NCS000240_Charlotte 2021 Annual Report_20211029

City of Charlotte
NPDES MS4 Permit Program

Stormwater
Management Program Plan

FY2021 Annual Report

Permit Number NCS000240

October 2021

City of Charlotte – MS4 Stormwater Management Program – FY2021 Annual Report

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Table of Contents

Section 1 Introduction ................................................................................................1

Section 2 Background Information ..........................................................................4

Section 3 Public Education and Outreach Program ...............................................9

Section 4 Public Involvement and Participation Program ...................................21

Section 5 Illicit Discharge Detection and Elimination Program ..........................29

Section 6 Construction Site Stormwater Runoff Control Program.....................42

Section 7 Post-Construction Stormwater Management Program .......................47

Section 8 Pollution Prevention/Good Housekeeping Program.............................52

Section 9 Program to Monitor and Control Pollutants in Stormwater
Discharges to Municipal Systems ...........................................................64

Section 10 Water Quality Assessment and Monitoring Program ..........................68

Section 11 Total Maximum Daily Load (TMDL) Program ....................................72

Acronyms Used in This Document:

AAS: Adopt-A-Stream
BMP: Best Management Practice(s)
CAR: Corrective Action Request(s)
CATS: Charlotte Area Transit System
CDOT: Charlotte Department of Transportation
CFD: Charlotte Fire Department
CITY: City of Charlotte
CMANN: Continuous Monitoring Alert Notification Network
CMCSI: Charlotte-Mecklenburg Certified Site Inspector
CMPD: Charlotte-Mecklenburg Police Department
CMSWS: Charlotte-Mecklenburg Storm Water Services
CSWS: Charlotte Storm Water Services
CSWS-LD: CSWS-Land Development Team
CW: Charlotte Water Department (formerly Charlotte-Mecklenburg Utilities)
DO: Dissolved Oxygen
DWF: Dry Weather Flow
ETJ: Extra Territorial Jurisdiction
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FY: Fiscal Year
GIS: Geographic Information System
IDDE: Illicit Discharge Detection and Elimination
IDEP: Illicit Discharge Elimination Program
MEP: Maximum Extent Practicable
MS4: Municipal Separate Storm Sewer System
NCDEQ: North Carolina Department of Environmental Quality
NOD: Notice of Deficiency
NOV: Notice of Violation
NPDES: National Pollutant Discharge Elimination System
O&M: Operation & Maintenance
PCSO: Post-Construction Stormwater Ordinance (City)
QA/QC: Quality Assurance/Quality Control Program
ROW : Right-of-Way
RSPC : Regional Stormwater Partnership of the Carolinas
SAP: Standard Administrative Procedure
SARA: Superfund Amendments and Reauthorization Act
SCM: Stormwater Control Measure(s)
SDM : Storm Drain Marking
SESCO: Soil Erosion and Sedimentation Control Ordinance (City)
SOP: Standard Operating Procedure(s)
SPRP: Spill Prevention and Response Procedures(s)
SSO: Sanitary Sewer Overflow(s)
SWAC: Stormwater Advisory Committee
SWMP: Stormwater Management Program Plan
SWPCO: Stormwater Pollution Control Ordinance (City)
SWPPP: Stormwater Pollution Prevention Plan
SWQ: Surface Water Quality
TMDL: Total Maximum Daily Load
TSS: Total Suspended Solids
UNCC: University of North Carolina at Charlotte
USEPA: United States Environmental Protection Agency
WLA: Waste Load Allocation
WQ: Water Quality
WQS: Water Quality Standards
WRRI-SWC: Water Resources Research Institute – Stormwater Consortium
WTP: Water Treatment Plant
WWTP: Wastewater Treatment Plant
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Section 1: Introduction

On November 1, 1993, the City of Charlotte (“City”) began operating under National Pollutant
Discharge Elimination System (“NPDES”) Municipal Separate Storm Sewer System (“MS4”)
Permit Number NCS000240. This permit has subsequently been renewed for a 5-year permit
term on four occasions and is currently in its 5th permit cycle effective October 10, 2018 through
October 9, 2023.

This document provides the Annual Report for the Stormwater Management Program Plan
(“SWMP”) for fiscal year (“FY”) 2021 under the current permit term as required by Part III,
paragraph 2 and Part IV, paragraph B of the NPDES MS4 permit. The overall objective of this
Annual Report is to document activities conducted in support of the SWMP during FY2021 (July
1, 2020 to June 30, 2021), assess program effectiveness, and discuss future proposed program
activities and/or SWMP changes as necessary.

The City’s Storm Water Services (“CSWS”) is the primary agency responsible for managing the
City’s NPDES MS4 permit, the MS4 system and the SWMP. The implementation of the
requirements within the permit program and SWMP are coordinated with other applicable City
departments as necessary. In addition, coordination is conducted with the NPDES MS4 permit
programs for the jurisdictions in Mecklenburg County adjacent to the City where appropriate and
feasible. This coordination is conducted to help ensure uniformity between the local NPDES
MS4 stormwater permit programs and jurisdictions. Mecklenburg County stormwater staff along
with CSWS staff collectively form Charlotte-Mecklenburg Storm Water Services (“CMSWS”).
City and County surface water quality staff within CMSWS work together to accomplish many
of the activities discussed in this report.

Included in this SWMP Annual Report are:

• Best management practice(s) (“BMPs”) that are being used to fulfill the program
requirements;
• Frequency and status of each BMP;
• Measurable program goals and planned future activities;
• Implementation schedule;
• Responsible positions; and
• An assessment of program activities conducted during the reporting year.

Staff of CSWS, under the direction of the City’s Surface Water Quality and Environmental
Permitting Program Manager, is responsible for the fulfillment of most of the activities discussed
in this SWMP. Exceptions to this include the CSWS-Land Development Team (“CSWS-LD”),
which was the primary group during FY2021 responsible for the Development and
Redevelopment Plan Review and Construction Site Stormwater Runoff Control programs within
the SWMP. In addition, the City’s Department of Transportation-Street Maintenance Division
and Solid Waste Services Department have responsibility for routine maintenance of certain
portions of the MS4, in coordination with CSWS. Funding for the BMPs specified in the SWMP
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is provided by local stormwater utility fees, except where noted. The City’s SWMP includes the
following core permit programs:

1. Public Education and Outreach Program – This program provides the public and businesses
with information on surface water quality, pollution prevention, and reporting problems, as
well as specialized information on various activities that have the potential to cause pollution
and harm surface water quality. This information is delivered through a wide range of
methods including print, web, radio, social media, television, presentations, and public
events.

2. Public Involvement and Participation Program – This program provides the public and
businesses the opportunity to participate in various programs within the City’s SWMP.
Charlotte-Mecklenburg government maintains a Storm Water Advisory Committee
(“SWAC”), which is an appointed citizen panel to review and comment on the City’s and
County’s stormwater programs. In addition, public volunteer opportunities are available with
City/County programs such as Storm Drain Marking, Adopt-a-Stream, and the annual Big
Spring Clean event.

3. Illicit Discharge Detection and Elimination Program – This program is designed to protect
surface water quality by detecting and eliminating pollution sources such as improper sewage
or wastewater connections; illegal discharges of chemicals, paint, or oil; and accidental
discharges from sanitary sewer lines and vehicle accidents. As part of this program, the City
enforces the “City of Charlotte - Stormwater Pollution Control Ordinance,” which prohibits
the discharge of pollutants to the storm drainage system and receiving streams. The City
relies on reports from the public, various monitoring programs, and a wide range of other
activities to assist in identifying and eliminating these sources of pollution.

4. Construction Site Stormwater Runoff Control Program – This program maintains the City’s
delegated erosion and sediment control program to control sediments and other pollutants
from construction sites. As part of this program, the City enforces the “City of Charlotte -
Soil Erosion and Sedimentation Control Ordinance,” which requires suitable erosion control
on project sites. The City conducts routine inspections of construction sites and issues
violation notices and fines when necessary to ensure compliance with the ordinance.

5. Post-Construction Stormwater Management Program – This program is designed to control
the discharge of pollutants in stormwater runoff from new development and redevelopment
projects. As part of this program, the City enforces the “City of Charlotte – Post-
Construction Stormwater Ordinance,” which requires structural stormwater controls for
applicable new development and redevelopment projects as defined in the ordinance. The
program involves review and approval of project plans as well as site inspections and
maintenance activities to ensure that treatment practices are properly operated and
maintained.

6. Pollution Prevention/Good Housekeeping Program – This program focuses on ensuring that
City facilities and field operations are managed in a way that minimizes stormwater pollutant
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discharges. Stormwater Pollution Prevention Plans and Spill Response Plans are maintained
for applicable facilities that conduct activities with the potential for stormwater pollutant
discharges. The City conducts inspections and training sessions at these facilities to ensure
that requirements are being met. Field operations are evaluated for impacts on stormwater
quality and best management practices are developed and implemented in order to minimize
those impacts.

7. Program to Monitor and Control Pollutants in Stormwater Discharges to Municipal Systems
This program focuses on industrial facilities that discharge stormwater to the City’s MS4 and
receiving streams. Inspections are conducted at these facilities on a rotational basis to review
site operations and materials handling practices. In addition, if the facility has a stormwater
permit, it is reviewed to ensure that permit conditions are adhered to.

8. Water Quality Assessment and Monitoring Program – This program maintains a surface
water quality monitoring plan designed to monitor major streams to determine surface water
quality conditions and assist in evaluating the effectiveness of various stormwater
management programs. The program is also used to assist in locating illicit discharges and
connections where possible.

9. Total Maximum Daily Load (“TMDL”) Program – This program maintains a TMDL
watershed plan designed to address applicable TMDL pollutants of concern by implementing
best management practices (BMPs) within the six minimum NPDES stormwater permit
measures. These BMPs are designed to reduce the TMDL pollutant of concern within the
Permittee’s assigned MS4 NPDES regulated waste load allocation to the maximum extent
practicable (“MEP”), and to the extent authorized by law.

Note: Due to the Coronavirus COVID-19 pandemic of 2020-2021 and resulting restrictions
placed by the State of North Carolina and Mecklenburg County, many of the programs discussed
in this report have experienced reduced ability to be implemented fully and, therefore, data
results reported for FY2021 may be lower, on average, than those reported in previous annual
report years.

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Section 2: Background Information

2.1 Population Served

The SWMP covers the jurisdictional area, including the incorporated area and extra territorial
jurisdiction (ETJ), for the City of Charlotte, as applicable and defined by the NPDES MS4
permit. Table 2-1 provides the population for the City of Charlotte based on the 2000 and 2010
US census. This census data was obtained from the following website of the US Census Bureau:

https://www.census.gov/quickfacts/table/PST045216/3712000,00

Table 2-1: Population and Growth Rate for the City of Charlotte.
2019 Population
(estimated)
2010 Population 2000 Population Average Annual Percent
Change (2010-2019)
885,708 731,424 540,828 2.34%

2.2 Growth Rate

Table 2-1 shows the population growth rate represented as an “Average Annual Percent
Change” for the City of Charlotte. This growth rate was calculated by dividing the overall
percent change between the 2010 and 2019 Census data by the 9-year interval period.
2.3 Jurisdictional and MS4 Service Areas

The jurisdictional and MS4 service area for the City is provided in Table 2-2. The location of
this area within Mecklenburg County and corresponding watershed areas is provided in Figure
2-1. The source of this information is the City of Charlotte Planning, Development and Design
Department, which updates jurisdictional and geographical boundaries as annexations occur.

Table 2-2: Jurisdictional and MS4 Service Area for the City of Charlotte.
Incorporated Area (Sq. Miles) ETJ (Sq. Miles) Total Jurisdiction (Sq. Miles)
309 67 376

2.4 MS4 Conveyance System

The existing MS4 serving the City is composed of street curbs, gutters, catch basins, culverts,
pipes, ditches, and outfalls that collect and convey stormwater for discharge to receiving streams.
The City’s current inventory collection system includes data on approximately 6,322 outfall
points, 180,049 structures (inlets, junctions, and outlets), and 2,498 miles of storm drain pipe.
Pipe systems are typically 15 inches or larger in diameter and are designed for the ten-year storm
event. Outlet energy is commonly dissipated through the use of end-walls or flared end sections
with riprap aprons. Although the natural alignment of many receiving streams has been altered
over the past century, many of the stream banks remain mostly vegetated as a result of the City’s
stormwater management philosophies. Stream banks that were previously armored with riprap
are currently allowed to re-vegetate naturally, and new projects incorporate “soft” methods
involving tree plantings and other vegetation.
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Maintenance and improvements to the MS4 system are funded by stormwater utility fees
collected within the City. Maintenance activities include cleaning inlets of debris and sediment,
maintaining channels to reduce erosion and maximize pollution reduction capabilities, and the
removal of blockages. Improvements to the MS4 system include solving infrastructure
problems, channel stabilization, safety improvements, stream habitat enhancement, surface water
quality enhancement, and resolving flooding problems associated with stormwater generated
from public streets.

2.5 Land Use Composition Estimates

The number of square miles and percentage of the MS4 service area under residential,
commercial, industrial and open space land use categories are provided in Table 2-3. These
percentages include the incorporated area and ETJ for the City. Land use estimates are derived
from Mecklenburg County land parcel geographic information system (GIS) data (2019).

Table 2-3: Percentage of Land Uses in the City of Charlotte (including ETJ).
Land use Category Number of Square Miles % of Land Use within City of
Charlotte
Residential 132 35
Commercial 56 15
Industrial 13 4
Open Space 98 26
Institutional 20 5
Transportation/Other 54 14
Lake Water/Open Space 3 1

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FIGURE 2-1
Charlotte Jurisdictional Area and Watersheds

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2.6 Receiving Waters

Approximately two-thirds of the City of Charlotte land area drains west in the Catawba River
Basin while the remaining one-third drains east in the Yadkin-Pee Dee River Basin. MS4
receiving stream information by river basin is provided in Table 2-4 (Catawba) and Table 2-5
(Yadkin-Pee Dee). The information for the development of these tables was obtained from the
2018 Category 5 303(d) List. The location of the watershed areas in the City of Charlotte is
illustrated in Figure 2-1.

Table 2-4: Catawba River Basin Streams
Receiving Stream
Name
Stream Segment
Index #
WQ
Classification
Use Support Rating WQ Issues
(303(d) Listing)
Catawba River
(Mountain Island
Lake below
elevation 648)
11-(114) WS-IV, B, CA Impaired PCB Fish Tissue Advisory(5)
Catawba River
(Lake Wylie below
elevation 570)
11-(117) WS-IV-CA Impaired PCB Fish Tissue Advisory(5)
Catawba River
(Lake Wylie below
elevation 570)
11-(122) WS-IV, B, CA Impaired PCB Fish Tissue Advisory(5)
Catawba River
(Lake Wylie below
elevation 570)
11-(123.5) WS-IV, B Impaired PCB Fish Tissue Advisory(5)
Long Creek 11-120-(0.5) C Not Rated None
Long Creek 11-120-(2.5) WS-IV Not Rated None
Dixon Branch 11-120-1 C Not Rated None
McIntyre Creek 11-120-3-(1) C Not Rated None
McIntyre Creek 11-120-3-(2) WS-IV Not Rated None
Gutter Branch 11-120-4-(1) C Not Rated None
Gutter Branch 11-120-4-(2) WS-IV Not Rated None
Gum Branch 11-120-5 WS-IV Not Rated None
Paw Creek 11-124 C Not Rated None
Ticer Branch 11-124-1 C Not Rated None
Little Paw Creek 11-125 C Not Rated None
Beaverdam Creek 11-126 C Not Rated None
Stowe Branch 11-127 C Not Rated None
Porter Branch 11-133 C Not Rated None
Studman Branch 11-134 C Not Rated None
Sugar Creek Portions of 11-
137a,b,c
C Impaired Fecal Coliform (4t); Turbidity
(1t); Benthos Impairment(5)
Irwin Creek 11-137-1 C Impaired Dissolved Oxygen (1t); Fecal
Coliform (4t); Turbidity (4t);
Fish impairment
Stewart Creek 11-137-1-2 C Not Rated None
Taggart Creek 11-137-2 C Not Rated None
Coffey Creek 11-137-4 C Not Rated None
Kings Branch 11-137-6 C Not Rated None
McCullough Branch 11-137-7 C Impaired Benthos impairment

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Receiving Stream
Name
Stream Segment
Index #
WQ
Classification
Use Support Rating WQ Issues
(303(d) Listing)
Little Sugar Creek 11-137-8 C Impaired Copper(5) Mercury(5)
Turbidity(1t) Dissolved
Oxygen(1t); Fecal Coliform (4t);
Benthos impairment(4s)
Dairy Branch 11-137-8-1 C Not Rated None
Briar Creek 11-137-8-2 C Not Rated None
Edwards Branch 11-137-8-2-1 C Not Rated None
Little Hope Creek 11-137-8-3 C Not Rated None
McAlpine Creek 11-137-9 C Impaired Dissolved Oxygen(1t); Fecal
Coliform (4t);Turbidity (1t);
Benthos and fish impairment(5)
Campbell Creek 11-137-9-1 C Not Rated None
Irvins Creek 11-137-9-2 C Not Rated None
Fourmile Creek 11-137-9-4 C Not Rated None
Rocky Branch 11-137-9-4-1 C Not Rated None
McMullen Creek 11-137-9-5 C Impaired Benthos impairment(5)
Steele Creek 11-137-10 C Not Rated None**
Walker Branch 11-137-10-1 C Not Rated None
Polk Ditch 11-137-10-1-1 C Not Rated None
Clems Branch 11-137-11 C Not Rated None
Sixmile Creek 11-138-3 C Impaired Fish impairment(5)
Twelvemile Creek 11-138 C Impaired Dissolved Oxygen(5);
Copper(5); Turbidity(5); Fish
impairment(4s)
Flat Branch 11-138-3-2 C Not Rated None

Table 2-5: Yadkin-Pee Dee River Basin Streams
Receiving Stream
Name
Stream Segment
Index #
WQ
Classification
Use Support Rating WQ Issues
(303(d) Listing)
Mallard Creek 13-17-5b C Impaired Turbidity(5)
Clarks Creek 13-17-5-2 C Impaired Benthos impairment(5)
Doby Creek 13-17-5-3 C Impaired Benthos impairment(5)
Toby Creek 13-17-5-4 C Impaired Benthos impairment(5)
Stony Creek 13-17-5-5 C Impaired Benthos impairment(5)
Back Creek 13-17-7 C Impaired Benthos impairment(5)
Fuda Creek 13-17-7-1 C Not Rated None
Reedy Creek 13-17-8 C Impaired Benthos impairment(5)*
McKee Creek 13-17-8-4 C Impaired Fecal Coliform(4t); Benthos
impairment(5)
Use Support Ratings
(1t) No criteria exceeded but approved TMDL for p arameter of interest
(4s) Impaired biological integrity with an identified Aquatic Life Standards Violation listed in Category 5
(4t) Designated use impaired with an approved TMDL
(5) Designated use impaired because of biological or ambient surface water quality standards violations and needing
a TMDL
** Listed as impaired on South Carolina 303(d) list for Fecal Coliform; TMDL developed May 2007.
Source: North Carolina’s 2018 303(d) Report

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Section 3: Public Education and Outreach Program

During the annual report period, the Public Education and Outreach Program distributed
educational information to the community and conducted outreach activities focused on the
impacts of stormwater discharges on water bodies per the SWMP. The following sub-sections
explain:

• The BMPs implemented to meet program requirements;
• Target audience and pollution sources;
• Outreach strategy;
• Measures of success;
• Future goals and planned activities; and
• Program assessment.

