NCS000422_Black Mtn Memo_20190916

MEMORANDUM

DATE: September 16, 2019
TO: Town of Black Mountain
FROM: Jeanette Powell, MS4 Program Coordinator
RE: NPDES MS4 Permit No. NCS000422

cc: DEMLR Asheville Regional Office
DEMLR NPDES MS4 Permit Laserfiche File

In cooperation with the EPA, the North Carolina Department of Environmental Quality (DEQ)
implemented a comprehensive stormwater permit compliance initiative beginning in 2018. As part of this
initiative, the Town of Black Mountain will be subject to a permit compliance audit sometime next year
(2020) for the Town’s current National Pollutant Discharge Elimination System (NPDES) Municipal
Separate Storm Sewer System (MS4) Permit. As part of the compliance audit, DEQ will specifically
review ordinances and implementation for required programs such as post-construction runoff controls,
illicit discharge detection and elimination, and on-site wastewater.

During the MS4 compliance audit, the auditor will provide an opportunity for the MS4 to describe what it
thinks it is doing well. This is an opportunity to highlight proactive measures the MS4 has taken to
implement a comprehensive stormwater management program. To date, the audited MS4 programs have
generally been found to be reactive rather proactive, and all but one audited MS4 has been issued an
enforcement action. Please note that it is a requirement of the MS4 Permit that the programs
implemented to meet MS4 permit requirements be proactive in their scope, structure and
implementation. This includes updating ordinances, establishing and implementing clear and
consistent requirements, institutionalizing documentation, and maintaining consistency with
ongoing state regulatory changes.