HomeMy WebLinkAboutNCS000424_Fletcher Draft SWMP v3 Partial Comments_20210610
Draft Stormwater Management Plan
Town of Fletcher
NCS000424
Document Date
Prepared By:
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 ............................................................................................................ 3
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 .......................................................... 7
3.7 Industrial Facility Discharges ................................................................................................... 7
3.8 Non-Stormwater Discharges ..................................................................................................... 8
3.9 Target Pollutants and Sources................................................................................................... 8
PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION ................................... 9
4.1 Organizational Structure ........................................................................................................... 9
4.2 Program Funding and Budget ................................................................................................. 11
4.3 Shared Responsibility ............................................................................................................. 12
4.4 Co-Permittees ........................................................................................................................ 13
4.5 Measurable Goals for Program Administration ....................................................................... 13
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 ..................... 33
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
NCS000424 SWMP
Town of Fletcher
Document Date
Page 1
PART 1: INTRODUCTION
The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which
the Town of Fletcher 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 Town of Fletcher 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 NCS000424, as issued by NCDEQ. This permit covers activities associated with
the discharge of stormwater from the MS4 as owned and operated by the Town of Fletcher and located
within the corporate limits of the Town of Fletcher.
In preparing this SWMP, the Town of Fletcher 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.
NCS000424 SWMP
Town of Fletcher
Document Date
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 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:
Print
Name:
Mark Biberdorf
Title:
Town Manager
Signed this ____ day of 2021 .
NCS000424 SWMP
Town of Fletcher
Document Date
Page 3
PART 3: MS4 INFORMATION
3.1 Permitted MS4 Area
This SWMP applies throughout the corporate limits of the Town of Fletcher., including all regulated
activities associated with the discharge of stormwater from the MS4. The map below shows the Town’s
boundary, as of the date of this document.
3.2 Existing MS4 Mapping
The most current MS4 mapping was completed in 2007 as part of a Stormwater Masterplan. It included
230 outfall locations and analysis (135 major pipe outfalls). Existing culverts were studied in 2007 to
determine conditions and possible pipe failure analysis. Documentation consisted of culvert sizes,
conditions and locations. This Mapping has not been updated since 2007. The Town’s 2007 Outfall
Map includes all pipe outfalls that were inventoried throughout the Town. A total of 230 outfall points
including pipes and channels, 59 pipes/culverts and 6 bridges were mapped. The number represented in
Table 1 represents an estimate of the mapped area and the estimated number of major outfalls.
NCS000424 SWMP
Town of Fletcher
Document Date
Page 4
The Town of Fletcher Stormwater Master Plan was created to address the following stormwater related
items:
• Creating a National Pollutant Discharge Elimination System (NPDES) Phase II compliant
Stormwater Ordinance.
• NPDES compliant stormwater outfall inventory and illicit discharge detection.
• Town of Fletcher culvert capacity analysis.
• Detailed Wildwood Garden/ Higgins Branch analysis.
• Minimum Detailed Hoopers Valley Estates / Hoopers Creek Analysis.
• On-going Stormwater Conveyance System Maintenance.
A MS4 GIS map is not available on-line at this time. See BMP #11 for plans to provide on-line maps.
Table 1: Summary of Current MS4 Mapping
Percent of MS4 Area Mapped 80 %
No. of Major Outfalls* Mapped 135 total
See BMPs #11 and #14 for updating mechanisms and timelines for improving the MS4 mapping.
*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 Town of Fletcher MS4 is located within the French Broad River Basin 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
NCS000424 SWMP
Town of Fletcher
Document Date
Page 5
Receiving Water Name Stream
Index / AU
Number
Water
Quality
Classification
303(d) Listed Parameter(s)
of Interest
Cane Creek C Benthos (Nar, AL, FW); Fish Tissue
Mercury (Nar, FC, NC)
Pinner Creek C;Tr
Hoopers Creek C;Tr
Kimsey Creek C
Higgins Creek C
Frady Lake C
C – Class C (fishable/swimmable waters)
Tr – Trout Waters
Benthos (Nar, AL, FW) – Narrative Standard, Aquatic Life, Fresh Waters
Fish Tissue Mercury (Nar, FC, NC) – All waters, river basins, and watershed in North Carolina
3.4 MS4 Interconnection
The Town of Fletcher MS4 is not interconnected with another regulated MS4 and directly discharges to
the receiving waters as listed in Table 2 above.
The MS4 does/does not interconnect with the statewide NCDOT MS4 and includes:
a. The interconnection is/is not receiving stormwater from the NCDOT MS4. The number of
interconnections is known/estimated/unknown. Quantity: ## or N/A
b. The interconnection is/is not discharging stormwater into the NCDOT MS4. The number of
interconnections is known/estimated/unknown. Quantity: ## or N/A
c. The MS4name MS4 mapping does/does not identify interconnections with the NCDOT MS4.
d. The MS4name MS4 mapping does/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.
Table 3: Summary of Approved TMDLs
Water Body Name TMDL Pollutant(s) of Concern Stormwater
Waste
Water
Quality
NCS000424 SWMP
Town of Fletcher
Document Date
Page 6
Load
Allocation
(Y/N)
Recovery
Program
(Y/N)
Statewide Mercury N N
Approximately 98% of the mercury deposited in NC is due to air emissions. Other minor sources may
include wastewater treatment plants and industrial wastewater dischargers. The Town of Fletcher has no
wastewater treatment facilities. There are several NPDES permit holders in Fletcher (see Section 3.7).