3.1 BMP Summary Table

Table 3-1 provides information concerning the BMPs implemented to fulfill the Public
Education and Outreach Program requirements.

Table 3-1: BMP Summary Table for the Public Education and Outreach Program.
BMP BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Describe target
pollutants and
target pollutant
sources
Describe the target pollutants and target pollutant
sources the permittee’s public education program is
designed to address and why they are an issue.

X X X X X Water Quality
Program
Manager
Describe target
audiences
Describe the target audiences likely to have
significant stormwater impacts and why they were
selected.
X X X X X Water Quality
Program
Manager
Informational Web
Site
The permittee shall promote and maintain an
internet web site designed to convey the program’s
message.
X X X X X Water Quality
Program
Manager
Distribute public
education materials
to identified user
groups.
Distribute general stormwater educational material to
appropriate target groups as likely to have a
significant stormwater impact.
X X X X X Water Quality
Program
Manager
Promote and
maintain
Hotline/Help line
Promote and maintain a stormwater hotline(s) or
helpline(s) for the public to request information
about stormwater, public involvement &
participation, and to report illicit connections &
discharges, etc.
X X X X X Water Quality
Program
Manager
Implement a Public
Education and
Outreach Program.
The permittee’s outreach program, including those
elements implemented locally or through a
cooperative agreement, shall include a combination
of approaches designed to reach the target
audiences. For each media, event, or activity the
permittee shall estimate and record the extent of
exposure.
X X X X X Water Quality
Program
Manager

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3.2 Target Pollutants and Sources

Table 3-2 provides the specific pollution sources targeted for the public education program as
well as a description as to why the sources are important for protecting surface water quality in
the City.

Table 3-2: Targeted Pollution Sources for the Public Education and Outreach Program.
Target
Pollutant
Pollution Source Issue
Bacteria Improper Waste Disposal
Sanitary Sewer Overflows
Pet Waste
Many surface waters in Charlotte are impaired due to high fecal
coliform levels. Improper handling and disposal of wastes can result
in the discharge of a variety of pollutants to the storm drainage
system, causing increases in harmful bacteria. Discharges of food
wastes such as fats, oils, and greases to the sanitary sewer system
can result in line blockages that cause sanitary sewer overflows.
Improper disposal of pet waste can also cause discharges of bacteria
to the storm drainage system.
Sediment Construction Erosion
Stream Bank Erosion
Many surface waters in Charlotte are impaired due to turbidity
related to sediment discharges. Improper erosion control practices at
construction sites can result in sediment discharges to the storm
drainage system. In addition, uncontrolled volumes of stormwater
runoff can cause scouring of stream banks resulting in in creased
sediment volumes in streams.

3.3 Target Audiences

The City’s public education and outreach program reaches a fairly broad representation of the
city’s population through various methods as explained in Section 3.4 with the goal of reaching
certain target audiences for particular reasons as explained below. The target audiences are
evaluated with each annual SWMP update and as part of the development of the SWMP
following permit renewal.

Multi-Family Residential Apartment Complexes: This target audience is selected because
private sanitary sewer systems at apartment complexes are often not well-maintained and have
been found to be significant contributors to sanitary sewer overflow(s) (“SSOs”) in the municipal
sewer system due to improper disposal of grease and other items by apartment residents.
Outreach efforts to multi-family communities are described further in Section 5 of this report.

Construction Industry: This target audience is selected because it has the greatest potential for
affecting erosion and sedimentation control at construction sites, which can be a significant
contributor of sediment to the City’s waterways. Outreach efforts to the construction industry
are described further in Section 6 of this report.

Commercial Sectors: Various commercial sectors are targeted for education each year due to the
significant negative impacts they can have on surface water quality by improperly handling and
disposing of wastes and practicing poor housekeeping at their facilities. Each year an evaluation
of previous pollution service requests, illicit discharges, and notices of violation is conducted to
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determine which commercial sectors are commonly demonstrating non-compliance. Based on
that evaluation, education and outreach efforts are focused on particular sectors for a certain time
period, typically a fiscal year. Outreach efforts to commercial sectors are described in this
section and Section 5 of this report.

School-aged Children: Children are very important when it comes to protecting surface waters.
They play in creeks and lakes and, therefore, want to protect them. They bring home what they
learn and encourage their parents to adopt positive behaviors for protecting surface water quality.
Lessons about surface water quality and stormwater pollution often fit into and enhance science
learning principles required by school curricula. Also, teaching children instills a sense of
responsibility for the environment that can carry forward and grow into their adult lives. For
these reasons, the City’s public education program focuses significant resources on teaching
students at various grade levels.

Pet Owners: Pet waste is identified as a significant source of bacteria in surface waters, so
starting during FY2018, CMSWS added pet owners as a target audience as one way to help
combat elevated fecal coliform counts in local creeks.

Diverse and under-represented audiences: CMSWS has also been exploring and implementing
ways to educate an even more diverse representation of our population. Research and
strategizing have been done to establish priorities and determine effective methods for sharing
water quality messages with various audiences and getting more of them involved in
volunteering and advocating for protection of water resources. Staff work each year to
implement efforts and programs for reaching out to diverse and under-represented audiences.

3.4 Stormwater Public Education and Outreach Program

The City’s Stormwater Public Education and Outreach Program provides surface water quality
and pollution prevention messages to educate residents and businesses about the ways they can
help protect surface water quality and get involved to help reduce stormwater pollution. The
program provides these messages in the following ways:

• Mass Media;
• Social Media;
• Public Hotline Promotion;
• School Presentations;
• Public Presentations and Events;
• Website;
• Public Education Materials; and
• Special Campaigns and Programs.

3.4.1 Mass Media

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Significant resources are spent on providing surface water quality messages through mass media
channels because they are one of the most effective ways to reach adult audiences. The media
campaign focuses on four main themes:

• Surface Water Quality;
• Volunteering;
• Flood Safety; and
• Aging Infrastructure.

Media channels utilized to promote events and messages consist of television, radio, and website
advertisements. During previous years, print advertisements were also used; however, public
opinion survey results have shown that these advertisements are seen less frequently and are less
effective.

Print media for the City’s program currently includes the use of:

• Environmental notices/brochures; and
• Utility bill inserts

Table 3-3 shows the data relative to these media channels for the report period.

Table 3-3: Mass Media, Social Media, and Website Program Results
Activity Results
Television advertising spots run 310
Radio advertising spots run 353
Television advertising media impressions 2,930,665
Radio advertising media impressions 1,229,400
Website advertisements run 42
Website advertising media impressions 3,448,030
Environmental notices/brochures issued 14
Utility bill inserts (stormwater related) mailed 1,407,000
Facebook fans 7,456
Instagram followers 1,140
Twitter followers 1,352
YouTube page subscribers 106
Social media posts made 986
Total Social media engagements (likes, replies, comments, shares) 14,819
CLT+ mobile app downloads 7,798
Public requests to hotline received (stormwater related) 7,810
Public requests to hotline (SWQ related) 445
Website page views 417,437
Website unique page views 176,924

3.4.2 Social Media

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CMSWS continues efforts to build a social media presence as more and more people are
receiving information through this media source. Four social media channels used by CMSWS
are shown in Table 3-4.

Table 3-4: Social Media Channels
Social Media Account Name Handle URL
Facebook CMSWS @StormWaterCM https://www.facebook.com/StormWaterCM
Twitter CMSWS @StormWaterCM https://twitter.com/StormWaterCM
Instagram CMSWS @StormWaterCM https://www.instagram.com/stormwatercm/
YouTube CMSWS N/A https://www.youtube.com/user/StormWaterServices

CMSWS posts various videos and news stories on its YouTube channel. CMSWS also provides
more content, pictures and videos related to stormwater pollution, surface water quality,
pollution prevention and flood messages on Facebook, Twitter and Instagram and boosts some
posts to reach tens of thousands of users, all aimed at reflecting the diversity of the community.
Table 3-3 shows the data relative to social media channels for the report period.

3.4.3 Public Reporting Mechanisms

The City, in cooperation with Mecklenburg County, operates a joint customer service hotline to
receive information about a variety of concerns. Citizens can call 311 to report pollution,
flooding, and blockages to the drainage system as well as request other City/County services.
The 311-call center is staffed to receive calls Monday through Friday from 7 am to 7 pm.
Citizens can also submit requests for service to 311 at any time by using the CLT+ app or by
going online to the “Report a Problem” section of the website. All personnel from the customer
service group receive training on stormwater issues and pollution to ensure calls are directed to
appropriate personnel and handled in a timely manner. The training manual for 311 staff is
reviewed and updated periodically to ensure information and resources are accurate.

A variety of methods and events are used to promote the 311-reporting hotline and other
reporting options including:

• Giving away promotional products such as magnets and water bottles with CMSWS logo
and 311 information;
• Providing information about reporting pollution on CMSWS website;
• Working with local TV stations to produce news segments focused on reporting
pollution;
• Buying media time and airing TV advertisements focused on reporting pollution;
• Designing and mailing the utility bill inserts focused on various program topics and
activities; and
• Implementing vehicle wraps.

The 311-call center refers calls for stormwater general, structural, and flooding concerns to
CSWS while surface water quality concerns are referred to CMSWS. Table 3-3 and Table 3-5
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provide information about the number and type of callers that reported stormwater and surface
water quality issues.

Table 3-5: Surface Water Quality Service Request Source Summary
Caller Type Service Requests
Public Citizen 267
Business 6
Charlotte Fire Department staff 26
Charlotte-Mecklenburg Police Department staff 2
Charlotte Storm Water Services staff 40
Charlotte Water staff 25
Mecklenburg County Storm Water Services staff 48
State – NCDEQ staff 5
Environmental Protection Agency/NRC 1
Other 25
TOTAL 445

3.4.4 School Presentations

Due to the 2021 COVID-19 pandemic, many school presentations were moved to a digital
format and staff created Facebook LIVE events. This allowed CMSWS to continue to get out
messages, even to those children that were not in schools due to the stay at home order.
Teachers were also able to review the Enviroscape presentation and give the presentation
themselves. The different programs available include:

• Blue Planet (also offered virtually);
• Common Water;
• Freddie the Fish (also offered virtually);
• Enviroscape Model and Video Demonstration;
• Flood Plain Model Demonstration
• Continuous Monitoring Alert Notification Network (“CMANN”) Demo and Power Point;
• Festival Table Demonstrations;
• Career Day A Day in the Life of Water Quality Staff; and
• Macroinvertebrate Identification.

Two stormwater pollution videos (made by a former local meteorologist) and the Enviroscape
model are also available on loan to schools upon their request. Table 3-6 shows the data relative
to the school presentations for the report period.

3.4.5 Public Presentations and Workshops

A variety of surface water quality presentations and workshops are available from CMSWS to
the public, interest groups, businesses and industrial facilities upon request. Each presentation,
while similar in nature, is also changed depending on the topic of interest and the audience
receiving the presentation. For example, presentations on topics such as yard waste, food grease,
City of Charlotte – MS4 Stormwater Management Program – FY2021 Annual Report

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pollution prevention, surface water quality information, and landscaping tips are typically
available. Table 3-6 shows the data relative to the public presentations for the report period.

3.4.6 Public Events

CMSWS staff participates in a variety of community events that are used to promote education
campaigns, give away promotional products, provide face-to-face education opportunities, and
provide formal presentations on surface water quality topics when appropriate. Table 3-6 shows
the data relative to public event participation for the report period.

Table 3-6: Presentation and Event Program Results
Activity Results
School presentations conducted 40
Students educated at school presentations 2,081
Public presentations conducted 29
Citizens educated at public presentations 1,211
Public events participated in 5
Citizens interacted with at public events 50

3.4.7 Informational Website

A significant number of resources are utilized to promote and maintain the CMSWS website
Stormwater.CharMeck.org which continues to be one of the best ways to provide the public with
surface water quality information. A vast amount of information is provided on this website
including, but not limited to, pollution prevention fact sheets, activities and lessons for kids,
volunteer activities, sediment and erosion, regulations, data, maps, watershed information, and
stormwater projects. Table 3-3 shows the number of website page views and the number of
unique page views (i.e. the number of times a page is accessed at least once during a browsing
session).

3.4.8 Public Education Materials

This outreach mechanism is used to target specific pollution sources associated with the public
and industrial/commercial facilities including lawn care practices, handling of used oil and other
automotive wastes, housekeeping techniques, etc. Public outreach materials consist of
environmental notices and brochures and are also used to increase public reporting of pollution
problems. Separate notices/brochures are written for over 30 different topics related to
stormwater pollution and are available to staff for distribution during citizen requests for service.
A number of these notices/brochures are available in Spanish and CMSWS offers translation
services in other languages as well. Table 3-3 shows the number of environmental
notices/brochures distributed for the report period.

3.4.8.1 Promotional Items

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Promotional items are designed and distributed to complement outreach activities such as group
presentations, workshops and public events. All promotional items have the CMSWS website
and include other messages as space allows. Table 3-7 shows the promotional items distributed.

Table 3-7: Promotional Items
Promotional Item Message
Ink Pens Six rotating messages – report pollution, street to
stream, volunteer, turn around don’t drown, flooding
can happen anywhere, buy flood insurance
Umbrella Rain Gauge General stormwater information;
Stormwater.CharMeck.org
Flashlight General stormwater information;
Stormwater.CharMeck.org

Sunscreen General stormwater information;
Stormwater.CharMeck.org
Stormy’s Guide to Stormwater Coloring Book General stormwater information
Hand Sanitizer Stormwater.CharMeck.org
Stormy Stickers & Temporary Tattoos General stormwater information;
Stormwater.CharMeck.org

3.4.8.2 Utility Bill Inserts

CMSWS includes utility bill inserts in various monthly water/sewer utility bills issued by
Charlotte Water (CW) department. The inserts focus on various topics which include typically
volunteering, surface water quality, flooding, infrastructure and CMSWS services and fee
changes. Table 3-3 shows the total number of stormwater related utility bill inserts that were
mailed during the report period.

3.4.9 Regional Stormwater Partnership

The City is an active member of the Regional Stormwater Partnership of the Carolinas
(“RSPC”); a partnership which includes 21 municipalities throughout the region that collaborate
on meeting NPDES MS4 permit requirements, particularly education and outreach initiatives.
Formed in 2006 and originally comprised of professionals from six municipalities in the
Charlotte metropolitan area, the RSPC was developed as a forum for stormwater professionals to
work collaboratively on local stormwater issues.

The RSPC’s media campaign runs television, radio and web-based television advertisements to
educate the regional public. Table 3-8 shows the data relative to these advertisements as well as
other initiatives for the report period.

Table 3-8: Regional Stormwater Partnership Program Results*
Activity Results*
Television advertising spots run 603
Radio advertising spots run 80
Television advertising media impressions (regular) 2,473,000
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Television advertising media impressions (web based) 327,891
Radio advertising media impressions 270,400
Educational workshops conducted 5
Attendees at workshops conducted 796
Educators contacted about RSPC available resources 285
RSPC website visits 4,795
RSPC website new users 3,461
* This data not included in summary data shown in Table 3-11

3.4.10 Special Campaigns and Programs

Pet Waste Campaign: CMSWS conducts a “Scoop the Poop” awareness campaign that targets
pet owners as a way to educate them about surface water quality impacts from pet waste and the
importance of cleaning it up. This program includes many components to promote awareness
such as posting signs that provide information about harmful impacts to surface water quality
and human health. The campaign also includes social media posts on Facebook, Instagram, and
Twitter to promote pet waste awareness.

Vehicle Wraps: Vehicle wraps (there are currently three) are a unique outreach tool for
publicizing stormwater issues. The wraps serve to make a connection between clean water and
healthy aquatic life; address the street to stream connection; smelly streams; and mud pollution.
In addition to informing and educating, these wraps encourage residents to recognize and report
pollution by calling 311.

Stormy Mascot: CMSWS uses the mascot “Stormy the Turtle” in various education and
outreach materials and in appearances at various events including parades, photo shoots, and
festivals. Table 3-9 shows the data relative to this program for the report period.

Creek Week: CMSWS participates in a nationwide program called Creek Week in order to bring
more attention to the importance of creeks in the community. CMSWS partners with several
other governmental and non-profit organizations to develop and market events that tie into the
overall surface water quality theme. A logo is used, and events are held including several story
times at libraries, a volunteer monitoring workshop, a stream restoration educational walk, and
various stream cleanups and educational workshops. During FY2021, Creek Week was
minimized due to COVID-19 but there were several volunteer events throughout the week. On
social media, the week focused on watersheds that are impaired and highlighted a different
watershed daily, providing facts and general information about the streams. Table 3-9 shows the
data relative to this program for the report period.

Table 3-9: Special Campaign and Activity Program Results
Activity Results
Stormy Mascot appearances at events 0
Creek Week events held 15

3.5 Measurable Goals/Planned Activities for Future Program Years

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Table 3-10 describes the various Public Education and Outreach BMPs and the Measurable
Goals and Planned Activities for Future Program Years for each BMP by permit term year.

[THIS SPACE INTENTIONALLY BLANK]
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Table 3-10: BMP Measurable Goals for the Public Education and Outreach Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5+
Describe target
pollutants and target
pollutant sources
Describe the target pollutants and target
pollutant sources the permittee’s public
education program is designed to address
and why they are an issue.

Identify target
pollution sources
utilizing
monitoring and
service request data
Review and update target pollution sources as necessary. (On-going, years 2 – 5+)
Describe target
audiences
Describe the target audiences likely to
have significant stormwater impacts and
why they were selected.
Identify target
audiences to adopt
desired surface
water quality
improvement
behaviors
Review and update target audiences as necessary. (On-going, years 2 – 5+)
Informational Web
Site
The permittee shall promote and
maintain an internet web site designed to
convey the program’s message.
Continue to maintain an informational website to provide program information to the public . (On-going,
years 1 – 5+)
Distribute public
education materials to
identified user groups.
Distribute general stormwater educational
material to appropriate target groups as
likely to have a significant stormwater
impact. Instead of developing its own
materials, the permittee may rely on state-
supplied Public Education and Outreach
materials, as available, when
implementing its own program.
Distribute educational materials at public events, workshops and presentations. (On-going, years 1 – 5+)
Promote and maintain
Hotline/Help line
Promote and maintain a stormwater
hotline/helpline.
Maintain a hotline that receives information from the public 24 hours a day . (On-going, years 1 – 5+)
Implement a Public
Education and
Outreach Program.
The permittee’s outreach program,
including those elements implemented
locally or through a cooperative
agreement, shall include a combination
of approaches designed to reach the
target audiences. For each media, event
or activity, including those elements
implemented locally or through a
cooperative agreement the permittee
shall estimate and record the extent of
exposure.
Continue to implement a plan to conduct education & outreach activities, including a media campaign, that
address target pollutants and audiences. (On-going, years 1 – 5+)
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3.6 Program Assessment

The measurable goals in Table 3-10 for the Public Education and Outreach Program were
successfully accomplished during the annual report period. Information in Section 3 provides
more detailed information about implementation efforts. Table 3-11 shows a summary of the
various items and corresponding data results for activities conducted under the program.

