2. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Number of plan
approvals issued for low
density and high density.
3. Maintain a current
inventory of low density
projects and constructed
SCMs including SCM
type or low density
acreage, location, and
last inspection date.
3. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
3. Summary of number
and type of SCMs added
to the inventory; and
number and acreage of
low density projects
constructed.
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 30
Table 20: Post Construction Site Runoff Control BMPs
4. Track number of
SCM inspections
performed.
4. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
4. Number of SCM
inspections.
5. Track number of low
density inspections
performed.
5. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
5. Number of low density
projects inspected.
6. Track number and
type of enforcement
actions taken.
6. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
6. Number of
enforcement actions
issued.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
Permit
Ref.
3.6.3: Plan Review and Approval
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.
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 31
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
Permit
Ref.
3.6.4: Inspections and Enforcement
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
Permit
Ref.
3.6.6: Fecal Coliform Reduction
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.
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 32
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
Ref.
3.7.1: Municipal Facilities Operation and Maintenance Program
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 practices.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
33. Operation and Maintenance Plan
Maintain and update the written
Operation and Maintenance Plan.
1. Implement all aspects
of the O&M Plan
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
Summary
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 33
2. Update plan on an
annual basis.
2. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
Summary
34. Inventory of Municipal Facilities
Update and maintain inventory of
municipal facilities that have the
potential to generate polluted
stormwater runoff.
1. Review and update list
of municipal facilities.
1. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Date
updated
35. Municipal Facility Inspections
Inspect municipal facilities deemed to
have the potential to generate
polluted stormwater runoff.
1. Review and update
municipal inspection
forms.
1. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Yes/No/Status
2. Perform municipal
facility inspections on
those facilities that have
the potential to pollute
stormwater.
2. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Yes/No/Status,
number of inspections
36. Municipal Employee Training
Conduct annual stormwater training
that covers general stormwater
awareness, pollution prevention and
spill response, and IDDE reporting
1. Perform employee
training at Facilities that
have been identified as
having the possibility to
have a negative impact
on stormwater.
1. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status,
Number trained
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 34
Permit
Ref.
3.7.2: Spill Response Program
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.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
37. Spill Response Plan
A written spill response plan has been
developed for municipal facilities that
store or use materials that could
contaminate stormwater runoff.
Municipal facilities with industrial
permits have a spill response plan as
part of their Stormwater Pollution
Prevention Plan or SPCC Plan.
1. Review and update
Spill Response Plan
annually to ensure plan is
effective.
1. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
2. Perform spill
response training for
municipal employees
annually.
2. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Yes/No/Status,
Number trained
3. Evaluate municipal
facilities to determine if
any need to be added or
removed from those
requiring a Spill
Response Plan.
3. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
3. Yes/No/Status
38. Maintain Inventory of Facilities with a Spill Response Plan
Maintain a list of city facilities that
have a SPCC Plan, SWPPP, or Spill
Response Plan.
1. Update list of city
facilities with the
potential to pollute
stormwater.
1. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 35
Permit
Ref.
3.7.3: MS4 Operation and Maintenance Program
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
39. Inspections and Maintenance of Stormwater Conveyances
Inspection and Maintenance Plan for
stormwater infrastructure inspections.
1. Develop an SOP that
identifies frequencies
and documentation for
maintenance.
1. Permit Year 1
FY21/22
1. Yes/No/Status
2.Perform inspections in
accordance with SOP
2. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Yes/No/Status
Number of MS4
inspections performed
3. Maintain a
prioritized Capital
Improvement Project
(CIP) list.
3. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
3. Yes/No/Status
Number of CIPs on list.
Number of CIPs
completed.
40. Employee Training
Continue stormwater training to
employees within the Public Services
Department (See BMP 36).
1. See BMP 36 1. See BMP 36 1. See BMP 36
Permit
Ref.
3.7.4: Municipal SCM Operation and Maintenance Program
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.
A B C D
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 36
BMP
No. Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
41. Municipal SCM Inventory
Maintain inventory of municipally
owned structural SCMs.
1. Maintain Operation
and Maintenance plans
for all City-owned
SCMs.
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
2. Update inventory of
City-owned SCMs.
2. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Yes/No/Date
updated; total
number of SCMs
inventoried
42. SCM Inspection and Maintenance
Perform regular inspections and
maintenance of municipal SCMs and
document on an annual basis with all
related documentation stored in a
tracking database.
1. NC SCM Certification
is maintained by
Stormwater Staff
conducting SCM
inspections.
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
Number of certified staff
2. Conduct annual SCM
inspections per the SCM
Inspection SOP.
2. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Number of inspections
performed
3. Perform needed
maintenance identified
during the inspections.
3. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
3. Number of SCMs
maintained
4. Update the tracking
data base with inspection
status and documents.
4. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
4. Yes/No/Status
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 37
Permit
Ref.
3.7.5: Pesticide, Herbicide and Fertilizer Management Program
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
43. Applicator Training for Pesticides, Herbicides and Fertilizer
Training of city staff who apply
chemicals to help prevent
negative water quality impacts
from pesticides, herbicides, and
fertilizers.
1. Maintain proper
licenses or
certification for
applying pesticides,
herbicides, and
fertilizers.
1. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
Number of licensed
staff
2. Provide staff training
in pollution prevention
and applying chemicals.
2. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Yes/No/Status,
Number trained
Permit
Ref.
3.7.6: Vehicle and Equipment Maintenance Program
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
No. A B C D
44. NPDES Industrial Permit Compliance
Ensure that municipal facilities
covered under an NPDES industrial
permit are maintaining compliance.
1. Update municipal
facility inventory with
NPDES permit status.
1. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 38
2. Ensure that all NPDES
Permits for municipal
facilities are renewed as
needed.
2. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Yes/No/Status;
number of industrial
stormwater permitted
facilities
3. Use industrial
facility inspection
form when
conducting annual
inspections at
municipal facilities
covered under a
NPDES permit.
3. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
3. Yes/No/Status;
number of industrial
facility inspections
performed
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
maintenance is included as part of the
annual facility inspection.
1. Perform annual
inspections and notify
responsible person of any
corrective actions
required.
1. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
Number of inspections
performed
2. Ensure any corrective
actions are made by
conducting a follow-up
inspection and/or
contacting the
responsible person.
2. Continuously
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Yes/No/Status
Number of follow-up
inspections performed
Permit
Ref.
3.7.7: Pavement Management Program
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
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
46. Street Sweeping
NCS000421 SWMP
City of High Point
November 15th, 2021
Page 39
Street sweeping following a regular
schedule in order to reduce
pollutants from City owned and
maintained streets.
1. Develop a standard
operating procedure,
including schedules,
zones/locations, and
proper disposal of
collected wash waters
and solids.
1. Permit Year 1
FY21/22
1. Yes/No/Status
2. Implement SOP and
documentation.
2. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Number of street
miles swept
47.
Loose Leaf Collection
Provide seasonal loose leaf collection
in residential areas and compost the
collected material at the city operated
composting center for use by the city
and residents.
1. Publicize/establish
protocols for residential
brush and bagged leaf
collections.
1. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
1. Yes/No/Status
2. Collect brush and
bagged leaves
2. Annually
Permit Years 1-5
FY21/22
FY22/23
FY23/24
FY24/25
FY25/26
2. Total weight of brush
collected