Local impacts of non-point source discharges are controlled by NCDEQ Water Quality programs such as
the Phase II Program. The Town of Fletcher has implemented its Phase II program by contracting with
Henderson County for permitting of stormwater management measures. See other areas of this SWMP
for additional information on strategies for water quality recovery.
The following link provides additional information on the NC Statewide Mercury TMDL.
https://files.nc.gov/ncdeq/Water%20Quality/Planning/TMDL/FINAL%20TMDLS/Statewide/NCMercury
TMDL_EPASubmit.pdf
NCS000424 SWMP
Town of Fletcher
Document Date
Page 7
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: PotentialFederally Listed Species/Habitat Impacted by Surface Water Quality
Scientific Name Common name Species Group Federal Listing Status
Haliaeetus leucocephalus Bald Eagle Vertebrate BGPA
Glyptemys muhlenbergii Bog Turtle Vertebrate T (S/A)
Myotis septentrionalis Northern long-eared bat Vertebrate T
Alasmidonta raveneliana Appalachian elktoe Invertebrate E
Sagottaroa fasciculata Bunched arrowhead Vascular Plant E
Sarracenia rubra
ssp.jonesii
Mountain sweet
pitcherplant
Vascular Plant E
Helonias bullata Swamp pink Vascular Plant T
BGPA – Bald and Golden Eagle Protection Act
T – Threatened T (S/A) – Threatened due to similarity of appearance
E – Endangered
3.7 Industrial Facility Discharges
The Town of Fletcher 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
NCS000424 Town of Fletcher SW Discharge, Individual (MS4)
NCG020167 Oldcastle Materials
NCG030011 Borg Warner Cooling Systems
NCG030430 Blue Ridge Metals Corp.
NCG050030 Wilson Art International
NCG050399 Upm Raflatac, Inc.
NCG080866 Southeastern Freight Line
NCG140160 Southern Concrete Materials
NCGNE0208 DHL Express
NCGNE0428 Borg Warner Remanufacturing
NCGNE0547 Upm Raflatac, Inc.
NCGNE0892 Smartrac Technology
NCS000424 SWMP
Town of Fletcher
Document Date
Page 8
3.8 Non-Stormwater Discharges
The water quality impacts of non-stormwater discharges have been evaluated by the Town of Fletcher as
summarized in Table 6 below. The unpermitted non-stormwater flows listed as incidental do not
significantly impact water quality. The Town of Fletcher has evaluated residential and charity car
washing for possible significant water quality impacts. Dry street sweeping is the method for street
cleaning.
The Division has not required that other non-stormwater flows be specifically controlled by the Town of
Fletcher.
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 been evaluated by the Town of Fletcher to determine whether they may
significantly impact water quality. As a result of no complaints, and the small amount of visual
observations, it has been determined that residential and charity car washing with detergent is considered
incidental in the Town of Fletcher.
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
Lawn watering Incidental
Residential and charity car washing Incidental
Flows from riparian habitats and wetlands Incidental
Dechlorinated swimming pool discharges Incidental
Street wash water N/A
Flows from firefighting activities Incidental
3.9 Target Pollutants and Sources
In addition to those target pollutants identified above, the Town of Fletcher is not aware of other
significant water quality issues within the permitted MS4 area.
NCS000424 SWMP
Town of Fletcher
Document Date
Page 9
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 Town of Fletcher has evaluated schools,
homeowners and businesses as target audiences that are likely to have significant stormwater impacts.
The target audiences, as shown in Table 7 were identified due to the potential for these entities to
contribute to pollutants and because they are the groups that have probable ability to affect positive
change.
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 Residents, Businesses, Schools Public Education & Outreach, Public
Involvement & Participation
Yard Waste Residents, Businesses, Schools Public Education & Outreach Public
Involvement & Participation
Illicit discharges Residents, Businesses, Industrial,
public employees
Public Education & Outreach, Public
Involvement & Participation, Illicit
Discharge Detection & Elimination
(IDDE)
Sediment Construction Sites Construction Site Runoff Control,
Post-Construction Site Runoff
Control
Illegal Dumping Residents, Businesses, Industrial,
public employees
Public Education & Outreach,
Pollution Prevention & Good
Housekeeping
Improper Disposal of
Waste
Residents, Businesses, Industrial,
public employees
Public Education & Outreach,
Pollution Prevention & Good
Housekeeping
PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION
4.1 Organizational Structure
In the Town of Fletcher the Planning Director is designated as the Stormwater Program Administrator.
The Stormwater Administrator is responsible for operation of the SWMP, the MS4 Permitting and for
yearly reporting to NCDEQ. The Planning Director falls under the umbrella of the Town Manager. The
Planning Director works closely with the Public Works Director for municipal operations and reporting as
specified in this SWMP.