Table 3-11: Program Summary
PUBLIC EDUCATION PROGRAM FY2019 FY2020 FY2021 FY2022 FY2023 FY2024
Advertising spots (TV and Radio) 924 731 663
Advertising media impressions (TV and Radio) 6,063,651 6,970,584 4,160,065
Utility bill inserts (stormwater related) 1,330,520 1,530,000 1,407,000
Social Media Followers/Subscribers 8,927 9,340 10,054
Social media posts 620 648 986
Social media responses 1,045 1,240 14,819
Public requests to hotline (stormwater related) 8,934 9,104 7,810
Public requests to hotline (SWQ related) 553 605 445
Presentations 135 55 29
Persons educated at presentations 3,492 2,088 1,211
Public events 33 8 5
Citizens interacted with at public events 3,970 1,860 50
Website page views 376,617 381,610 417,437

Overall: A combination of evaluation tools indicates that the City’s residents were successfully
being exposed to surface water quality education messages. Staff has developed plans and done
research on potential methods that can be used to reach more diverse audiences and expand the
outreach program. The following provides more detail regarding some of the numbers reported
above.

Target Pollutants and Audiences: The target pollutants for the education and outreach program
are bacteria and sediment because these two pollutants are the primary pollutants causing
impairment in local surface waters. As such, efforts are focused on target audiences and
primarily aimed at reducing these target pollutants as well as other pollutants.

Mass Media: CMSWS utilized traditional media such as television and radio as well as website
advertisements and social media.

Utility Bill Inserts: Seven utility bill inserts were created which was one more than the year
before.

Public Events & Public Presentations: The number of presentations, public events and citizen
interactions decreased. This is due to COVID -19 related cancellations.
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School Presentations: The number of school presentations and students educated increased this
fiscal year. This is due to virtual school presentation options.

Website Page views: The number of website page views increased this fiscal year.

Social Media: With social media becoming an increasingly used source of information for many
people, CMSWS has focused more resources on this method of public education and outreach.
An additional 300 posts were made during FY2021 compared to FY2020 and the number of
responses dramatically increased by almost 1,100% over last year. We also gained an additional
714 followers/subscribers.

Public Requests: Calls from citizens as a group made up 60% of all calls, which was 50% higher
than from the next most frequent caller type, Mecklenburg County Storm Water Services staff,
which accounted for 10% of calls. This is important information for targeting education
campaigns related to pollution reporting.

Public Opinion Survey Results: A Public Opinion Survey is conducted annually in order to
gather data on our outreach campaigns. Of the respondents, 40% recall seeing information from
CMSWS during the last 12 months. Utility bill inserts and television were the top two ways
people received program information which is consistent with utility bill inserts and television
being the top two preferred methods of communication.

Section 4: Public Involvement and Participation Program

During the annual report period, the Public Involvement and Participation Program provided
opportunities for the public to participate in program development and implementation per the
SWMP. The following sub-sections explain:

• The BMPs implemented to meet program requirements;
• Target audiences;
• Volunteer opportunities;
• Public involvement mechanisms;
• Measures of success;
• Future goals and planned activities; and
• Program assessment.

4.1 BMP Summary Table

Table 4-1 provides information concerning the BMPs implemented to fulfill the Public
Involvement and Participation Program requirements.

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Table 4-1: BMP Summary Table for the Public Involvement and Participation Program.
BMP

BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Volunteer
community
involvement
program
The permittee shall include and promote volunteer
opportunities designed to promote ongoing citizen
participation.

X X X X X Water Quality
Program
Manager
Establish a
Mechanism
for Public
involvement
The permittee shall provide and promote a mechanism
for public involvement that provides for input on
stormwater issues and the stormwater program.

X X X X X Stormwater
Division
Manager
Establish
Hotline/Help line
The permittee shall promote and maintain a
hotline/helpline for the purpose of public involvement
and participation.
X X X X X Water Quality
Program
Manager
Public Review
and Comment
The permittee shall make copies of their most recent
Stormwater Plans available for public review and
comment.
X X X X X Water Quality
Program
Manager
Public Notice Pursuant to 122.34 the permittee must, at a minimum,
comply with State, Tribal and local public notice
requirements when implementing a public
involvement/ participation program.
X X X X X Water Quality
Program
Manager

4.2 Volunteer Involvement Program

4.2.1 Target Audiences

Public involvement is essential for ensuring the success of the overall stormwater management
program. CMSWS strives to reach out and provide opportunities to a broad range of audiences
as it’s felt that everyone who wants to be involved should be able to. To that end, efforts to
reach more diverse audiences have been expanded through mass media and social media
outreach. A variety of volunteer events are held year-round in different locations which helps to
draw many different people. “VolunThursday” events were added to draw people who are too
busy to volunteer on weekends. Programs such as “Streamside Monitoring and Assessment”
were added which are fairly quick and simple ways for people to get involved, further expanding
the volunteer base. The following sub-sections discuss the volunteer programs used in the City’s
overall Public Involvement and Participation Program.

4.2.2 Storm Drain Marking Program

This program enables volunteers to adhere vinyl printed markers to storm drains along streets
they select in their neighborhoods. CMSWS provides the decals, adhesive, safety vests and
information forms for completion by the groups. Following the completion of storm drain
marking activities, the groups submit a report that includes the street names and number of drains
marked, information concerning the condition of storm drains, and whether any pollution
problems were observed. CMSWS staff records and maps the streets where storm drains are
marked and ensures any issues reported receive follow-up investigation. Table 4-2 shows the
data relative to this program for the report period.

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4.2.3 Adopt-A-Stream Program

The objective of this program is for volunteers to “adopt” segments of streams and agree to walk
them, picking up trash and reporting any pollution problems found along the way. The program
not only serves as a public involvement initiative, but it also allows for interaction and
observations of the City’s streams by its citizens, which can lead to the identification and
elimination of pollution sources. AAS activities are tracked in order to help determine
programmatic gaps and to identify where resources should be focused. Table 4-2 shows the data
relative to this program for the report period.

Table 4-2: SDM, AAS, and Big Spring Clean Program Results
Activity Results
Storm drains marked 1,295
Storm Drain Marking volunteers 192
Storm Drain Marking volunteer hours 502
Adopt-A-Stream groups 152
Adopt-A-Stream clean-ups 140
Adopt-A-Stream volunteers 1,811
Adopt-A-Stream volunteer hours 4,388
Adopt-A-Stream miles cleaned 114
Adopt-A-Stream trash collected (tons) 22
Big Spring Clean volunteers 0
Big Spring Clean volunteer hours 0
Big Spring Clean stream miles cleaned 0
Big Spring Clean trash collected (tons) 0
Illicit discharges detected through these programs1. 3
1. This data also included in the total Illicit Discharges data shown in Table 5-15.

4.2.4 The Big Spring Clean

The Big Spring Clean is a one-day annual event promoted by CMSWS and the local organization
Keep Mecklenburg Beautiful. The event is held on a selected Saturday morning during the
spring season and typically provides seven to nine locations where citizens can go to remove
trash from local streams. These locations are conveniently situated at greenway trailheads with
ample parking and staffed by CMSWS to provide the volunteers with supplies, drinks and
snacks. CMSWS coordinates the logistics during this event and collects statistics such as
number of volunteers participating, volunteer hours, and the amount of trash removed at each
location. Table 4-2 shows the data relative to this program for the report period for local
waterways at various locations throughout the City. This event was cancelled for FY2021 due to
COVID-19 restrictions.

4.2.5 Volunteer Monitoring

The Volunteer Monitoring Program uses a Visual Assessment and Snapshot Assessment
methodology. Visual assessment includes volunteers who are trained in workshops about
surface water quality, common stream pollutants, and how to identify them. Trained individuals
then select a stream site from among a list and agree to send in qualitative, visual assessment
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forms every month for their assigned sites. Snapshot Assessment is available to all citizens
without having to attend a workshop. Three signs have been posted along stream greenways that
have a number for people to text a picture and report the condition of the stream. Staff
investigate any problems reported through these programs.

In addition, other volunteer monitoring programs including stream chemical monitoring and
macroinvertebrate monitoring continues. Due to weekend workshops to recruit volunteers being
resource-intensive and not well-attended, staff now advertises the program and trains volunteer
groups upon request. These programs tend to be most popular among school groups. Table 4-3
shows the data relative to this program for the report period.

4.2.6 Second Saturday Volunteer Events

The “Second Saturday” events take place usually on the second Saturday of every month and run
typically from 9 am to 12 noon at different locations that are selected based on clean-up or
maintenance needs. The events rotate between stream cleanups, tree maintenance, and storm
drain marking. To make it easy for citizens to participate, registration is not required, and the
location of each event is made known to the public the month prior to each event. Table 4-3
shows the data relative to this program for the report period.

4.2.7 Tree Planting Program

The City and CMSWS maintain various tree planting programs where citizens can volunteer to
plant and maintain trees on select public property and project sites. This effort helps to stabilize
soil and reduce stormwater runoff and pollution. Table 4-3 shows the data relative to this
program for the report period.

4.2.8 Adopt-A-Street Program

The City’s Keep Charlotte Beautiful program maintains an Adopt-A-Street program where
citizens can volunteer to adopt a section of roadway to remove trash and litter. This effort helps
to keep trash from entering the storm drain system and streams. Table 4-3 shows the data
relative to this program for the report period.

4.3 Public Involvement Mechanism

The City of Charlotte and Mecklenburg County maintain a citizen Storm Water Advisory
Committee (SWAC).

SWAC serves as the City’s stormwater management citizen advisory panel for involving the
public in the development and implementation of the permit program. The SWAC reviews:

• Capital and operational programs;
• Appeals;
• Stormwater program policies;
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• Long-range plans; and
• Budgets.

The committee also adjudicates appeals for erosion control violations, pollution control
violations, service charges, and fee credits and adjustments. Table 4-3 shows the data relative to
this program for the report period.

Table 4-3: Public Involvement Program Results
Activity Results
Volunteer Monitoring participants 313
Volunteer Monitoring participant hours 45
Volunteer Monitoring samples collected 84
Volunteer Monitoring visual observations made 61
Illicit discharges detected through this program 1. 10
Second Saturday total events 11
Second Saturday volunteers 254
Second Saturday volunteer hours 762
Second Saturday Event – Stream Clean-ups 3
Second Saturday Event trash collected (tons) 3
Second Saturday Event – Tree Maintenance 5
Second Saturday Event – Storm Drain Marking 4
Tree planting volunteers 87
Tree planting volunteer hours 261
Trees planted by volunteers 245
Adopt-A-Street volunteers 2,528
Adopt-A-Street volunteer hours 4,789
Adopt-A-Street miles cleaned 402
Adopt-A-Street bags of trash collected 2,422
Adopt-A-Street bags of recyclables collected 262
SWAC meetings 11
Attendees at SWAC meetings 73
1. This data also included in the total Illicit Discharges data shown in Table 5-15.

4.4 Public Reporting Mechanisms

The City, in cooperation with Mecklenburg County, operates a joint customer service hotline to
receive information about a variety of concerns. Citizens can call 311 to report pollution,
flooding, and blockages to the drainage system as well as request other City/County services.
The 311-call center is staffed to receive calls Monday through Friday from 7 am to 7 pm.
Citizens can also submit requests for service to 311 at any time by using the CLT+ app or by
going online to the “Report a Problem” section of the website. All personnel from the customer
service group receive training on stormwater issues and pollution to ensure calls are directed to
appropriate personnel and handled in a timely manner. The training manual for 311 staff is
reviewed and updated periodically to ensure information and resources are accurate.

4.5 Public Review and Comment Opportunities

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The City provides opportunities for public review and comment on the implementation of its
NPDES MS4 permit and SWMP plan through website information.

4.6 Public Notice

During the report period the City issued no public notices relevant to the NPDES MS4 program.

4.7 Measurable Goals/Planned Activities for Future Program Years

Table 4-4 describes the various Public Involvement and Participation Program BMPs and the
Measurable Goals and Planned Activities for Future Program Years for each BMP by permit
term year.

[THIS SPACE INTENTIONALLY BLANK]

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Table 4-4: BMP Measurable Goals for the Public Involvement and Participation Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5+
Volunteer
community
involvement
program
The permittee shall include and
promote volunteer opportunities
designed to promote ongoing citizen
participation.

Continue to maintain a public involvement and participation program that outlines campaigns and tools to
encourage public involvement. (On-going, years 1 – 5+)
Establish a
Mechanism
for Public
involvement
The permittee shall provide and
promote a mechanism for public
involvement that provides for input on
stormwater issues and the stormwater
program.
Maintain the Stormwater Advisory Committee. (On-going, years 1 – 5+)
Establish
Hotline/Help line
The permittee shall promote and
maintain a hotline/helpline for the
purpose of public involvement and
participation.
Maintain a hotline that receives information from the public 24 hours a day . (On-going, years 1 – 5+)
Public Review and
Comment
The permittee shall make copies of
their most recent Stormwater Plans
available for public review and
comment.
Maintain an informational website which includes the SWMP available for review and comment. (On-going,
years 1 – 5+)
Public Notice Pursuant to 122.34 the permittee must,
at a minimum, comply with State,
Tribal and local public notice
requirements when implementing a
public involvement/ participation
program.
Comply with State and local public notice requirements when making major changes to the stormwater program
and/or applying for permit renewals. (On-going, as needed)
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4.8 Program Assessment

The measurable goals in Table 4-4 for the Public Involvement and Participation Program were
successfully accomplished during the annual report period. Information in Section 4 provides
more detailed information about implementation efforts. Table 4-5 shows a summary of the
various items and corresponding data results for activities conducted under the program.

Table 4-5: Program Summary
PUBLIC INVOLVEMENT PROGRAM FY2019 FY2020 FY2021 FY2022 FY2023 FY2024
Total Volunteers 3,859 2,648 2,657
Total Volunteer hours 16,019 5,348 5,958
Total miles cleaned (linear miles) 612 114 114
Total trash collected (tons) 72 56 25
SWAC meetings 9 8 11
Attendees at SWAC meetings 167 158 73
Does not include Adopt-a-Street program data which is shown separately in Table 4.3

The City’s Public Involvement and Participation Program provides a combination of activities
that allows residents to be involved in the City’s stormwater management program and the
opportunity to comment on components of the City’s plan to meet NPDES MS4 permit
requirements. The following provides an overview of the program’s effectiveness:

Storm Drain Marking Program:
With evolving COVID-19 protocols related to gatherings and events, CMSWS continued to
promote the program via social media. The program was promoted as an activity that could be
done within a quarantining family unit and allowed for social distancing. The program was
successful in fiscal year 2021 with close to 1,300 storm drains marked and over 500 volunteer
hours.

Adopt-A-Stream Program:
The number of Adopt-A-Stream volunteers increased slightly. One-time stream clean-ups are
becoming more popular with groups versus signing up to conduct two clean-ups per year, which
is a requirement for adopting a stream segment.

Big Spring Clean:
The Big Spring Clean event was unable to be held due to COVID-19 restrictions. CMSWS plans
to partner with other organizations for a large cleanup event in the fall.

Volunteer Monitoring Program:
The Volunteer Monitoring Program was modified due to COVID-19 protocols and virtual
training was created. Volunteer Monitoring is now offered as an activity that can be completed
during a stream cleanup in hopes of engaging more volunteers in the program. This is an
example of continued program evaluation, creative thinking, and adaptation. When in-person
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training of groups wasn’t feasible or otherwise resource-intensive and not very popular, staff
found new and easier ways to engage volunteers in monitoring streams.

Public Involvement Strategy:
The purpose of the Public Involvement program is to provide an opportunity for citizens to get
involved in activities aimed at protecting and improving surface water quality. The City’s
various volunteer programs are promoted via traditional media such as television and radio,
digital media and streaming platforms and on social media platforms. Staff meets quarterly to
communicate about volunteer participation and to determine changes that need to take place in
order to continue to be successful.

SWAC meetings:
Meeting frequency and participation continues to be maintained in a virtual format. These
meetings continue to be a highly effective method for involving the public in policy decisions
related to the overall stormwater program.

Public Hotline/ Helpline: The 311-hotline continued to be a successful tool for allowing the
public to report surface water and stormwater pollution problems.

Section 5: Illicit Discharge Detection and Elimination (IDDE) Program

During the annual report period, staff implemented the Illicit Discharge Detection and
Elimination (“IDDE”) program to identify and eliminate sources of pollution to the MS4 per the
SWMP. The following sub-sections explain:

• The BMPs implemented to meet program requirements;
• Measures of success;
• Future goals and planned activities; and
• Program assessment.

5.1 BMP Summary Table

Table 5-1 provides information concerning the BMPs implemented to fulfill the IDDE Program
requirements.

Table 5-1: BMP Summary Table for the Illicit Discharge Detection and Elimination Program.
BMP BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Maintain
appropriate legal
authorities
Maintain adequate ordinances or other legal
authorities to prohibit illicit connections and
discharges and enforce the approved IDDE Program.
X X X X X Water Quality
Program
Manager
Maintain a Storm
Sewer System Base
Map
The permittee shall maintain a current map showing
major outfalls and receiving streams.

X X X X X Water Quality
Program
Manager
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Inspection /
detection program
to detect dry
weather flows at
MS4 outfalls
Maintain written procedures and/or Standard
Operating Procedures (SOPs) for detecting and
tracing the sources of illicit discharges and for
removing the sources or reporting the sources to the
State to be properly permitted. Written procedures
and/or SOPs shall specify a timeframe for monitoring
and how many outfalls and the areas that are to be
targeted for inspections.
X X X X X Water Quality
Program
Manager
Employee Training Conduct training for appropriate municipal staff on
detecting and reporting illicit connections and
discharges.
X X X X X Water Quality
Program
Manager
Maintain a public
reporting
mechanism
Maintain and publicize reporting mechanism for the
public to report illicit connections and discharges.
Establish citizen request response procedures.
X X X X X Water Quality
Program
Manager
Documentation The permittee shall document the date of
investigations, any enforcement action(s) or
remediation that occurred.
X X X X X Water Quality
Program
Manager

5.2 Ordinance Administration and Enforcement

The City adopted its original Stormwater Pollution Control Ordinance (SWPCO) on January 30,
1995 for the initial NPDES MS4 permit term. The ordinance was subsequently updated and
amended most recently on May 26, 2020 with the latest revisions effective on July 1, 2020. This
ordinance continues to be implemented as part of the NPDES MS4 permit program and SWMP.
All procedures and guidelines for proper administration and enforcement of the ordinance are
reviewed and updated, as necessary.

SWPCO data has been maintained since the inception of the program in FY1995. Determined
violations of the SWPCO result in the issuance of an NOV and additional enforcement measures,
such as civil penalty assessment, when deemed necessary.

Tables 5-2 and 5-3 show the data relative to the SWPCO program for the report period.