Mayor
Town Council
Town Manager
NCS000424 SWMP
Town of Fletcher
Document Date
Page 10
Table 8: Summary of Responsible Parties
SWMP Component Responsible Position Staff Name Department
Stormwater Program
Administration
Planning Director Eric Rufa Planning and Zoning
SWMP Management Planning Director Eric Rufa Planning and Zoning
Public Education &
Outreach
Planning Director Eric Rufa Planning and Zoning
Public Involvement &
Participation
Planning Director Eric Rufa Planning and Zoning
Illicit Discharge
Detection &
Elimination
Planning Director Eric Rufa Planning and Zoning
Construction Site
Runoff Control
Planning Director
Implemented by
Henderson County
Engineering
Eric Rufa
Natalie Berry, PE
Erosion Control Local
Program
Post-Construction
Stormwater
Management
Planning Director
Implemented by
Henderson County
Engineering
Eric Rufa
Natalie Berry, PE
Phase II Local Program
Pollution
Prevention/Good
Housekeeping for
Municipal Operations
Public Works Director Jabbo Pressley Public Works
Municipal Facilities
Operation &
Maintenance Program
Public Works Director Jabbo Pressley Public Works
Spill Response Program Planning Director
Public Works Director
Eric Rufa
Jabbo Pressley
Planning and Zoning
Public Works
MS4 Operation &
Maintenance Program
Planning Director
Public Works Director
Eric Rufa
Jabbo Pressley
Planning and Zoning
Public Works
Planning Director Public Works
NCS000424 SWMP
Town of Fletcher
Document Date
Page 11
Municipal SCM
Operation &
Maintenance Program
Public Works Director
Jabbo Pressley
Eric Rufa
Public Works for
scheduled maintenance
and rainfall event
inspections
Planning and Zoning
Outsourcing for annual
inspection/certifications
Pesticide, Herbicide &
Fertilizer Management
Program
Public Works Director Jabbo Pressley Public Works
Vehicle & Equipment
Cleaning Program
Public Works Director Jabbo Pressley Public Works
Pavement Management
Program
Public Works Director Jabbo Pressley Public Works
Total Maximum Daily
Load (TMDL)
Requirements
Planning Director Eric Rufa Planning and Zoning
4.2 Program Funding and Budget
In accordance with the issued permit, the Town of Fletcher 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 Town of Fletcher’s current stormwater program is funded under the Planning Department Budget.
An amount of $30,000 is currently budgeted for the program over the permit term. Current analysis
shows the MS4 program to be under-funded. The Town is currently evaluating their budget in order to
have adequate funds for implementation of the SWMP and to comply with MS4 Permit requirements.
The Town currently has one full time employee and one part-time employee in the Planning and Zoning
Department. Stormwater Program responsibilities are currently overseen by the Planning and Zoning
Director. The Public Works Director is also involved in elements of the SWMP. In order for the
successful implementation of certain sections of this SWMP, it will be determined (BMP #4) if additional
funds will be required for adding staffing or contract employees.
Additional funding will be necessary to meet the requirements of the Town’s MS4 Permit. Steps will be
taken to evaluate this need and put funding mechanisms in place (see BMP #3 and #4). In the last
2 fiscal years, the Town has increased their Stormwater budget which is at $30,000. Town Council is
aware of the recent Audit and creation of a new SWMP. There is a plan to go back to Council for the
next budget cycle (Jan-March) with a more accurate picture of cost needs to properly run the program.
NCS000424 SWMP
Town of Fletcher
Document Date
Page 12
The Town is currently in discussions with Land of Sky Regional Council to evaluate what can be funded
through Grants, aiding in the Town’s funding analysis.
4.3 Shared Responsibility
The Town of Fletcher will share the responsibility to implement the following minimum control
measures, which are at least as stringent as the corresponding NPDES MS4 Permit requirement. The
Town of Fletcher remains responsible for compliance if the other entity fails to perform the permit
obligation, and may be subject to enforcement action if neither the Town of Fletcher nor the other entity
fully performs the permit obligation. Table 9 below summarizes who will be implementing the
component, what the component program is called, the specific SWMP BMP or permit requirement that
is being met by the shared responsibility, and whether or not a legal agreement to share responsibility is in
place. Listed in Table 9 are the current shared program that are in place.
Table 9: Shared Responsibilities
SWMP BMP or
Permit Requirement Implementing Entity & Program Name
Legal
Agreement
(Y/N)
3.5 Construction Site Runoff
Control Program
Henderson County Delegated Erosion and Sediment Control
Permitting
Y
3.6 Post Construction
Program
Henderson County Delegated Phase II Post-Construction
Stormwater Permitting
Y
BMP #5 Land of Sky Regional Council N
NCS000424 SWMP
Town of Fletcher
Document Date
Page 13
4.4 Co-Permittees
There are no other entities applying for co-permittee status under the NPDES MS4 permit number
NCS000424 for the Town of Fletcher. Table 10 summarizes contact information for each co-permittee.
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 Town of Fletcher 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).
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
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
NCS000424 SWMP
Town of Fletcher
Document Date
Page 14
Table 11: Program Administration BMPs
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
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 2. Submit Self-Audit to
DEMLR (required
component of permit
renewal application
package).
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 3. Date of permit renewal
application submittal
Permit
Ref. 2.1.1: Adequate Funding and Staffing
The permittee shall maintain adequate funding and staffing to implement and manage the provisions of the
SWMP and meet all requirements of this permit.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
3. Adequate Funding and Staff
Explore options to obtain adequate
program funding to fully fund the
stormwater program.
1. Work with other Town
officials to prepare a gap
analysis.
1. Permit Year 1. 1. Yes/No/Status
2. Evaluate methods and
options for obtaining
additional funding.
2. Permit Year 2. 2. Yes/ No/Status
NCS000424 SWMP
Town of Fletcher
Document Date
Page 15
Table 11: Program Administration BMPs
3. Implement action
items for obtaining the
chosen funding
mechanism.
3. Permit Year 4. 3. Yes/No/Status
4. Evaluate need for additional staffing.
Evaluate need for additional staffing
and/or contract services.
1. Work with other Town
officials to determine if
additional staffing and/or
contract services will be
required for successfully
implementing the
SWMP.
1. Permit Year 2. 1.
Yes/No/Status
2. Based on findings,
create a timeline for
hiring additional staff or
contract services and
determine job
description/duties.
1. Permit Year 4. 1. Yes/No/Status
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM
The Town of Fletcher 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 Town of
Fletcher 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 Residents, Businesses, Schools
Yard Waste Residents, Businesses, Schools
Illicit Discharges Residents, Businesses, Industrial, public employees
Sediment Construction Sites
Illegal Dumping Residents, Businesses, Industrial, public employees
Improper Disposal of Waste Residents, Businesses, Industrial, public employees
NCS000424 SWMP
Town of Fletcher
Document Date
Page 16
The Town of Fletcher 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.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
5. Partnership with Land of Sky Council of Governments
The Town will contract with the Land
of Sky Regional Council (LOSRC) to
implement programs and create
materials for public education and
outreach to residents, youth,
businesses, and commercial property
owners within the Town’s
jurisdiction. Include social media.
1. Execute a legal
agreement with LOSRC
to provide educational
materials and activities
that target Town of
Fletcher audiences as
listed in Table 12.
1. Permit Year 2. 1.
Yes/No/Status
2. Provide education and
outreach to target
audiences on topics per
Table 12 each year so
that all topics and
audiences have been
addressed by permit year
5.
2.Annually
Permit Years 2 - 5.
2. Report event type,
number of contacts made
and topics addressed
6. Update literature
The Town will evaluate their current
handout and if necessary create an
updated brochure that can be used
throughout the permit period. Key
placement of brochures will be
determined and distributed at Town
Hall.
1. Inventory current
literature. Evaluate
whether current literature
is appropriate for use and
if not create and have
printed new materials.
1. Permit Year 1. 1. Yes/No/Status
2. Place literature in key
locations at the Town
Hall facility. Re place
monthly.
2. Permit Years 1 - 5. 2. Yes/No/Status
Number of brochures
distributed
NCS000424 SWMP
Town of Fletcher
Document Date
Page 17
Table 13: Public Education and Outreach BMPs
7. Participate in a public event
The Town will pass out general
stormwater awareness literature at a
minimum at one public event lead by
the Town and display informative
information related to stormwater.
1. Man a booth at one
public event to distribute
literature.
1. Permit Years 3-5. 1. Yes/No/Status
Number of contacts
made
2. For the events, create a
display and/or other
visual materials with
specific information
about pollutants of
concern such as litter,
nutrients, non-point
source pollution, waste
disposal. Include how to
help material pertaining
to the target audience(s).
2. Permit Year 3 2. Yes/No/Status
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
8. Stormwater Page on the Town’s Website
The Stormwater web page will be
updated to include at a minimum the
following stormwater related items:
• Links to pertinent permitting
authorities.
• Links to Applicable
Ordinances.
• The MS4 Permit and
SWMP.
• Hotline and instructions for
reporting illicit discharges
and other environmental
issues.
• Opportunities for public
involvement.
• General stormwater
awareness information.
1. Make improvement to
the Stormwater web page
to include listed items.
1. Permit Years 1
through 3.
1. Yes/No/Status
Date that it was rolled
out.
2. Maintain the web
page, including any
updates and resolving
technical issues.
2. Annually, Permit
Years 1-5.
2. Yes/No/Status
NCS000424 SWMP
Town of Fletcher
Document Date
Page 18
Table 13: Public Education and Outreach BMPs
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
9. Advertise the Stormwater Hotline
Provide the hotline number and
protocol to the general public and
business community.
1. Provide the hotline
and pertinent information
on the Stormwater Web
page and in all new
stormwater literature.
1. Continuously
Permit Years 1-5
1. Yes/No/Status
10. Train Hotline Staff
Train staff on SOP to direct hotline
calls to appropriate responders.
1. Develop SOP for
managing hotline calls.
2. Train staff on SOP.
1. Permit Year 1
2. Annually
Permit Years 1-5
1. Yes/No/Status
2. Number trained
NCS000424 SWMP
Town of Fletcher
Document Date
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 Town of Fletcher 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
10. Town Meetings
Stormwater issues and program
implementation items will be brought
to the Town Council. Citizens can
provide input.
1. Advertise Board
meetings and agendas on
web site.
1. Annually
Permit Years 1 - 5.
1. Yes/No/Status
11. Stormwater Website Page
Provide a contact person and e-mail
address for citizen’s questions related
to stormwater on the Stormwater
website page. Provide a link to the
Town’s MS4 mapping for availability
to the public.
1See BMP 10
1. See BMP 10. 1. See BMP 10
2. Inform relevant Town
departments about this
protocol.
2. Permit Year 1. 2. Yes/No/Status
3. Provide a link to the
Town’s MS4 mapping.
3. Permit Year 5 3. Yes/No/Status
Date it became available.