Table 5-2: SWPCO Program Results
Activity Results
Total NOVs issued 100
Total Civil penalties issued 7

[THIS SPACE INTENTIONALLY BLANK]

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Table 5-3: NOVs Issued per Material Category per Month

5.3 Stormwater System Inventory and Storm System Base Map

The City collects stormwater system inventory using a Stormwater Inventory Program and a
Stream Walk Program.

Stormwater Inventory Program: This program collects data on components of the stormwater
system such as catch basins, inlets, pipes, etc. while the stream walk program discussed below
collects data on outfalls. All inventory data receives quality assurance/quality control
(“QA/QC”) and is converted digitally into GIS.

Stream Walk Program: This program focuses on CMSWS staff walking stream channels to
inspect outfalls, identify and collect outfall data, and to identify dry weather flows and other
programs along the stream corridor. Stream walks are scheduled in every sub-basin within the
City at least one time every five years. All Stream Walk Program data is transferred to the City’s
Inventory Program annually.

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Table 5-4 shows the data relative to the stormwater system inventory program for the report
period.

Table 5-4: Stormwater Inventory Program Results
Activity Results
Stream walk sub-basins (six sq.mi.) assessed 17
Stream walk stream miles assessed 214
New outfalls identified 213
Existing outfalls QA/QC’d 219
System work zone areas (one sq. mi.) evaluated 104
Square miles evaluated (system inventory watershed) 81.5
Pipe miles inventoried 727
Open drainage miles inventoried 337
Stormwater features inventoried 110,265
Development projects added (system inventory) 63

5.4 Illicit Discharge Detection and Elimination Program

5.4.1 Outfall Inspection and Dry Weather Flow Detection

Each year select sub-basin outfalls are inspected for physical condition, the presence of dry
weather flows (DWFs), and illicit discharges. These inspections are primarily conducted during
Stream Walks and Hot Spot Investigations. Outfall inspections also occur during service request
and field investigations, municipal facility inspections, and industrial facility inspections.

DWFs are sampled for physical parameters (temperature, conductivity, pH, etc.), fecal coliform
and total phosphorus. Staff also conducts qualitative observations of DWFs for signs of
pollution such as color, odor, clarity, suds, oil sheen, etc. Table 5-5 shows the data relative to
the outfall inspection and DWF detection program for the report period.

Table 5-5: Outfall Inspection and DWF Program Results
Activity Results
Total outfalls inspected 687
Outfalls inspected during stream walks 432
Outfalls inspected during service requests/field investigations 42
Outfalls inspected during municipal inspections 126
Outfalls inspected during industrial inspections 87
DWFs detected 80
DWFs sampled 7
Fecal Coliform samples collected 9
Total Phosphorus samples collected 9
Fecal Coliform results investigated 1
Illicit discharges detected through this program 1. 6
Municipal SSOs reported to CW 4
Stream blockages detected/reported 39
Severe stream bank erosion areas detected/recorded 23
Other potential issues detected 20
1. This data also included in the total Illicit Discharges data shown in Table 5-15.
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5.4.2 Surface Water Quality Monitoring

The two main monitoring programs used to support IDDE efforts are the Fixed Interval and
CMANN stream monitoring programs. The Fixed Interval program conducts in-stream
monitoring for various chemical and physical parameters on a monthly basis and is discussed
further in Section 10. The CMANN program is an automated monitoring network that takes in-
stream readings every 60 minutes at select monitoring sites for dissolved oxygen, temperature,
pH, conductivity, and turbidity. This parameter data is transferred to a database in real-time
using cellular telemetry.

“Watch” and “Action” levels for the monitoring parameters are used as part of the program to
determine when follow-up investigations are needed to address potential problems. Exceedance
of these levels may trigger a field investigation if deemed appropriate.

5.4.3 Illicit Discharge Elimination Program

The Illicit Discharge Elimination Program (“IDEP”) is a sub-set of the overall IDDE program.
This program conducts proactive illicit discharge detection, investigation and outreach activities
in areas where data and staff experience indicate the greatest likelihood for the occurrence of
illicit discharges and/or poor housekeeping practices. During FY2021, the following activities
were conducted:

• Multi-Family Residential Community Inspections
• Business Corridor Runs
• Pet Waste Awareness Campaign
• Inspection of facilities that were previously issued a SWPCO civil penalty

Multi-Family Residential Community Inspections: This activity conducts windshield
investigations of privately maintained multi-family residential sewer systems to look for signs of
problems with the operation and maintenance of these systems. The multi-family systems are
selected based on their sewer overflow history. Table 5-6 shows the data relative to this
program for the report period.

Business Corridor Runs: This activity conducts windshield surveys along streets throughout the
City that have a high concentration of commercial businesses where illicit discharges and poor
housekeeping practices may potentially be found. Table 5-6 shows the data relative to this
program for the report period.

Pet Waste Awareness Campaign: This effort is maintained with the goal of reducing the amount
of improperly disposed pet waste. During FY2021, staff placed small flags and signs beside dog
waste deposits in a popular park with messages of the environmental and health risks resulting
from improper disposal of pet waste as a method to promote awareness. Table 5-6 shows the
data relative to this program for the report period.

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Inspection of Previous SWPCO Penalized Facilities : This program inspects businesses that
previously received a SWPCO civil penalty within the past three years. The purpose of these
inspections is to verify these facilities are maintaining compliance with the SWPCO.

Table 5-6: IDEP Program Results
Activity Results
Multi-family community inspections conducted 30
Business corridor inspections conducted 30
Business corridor catch basin inspections conducted 120
Pet waste flagging events 9
Inspections at previous SWPCO civil penalty facilities 25
Illicit discharges detected through this program 1. 4
1. This data also included in the total Illicit Discharges data shown in Table 5-15.

5.4.4 Sanitary Sewer Overflows and Septic System Discharges

CMSWS works with two separate City/County departments to reduce sources of bacteria from
municipal system SSOs and private septic systems: Charlotte Water (CW) department and
Mecklenburg County Groundwater and Wastewater Services. CMSWS is also working with
CLT Water and Mecklenburg County Soil & Water Conservation on a pilot outreach program to
address private sewer system SSO issues.

Sanitary Sewer Overflows: CW is the City department responsible for operating the municipal
water supply and sanitary sewer systems in the City. CW monitors the causes of SSOs and
implements various system programs and maintenance activities to reduce SSO occurrences.
Table 5-7 shows the data relative to these programs for the report period.

The City works to decrease SSOs in several ways, which include:

• System infrastructure inspections and maintenance;
• Lift station inspections and maintenance;
• Increasing system capacity with sewer relief projects;
• Commercial, restaurant, industrial, and multi-family inspections;
• The Flow Free education program; and
• Multi-family residential program.

System infrastructure & lift station inspections, maintenance, and improvement: CW
implements a number of infrastructure inspection, maintenance, and improvement programs
which are designed to reduce inflow and infiltration and SSOs, including:

• SSO rapid response;
• CCTV sewer line inspections;
• Manhole inspections, maintenance, and replacement;
• Cleaning and root treating sewer lines;
• Sewer line ROW clearing;
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• Sewer pipe re-lining;
• Lift station inspections and maintenance; and
• Increasing system capacity with sewer relief projects.

Table 5-7 shows the data relative to this program for the report period.

Table 5-7: Municipal Sanitary Sewer System Program Results*
Activity Results*
Sewer System SSOs discovered/addressed 152
Sewer system SSO volume (gallons) 127,773
SSOs per 100 system miles 3.41
Sewer system lines inspected via CCTV (miles) 279
Sewer system manholes inspected 22,772
Sewer system lines replaced or repaired (miles) 11.3
Sewer system lines re-lined (miles) 10.1
Sewer system manholes replaced or repaired 160
Sewer system lines cleaned (miles) 941
Sewer system lines treated with root chemicals (miles) 328.5
Sewer system lines ROW cleared for access (miles) 106
Sewer system service connections replaced 229
Sewer system lift-station preventative maintenance tasks 155
Sewer system lines added by sewer relief projects (miles) 6.7
* This data is not included in summary data shown in Table 5-15

Commercial/restaurant/industrial inspections: CW performs the following inspection and
enforcement activities to address SSO sources from commercial and industrial business:

• Inspection of grease handling facilities at food service establishments and restaurants;
• Inspection and permitting of industrial pretreatment facilities; and
• Enforcement of the City’s Sewer Use Ordinance including issuance of NOVs and Notices
of Deficiency (NOD) as warranted.

Table 5-8 shows the data relative to this program for the report period.

Flow Free education program: CW implements the following education activities to address
SSO sources from commercial and industrial business and residential sources:

• Implementation of the Flow Free - Fats, Oils, and Grease (FOG) education program to
provide information on proper disposal of pipe-blocking items through the use of mailers,
brochures, and presentations.
• Distribution of door hangers to maintenance personnel and property managers of multi-
family communities.
• Implementation of the Pipes Hate Wipes campaign to educate residents about the impact
flushable wipes have on the collection system and wastewater treatment plants.

Table 5-8 shows the data relative to this program for the report period.
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Table 5-8: Sewer System Inspection and Education Program Results*
Activity Results*
Food grease/oil handling inspections conducted 3,287
Industrial pretreatment inspections conducted 120
City sewer use ordinance NOVs issued 39
City sewer use ordinance NODs issued 44
FOG mailers issued 1,025
FOG brochures distributed 3,333
FOG presentations conducted 2
Citizens educated at FOG presentations 160
* This data is not included in summary data shown in Table 5-15 and Table 3-11

Multi-Family Residential Program:

The multi-family program includes:

• Maintaining a master list of multi-family communities;
• Compiling a list of 50 priority communities for inspection annually;
• Informational letters sent to priority list of multi-family residential communities;
• Education of multi-family community staff to help them comply with the regulations;
• Provision of sewer system Operation & Maintenance Plan templates and other resources
on CMSWS’ website to help them comply with regulations;
• Inspection of multi-family communities for problems in their private sanitary sewer
systems; and
• Issuance of SWPCO NOVs as necessary.

Table 5-9 shows the data relative to this program for the report period.

Table 5-9: Multi-Family Community Program Results
Activity Results
Multi-family informational letters issued by CMSWS 50
Multi-family inspections conducted by CMSWS 50
Operation & Maintenance Plans developed 22
Multi-family sewer system problems discovered 14
Illicit discharges detected through this program 1. 0
1. This data also included in the total Illicit Discharges data shown in Table 5-15.

Septic Systems: CMSWS works with Mecklenburg County Groundwater and Wastewater
Services (GWWS) each year to monitor discharges from septic systems. The GWWS program
conducts the permitting, inspections, education and enforcement activities related to septic
systems. CMSWS reviews this information to look for potential impacts on surface waters.
Table 5-10 shows the data relative to this program for the report period.

Table 5-10: Septic System Program Results
Activity Results
Total failing septic systems discovered 25
Failing septic systems connected to municipal sanitary sewer system 15
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Failing septic systems repaired 10
Illicit discharges detected through this program 1. 0
1. This data also included in the total Illicit Discharges data shown in Table 5-15.

5.5 Employee IDDE Training and Education

Employee IDDE Training and Education involves training municipal employees about the
detection of illicit connections and discharges, and the various methods for reporting suspected
pollution problems. Training varies from year to year and is provided through a combination of
the following methods:

• Staff meeting presentations;
• On-site, in-person training sessions;
• On-line training module; and
• Other methods such as online contests, posters, fliers, light box displays, emails,
websites, and displays and information at employee gatherings.

During FY2021, staff IDDE training and education was provided through in-person training
sessions, an online training module in combination with municipal pollution prevention training,
and a contest delivered weekly for four weeks via employee e-newsletter. Table 5-11 shows the
data relative to this program for the report period.

Table 5-11: Employee IDDE Training/Education Program Results
Activity Results
Total staff trained on IDDE 1,870
Presentations at staff meetings1. 0
Employees trained at staff meeting presentations1. 0
On-site training presentations and tailgate training sessions at
municipal facilities 43
Employees trained at on-site sessions 500
Facilities assigned on-line training sessions 38
Staff trained via on-line training module 656
Staff trained via other methods 714
1. Presentations by CMSWS staff to groups that are not part of the annual municipal site training effort. Examples include employee contests,
displays at employee events, etc. This activity was not conducted during FY2021 due to COVID-19 precautions.

5.6 Public Reporting Mechanisms

The City, in cooperation with Mecklenburg County, operates a joint customer service hotline to
receive information about a variety of concerns. Citizens can call 311 to report pollution,
flooding, and blockages to the drainage system as well as request other City/County services.
The 311-call center is staffed to receive calls Monday through Friday from 7 am to 7 pm.
Citizens can also submit requests for service to 311 at any time by using the CLT+ app or by
going online to the “Report a Problem” section of the website. All personnel from the customer
service group receive training on stormwater issues and pollution to ensure calls are directed to
appropriate personnel and handled in a timely manner.

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5.6.1 Public Education and Outreach

The City maintains a public education and outreach program to inform businesses, industries and
the public about illicit discharges and improper waste disposal and how they impact the
environment. This education and outreach program includes instructions regarding the proper
method for reporting illicit discharges. The primary education and outreach mechanisms used
are:

• Media campaign (included mass media and social media);
• Website;
• Utility bill inserts;
• Handouts/brochures/environmental notices;
• Public events; and
• In-person education and training sessions.

Commercial Sector Education and Outreach

The City has created best practices guidance documents for many commercial sectors based on
problems revealed through data including service requests, illicit discharges, violation notices,
and staff observations. The documents are available online and staff provide them to businesses
during service requests and inspections. Past guidance documents created include:

• Landscape Maintenance • Concrete
• Pressure Washers • Horizontal Directional Drilling
• Mobile Vehicle Detailers • Painting
• Food Service Industry • Swimming Pools and Spas
• Managers of Apartments and Condos • Rooftop Work
• Asphalt Sealing • Stone Cutting
• Indoor Cleaning • Vehicle and Equipment Repair
• Commercial Property Management
• Breweries
• Municipal Contractors

During FY2021, staff created a new best practices guidance document for well drilling as it
relates to stormwater pollution and updated the flyer for pressure washers. The documents along
with a cover letter were mailed to many local and regional businesses engaged in those activities.
Table 5-12 shows the data relative to this program for the report period.

Table 5-12: Commercial Sector Education Program Results
Activity Results
Well Drilling BMP guidance documents mailed 112
Pressure Washing BMP guidance documents mailed 647

5.7 Service Requests and Documentation

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The 311-call center refers calls for stormwater general, structural, and flooding concerns to
CSWS while surface water quality (SWQ) concerns are referred to CMSWS-LUESA.
Responding to SWQ service requests continues to be one of the most important methods for
detecting and eliminating illicit discharges and connections in the City. Table 5-13 shows the
data relative to this program for the report period.

Table 5-13: Service Request Program Results
Activity Results
Total stormwater service requests received 3,868
SWQ service requests (pollution related) 445
SWQ emergency responses 35

The City utilizes the Cityworks® database platform to maintain electronic files documenting all
IDDE activities including service requests. These are tracked from the original call for service,
through investigations and applicable enforcement actions, and until final remedial work is
completed.

5.8 Measurable Goals/Planned Activities for Future Program Years

Table 5-14 describes the various Illicit Discharge Detection and Elimination program
BMPs and the Measurable Goals and Planned Activities for Future Program Years for each BMP
by permit term year.

[THIS SPACE INTENTIONALLY BLANK]

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Table 5-14: BMP Measurable Goals for the Illicit Discharge Detection and Elimination Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5+
Maintain
appropriate legal
authorities
Maintain adequate ordinances or other
legal authorities to prohibit illicit
connections and discharges and
enforce the approved IDDE Program.
Continue administration and enforcement of the Pollution Control Ordinance and IDDE Program. (On-going,
years 1 – 5+)
Maintain a Storm
Sewer System Base
Map
The permittee shall maintain a current
map showing major outfalls and
receiving streams.

Continue to maintain storm sewer map in GIS and update as necessary to show additional outfalls. (On-going,
years 1 – 5+)
Inspection /
detection program
to detect dry
weather flows at
MS4 outfalls
Maintain written procedures and/or
Standard Operating Procedures (SOPs)
for detecting and tracing the sources of
illicit discharges and for removing the
sources or reporting the sources to the
State to be properly permitted. Written
procedures and/or SOPs shall specify a
timeframe for monitoring and how
many outfalls and the areas that are to
be targeted for inspections.
Maintain and update SOPs for detecting and eliminating illicit discharges and performing outfall inspections.
Roughly 20% of identified outfalls will be inspected each year, with extra emphasis on hotspot areas. (On-going,
years 1 – 5+)
Employee Training Conduct training for appropriate
municipal staff on detecting and
reporting illicit connections and
discharges.
Maintain an employee training program and conduct employee training. (On-going, years 1 – 5+)
Maintain a public
reporting
mechanism
Maintain and publicize reporting
mechanism for the public to report
illicit connections and discharges.
Establish citizen request response
procedures.
Maintain the public reporting hotline and publicize through the media outreach campaign.
(On-going, years 1 – 5+)
Documentation The permittee shall document the date
of investigations, any enforcement
action(s) or remediation that occurred.
Continue to maintain IDDE program records and databases to accurately document the activities in the progr am.
(On-going, years 1 – 5+)
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5.9 Program Assessment

The measurable goals in Table 5-14 for the Illicit Discharge Detection and Elimination Program
were successfully accomplished during the annual report period. Information in Section 5
provides more detailed information about implementation efforts. Table 5-15 shows a summary
of the various items and corresponding data results for activities conducted under the program.

Table 5-15: Program Summary
IDDE PROGRAM FY2019 FY2020 FY2021 FY2022 FY2023 FY2024
SWPCO NOVs issued 125 124 100
SWPCO civil penalties issued 11 13 7
Stream miles assessed 218 196 214
Outfalls inspected 1,237 802 474
Illicit discharges detected/corrected 371 336 307
SWQ Service requests/reported problems 553 605 445
Municipal employee IDDE onsite training
sessions and facilities assigned online
module
86 54 81

Municipal employees trained on IDDE 1,993 1,692 1,870

Summary:

• Staff continued administration and enforcement of the Stormwater Pollution Control
Ordinance and IDDE program. Staff issued 100 NOVs and 7 civil penalties and
responded to 445 reports of potential stormwater pollution/illicit discharges;
• Staff continued to maintain and update the GIS map of stormwater system outfalls.
During FY2021, 213 new outfalls were identified and added to the GIS map;
• The IDDE Manual and other IDDE-related SOPs were reviewed and updated during
FY2021. Following the five-year plan for outfall inspections during stream walks,
outfalls along 214 miles of streams were inspected which represents roughly 20% of
stream miles draining greater than 50 acres;
• Staff continued its robust employee training program on illicit discharge detection and
reporting. Due to COVID-19, instead of being able to conduct some training through
onsite presentations by CMSWS staff, training information was provided to
knowledgeable supervisors at several facilities who used the information to conduct
“tailgate-style” small group training sessions. Other employees were trained using an
online training module developed by CMSWS staff. An employee contest using the
mascot Stormy the Turtle was also held over four weeks during May 2021. A total of
1,870 employees were trained and educated about IDDE issues;
• The public reporting hotline 311 continued to be maintained as well as an online
reporting form and the City’s CLT+ phone app. All of these public reporting
mechanisms were publicized through the program’s media outreach campaign, website,
and other ways; and
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• Staff continued to input all IDDE-related information into the Cityworks application.
This includes all service requests (dates, names, follow-up, etc.), notices of violation,
penalties, inspections, and other program data. Various other documentation methods are
used to record and track program information such as spreadsheets, tables, and Word
documents which are stored electronically in appropriately labeled folders.