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
12. Identify Volunteer Groups Existing in the Area
Create a list of existing volunteer
groups that could have potential for
improving stormwater issues and
reducing pollutants. Focus would be
participation with residents,
1. Create a list of
potential volunteer
groups and document
their main focus.
1. Permit Year 2. 1. Yes/No/Status
NCS000424 SWMP
Town of Fletcher
Document Date
Page 20
Table 14: Public Involvement and Participation BMPs
commercial businesses, and/or
students.
2. Contact at least one of
the volunteer groups and
establish an activity
focused on stormwater
issues.
2. Annually
Permit Years 2-5
2. Yes/No/Status
3..,Implement a
minimum of one citizen
participation activity
focused on stormwater
issues.
3. Annually
Permit Years 3-5.
3. Date and type of
event, number of
participants
13. Create a Town Park Clean-up Day
Create and Implement a Town Park
Clean-up Day Event.
1. Plan a clean up day for
one of the Town’s Parks.
Decide how it will be
advertised, who will run
it, and what equipment is
needed.
1. Permit Year 2. 1. Yes/No/Status
2. Implement Town Park
Clean-up Day. Document
how many volunteers,
what took place, take
pictures.
2. Annually
Permit Years 3-4.
2. Date of event and
number of participants
NCS000424 SWMP
Town of Fletcher
Document Date
Page 21
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM
The Town of Fletcher 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
14. Update MS4 Major Outfalls and Municipal Storm Sewer System Map
Create a strategy to update the
existing Outfall Map and complete a
new municipal storm sewer system
map starting with the existing maps
and information provided in the
Town’s 2007 Stormwater Masterplan.
Map to include inlets, pipe systems
and sizes, flow directions, culvert
locations, major outfalls and streams.
1. Evaluate existing
materials and create a
scope for moving
forward in the creation of
a new MS4 Map. Put
measures in place for the
effort to be completed.
1. Permit Year 1. 1. Yes/No/Status
2. Create New MS4 Map
and determine areas to be
inventoried by creating
three inventory areas that
comprise approximately
1/3 of the Town’s
jurisdictional area.
2. Permit Year 2. 2. Yes/No/Status
Report currently known
number of major outfalls.
3. Perform an inventory
and inspections of
outfalls and sewer
systems within one
inventory area area and
add to the map.
3. Annually
Permit Years 3-5.
3. Yes/No/Status
Report number of major
outfalls added and total.
4. Continuously update
the MS4 Map
documenting any new
additions/changes to
inventoried areas..
4. Annually
Permit Years 4-5.
4. Yes/No/Status
Report number of major
outfalls added and total.
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.
NCS000424 SWMP
Town of Fletcher
Document Date
Page 22
Table 15: Illicit Discharge Detection and Elimination BMPs
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
15. Maintain Legal Authority
Review existing Ordinance
confirming the Town’s legal
authority to enforce and take actions
for prohibiting, detecting and
eliminating illicit discharges and
connections and illegal dumping and
spills.
1. Review ordinance and
make any necessary
changes. Document any
revisions.
1. Permit Year 1. 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
16. IDDE Plan
Develop and implement a written
IDDE Plan which includes an
assessment of the most vulnerable
areas for illicit discharges. Use the
current MS4 mapping for all known
outfalls and determine on paper areas
of higher risk by studying factors
such as location to industries, zoning,
higher concentration of population,
areas along Cane Creek, watershed
considerations.
1. Create a written IDDE
Plan using current Town
resources, include
procedures and
documentation to address
a) though e) in Permit
Ref. 3.4.3.
1. Permit Year 1 1. Yes/No/Status
2. Submit the IDDE Plan
to DEQ for approval.
2. Permit Year 1 2. Yes/No/Status
Report date submitted.
3. Implement the IDDE
plan.
3. Continuously
Permit Years 2-5.
3. Yes/No/Status
17. Review and Enhancements to the IDDE Plan
NCS000424 SWMP
Town of Fletcher
Document Date
Page 23
Table 15: Illicit Discharge Detection and Elimination BMPs
Review the IDDE Plan and make any
necessary improvements.
1. Review annually, and
make necessary
improvements to the
IDDE Plan.
1. Annually
Permit Years 2-5.
1. 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
18. Track all known illicit discharge, illicit connection and illegal dumping events
Create a tracking mechanism for
documenting where illegal activities
took place, what was done to inform
the violator, records of all
correspondence, records of all
activities related to the illegal activity
and final resolutions.
1. Create a documenting
data sheet, that can be
used by the appropriate
municipal departments
for tracking of all
activities related to the
IDDE.
1. Permit Year 1
1. Yes/No/Status
2. Perform IDDE
inspections using the
data sheet.
2. Annually
Permit Years 2-5.
2. Number of illegal
activities documented.
Yes/No/Status
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
19. Staff Training
Create a program to train Town staff
in IDDE procedures and hotline
protocol (see BMP 10).
1. Develop training
program.
1. Permit Year 2 1. Yes/No/Status
2. Train public works
staff that will be using
the IDDE Plan and new
employees that will be
involved in IDDE, when
hired.
2. Permit Year 2 and
new employees within
first year hired.