Section 6: Construction Site Stormwater Runoff Control Program

During the annual report period, the Construction Site Stormwater Runoff Control program
conducted site evaluations and enforced the local ordinance per the SWMP. The following sub-
sections explain:

• The BMPs implemented to meet program requirements;
• Measures of success;
• Future goals and planned activities; and
• Program assessment.

6.1 BMP Summary Table

Table 6-1 provides information concerning the BMPs implemented to fulfill the requirements of
the Construction Site Stormwater Runoff Control Program. Funding for the BMPs in this section
is covered by local land development fees.

Table 6-1: BMP Summary Table for the Construction Site Stormwater Runoff Control Program.
BMP BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Erosion and
Sediment Control
Program
The permittee has a delegated Sediment and
Erosion Control Program. As such, to the extent
authorized by law, the permittee is responsible for
compliance with the Sediment Pollution Control
Act of 1973 and Chapter 4 of Title 15A of the
North Carolina Administrative Code. The
delegated Sediment and Erosion Control Program
effectively meets the maximum extent practicab le
(MEP) standard for Construction Site Runoff
Controls by permitting and controlling
development activities disturbing one or more
acres of land surface and those activities less than
one acre that are part of a larger common plan of
development as authorized under the Sediment
Pollution Control Act of 1973 and Chapter 4 of
Title 15A of the North Carolina Administrative
Code.
X X X X X Land
Development
Division
Manager
Develop
requirements for
construction site
operators
The NCG010000 permit establishes requirements
for construction site operators to control waste
such as discarded building materials, concrete
truck washout, chemicals, litter, and sanitary waste
X X X X X Land
Development
Division
Manager
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at the construction site that may cause adverse
impacts to water quality, as part of the Permittee’s
delegated program.
Public information
and reporting
The permittee shall provide and promote a means
for the public to notify the appropriate authorities
of observed erosion and sedimentation problems.
The permittee may implement a plan promoting
the existence of the NCDEQ, Division of Land
Resources “Stop Mud” hotline to meet the
requirements of this paragraph.
X X X X X Land
Development
Division
Manager
Plan reviews Implement construction site plan reviews as part of
the Permittee’s delegated program. For new
development and redevelopment projects to be
built within the permittee’s planning jurisdiction
by entities with eminent domain authority, the
permittee shall, to the maximum extent
practicable, coordinate the approval of the
construction site runoff control with the Division
of Land Resources of NCDEQ.
X X X X X Land
Development
Division
Manager

6.2 Erosion and Sediment Control Program

The City operates a delegated Sediment and Erosion Control Program under authority granted by
the North Carolina Sedimentation Commission. As such, to the extent authorized by law, the
City is responsible for compliance with the Sediment Pollution Control Act of 1973 and Chapter
4 of Title 15A of the North Carolina Administrative Code. The “City of Charlotte – Soil Erosion
and Sedimentation Control Ordinance (SESCO),” amended and adopted by City Council in
2008, serves as the backbone of the program.

6.2.1 Inspection Procedures

All construction sites that require a preconstruction meeting and an approved plan are logged,
filed and placed in the queue for regular inspections. Staff goals are to visit and inspect every
logged site utilizing a scheduled inspection process. Sites that generated citizen complaints, had
a history of non-compliance, or are in close proximity to a critical area are considered a priority
for additional inspections and follow-up. Table 6-4 shows the data relative to this program for
the report period.

6.3 Construction Site Requirements

The program requires that all land disturbing activities comply with ordinance requirements for
controlling erosion and sediment on site. As an additional requirement, and in compliance with
NPDES regulations, all construction sites one acre or greater must have an approved soil erosion
and sediment control plan designed specifically for the site as required by NPDES General
Permit NCG010000 for Construction Related Activities.

6.4 Public Information and Reporting

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The City’s Erosion Control Program maintains a website to assist with the dissemination of
information to the development community and the public. In addition, the City, in cooperation
with Mecklenburg County, operates a joint customer service hotline to receive information about
a variety of concerns. Citizens can call 311 to report pollution, flooding, and blockages to the
drainage system as well as request other City/County services. The 311-call center is staffed to
receive calls Monday through Friday from 7 am to 7 pm. Citizens can also submit requests for
service to 311 at any time by using the CLT+ app or by going online. The hotline serves as a
clearinghouse for general information and ensures that erosion control related issues are directed
to appropriate CSWS-LD staff for resolution.

Table 6-4 shows the data relative to this program for the report period.

6.4.1 Education and Training Materials

The City maintains an education and training program for developers, contractors and other
interested parties within the region. In a cooperative effort with Mecklenburg County, the City
maintains the Charlotte-Mecklenburg Certified Site Inspector (“CMCSI”) training program,
which has provided training to many individuals since its inception in 2003. Table 6-2 shows
the data relative to this program for the report period.

In addition to the CMCSI education program, all developers, builders and responsible parties
receive handouts and materials at preconstruction meetings and at other times as necessary to
explain ordinance requirements, minimum standards and other relevant information for the
financially responsible party and/or site operators.

Table 6-2: CMCSI Training Program Results
Activity Results
Cumulative total persons trained since program inception (FY2003) 6,731
Training sessions conducted 0
Total persons trained 257
Persons attending training sessions 0
Persons trained on-line 257
No in-person training sessions were held during the permit term due to COVID; all training was done online

6.5 Plan Reviews

All land disturbing activities one acre or greater are required to obtain plan approval of the soil
erosion and sediment control plan prior to scheduling a preconstruction conference. Erosion
control plans submitted by the applicants are reviewed and approved by CSWS-LD erosion
control staff.

All CSWS-LD erosion control staff obtain and maintain their status as a Certified Professional in
Erosion and Sediment Control (CPESC) which provides accreditation for plan review. Plans are
reviewed for suitability of selected measures and to ensure that design parameters and
calculations are appropriately utilized and minimum standards are achieved.

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6.6 Measurable Goals/Planned Activities for Future Program Years

Table 6-3 describes the various Construction Site Stormwater Runoff Control BMPs and the
Measurable Goals and Planned Activities for Future Program Years for each BMP by permit
term year.

[THIS SPACE INTENTIONALLY BLANK]

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Table 6-3: BMP Measurable Goals for the Construction Site Stormwater Runoff Control Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5+
Erosion and
Sediment Control
Program
The permittee has a delegated Sediment and Erosion
Control Program. As such, to the extent authorized by
law, the permittee is responsible for compliance with the
Sediment Pollution Control Act of 1973 and Chapter 4
of Title 15A of the North Carolina Administrative Code.
The delegated Sediment and Erosion Control Program
effectively meets the maximum extent practicable
(MEP) standard for Construction Site Runoff Controls
by permitting and controlling development activities
disturbing one or more acres of land surface and those
activities less than one acre that are part of a larger
common plan of development as authorized under the
Sediment Pollution Control Act of 1973 and Chapter 4
of Title 15A of the North Carolina Administrative Code.
Continue to implement the delegated Sediment and Erosion Control program and enforce the
City ordinance. (On-going, years 1 – 5+)
Develop
requirements for
construction site
operators
The NCG010000 permit establishes requirements for
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 impacts to water quality, as
part of the Permittee’s delegated program.
Continue requirements for BMPs and waste control through issuance of General Construction
Permit NCG010000. (On-going, years 1 – 5+)
Public information
and reporting
The permittee shall provide and promote a means for the
public to notify the appropriate authorities of observed
erosion and sedimentation problems. The permittee may
implement a plan promoting the existence of the
NCDENR, now NCDEQ, Division of Land Resources
“Stop Mud” hotline to meet the requirements of this
paragraph.
Continue to maintain reporting hotline and website. (On-going, years 1 – 5+)
Plan reviews Implement construction site plan reviews as part of the
Permittee’s delegated program. For new development
and redevelopment projects to be built within the
permittee’s planning jurisdiction by entities with
eminent domain authority, the permittee shall, to the
maximum extent practicable, coordinate the approval of
the construction site runoff control with the Division of
Land Resources of DENR.
Continue plan reviews to ensure program requirements are met. Coordinate with NCDEQ-
Division of Energy, Mining, and Land Resources as necessary. (On-going, years 1 – 5+)
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6.7 Program Assessment

The measurable goals in Table 6-3 for the Construction Site Stormwater Runoff Control Program
were successfully accomplished during the annual report period. Information in Section 6
provides more detailed information about implementation efforts. Table 6-4 shows a summary
of the various items and corresponding data results for activities conducted under the program.

Table 6-4: Program Summary
CONSTRUCTION SITE RUNOFF PROGRAM FY2019 FY2020 FY2021 FY2022 FY2023 FY2024
SESCO NOVs issued 51 41 35
SESCO civil penalties issued 60 31 20
Site inspections conducted 3,513 4,902 5,044
Service requests/reported problems 500 550 510
CMCSI training sessions (in-person) 3 2 0
Persons trained on CMCSI 349 339 257
Project/site plans reviewed 1,254 1,030 1,293

Section 7: Post-Construction Stormwater Management Program

During the annual report period, the City conducted implementation of its Post-Construction
Stormwater Management program in accordance with the Post-Construction Stormwater
Ordinance (“PCSO”) and program administrative manual. The following sub-sections explain:

• The BMPs implemented to meet program requirements;
• Measures of success;
• Future goals and planned activities; and
• Program assessment.

7.1 BMP Summary Table

Table 7-1 provides information concerning the BMPs implemented to fulfill the requirements of
the Post-Construction Stormwater Management Program. Funding for the BMPs in this section
is covered by local stormwater utility fees and land development fees.

Table 7-1: BMP Summary Table for the Post-Construction Stormwater Management Program.
BMP BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Post-Construction
Stormwater
Management
Program
Maintain an ordinance (or similar regulatory
mechanism) and program to address stormwater
runoff from new development and redevelopment.

X X X X X
Water Quality
Program
Manager
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Strategies which
include BMPs
appropriate for the
MS4
Maintain strategies that include a combination of
structural and/or non-structural BMPs implemented
in concurrence with ordinance above. Provide a
mechanism to require long-term operation and
maintenance of structural BMPs. Require annual
inspection reports of permitted structural BMPs
performed by a qualified professional.

A qualified professional means an individual
trained and/or certified in the design, operation,
inspection and maintenance aspects of the BMPs
being inspected, for example, someone trained and
certified by NC State for BMP Inspection &
Maintenance.

X X X X X
Water Quality
Program
Manager
Deed Restrictions
and Protective
Covenants
The permittee shall provide mechanisms such as
recorded deed restrictions and protective covenants
so that development activities maintain the project
consistent with approved plans.

X X X X X
Water Quality
Program
Manager
Operation and
Maintenance Plan
The developer shall provide the permittee with an
operation and maintenance plan for the stormwater
system, indicating the operation and maintenance
actions that shall be taken, specific quantitative
criteria used for determining when those actions
shall be taken, and who is responsible for those
actions. The plan must clearly indicate the steps that
shall be taken and who shall be responsible for
restoring a stormwater system to design
specifications if a failure occurs and must include
an acknowledgment by the responsible party.
Development must be maintained consistent with
the requirements in the approved plans and any
modifications to those plans must be approved by
the Permittee.

X X X X X
Water Quality
Program
Manager
Educational
materials and
training for
developers
Provide educational materials and training for
developers. New materials may be developed by
the permittee, or the permittee may use materials
adopted from other programs and adapted to the
permittee’s new development and redevelopment
program.

X X X X X Water Quality
Program
Manager

7.2 Post-Construction Stormwater Management Program

The City’s post-construction program is designed to meet the stormwater management and
surface water quality protection requirements of North Carolina Administrative Code at 15A
02H Sections .0126, .0150 - .0154 (NPDES) and at 15A 02H Section .1000 (Stormwater
Management) to address post-construction stormwater runoff from new development and
applicable redevelopment projects as required by the NPDES MS4 permit program and as
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allowable under current State law. The City PCSO covers the entire jurisdictional area
(incorporated and ETJ areas) of the City and includes provisions for enforcement remedies and
civil penalties to ensure compliance. An administrative manual is maintained to ensure
successful implementation of the program and ordinance. Table 7-3 shows the data relative to
this program for the report period.

7.3 Post-Construction BMP Strategies

BMP strategies for the City’s Post-Construction Stormwater Management program consist
mainly of structural stormwater control measure(s) (“SCMs”) such as sand filters, wet ponds,
wetlands, and bioretention areas. SCMs and design procedures are detailed in a local manual
developed by the City and County. SCMs are required on projects that have 24% or greater built
upon area as defined by the program. This threshold is reduced to 10-12% built upon area for
developments disturbing more than an acre and/or adding more than 20,000 sf of built upon area
in sensitive watersheds as defined by the ordinance. In addition, SCMs must be designed to:

• Remove 85% of Total Suspended Solids (“TSS”) for the runoff volume generated from
the first 1-inch of rainfall;
• Control the runoff volume from the 1-year – 24-hour storm event; and
• Control the peak flow from the 10 and 25-year storm events for residential and
commercial development.

Table 7-3 shows the data relative to this program for the report period.

7.4 Deed Restrictions and Protective Covenants

As part of the PCSO program, the City requires deed restrictions and protective covenants to
ensure that development projects remain consistent with approved plans. Stream and buffer
boundaries are required to be specified on all surveys and record plats. An operation and
maintenance agreement for SCMs is required to be referenced on record plats and recorded in
deeds.

7.4.1 Setbacks for Built-Upon Areas

The PCSO program requires a minimum of 30-foot buffers on all perennial and intermittent
streams draining less than 50 acres, and incrementally increased required buffer widths up to
100-feet for streams draining 640 acres or more. A special provision in the program requires
200-foot buffers on all perennial streams and 100-foot buffers on all intermittent streams in the
Six Mile Creek watershed due to the potential presence of the federally endangered species,
Carolina Heelsplitter (Lasmigona decorata). These buffers are recorded on record plats as noted
in sub-section 7.4.

7.5 Operation and Maintenance Plan

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The PCSO program requires an operation and maintenance agreement executed by the
responsible party (owner) of each stormwater control measure (SCM). As part of the program,
the owner is required to:

• Conduct annual inspections of SCMs;
• Maintain proper records documenting operation and maintenance activities; and
• Submit inspection reports to the City.

CSWS conducts annual inspections of SCMs to ensure proper operation and maintenance and
compliance with the PCSO. Table 7-3 shows the data relative to this program for the report
period.

7.6 Education and Training Program

The City implements an education and training program designed to provide developers,
designers, and site owners with the information necessary to comply with the City’s Post-
Construction Stormwater Ordinance. Education and training typically includes information on:

• Overall ordinance requirements;
• Review processes;
• Land development and SCM design requirements;
• Deed restrictions and protective covenants;
• Buffer requirements; and
• Operation, maintenance, and inspection requirements for SCMs.

Education and training are accomplished by providing the following:

• Website information;
• Individual meetings with developers and designers;
• Presentations at public meetings;
• Periodic seminars and training sessions; and
• Training City project design and land development review staff.

Table 7-3 shows the data relative to this program for the report period.

7.7 Measurable Goals/Planned Activities for Future Program Years

Table 7-2 describes the various Post-Construction Stormwater Management Program BMPs and
the Measurable Goals and Planned Activities for Future Program Years for each BMP by permit
term year.

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Table 7-2: BMP Measurable Goals for the Post-Construction Stormwater Management Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5+
Post-Construction
Stormwater
Management
Program
Maintain an ordinance (or similar regulatory mechanism) and program to address
stormwater runoff from new development and redevelopment.

Maintain the City’s Post- Construction Ordinance (PCSO) and
implement and enforce the ordinance. (On-going, years 1 – 5+)
Strategies which
include BMPs
appropriate for the
MS4
Maintain strategies that include a combination of structural and/or non-structural BMPs
implemented in concurrence with (a) above. Provide a mechanism to require long -term
operation and maintenance of structural BMPs. Require annual inspection reports of
permitted structural BMPs performed by a qualified professional.

A qualified professional means an individual trained and/or certified in the design,
operation, inspection and maintenance aspects of the BMPs being inspected, for example,
someone trained and certified by NC State for BMP Inspection & Maintenance.

Continue PCSO program and ensuring proper BMP operation,
maintenance, and annual inspections. (On-going, years 1 – 5+)
Deed Restrictions
and Protective
Covenants
The permittee shall provide mechanisms such as recorded deed restrictions and protective
covenants so that development activities maintain the project consistent with approved
plans.

Continue to implement Deed Restrictions and Protective
Covenants through administration of the PCSO Program. (On-
going, years 1 – 5+)
Operation and
Maintenance Plan
The developer shall provide the permittee with an operation and maintenance plan for the
stormwater system, indicating the operation and maintenance actions that shall be taken,
specific quantitative criteria used for determining when those actions shall be taken, and
who is responsible for those actions. The plan must clearly indicate the steps that shall be
taken and who shall be responsible for restoring a stormwater system to design
specifications if a failure occurs and must include an acknowledgment by the responsible
party. Development must be maintained consistent with the requirements in the approved
plans and any modifications to those plans must be approved by the Permittee.

Continue to implement BMP operation, maintenance, and
inspection plan and procedures. (On-going, years 1 – 5+)
Educational
materials and
training for
developers
Provide educational materials and training for developers. New materials may be
developed by the permittee, or the permittee may use materials adopted from other
programs and adapted to the permittee’s new development and redevelopment program.

Continue to provide and update education/ training tools for
developers. (On-going, years 1 – 5+)
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7.8 Program Assessment

The measurable goals in Table 7-2 for the Post-Construction Stormwater Management Program
were successfully accomplished during the annual report period. Information in Section 7
provides more detailed information about implementation efforts. Table 7-3 shows a summary
of the various items and corresponding data results for activities conducted under the program.

Table 7-3: Program Summary
POST-CONSTRUCTION PROGRAM FY2019 FY2020 FY2021 FY2022 FY2023 FY2024
PCSO NOVs/CARs issued3. 948 933 711
PCSO civil penalties issued 0 4 7
Site plans reviewed 126 157 162
SCMs added by development 112 90 144
SCM inspections conducted4. 1,600 1,600 1,440
PCSO training sessions 1 1 1
Persons trained on PCSO5. 128 74 124
3. Includes NOVs and Corrective Action Requests (CARs); and notice of maintenance and report due letters to remind the property owner that a
yearly inspection report is due.
4. Includes Post-Construction and Peak Detention SCMs inspected.
5. Number includes only attendees at workshops. Others were educated about aspects of the Post-Construction program through phone calls,
website, and other ways.

Section 8: Pollution Prevention/Good Housekeeping Program

During the annual report period, inspection, training, and program development activities were
conducted for municipal facilities and operations as part of the Pollution Prevention and Good
Housekeeping Program per the SWMP. The following sub-sections explain:

• The BMPs implemented to meet program requirements;
• Measures of success;
• Future goals and planned activities; and
• Program assessment.

8.1 BMP Summary Table

Table 8-1 provides information concerning the BMPs implemented to fulfill the requirements of
the Pollution Prevention & Good Housekeeping Program.

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Table 8-1: BMP Summary Table for the Pollution Prevention/Good Housekeeping Program.
BMP BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Operation and
maintenance program
for municipal
facilities and
operations.
Maintain and implement an operation and
maintenance program for municipal facilities
owned and operated by the permittee that have
been determined by the permittee to have
significant potential for generating polluted
stormwater runoff that has the ultimate goal of
preventing or reducing pollutant runoff.
X X X X X
Water Quality
Program
Manager
Site Pollution
Prevention Plans for
municipal facilities
and operations.
Maintain and implement Site Pollution Prevention
Plans for municipal facilities owned and operated
by the permittee that have been determined by the
permittee to have significant potential for
generating polluted stormwater runoff that has the
ultimate goal of preventing or reducing pollutant
runoff.
X X X X X
Water Quality
Program
Manager
Inspection and
evaluation of
municipal facilities
and operations.
Maintain an inventory of municipal facilities and
operations owned and operated by the permittee
that have been determined by the permittee to have
significant potential for generating polluted
stormwater runoff, including the MS4 system and
associated structural SCMs, conduct inspections
at facilities and operations owned and operated by
the permittee for potential sources of polluted
runoff, the stormwater controls, and conveyance
systems, and evaluate the sources, document
deficiencies, plan corrective actions, implement
appropriate controls, and document the
accomplishment of corrective actions.
X X X X X
Water Quality
Program
Manager
Spill Response
Procedures municipal
facilities and
operations.
Maintain spill response procedures for municipal
facilities and operations owned and operated by
the permittee that have been determined by the
permittee to have significant potential for
generating polluted stormwater runoff.
X X X X X Water Quality
Program
Manager
Prevent or Minimize
Contamination of
Stormwater Runoff
from all areas used
for Vehicle and
Equipment Cleaning
Describe measures that prevent or minimize
contamination of the stormwater runoff from all
areas used for vehicle and equipment cleaning,
including fire stations that serve more than three
fire trucks and ambulances. Perform all cleaning
operations indoors, cover the cleaning operations,
ensure wash water drains to the sanitary sewer
system, collect stormwater runoff from the
cleaning area and providing treatment or r ecycling,
or other equivalent measures. If sanitary sewer is
not available to the facility and cleaning operations
take place outdoors, the cleaning operations shall
take place on grassed or graveled areas to prevent
point source discharges of the wash water into the
storm drains or surface waters.
Where cleaning operations cannot be performed as
described above and when operations are
performed in the vicinity of a storm drainage
X X X X X Water Quality
Program
Manager
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collection system, the drain is to be covered with a
portable drain cover during cleaning activities.
Any excess standing water shall be removed and
properly handled prior to removing the drain
cover.

Facilities that serve three or fewer fire trucks and
ambulances and that cannot comply with these
requirements shall incorporate structural measures
during facility renovation.
Streets, roads, and
public parking lots
maintenance
The permittee shall evaluate BMPs to reduce
polluted stormwater runoff from municipally-
owned streets, roads, and public parking lots
within the corporate limits. Within 12 months of
permit issuance, the permittee must update its
Stormwater Plan to include the BMPs selected.
X Water Quality
Program
Manager
Streets, roads, and
public parking lots
maintenance
Within 24 months of permit issuance, the
permittee must implement BMPs selected to
reduce polluted stormwater runoff from
municipally-owned streets, roads, and public
parking lots identified by the permittee in the
Stormwater Plan.
X X X X Water Quality
Program
Manager
Operation and
Maintenance (O&M)
for municipally-
owned or maintained
structural SCMs and
the storm sewer
system (including
catch basins, the
conveyance system,
and structural
stormwater controls).
Within 12 months of permit issuance, the
permittee shall develop and implement an
operation and maintenance program for structural
SCMs and the storm sewer system (including
catch basins, the conveyance system, and
structural stormwater controls).

X X X X X Water Quality
Program
Manager
Staff training Maintain and implement a training plan that
indicates when, how often, who is required to be
trained and what they are to be trained on.
X X X X X Water Quality
Program
Manager

8.2 Operation and Maintenance Program

Operation and maintenance of municipal facilities with regards to stormwater is primarily
managed through implementation of Stormwater Pollution Prevention Plan(s) (“SPPPs”) and the
municipal facility inspection program. CSWS staff continue to work with various departments to
improve and refine best management practices to minimize negative impacts to the storm
drainage system. This is primarily accomplished through observations in the field and response
to reports from concerned residents and internal staff about field operation practices where
improvements are needed. Implementation of BMPs occurs through a combination of
communications with management, training of field operations staff, and revision of contract
requirements.

8.3 Municipal Facility Stormwater Pollution Prevention Plans

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SPPPs are developed for all municipal facilities listed in Table 8-2 regardless of whether or not
they are required; however, SWPPPs are not required or developed for fire stations. The SPPPs
are reviewed and updated annually with all documentation kept in the SPPPs, including site
maps.

Table 8-2: City Facilities within the Pollution Prevention/Good Housekeeping Program.
Municipal Facility Physical Address
Charlotte-Douglas International Airport 5501 Josh Birmingham Pkwy., Charlotte, NC 28208
CATS Bus Maintenance Operations Facility 3145 S. Tryon St., Charlotte, NC 28217
CATS Transit Maintenance Operations Center 901 N. Davidson St., Charlotte, NC 28202
CATS Transit Center 310 E. Trade St., Charlotte, NC 28202
CATS Light Rail Maintenance Facility – North Yard 1911 North Brevard Street, Charlotte NC 28202
CATS Light Rail Maintenance Facility – South Yard 3305 Pelton St., Charlotte, NC
CDOT - Traffic Engineering Operations Center 3701 Craig Ave., Charlotte, NC 28211
CDOT – Street Maintenance Division - Northwest
District 4411 Northpointe Industrial Blvd., Charlotte, NC 28216
CDOT – Street Maintenance Division - Northeast
District 6001 General Commerce Dr., Charlotte, NC 28213
CDOT – Street Maintenance Division - Southwest
District 4600 Sweden Rd., Charlotte, NC 28273
Charlotte Water Department - Irwin Creek WWTP 4000 Westmont Dr., Charlotte, NC 28217
Charlotte Water Department - Mallard Creek WWTP 12400 Hwy 29 N, Charlotte, NC 28262
Charlotte Water Department - McAlpine Creek
WWTP & Zone 3 Water/Wastewater Operations 12701 Lancaster Hwy, Pineville, NC 28134
Charlotte Water Department - McDowell Creek
WWTP 4901 Neck Rd., Huntersville, NC 28078
Charlotte Water Department - Sugar Creek WWTP 5301 Closeburn Rd., Charlotte, NC 28210
Charlotte Water Department - Franklin WTP 5200 Brookshire Blvd, Charlotte, NC 28216
Charlotte Water Department - Lee S Dukes WTP 7980 Babe Stillwell Rd., Huntersville, NC 28078
Charlotte Water Department - Vest WTP 820 Beatties Ford Rd., Charlotte, NC 28216
Charlotte Water Department – Zone 1
Water/Wastewater Field Operations 11609 Hord Dr., Huntersville, NC 28078
Charlotte Water Department – Zone 2
Water/Wastewater Field Operations 5730 General Commerce Dr., Charlotte, NC 28213
Charlotte Water Department – Zone 4
Water/Wastewater Field Operations 4100 W. Tyvola Rd., Charlotte, NC 28208
Charlotte Water Department – Catawba Pump
Station 12548 Pump Station Rd., Charlotte, NC 28216
General Services - Heavy Equipment Shop 4600 Sweden Rd., Charlotte, NC 28273
General Services - Heavy Truck Shop / Central Yard
Truck Wash 829 Louise Ave., Charlotte, NC 28204
General Services - Light Vehicle Shop 1031 Atando Ave., Charlotte, NC 28216
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General Services - Small Engine Repair Shop 701 Tuckaseegee Rd., Charlotte, NC 28208
General Services - 12th Street Vehicle Garage 900 W 12th St, Charlotte, NC 28206
CFD - Fire Logistics 1501 N. Graham St., Charlotte, NC 28206
CMPD - Animal Control Shelter 8315 Byrum Dr., Charlotte, NC 28217
CMPD - Police and Fire Training Academy 1770 Shopton Rd., Charlotte, NC 28217
Solid Waste Services - Street Sweeper Facility &
Sanitation Packer Lot 829 Louise Ave., Charlotte, NC 28204
Landscape Management Operations 701 Tuckaseegee Rd., Charlotte, NC 28208

8.4 Municipal Facility Inventory and Site Inspections

All parcels of land owned or operated by the City continue to be examined to determine whether
they should be included in the Municipal Facilities Inventory within the Pollution
Prevention/Good Housekeeping Program. A standard administrative procedure (“SAP”) is
followed when evaluating parcels for this inventory. Once included in the inventory, applicable
facilities receive:

• Preparation and implementation of a SPPP;
• Regular inspections; and
• Annual employee training.

Table 8-3 shows the data relative to this program for the report period.

Table 8-3: Municipal Facility Program Results
Activity Results
New City owned parcels reviewed for inventory 12
Municipal facility inspections conducted1. 53
SPPP reviews conducted 33
Spill Prevention & Response Plan reviews conducted 33
SWPPP deficiencies noted 5
O & M improvement recommendations made to municipal facilities 91
Municipal operation program evaluations conducted 1
Illicit discharges detected through the municipal facility inspection
program2. 4
1. This number includes 20 fire stations which are inspected once every 5 years. Fire stations do not have individual SPPPs.
2. This data also included in the total Illicit Discharges data shown in Table 5-15.

8.4.1 NPDES Stormwater Permitted Municipal Facilities Review

Twelve of the 33 municipal facilities discussed in sub-section 8.3 above have their own NPDES
stormwater permits (*Note: The airport’s permit is a combined stormwater/wastewater individual
permit). Table 8-4 shows these facilities.

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Table 8-4: Municipal Facilities with NPDES Stormwater Permits
Municipal Operation Permit
Number
Certificate of Permit
Coverage Number
Address
CATS Transit Maintenance
Operations Center
NCG080000 NCG080029 901 N. Davidson Street
CATS Bus Maintenance
Operations Facility
NCG080000 NCG080710 3145 S. Tryon Street
Heavy Truck Shop, Truck
Wash & Street Sweeper
Yard
NCG080000 NCG080822 829 Louise Avenue
Heavy Equipment Shop NCG080000 NCG080840 4600 Sweden Road
Light Vehicle Maintenance
Shop
NCG080000 NCG080879 1031 Atando Avenue
12th Street Fleet
Maintenance
NCG080000 NCG080063

900 West 12th Street
Charlotte-Douglas
International Airport*
NC0083887 Not applicable 5501 Josh Birmingham Parkway
Irwin Creek WWTP NCG110000 NCG110008 4000 Westmont Drive
Mallard Creek WWTP NCG110000 NCG110114 12400 Highway 29 North
McAlpine Creek WWTP NCG110000 NCG110010 12701 Lancaster Hwy
McDowell Creek WWTP NCG110000 NCG110011 4901 Neck Road
Sugar Creek WWTP NCG110000 NCG110012 5301 Closeburn Road

Annual inspections are conducted by CMSWS staff along with facility management at each
facility listed in Table 8-4. A second inspection during the year is also conducted by each
facility’s management staff. Emphasis is placed on elimination of illicit discharges, good
housekeeping improvements, and compliance with permit and SPPP requirements, including
inspections, monitoring and training. The SPPPs are reviewed annually and updated as
necessary.

8.5 Municipal Spill Response Procedures

Spill prevention and response procedures (SPRPs) are maintained for all facilities (and
associated field operations) listed in Table 8-2. These procedures are incorporated into the
facility SPPPs. The procedures and proper implementation of them is evaluated as part of the
annual inspections.

8.6 Vehicle and Equipment Cleaning Operations

The City recognizes the negative impacts that municipal vehicle and equipment wash water
runoff can have on stormwater and, ultimately, surface waters. Municipal employees wash the
majority of vehicles and equipment at commercial or municipal vehicle wash facilities that drain
to the sanitary sewer system. Vehicle and equipment washing at municipal facilities continue to
be assessed during annual inspections at facilities listed in Table 8-2, where applicable.

8.7 Streets, Roads, and Public Parking Lots Maintenance

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Streets and parking lots can be a significant source of stormwater pollution and the City
implements various BMPs to best address polluted stormwater runoff from these sources, as
shown below:

• Street sweeping program;
• Adopt-A-Street program;
• Leaf and yard waste collection program;
• Trash receptacles along downtown streets;
• Trash receptacles and litter control activities at Park and Ride parking lots; and
• Public education to address polluted stormwater runoff from municipally-owned streets
and public parking lots.

Table 8-5 shows the data relative to this program for the report period.

Table 8-5: Streets/Roads and Parking Maintenance Program Results
Activity Results*
Streets/roads swept (miles)* 42,870
Streets/roads sweeping debris removed (tons)* 907
Yard waste collected (tons)* 51,054
Adopt-A-Street miles cleaned6. 402
Adopt-A-Street bags of trash collected6. 2,422
Adopt-A-Street bags of recyclables collected6. 262
* This data not included in summary data shown in Table 4-5
6. This data also shown in Table 4-3.

In addition, to address spills that may occur on municipal streets and in other areas as related to
the overall IDDE program, CMSWS maintains a 24-hour emergency response team that
responds to environmental emergencies. Members of the team act in an advisory role to the
Charlotte Fire Department (“CFD”) Hazmat Unit. The City also has contracts with two
environmental cleanup companies to respond to spills generated at municipal facilities and
operations and in cases within city limits where the spiller is unknown.

8.8 Municipal SCMs and MS4 System Operation and Maintenance

The City maintains an inventory of municipal structural SCMs which are inspected for proper
operation and maintenance at various frequencies based on the type of SCM. The inventory
continues to be updated as new SCMs are constructed. Routine maintenance activities for these
SCMs include:

• Mowing;
• Trash removal;
• Woody growth removal;
• Cattail removal; and
• Inlet and outlet clearing.

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The City also conducts extensive cleaning and maintenance of the MS4 system which includes,
but is not limited to:

• Catch basin cleaning (manually and with vacuum trucks);
• Storm drain top cleaning;
• Curb and gutter cleaning;
• Culvert/channel cleaning;
• Drainage structure installation and repair;
• Ditch reshaping; and
• Erosion control.

Table 8-6 shows the data relative to this program for the report period.

Table 8-6: Stormwater System Maintenance Program Results
Activity Results
Catch basins top cleaned (surface grates, inlets, etc.) 26,603
Catch basins cleaned (entire catch basin vacuumed out) 824
Stormwater pipelines cleaned (pipe vacuumed out) (feet) 8,395

8.9 Employee Staff Training at Municipal Facilities

Training is conducted for employees at all of the facilities listed in Table 8-2. The goal of
training is to inform employees of the actions necessary to reduce the discharge of pollutants
from their facilities/operations and protect surface water quality. Topics for this training include:

• Description of common pollutants, their sources and surface water quality impacts;
• Description of the actions that each facility should take to reduce discharges of
pollutants, with an emphasis on good housekeeping;
• Description of effective spill prevention measures that should be employed at each
facility;
• Discussion of typical pollution sources at municipal operations and specific actions that
should be taken to eliminate these sources and protect surface water quality;
• Review of the facility SWPPP, where applicable;
• Explanation of the potential negative consequences of failing to control pollutants at
facilities; and
• Overview of IDDE Program and how to report observed surface water quality
problems.

Table 8-7 shows the data relative to this program for the report period.

Table 8-7: Municipal Facility Employee Training Program Results
Activity Results
Training sessions conducted (in person) 43
Employees trained at sessions (in person) 500
Employees trained via on-line training module 656
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Total employees trained 1,156

8.10 Measurable Goals/Planned Activities for Future Program Years

Table 8-8 describes the various Pollution Prevention/Good Housekeeping Program BMPs and
the Measurable Goals and Planned Activities for Future Program Years for each BMP by permit
term year.

[THIS SPACE INTENTIONALLY BLANK]
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Table 8-8: BMP Measurable Goals for the Pollution Prevention/Good Housekeeping Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5+
Operation and maintenance program for
municipal facilities and operations.
Maintain and implement an operation and maintenance program for
municipal facilities owned and operated by the permittee that have
been determined by the permittee to have significant potential for
generating polluted stormwater runoff that has the ultimate goal of
preventing or reducing pollutant runoff.
Review and update Operation and Maintenance programs as
necessary. Continue operation and maintenance activities
per established procedures. (On-going, years 1 – 5+)
Site Pollution Prevention Plans for
municipal facilities and operations.
Maintain and implement Site Pollution Prevention Plans for municipal
facilities owned and operated by the permittee that have been
determined by the permittee to have significant potential for generating
polluted stormwater runoff that has the ultimate goal of preventing or
reducing pollutant runoff.
Review and update facility SWPPPs as necessary. Continue
implementation of SWPPPs. (On-going, years 1 – 5+)
Inspection and evaluation of municipal
facilities and operations.
Maintain an inventory of municipal facilities and operations owned
and operated by the permittee that have been determined by the
permittee to have significant potential for generating polluted
stormwater runoff, including the MS4 system and associated structural
SCMs, conduct inspections at facilities and operations owned and
operated by the permittee for potential sources of polluted runoff, the
stormwater controls, and conveyance systems, and evaluate the
sources, document deficiencies, plan corrective actions, implement
appropriate controls, and document the accomplishment of corrective
actions.
Review and update inventory of facilities for inspection.
Conduct inspections of applicable facilities and make
corrective actions where necessary. (On-going, years 1 – 5+)
Spill Response Procedures municipal
facilities and operations.
Maintain spill response procedures for municipal facilities and
operations owned and operated by the permittee that have been
determined by the permittee to have significant potential for generating
polluted stormwater runoff.
Review facility spill response procedures and update as
necessary. Continue implementation of procedures. (On-
going, years 1 – 5+)
Prevent or Minimize Contamination of
Stormwater Runoff from all areas used
for Vehicle and Equipment Cleaning
Describe measures that prevent or minimize contamination of the
stormwater runoff from all areas used for vehicle and equipment
cleaning, including fire stations that serve more than three fire trucks
and ambulances. Perform all cleaning operations indoors, cover the
cleaning operations, ensure wash water drains to the sanitary sewer
system, collect stormwater runoff from the cleaning area and providing
treatment or recycling, or other equivalent measures. If sanitary sewer
is not available to the facility and cleaning operations take place
outdoors, the cleaning operations shall take place on grassed or
graveled areas to prevent point source discharges of the wash water
into the storm drains or surface waters.
Review procedures for vehicle and equipment cleaning
operations and update as necessary. Ensure that corrective
actions are implemented where operations are found to not
be in compliance with the permit. (On-going, years 1 – 5+)
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Where cleaning operations cannot be performed as described above
and when operations are performed in the vicinity of a storm drainage
collection system, the drain is to be covered with a portable drain cover
during cleaning activities. Any excess standing water shall be
removed and properly handled prior to removing the drain cover.

Facilities that serve three or fewer fire trucks and ambulances and that
cannot comply with these requirements shall incorporate structural
measures during facility renovation.