2. Yes/No/Status
Number trained
20. Review Public Works Standard Operating Procedure (SOP)
NCS000424 SWMP
Town of Fletcher
Document Date
Page 24
Table 15: Illicit Discharge Detection and Elimination BMPs
Review and adopt any necessary
changes to the Town’s Public Works
Standard Operating Procedure (SOP)
so field staff can identify and report
stormwater issues, illicit discharges,
illegal dumping, etc.
1. Make the written SOP
available to Public
Works Staff and provide
an SOP and stormwater
awareness orientation for
staff.
1. Permit Year 4 1. Yes/No/Status
2. Create a summary
checklist
2. Permit Year 4 2. Yes/No/Status
3. Post checklist in key
locations for quick
reference by staff
members.
3. Continuously
Permit Years 4-5
3. Yes/No/Status
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
21. Stormwater Hotline
A Stormwater Hotline will be
maintained for Town’s citizens to ask
questions and report stormwater
issues. The hotline number will be
available on the Town’s Website and
in educational literature (See BMPs
#8 and #11).
1. See BMPs #8 and #11. 1. See BMPs #8 and #11. 1. See BMPs #8 and #11.
NCS000424 SWMP
Town of Fletcher
Document Date
Page 25
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
In accordance with 15A NCAC 02H .0153, the MS4name 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
Meets Whole
or Part of
Requirement
3.5.1 -
3.5.4
Henderson County
Delegated SPCA Program*
15A NCAC
Chapter 04
NCDEQ
Approved
Delegation &
Resolution R-
07-4 between
Henderson
County and the
Town of
Fletcher
Henderson County Whole
2 * The local delegated SPCA Program ordinance(s)/regulatory mechanism(s) can be found at:
https://www.hendersoncountync.gov/waterresources/page/erosion-control-local-program-0
The Town of Fletcher 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
22. Municipal Staff Training
NCS000424 SWMP
Town of Fletcher
Document Date
Page 26
Table 17: Construction Site Runoff Control BMPs
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
1. Number of staff
trained
23. Stormwater Hotline and Town’s Stormwater Webpage
The Stormwater Hotline will be
maintained for citizen’s use for
reporting sediment run-off from
construction sites and for questions
concerning construction site
activities. (See BMPs #8 and #11.)
1. See BMPs #8 and
#11.
1. See BMPs #8 and #11 1. See BMPs #8 and #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
24. Ordinance for Waste Management
Review current Town Ordinance and
Henderson County Resolution to
determine authority and to ensure
proper legal authority concerning
construction site waste management.
Develop and implement an ordinance
to require construction site operators
to control waste.
1. Review current
Ordinance and
Henderson County
Resolution.
1. Permit Year 1
1. Yes/No/Status
2. Update the Town
Ordinance and
County Resolution to
provide enforcement
authority.
2. Permit Year 1
2. Yes/No/Status
3. Maintain legal
authority.
Continuously, after
ordinance is adopted.
3. Yes/No/Status
NCS000424 SWMP
Town of Fletcher
Document Date
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 Town of Fletcher 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 Town of Fletcher 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
Table 19: Summary of Existing Post-Construction Program Elements
NCS000424 SWMP
Town of Fletcher
Document Date
Page 28
Permit Requirements for
Plan Review and Approval
Municipal Ordinance/Code Reference(s)
and/or Document Title(s)
Date Adopted
3.6.2(a) Authority Legal Agreement between Henderson Co.
and the Town of Fletcher
8-9-2010
3.6.3(a) & 15A NCAC 02H.0153(c)
Federal, State & Local Projects
Town of Fletcher Land Development
Code
Article 6. Environmental Protection 6.5
Water Quality Protection
Adopted:
11-14-2005
Amended:
04-08-2019
3.6.3(b) Plan Review Town of Fletcher Land Development
Code
Article 6. Environmental Protection 6.5 F
and I
Adopted:
11-14-2005
Amended:
04-08-2019
3.6.3(c) O&M Agreement Town of Fletcher Land Development
Code
Article 6. Environmental Protection 6.5 K
Adopted:
11-14-2005
Amended:
04-08-2019
3.6.3(d) O&M Plan Town of Fletcher Land Development
Code
Article 6. Environmental Protection 6.5 K
Adopted:
11-14-2005
Amended:
04-08-2019
3.6.3(e) Deed
Restrictions/Covenants
Currently not addressed in the Land
Development Code. (See BMP #26)
3.6.3(f) Access Easements Town of Fletcher Land Development
Code
Article 6. Environmental Protection 6.5 K
Adopted:
11-14-2005
Amended:
04-08-2019
Permit Requirements for
Inspections and Enforcement
Municipal Ordinance/Code Reference(s)
and/or Document Title(s)
Date Adopted
3.6.2(b) Documentation Town of Fletcher Land Development
Code
Article 6. Environmental Protection 6.5 L
and M
Adopted:
11-14-2005
Amended:
04-08-2019
3.6.2(c) Right of Entry Town of Fletcher Land Development
Code
Article 6. Environmental Protection 6.5 O
Adopted:
11-14-2005
Amended:
04-08-2019
3.6.4(a) Pre-CO Inspections Town of Fletcher Land Development
Code
Article 6. Environmental Protection 6.5
M. 1.
Adopted:
11-14-2005
Amended:
04-08-2019
3.6.4(b) Compliance with Plans Town of Fletcher Land Development
Code
Article 6. Environmental Protection 6.5 L
and M
Adopted:
11-14-2005
Amended:
04-08-2019
NCS000424 SWMP
Town of Fletcher
Document Date
Page 29
3.6.4(c) Annual SCM Inspections Town of Fletcher Land Development
Code
Article 6. Environmental Protection 6.5 O
Adopted:
11-14-2005
Amended:
04-08-2019
3.6.4(d) Low Density Inspections Currently not specifically addressed in the
Land Development Code. (See BMP #26)
3.6.4(e) Qualified Professional Town of Fletcher Land Development
Code
Article 6. Environmental Protection 6.5 O
Adopted:
11-14-2005
Amended:
04-08-2019
Permit Requirements for
Fecal Coliform Reduction
Municipal Ordinance/Code Reference(s)
and/or Document Title(s)
Date Adopted
3.6.6(a) Pet Waste Town of Fletcher Land Development
Code
Article 6. Environmental Protection 6.6 A
Adopted:
11-14-2005
Amended:
04-08-2019
3.6.6(b) On-Site Domestic
Wastewater Treatment
Henderson Co Septic Program and Water
and Well Program
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
25. 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
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
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
3. Summary of number
and type of SCMs added
to the inventory; and
number and acreage of
low density projects
constructed.
4. Track number of SCM
inspections performed.
4. Continuously
Permit Years 1-5
4. Number of SCM
inspections.
NCS000424 SWMP
Town of Fletcher
Document Date
Page 30
Table 20: Post Construction Site Runoff Control BMPs
5. Track number of low
density inspections
performed.
5. Continuously
Permit Years 1-5
5. Number of low density
projects inspectedions.
6. Track number and
type of enforcement
actions taken.
6. Continuously
Permit Years 1-5
6. Number and type of
enforcement actions
taken/issued.
Permit
Ref. 3.6.2: Legal Authority
Measures to maintain adequate legal authorities through ordinance or other regulatory mechanism to: (a) review
designs and proposals for new development and redevelopment to determine whether adequate stormwater
control measures will be installed, implemented, and maintained, (b) request information such as stormwater
plans, inspection reports, monitoring results, and other information deemed necessary to evaluate compliance
with the Post-Construction Stormwater Management Program, and (c) enter private property for the purpose of
inspecting at reasonable times any facilities, equipment, practices, or operations related to stormwater
discharges to determine whether there is compliance with the Post-Construction Stormwater Management
Program.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
26. Evaluation of Ordinance and Existing Agreement with Henderson County to implement the Town of Fletcher’s
Post Construction Stormwater Program.
The in-place Agreement with
Henderson County for implementing
the Post-Construction Stormwater
Program for the Town of Fletcher
shall be reviewed in its entirety along
with related mechanisms such as
Town’s ordinance, County
Ordinance, and both websites.
1. Develop an ordinance
and mechanism for deed
restrictions, covenants,
and low-density
inspections.
1. Permit Year 1. 1. Yes/No/Status
Report code reference
and projected adopted
dates.
2. Proceed with any
required legal processes
such as Council or Board
approvals.
2. Permit Year 2. 2. Yes/No/Status
3. Implement changes
and make any necessary
updates to public
materials.
3. Permit year 3. 3. Yes/No/Status
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).
NCS000424 SWMP
Town of Fletcher
Document Date
Page 31
Table 20: Post Construction Site Runoff Control BMPs
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
27. Agreement with Henderson County for executing Plan Reviews and Approvals.
An agreement is currently in place for
Henderson County to review and
approve plan submittals for post
construction stormwater projects
within the Town of Fletcher. The
Town’s own projects will be
reviewed and approved by NCDEQ
regional office staff.
1. Obtain data from
Henderson County for
the Town to track
projects within their
jurisdiction. How many
projects and their final
status.
1. Continuously. 1. Report number of Post
Construction Approvals
which have been
implemented.
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.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
28. Inspections of low-density projects
Establish the legal authority for
inspection of low-density projects.
1. Code revision and
implementation as part of
BMP #26.
1. Permit Year 3(See
BMP #26)
1. Yes/No/Status
2. Perform inspections of
Low-Density Projects
2. After BMP #26 is in
place and then each
project a minimum of
once within the 5 year
permit term, with a
minimum goal of 50%
year 4, and 50% year 5.
2. Yes/No/Status
How many were
inspected.
29. Inspection of Post Construction Stormwater SCMs
Develop a schedule and detailed
strategies for inspection of post
construction SCMs.
1. Inspect all the post
construction SCMs
within the Town’s
jurisdiction and take
appropriate actions for
SCMs that are out of
compliance.
1. Each SCM shall be
inspected at a minimum
once within the 5-year
permit term, with a
minimum goal of 20%
per year.
1.
Number of SCMs
inspected and how many
SCMs there are.
NCS000424 SWMP
Town of Fletcher
Document Date
Page 32
Table 20: Post Construction Site Runoff Control BMPs
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.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
30. Pet Waste Management
Review pet waste management
currently being implemented within
the Town. Evaluate if there is a need
to expand this initiative.
1. Evaluate what is
currently in place.
1. Permit Year 3. 1. Yes/No/Status
2. If determined
additional mechanisms
are needed for pet waste
control provide for these
measures.