Streets, roads, and public parking lots
maintenance
The permittee shall evaluate BMPs to reduce polluted stormwater
runoff from municipally-owned streets, roads, and public parking lots
within the corporate limits. Within 12 months of permit issuance, the
permittee must update its Stormwater Plan to include the BMPs
selected.

Evaluate various types
of BMPs that would
best address polluted
stormwater runoff
from municipally-
owned streets and
parking lots and select
BMPs based on the
evaluation by Feb 28,
2014.
None (years 2 – 5+)
Streets, roads, and public parking lots
maintenance
Within 24 months of permit issuance, the permittee must implement
BMPs selected to reduce polluted stormwater runoff from municipally -
owned streets, roads, and public parking lots identified by the
permittee in the Stormwater Plan.
None Implement
BMPs selected
from year one
evaluation by
Feb 28, 2015.
Continue to
implement
selected BMPs.
(On-going, years
3 – 5+)
Operation and Maintenance (O&M) for
municipally-owned or maintained
structural SCMs and the storm sewer
system (including catch basins, the
conveyance system, and structural
stormwater controls).
Within 12 months of permit issuance, the permittee shall develop and
implement an operation and maintenance program for structural SCMs
and the storm sewer system (including catch basins, the conveyance
system, and structural stormwater controls).

Continue to implement structural SCM operation,
maintenance, and inspection program. Continue operation
and maintenance program for the MS4 system. (On-going,
years 1 – 5+)
Staff training Maintain and implement a training plan that indicates when, how often,
who is required to be trained and what they are to be trained on.

For facilities included in the municipal facility inspection
program, conduct staff training on SWPPPs and Spill
Response Procedures according to the Training Plan. (On-
going, years 1 – 5+)
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8.11 Program Assessment

The measurable goals in Table 8-8 for the Prevention and Good Housekeeping Program were
successfully accomplished during the annual report period. Information in Section 8 provides
more detailed information about implementation efforts. Table 8-9 shows a summary of the
various items and corresponding data results for activities conducted under the program.

Table 8-9: Program Summary
MUNICIPAL GOOD HOUSEKEEPING PROGRAM FY2019 FY2020 FY2021 FY2022 FY2023 FY2024
New City-owned parcels reviewed for inventory 35 42 12
Municipal facilities inspected 32 33 537.
Municipal operation program evaluations 17 14 1
O & M improvement recommendations made 72 78 91
Municipal facility employee training sessions 86 18 43
Municipal facility employees trained 1,993 1,008 1,156
7. FY2021 inspections included 20 municipal fire stations which are only inspected once per permit term

Summary:

• Operation and maintenance activities for municipal facilities continued to be
implemented during FY2021. Such activities are included in facility SPPPs, and each
of the 33 facility SPPPs were reviewed and updated as part of annual facility
inspections and reviews;
• New properties purchased by the City in the previous year were evaluated for activities
and potential inclusion in the Municipal Good Housekeeping program. Twelve
properties were evaluated. A new vehicle and equipment maintenance facility being
constructed was added to the program. Inspections were conducted at 53 facilities
during FY2021 which included the 33 facilities conducted every year plus 20 fire
stations which are inspected once every 5 years. Inspection reports were issued to
facility Managers which pointed out any deficiencies and recommendations. For any
issues requiring follow-up, a corrective action documentation sheet was included in the
report and facility Managers were directed to conduct remedial activities, fill in the
sheet with actions taken and dates completed, and return them to CMSWS staff. A total
of 91 deficiencies and recommendations were identified during the inspections;
• Facility spill response procedures are included in facility SPPPs. The procedures were
reviewed and updated, as necessary, as part of SPPP reviews during FY2021. Staff
continued to maintain contracts with two spill response contractors and utilized their
services to clean up discharges as needed;
• Staff inspected vehicle and equipment wash areas as part of facility inspections. Best
practices and procedures are documented in facility SPPPs which are reviewed
annually. Staff did not identify any issues with vehicle and equipment washing during
FY2021;
• City staff continued to implement selected BMPs for public streets and parking lot
maintenance;
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• City staff continued to conduct inspections and maintenance of City-owned SCMs in
accordance with the SOP. During FY2021, a Long-Term Stewardship program
supervisor was hired to expand and improve upon long-term maintenance of CSWS
stormwater projects and City-owned SCMs; and
• Training about stormwater pollution prevention, good housekeeping, and spill response
procedures was provided in various forms to municipal staff to 1,156 employees.

Section 9: Program to Monitor and Control Pollutants in Stormwater
Discharges to Municipal Systems

During the annual report period, inspection and monitoring activities were conducted under the
Program to Monitor and Control Pollutants in Stormwater Discharges to Municipal Systems per
the SWMP. The following sub-sections explain:

• The BMPs implemented to meet program requirements;
• Measures of success;
• Future goals and planned activities; and
• Program assessment.

9.1 BMP Summary Table

Table 9-1 provides information concerning the BMPs implemented to fulfill the requirements of
the Industrial Facilities Program.

Table 9-1: BMP Summary Table for the Program to Monitor and Control Pollutants in
Stormwater Discharges to Municipal Systems.
BMP BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Maintain an
Inventory of
Industrial Facilities
Maintain an inventory of permitted hazardous
waste treatment, disposal, and recovery facilities,
industrial facilities that are subject to Section 313
of Title III of the Superfund Amendments and
Reauthorization Act of 1986 (SARA), industrial
facilities identified with an industrial activity
permitted to discharge stormwater to the
permittee’s MS4, or as identified as an illicit
discharge under the IDDE Program.

For the purposes of this permit, industrial activities
shall mean all permitted industrial activities as
defined in 40 CFR 122.26.

X X X X X Water Quality
Program
Manager
Inspection Program Identify priorities and inspection procedures. At a
minimum, priority facilities include those
identified above in subsection II.H.2.a.
X X X X X Water Quality
Program
Manager
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Evaluate Industrial
Facilities discharging
stormwater to the
City’s MS4
The Permittee is required to evaluate control
measures implemented at permitted hazardous
waste treatment, disposal, and recovery facilities,
industrial facilities that are subject to Section 313
of Title III of the Superfund Amendments and
Reauthorization Act of 1986 (SARA), industrial
facilities identified with an industrial activity
permitted to discharge stormwater to the
permittee’s MS4, or as identified as an illicit
discharge under the IDDE Program.

For permitted facilities, the municipality shall
establish procedures for reporting deficiencies and
non-compliance to the permitting agency. Where
compliance with an existing industrial stormwater
permit does not result in adequate control of
pollutants to the MS4, municipality will
recommend and document the need for permit
modifications or additions to the permit issuing
authority.

For the purposes of this permit, industrial activities
shall mean all permitted industrial activities as
defined in 40 CFR 122.26. For the purpose of this
permit, the Permittee is authorized to inspect the
permitted hazardous waste treatment, disposal, and
recovery facilities as an authorized representative
of the Director.
X X X X X Water Quality
Program
Manager

9.2 Industrial Facility Inventory

An inventory of facilities is maintained showing those facilities that discharge to the City’s MS4
and have the potential to discharge significant pollutant loads. The inventory is used to select
each year’s facilities for inspection and monitoring. Facilities included in the inventory fit into
one or more of the following categories:

• Hazardous waste TSD facility;
• SARA Title III facility (TRI reporter);
• NPDES Stormwater permitted facility;
• Stormwater No Exposure Certificate facility;
• Industrial Wastewater Pre-Treatment permitted facility; and
• Facilities identified as having an illicit discharge under the IDDE Program.

9.3 Industrial Facilities Inspection Program

The purpose of the Industrial Facilities Inspection program is to evaluate activities at industrial
facilities that may impact stormwater discharges and then work with identified problem facilities
to reduce stormwater pollution from the facility. Due to a history of stormwater pollution
problems found at vehicle maintenance facilities, staff inspect twenty (20) of those facilities
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annually as well. A written Prioritization Strategy provides guidance to staff for inspection
frequency of different types of industrial facilities based on a facility’s categorization of high,
medium, or low priority. An Industrial Facilities Inspection and Monitoring Procedures Manual
is also utilized to guide the overall program. Table 9-2 shows the data relative to this program
for the report period.

Table 9-2: Industrial Facility Program Results
Activity Results
Industrial facility inspections conducted 39
Vehicle maintenance facility inspections conducted 21
Industrial facilities monitored 8
Illicit discharges detected through this program 1. 1
SWPCO NOVs issued2. 2
Notices of Deficiency issued 1
1. This data also included in the total Illicit Discharges data shown in Table 5-15.
2. This data also included in the total NOVs data shown in Table 5-2.

9.3.1 Industrial Facilities Monitoring Program

The purpose of the Industrial Facilities Monitoring Program is to monitor stormwater runoff
from select industrial facilities and identify and correct pollution sources related to industrial
activities. Once monitoring is completed, a letter summarizing the results is sent to each
monitored facility. For facilities with elevated pollutant levels, recommendations are made to
improve outdoor operations, housekeeping, material storage practices, and other measures that
should result in reduced pollutant runoff. Staff refer to the Industrial Facility Monitoring
Follow-up SOP to guide actions following receipt of monitoring results.

Table 9-2 shows the number of facilities monitored during wet weather conditions for the report
period.

9.4 Evaluation Measures

The appropriate evaluation measures to reduce polluted discharges to the City’s MS4 are
industrial inspections and monitoring. Inspection letters note that the inspection is being
conducted to satisfy both State and City NPDES MS4 permit requirements. For permitted
facilities, inspection reports note completion of State-issued permit requirements such as annual
training, annual SPPP updates, and monitoring, and staff send a copy of the report to NCDEQ.
As pollution sources are identified through the inspection and monitoring program, CMSWS
works with the facility personnel, and NCDEQ as applicable, to eliminate the pollution sources.
When violations of SWPCO prohibitions and other applicable regulations are identified,
enforcement measures are implemented either by the City or NCDEQ, as applicable.

9.5 Measurable Goals/Planned Activities for Future Program Years

Table 9-3 describes the various Industrial Facilities Program BMPs and the Measurable Goals
and Planned Activities for Future Program Years for each BMP by permit term year.
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Table 9-3: BMP Measurable Goals for the Industrial Facilities Program.

BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5+
Maintain an
Inventory of
Industrial
Facilities
Maintain an inventory of permitted hazardous waste treatment, disposal, and
recovery facilities, industrial facilities that are subject to Section 313 of Title III of
the Superfund Amendments and Reauthorization Act of 1986 (SARA), industrial
facilities identified with an industrial activity permitted to discharge stormwat er to
the permittee’s MS4, or as identified as an illicit discharge under the IDDE
Program.

For the purposes of this permit, industrial activities shall mean all permitted
industrial activities as defined in 40 CFR 122.26.

Maintain and update the industrial facility inventory as needed.
(On-going, years 1 – 5+)
Inspection
Program
Identify priorities and inspection procedures. At a minimum, priority facilities
include those identified above in subsection II.H.2.a.
Review and update, as necessary, current Industrial Inspection
and Monitoring Procedures and develop an inspection
prioritization strategy. (On-going, years 1 – 5+)
Evaluate
Industrial
Facilities
discharging
stormwater to
the City’s MS4
The Permittee is required to evaluate control measures implemented at permitted
hazardous waste treatment, disposal, and recovery facilities, industrial facilities that
are subject to Section 313 of Title III of the Superfund Amendm ents and
Reauthorization Act of 1986 (SARA), industrial facilities identified with an
industrial activity permitted to discharge stormwater to the permittee’s MS4, or as
identified as an illicit discharge under the IDDE Program.

For permitted facilities, the municipality shall establish procedures for reporting
deficiencies and non-compliance to the permitting agency. Where compliance with
an existing industrial stormwater permit does not result in adequate control of
pollutants to the MS4, municipality will recommend and document the need for
permit modifications or additions to the permit issuing authority.

For the purposes of this permit, industrial activities shall mean all permitted
industrial activities as defined in 40 CFR 122.26. For the purpose of this permit, the
Permittee is authorized to inspect the permitted hazardous waste treatment,
disposal, and recovery facilities as an authorized representative of the Director.
Conduct inspection activities based on established procedures
and prioritization strategy at 50 facilities for years 1 and 2; and
40 facilities in years 3 -5+. Conduct stormwater runoff
monitoring at 10 facilities for years 1 and 2; and 8 facilities in
years 3 -5+.
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9.6 Program Assessment

The measurable goals in Table 9-3 for the Industrial Facilities and Monitoring Program were
successfully accomplished during the annual report period. Information in Section 9 provides
more detailed information about implementation efforts. Table 9-4 shows a summary of the
various items and corresponding data results for activities conducted under the program.

Table 9-4: Program Summary
INDUSTRIAL FACILITIES PROGRAM FY2019 FY2020 FY2021 FY2022 FY2023 FY2024
Master industrial inspection inventory sites 514 515 514
Facilities inspected* 63 62 60
Facilities monitored 12 9 8
Notices of Deficiency issued 15 4 1
*This data is a combination of industrial facilities and vehicle maintenance facilities.

Section 10: Water Quality Assessment and Monitoring Program

During the annual report period, monitoring activities were conducted per the Water Quality
Assessment and Monitoring program plan and the SWMP. The following sub-sections explain:

• The BMPs implemented to meet program requirements;
• Measures of success;
• Future goals and planned activities; and
• Program assessment.

10.1 BMP Summary Table

Table 10-1 provides information concerning the BMPs implemented to fulfill the requirements
of the Water Quality Assessment and Monitoring Program.

Table 10-1: BMP Summary Table for the Water Quality Assessment and Monitoring Program.
BMP BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Water Quality
Assessment and
Monitoring Plan
Maintain a Water Quality Assessment and
Monitoring Plan. The Plan shall include a schedule
for implementing the proposed assessment and
monitoring activities.

X X X X X Water Quality
Program
Manager
Water Quality
Monitoring
Maintain and implement the Water Quality
Assessment and Monitoring Plan submitted to
DWQ.

X X X X X Water Quality
Program
Manager

10.2 Water Quality Assessment and Monitoring Plan
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The City implements the Water Quality Assessment and Monitoring Plan that specifies the basic
surface water quality monitoring program and activities to be performed at specified stream sites
within the major watersheds in the City (Table 10-3). Monitoring is conducted for chemical and
physical parameters listed in Table 10-2 on a fixed interval monitoring basis.

Table 10-2: Water Quality Monitoring Parameters.
Parameter Sample Type Frequency (Minimum)
Fecal Coliform Grab Quarterly
E-Coli Grab Quarterly
Total Phosphorus Grab Quarterly
Nitrite + Nitrate Grab Quarterly
Total Kjeldahl Nitrogen Grab Quarterly
Ammonia Nitrogen Grab Quarterly
Total Suspended Solids Grab Quarterly
Turbidity Grab Quarterly
Copper Grab Quarterly
Zinc Grab Quarterly
Chromium Grab Quarterly
Lead Grab Quarterly
Dissolved Oxygen In Situ Quarterly
Temperature In Situ Quarterly
Conductivity In Situ Quarterly
pH In Situ Quarterly

Table 10-3: Description of City of Charlotte Surface Water Quality Monitoring Sites.
Site # Stream Location
MY11B Mallard Creek Pavilion Blvd Bridge, S. of US Hwy 29
MY12B Back Creek Stream location, off of Wentwater Street, near Caldwell Rd.
MY13 Reedy Creek Reedy Creek Rd. Bridge, S. of Plaza Rd. Ext.
MY7B McKee Creek Reedy Creek Rd. Bridge, S. of Harrisburg Rd.
MC14A Long Creek Pine Island Dr. at End of Street at Golf Course
MC17 Paw Creek Hwy 74 Culvert, Between Sam Wilson & Little Rock Rd.
MC22A Irwin Creek Westmont Dr. Bridge, at Irwin Creek WWTP
MC27 Sugar Creek Hwy. 51 Bridge, E. of Downs Rd.
MC38 McAlpine Creek Sardis Rd. Bridge, Between Sardis Ln. & Sardis Rd. N.
MC40A Four Mile Creek Elm Ln. Bridge, S. of Hwy. 51
MC42 McMullen Creek Sharon View Rd. Bridge, Between Sharon Rd. & Colony Rd.
MC45 McAlpine Creek McAlpine Creek WWTP
MC47A Steele Creek Carowinds Blvd. Culvert, W. of Carowinds Amusement Park
MC49A Little Sugar Creek Hwy. 51 Bridge, W. of Carolina Place Mall
MC51 Six Mile Creek Marvin Rd. Bridge, S. of Ardrey Kell Rd.

10.3 Surface Water Quality Monitoring Implementation

The City conducts the fixed interval monitoring program at the monitoring sites listed in Table
10-3. Following completion of monitoring activities at the end of each permit reporting year
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(June 30th), monitoring data is assessed to determine whether surface water quality trends are
apparent. This can help to gauge the combined effectiveness of NPDES MS4 program efforts.
Table 10-4 shows the data relative to this program for the report period.

Table 10-4: Surface Water Quality Monitoring Program Results
Activity Results
Stream sites monitored 23
Sampling events 12
Stream samples collected 276
Laboratory sample analyses conducted 3,404
Stream physical measurements conducted (DO, Temp, pH, Cond) 1,104
Illicit discharges detected through this program1. 0
1. This data also included in the total Illicit Discharges data shown in Table 5-15.

10.4 Water Quality Assessment and Monitoring Plan Revisions

The City has reviewed the basic monitoring program plan and data generated during the report
period and proposes no changes to the plan.

10.5 Measurable Goals/Planned Activities for Future Program Years
Table 10-5 describes the Water Quality Assessment and Monitoring Program BMPs and the
Measurable Goals and Planned Activities for Future Program Years for each BMP by permit
term year.

[THIS SPACE INTENTIONALLY BLANK]

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Table 10-5: BMP Measurable Goals for the Water Quality Assessment and Monitoring Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5
Water Quality
Assessment and
Monitoring Plan
Maintain a Water Quality Assessment
and Monitoring Plan. The Plan shall
include a schedule for implementing
the proposed assessment and
monitoring activities.
Maintain the WQ Assessment & Monitoring Plan and update as necessary. (On-going, years 1 – 5+)
Water Quality
Monitoring
Maintain and implement the Water
Quality Assessment and Monitoring
Plan submitted to DWQ.

Maintain and implement the monitoring plan and conduct WQ assessment and monitoring activi ties per the plan.
(On-going, years 1 – 5+)
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10.6 Program Assessment

The measurable goals in Table 10-5 for the Water Quality Assessment and Monitoring Program
were successfully accomplished during the annual report period. Information in Section 10
provides more detailed information about implementation efforts. Table 10-6 shows a summary
of the various items and corresponding data results for activities conducted under the program.

Table 10-6: Program Summary
SURFACE WATER QUALITY MONITORING PROGRAM FY2019 FY2020 FY2021 FY2022 FY2023 FY2024
Stream sites monitored 23 23 23
Stream samples collected 276 253 276
Laboratory sample analyses conducted 3,312 3,036 3,312
Stream physical measurements (DO, Temp, pH, Cond) 1,104 1,012 1,104

Section 11: Total Maximum Daily Load (TMDL) Program

The City continued to fulfill the NPDES MS4 permit requirements regarding the TMDL
Program by implementing the following BMPs within the six minimum NPDES MS4 permit
measures. The BMPs are designed to reduce the TMDL pollutant of concern within the TMDL
assigned MS4 NPDES regulated waste load allocation to the maximum extent practicable (MEP)
within the impaired water bodies in the City’s jurisdiction that are subject to approved TMDLs.
The following sub-sections explain:

• The BMPs implemented to meet program requirements;
• Measures of success;
• Future goals and planned activities; and
• Program assessment.