2. Permit Year 4. 2. Yes/No/Status or Not
needed
NCS000424 SWMP
Town of Fletcher
Document Date
Page 33
PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS
This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the
Town of Fletcher 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 Town of Fletcher 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
31. Inventory of Municipal Facilities
Create an inventory of all Municipal
Facilities, including location,
function,and document what
activities or framework have the
potential to generate stormwater
runoff pollution.
1. List of all municipal
facilities.
1. Permit Year 1. 1. Yes/No/Status
Number of facilities.
2. Perform a site
inspection of municipal
facilities to determine
and document items of
potential for spills or
stormwater pollution.
Review in place SPCC
plans and update as
necessary.
2. Permit Year 2. 2. Yes/No/Status
Number of facility site
visits.
NCS000424 SWMP
Town of Fletcher
Document Date
Page 34
Table 21: Pollution Prevention and Good Housekeeping BMPs
3. D Develop SPCC
plans for facilities that
are determined to need
them.
3. Permit Year 2. 3. Yes/No/Status
Number of facilities that
require a new SPCC Plan
32. Public Works Standard Operating Procedure (SOP)
Review Public Works Department’s
Standard Operating Procedure (SOP)
See BMP #20.
1. See BMP #20. 1.See BMP #20. 1. See BMP #20.
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
33. Spill Potential and Response Procedures
Any municipal facility that stores or
works with materials which have the
potential to contribute to polluted
run-off shall be identified and written
spill response procedures put in
place.
1. Create written spill
response procedures and
provide to staff.
Consider pertinent
locations to post
document.
1. Permit Year 2. 1. Yes/No/Status
2. Review procedures
with all relevant staff.
2. Annually 2. Yes/No/Status
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
34. Staff Training for Operation and Maintenance Activities
Create a list of operation and
maintenance activities to be
performed by the Public Works staff.
Train staff in maintenance
procedures, stormwater awareness
and pollution prevention.
1. Create list and means
for documentation of O
& M duties.
1. Permit Year 1. 1. Yes/No/Status
2. Inspect and Maintain
the MS4 collection
system. Document dates
and where the
maintenance took place.
2. 20% of the MS4
system each year, to
accomplish full
maintenance of the entire
system within the 5 year
permit period.
2. Report number of
storm drains/catch basins
cleaned.
NCS000424 SWMP
Town of Fletcher
Document Date
Page 35
Table 21: Pollution Prevention and Good Housekeeping BMPs
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.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
35. Schedule and Training for Municipal SCMs O & M
Review the Town’s Operation and
Maintenance Agreements for all
municipal SCM’s. Create a schedule
and train staff to perform regular
maintenance and inspections as
required of each SCM.
1. Complete an inventory
of all municipal SCMs.
2. Complete maintenance
and inspections, create
documentation of when,
what was done, issues
and corrective measures.
1. Permit Year 1.
2. As required by each
specific municipal
SCM’s O & M
Agreement.
1. Number of municipal
SCMs.
2. Report how many
SCMs were inspected
and maintained.
2. Complete an annual
inspection of each
municipal SCM by
appropriate personnel for
required certification.
2. Annually. 2. Report date of annual
certification of each
municipal SCM.
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
36. Pesticide, Herbicide, Fertilizer Applicator Training
Town staff that are responsible for
application of pesticides, herbicides
and fertilizers shall be certified in
proper storage, handling and
application of landscape chemicals.
1. Create a list of all
Town employees that
hold certifications and
their certification
number.
1. As required by
certification schedule.
1. Report how many are
certified.
2. Train all staff on the
storage and handling of
landscape materials and
pollution prevention
procedures.
2. Annually. 2. Yes/No/Status
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.
A B C D
NCS000424 SWMP
Town of Fletcher
Document Date
Page 36
Table 21: Pollution Prevention and Good Housekeeping BMPs
BMP
No. Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
37. Vehicle and Equipment Cleaning and Maintenance Facility Inspection
Perform routine inspections to ensure
that vehicle and equipment facilities
are following proper procedures to
minimize water quality impacts from
vehicle and equipment cleaning and
maintenance.
1. Develop an inspection
checklist.
1. Permit year 2. 1. Yes/No/Status
2. Inspect facilities
where vehicle and
equipment maintenance
is performed. Record
results and any issues
and how issues were
resolved.
2. Annually after year 2. 2. Yes/No/Status
Number of inspections.
3.
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
38. Street Sweeping
Review street sweeping schedule and
implementation. Make adjustments if
necessary. Enhance documentation
materials.
1. Document the
Street Sweeping
activity
protocols and
miles of streets
swept
2. Document leaf
collection time
periods and
volume
collected.
1. Annually.
2. Annually.
1. Report miles of
streets swept.
2. Report volume
of leaves
collected.
39. Catch Basin Cleaning
Create a written schedule for catch
basin inspection and cleaning.
Document when it was done. (See
BMP #38).
1. Document how many
basins were inspected
and how many cleaned
out.
1. See BMP #34 1. See BMP #34
40. Vehicle Spill Cleanup
Maintain a document for procedures
of spill clean-up in emergency
situations such a vehicle accidents.
And documentation for each event.
1. Create a document for
spill procedure on streets
in emergency situations.
(See BMP #33).
1. Permit Year 2. 1. Yes/No/Status
2. Document each event
and how the issue was
taken care of including
dates.
2. Annually. 2. Yes/No/Status
How many events.
NCS000424 SWMP
Town of Fletcher
Document Date
Page 37