11.1 BMP Summary Table

Table 11-1 provides information concerning the BMPs implemented to fulfill the Total
Maximum Daily Load (TMDL) Program requirements. These BMPs pertain to the City’s
existing TMDL watershed plan that was developed under the City’s previous NPDES MS4
permit.

Table 11-1: BMP Summary Table for Total Maximum Daily Load (TMDL) Program.
BMP

BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Identify, describe
and map
watershed, outfalls,
and streams

Within 24 months the permittee shall prepare a plan
that:
• Identifies the watershed(s) subject to an
approved TMDL with an approved Waste Load
Allocation (WLAs) assigned to the permittee,
• Includes a description of the watershed(s),
X X X X X Water Quality
Program
Manager
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• Includes a map of watershed(s) showing streams
& outfalls
• Identifies the locations of currently known major
outfalls within its corporate limits with the
potential of contributing to the cause(s) of the
impairment to the impaired segments, to their
tributaries, and to segments and tributaries
within the watershed contributing to the
impaired segments and
• Includes a schedule to discover and locate other
major outfalls within its corporate limits that
may be contributing to the cause of the
impairment to the impaired stream segments, to
their tributaries, and to segments and tributaries
within the watershed contributing to the
impaired segments.
Existing measures

Within 24 months the Permittee’s plan:
• Shall describe existing measures being
implemented by the Permittee designed to
achieve the MS4’s NPDES WLA and to reduce
the TMDL pollutant of concern to the MEP
within the watershed to which the TMDL
applies; and
• Provide an explanation as to how those measures
are designed to reduce the TMDL pollutant of
concern.
• The Permittee shall continue to implement the
existing measures until notified by DWQ.
X X X X X Water Quality
Program
Manager
Assessment of
available
monitoring data
Within 24 months the permittee’s plan shall include
an assessment of available monitoring data. Where
long-term data is available, this assessment should
include an analysis of the data to show trends.
X X X X X Water Quality
Program
Manager
Monitoring Plan

Within 36 months the permittee shall develop and
submit to the Division a Monitoring Plan for the
permittee’s assigned NPDES regulated WLA as
specified in the TMDL. The permittee shall maintain
and implement the Monitoring Plan as additional
outfalls are identified and as accumulating data may
suggest. Following any review and comment by the
Division the permittee shall incorporate any
necessary changes to monitoring plan and initiate the
plan within six months. Modifications to the
monitoring plan shall be approved by the Division.
Upon request, the requirement to develop a
Monitoring Plan may be waived by the Division if
the existing and proposed measures are determined
to be adequate to achieve the MS4’s NPDES WLA
to MEP within the watershed to which the TMDL
applies.

X X X X X Water Quality
Program
Manager
Additional
Measures
Within 36 months the permittee’s plan shall:
• Describe additional measures to be
implemented by the permittee designed to
X X X X X Water Quality
Program
Manager
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achieve the permittee’s MS4’s NPDES
WLA and to reduce the TMDL pollutant of
concern to the MEP within the watershed to
which the TMDL applies; and
• Provide an explanation as to how those
measures are designed to achieve the
permittee’s MS4’s NPDES regulated WLA
to the MEP within the watershed to which
the TMDL applies.
Implementation
Plan
Within 48 months the permittee’s plan shall:
• Describe the measures to be implemented
within the remainder of the permit term
designed to achieve the MS4’s NPDES
WLA and to reduce the TMDL pollutant of
concern to the MEP and
• Identify a schedule, subject to DWQ
approval, for completing the activities.
X X X X X Water Quality
Program
Manager
Incremental
Success

The permittee’s plan must outline ways to track and
report successes designed to achieve the MS4’s
NPDES regulated WLA and to reduce the TMDL
pollutant of concern to MEP within the watershed to
which the TMDL applies.
X X X X X Water Quality
Program
Manager
Reporting The permittee shall conduct and submit to the
Division an annual assessment of the program
designed to achieve the MS4’s NPDES WLA and to
reduce the TMDL pollutant of concern to the MEP
within the watershed to which the TMDL applies.
Any monitoring data and information generated from
the previous year are to be submitted with each
annual report.
X X X X X Water Quality
Program
Manager

11.2 TMDL Watershed Plan

The City maintains a TMDL watershed plan for the applicable identified watersheds that are
subject to an approved TMDL within the City’s jurisdiction as defined in Part II, Sec J.1 and J.2
within the City’s current NPDES MS4 permit. The plan utilizes BMPs as outlined in the permit
within the six minimum NPDES MS4 permit measures that are designed to reduce the TMDL
pollutant of concern within the TMDL assigned MS4 NPDES regulated waste load allocation to
the MEP. In addition, per Part II, Sec J.3 within the City’s current NPDES MS4 permit, the plan
addresses the pollutant of concern for approved TMDLs that do not assign a waste load
allocation for the pollutant of concern to the municipal stormwater system by evaluating
strategies and tailoring BMPs within the scope of the six minimum permit measures to address
the pollutant of concern to the MEP in the watershed(s) to which the TMDL applies. The plan is
available for review on the City’s website:
https://charlottenc.gov/StormWater/SurfaceWaterQuality/Documents/TMDL%20Watershed%20Plan%20
FY2021%20-%20FINAL.pdf

11.2.1 TMDL Watershed Identification

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Currently, there are seven approved TMDLs applicable to multiple streams in the City, some of
which also include portions of Mecklenburg County. Table 11-2 provides information on these
TMDLs and affected watersheds. Additional information concerning these TMDLs is provided
in the City’s TMDL Watershed Plan referenced in section 11.2.

Table 11-2: City of Charlotte Streams with Approved TMDLs
Receiving Stream
Name
WQ
Classification
TMDL Approved TMDL Pollutant of Concern
Irwin Creek C February 1996 Dissolved Oxygen
Little Sugar Creek C February 1996 Dissolved Oxygen
McAlpine Creek C February 1996 Dissolved Oxygen
Lake Wylie WS-IV, B, CA February 1996 Chlorophyll-a
Irwin Creek C March 2002 Fecal Coliform
Little Sugar Creek C March 2002 Fecal Coliform
McAlpine Creek C March 2002 Fecal Coliform
Sugar Creek C March 2002 Fecal Coliform
McKee Creek C August 2003 Fecal Coliform
Irwin Creek C February 2005 Turbidity
Little Sugar Creek C February 2005 Turbidity
Long Creek C February 2005 Turbidity
McAlpine Creek C February 2005 Turbidity
Sugar Creek C February 2005 Turbidity
Steele Creek C May 2007 Fecal Coliform
Statewide All October 2012 Mercury
Source: 2021 NCDEQ-Division of Water Resources website:
https://deq.nc.gov/about/divisions/water-resources/planning/modeling-assessment/tmdls/draft-and-approved-
tmdls#Catawba
https://deq.nc.gov/about/divisions/water-resources/planning/modeling-assessment/tmdls/draft-and-approved-
tmdls#Yadkin

11.2.2 Outfall Identification for TMDL Watersheds

As part of the development of the TMDL watershed plan the City developed an existing outfall
inventory for the applicable TMDL watersheds. This inventory is maintained using a GIS
coverage to show existing outfalls within the TMDL watersheds that have the potential of
contributing to the cause(s) of the impairment to the impaired segments, to their tributaries, and
to segments and tributaries within the watershed contributing to the impaired segments.
Additional information on the outfall inventory is provided in the City’s TMDL Watershed Plan
referenced in section 11.2.

11.3 Identification of Existing Measures

As part of the development of the TMDL watershed plan the City identified existing programs
and measures which are currently in use within the City’s NPDES MS4 permit and surface water
quality monitoring programs that are designed to address the assigned MS4 NPDES regulated
waste load allocation (“WLA”) and to reduce the TMDL pollutant of concern to the MEP within
the watershed to which the TMDL applies. Additional information on the existing measures is
provided in the City’s TMDL Watershed Plan referenced in section 11.2.
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11.4 Assessment of Available Monitoring Data

Fixed interval surface water quality data collected from 2006 through 2021 was analyzed for all
applicable TMDL watersheds and pollutants of concern in the City and County. These data help
to illustrate surface water quality trends in relation to the NC surface water quality standards.
The City’s current NPDES MS4 permit, effective October 10, 2018, states that the “The
permittee is not responsible for attaining water quality standards (“WQS”). The Division expects
attaining WQS will only be achieved through reduction from all point and nonpoint source
contributors identified in the approved TMDL.” It is infeasible to monitor every MS4
stormwater outfall to determine how progress is being made toward achieving MS4 NPDES
WLAs; therefore, the City utilizes fixed interval surface water data to investigate surface water
quality trends. The data presented below, while illustrating how in-stream surface water quality
has changed over time, unfortunately are not able to distinguish MS4 contributions from other
point and nonpoint sources that are not under the control of the MS4. Consequently, increases in
surface water contaminants observed in the data do not necessarily indicate that MS4
contributions are also increasing.

11.4.1 Fecal Coliform

Data from the six watersheds listed as being subject to fecal coliform TMDLs in Table 11-2 are
discussed in this sub-section. Of the six watersheds listed in Table 11-2, a MS4 NPDES WLA
was only developed for McKee and Steele Creeks. According to Part II, Section J.3 of the City’s
NPDES MS4 permit, for approved TMDLs where a MS4 NPDES WLA for the pollutant of
concern is not assigned to the municipal stormwater system, the Permittee is still required to
“evaluate strategies and tailor BMPs within the scope of the six minimum permit measures to
address the pollutant of concern in the watershed(s) to which the TMDL applies.” Watersheds
with and without MS4 WLAs are discussed in the subsections below.

11.4.1.1 McKee Creek

Fixed interval stream data for fecal coliform was collected at the CMSWS monitoring site
MY7B on McKee Creek. From July 2006 through June 2021, a total of 182 samples were
collected under the fixed interval monitoring program (Figure 11-1). Of these, 57% exceeded
the 400 cfu/100mL State standard with 90% confidence. Exceedances tended to be more
frequent and more extreme under wet weather influenced sampling conditions (meaning some
precipitation within the County in the 72-hour preceding the sampling event); however,
exceedances did occur under both ambient and wet weather influenced conditions.

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Figure 11-1: McKee Creek –MY7B - Overall Monitoring Data

11.4.1.2 Steele Creek Watershed

Fixed interval stream data for fecal coliform were collected at the CMSWS monitoring site
MC47A on Steele Creek. From July 2006 through June 2021, a total of 193 samples were
collected under the fixed interval monitoring program (Figure 11-2). Of these, 52% exceeded
the 400 cfu/100mL State standard with 90% confidence. Exceedances tended to be more
frequent and more extreme under wet weather influenced sampling conditions (meaning some
precipitation within the County in the 72-hour preceding the sampling event); however,
exceedances did occur under both ambient and wet weather influenced conditions.

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Figure 11-2: Steele Creek –MC47A - Overall Monitoring Data

11.4.1.3 Sugar/Irwin Creek Watershed

There are two fixed interval monitoring locations in the Sugar Creek watershed, MC27 on Sugar
Creek southern Mecklenburg County, and MC22A on Irwin Creek just before its confluence with
Sugar Creek. An assessment of available watershed and surface water quality data was
conducted utilizing fixed interval stream data for fecal coliform collected at these two
monitoring locations.

From July 2006 through June 2021, a total of 188 samples were collected at MC27 under the
fixed interval monitoring program (Figure 11-3). Of these, 42% exceeded the 400 cfu/100mL
State standard with 90% confidence. Exceedances tended to be more frequent and more extreme
under wet weather influenced sampling conditions (meaning some precipitation within the
County in the 72-hour preceding the sampling event); however, exceedances did occur under
both ambient and wet weather influenced conditions.

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Figure 11-3: Sugar Creek –MC27 - Overall Monitoring Data

During the same period, a total of 184 samples were collected at MC22A under the fixed interval
monitoring program (Figure 11-4). Of these, 47% exceeded the 400 cfu/100mL State standard
with 90% confidence. Exceedances tended to be more frequent and more extreme under wet
weather influenced sampling conditions (meaning some precipitation within the County in the
72-hour preceding the sampling event); however, exceedances did occur under both ambient and
wet weather influenced conditions.

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Figure 11-4: Irwin Creek –MC22A - Overall Monitoring Data

11.4.1.4 Little Sugar Creek Watershed

There are two monitoring locations on Little Sugar Creek, MC49A in southern Mecklenburg
County just outside the City, and MC29A-1 just downstream of downtown area of the City. An
initial assessment of available watershed and surface water quality data was conducted utilizing
fixed interval stream data for fecal coliform collected at these two monitoring locations.

From July 2006 through June 2021, a total of 189 samples were collected at MC49A under the
fixed interval monitoring program (Figure 11-5). Of these, 51% exceeded the 400 cfu/100mL
State standard with 90% confidence. Exceedances tended to be more frequent and more extreme
under wet weather influenced sampling conditions (meaning some precipitation within the
County in the 72-hour preceding the sampling event); however, exceedances did occur under
both ambient and wet weather influenced conditions.

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Figure 11-5: Little Sugar Creek –MC49A - Overall Monitoring Data

A total of 184 samples have been collected at MC29A-1 over this period under the fixed interval
monitoring program (Figure 11-6). Of these, 79% exceeded the 400 cfu/100mL State standard
with 90% confidence. Exceedances tended to be more frequent and more extreme under wet
weather influenced sampling conditions (meaning some precipitation within the County in the
72-hour preceding the sampling event); however, exceedances did occur under both ambient and
wet weather influenced conditions.

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Figure 11-6: Little Sugar Creek –MC29A-1 - Overall Monitoring Data

11.4.1.5 McAlpine Creek Watershed

There are two monitoring locations on McAlpine Creek, MC45B just downstream of the North
Carolina/South Carolina border, and MC38 downstream of the confluence with Campbell Creek
and Irvins Creek. An initial assessment of available watershed and surface water quality data
was conducted utilizing fixed interval stream data for fecal coliform collected at these two
monitoring locations.

From July 2006 through June 2021, a total of 183 samples were collected at MC45B under the
fixed interval monitoring program (Figure 11-7). Of these, 36% exceeded the 400 cfu/100mL
State standard with 90% confidence. Exceedances tended to be much more frequent under wet
weather influenced sampling conditions (meaning some precipitation within the County in the
72-hour preceding the sampling event); however, exceedances did occur under both ambient and
wet weather influenced conditions.

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Figure 11-7: McAlpine Creek –MC45B - Overall Monitoring Data

A total of 189 samples have been collected at MC38 over this period under the fixed interval
monitoring program (Figure 11-8). Of these, 48% exceeded the 400 cfu/100mL State standard
with 90% confidence. Exceedances tended to be much more frequent and more extreme under
wet weather influenced sampling conditions (meaning some precipitation within the County in
the 72-hour preceding the sampling event); however, exceedances did occur under both ambient
and wet weather influenced conditions.

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Figure 11-8: McAlpine Creek –MC38 - Overall Monitoring Data

11.4.1.6 Fecal Coliform Summary

The State standard for fecal coliform is exceeded by more than 10% with 90% confidence for all
watersheds with a fecal coliform TMDL identified above, based on fixed interval data collected
between 2006 and 2021. These exceedances are more common in wet weather influenced
conditions, but exceedances also occurred during ambient conditions in each of these watersheds.
Since exceedance rates are highly influenced by wet weather, long term variations in the
exceedance rates should account for how many samples in a given year are influenced by wet
weather conditions. A higher percentage of wet weather events on fixed interval sampling days
is expected to result in a higher percentage of samples that exceed surface water quality
standards. Since “wet weather” is defined as at least 0.1 inches of rainfall recorded anywhere in
the City of Charlotte/Mecklenburg County in the 72 hours prior to sampling, future analysis may
also attempt to utilize rain gages in closer proximity to each monitoring station to more
accurately verify whether a sample was influenced by wet weather conditions, as rainfall in one
part of the City/County does not necessarily mean it is raining everywhere in the City/County.

11.4.2 Turbidity

As discussed in sub-section 11.2, the turbidity TMDL developed in 2005 included five Charlotte-
Mecklenburg watersheds but only developed a WLA for turbidity for Long Creek since the
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surface water quality data assessment performed for the TMDL demonstrated that the remaining
four watersheds had less than a 10% exceedance rate of the 50 NTU State standard. Therefore,
this sub-section includes an assessment of turbidity data only for Long Creek.

11.4.2.1 Long Creek Watershed

An initial assessment of available watershed and surface water quality data was conducted
utilizing stream data for turbidity collected at the CMSWS monitoring site MC14A on Long
Creek. From July 2006 through June 2021, a total of 178 samples were collected under the fixed
interval monitoring program (Figure 11-9), with 16% exceeding the 50 NTU State standard with
90% confidence. These exceedances all occurred under wet weather conditions.

Figure 11-9: Long Creek –MC14A - Overall Monitoring Data

11.4.3 Dissolved Oxygen

As stated in sub-section 11.2, the 1996 dissolved oxygen (“DO”) TMDL for Irwin Creek,
McAlpine Creek, and Little Sugar Creek did not include a MS4 NPDES WLA. Nevertheless,
since the City’s NPDES MS4 permit states in Part II, Section J.3, for approved TMDLs where a
MS4 NPDES WLA for the pollutant of concern is not assigned to the MS4, the Permittee is still
required to “evaluate strategies and tailor BMPs within the scope of the six minimum permit
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measures to address the pollutant of concern in the watershed(s) to which the TMDL applies.”
For this reason, the dissolved oxygen data is provided below in Figures 11-10 through 11-14.

Unlike the other parameters, for dissolved oxygen the State standard is violated when
concentrations go below the standard rather than exceeding the standard. Based on the fixed
interval sampling conducted between July 2006 and June 2021, only one sample collected from a
TMDL watershed was lower than the instantaneous State standard of 4 mg/L. On October 10,
2017, a value of 3.81 mg/L was recorded at McAlpine Creek (MC38). No other sample violated
the standard during this period of record. The 2018 NC Integrated Report categorizes each of
these watersheds as 1i for DO, meaning that they have a TMDL but are not impaired and are
supporting their designated uses.

Figure 11-10: Irwin Creek–MC22A - Overall Monitoring Data

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Figure 11-11: McAlpine Creek –MC45B - Overall Monitoring Data

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Figure 11-12: McAlpine Creek –MC38 - Overall Monitoring Data

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Figure 11-13: Little Sugar Creek –MC49A - Overall Monitoring Data

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Figure 11-14: Little Sugar Creek –MC29A-1 – Overall Monitoring Data

11.4.4 Chlorophyll a

As stated in sub-section 11.2, Mecklenburg County is responsible for providing annual
assessment reports for the Lake Wylie chlorophyll-a TMDL under their NPDES MS4 permit
program.

11.4.5 Mercury

NCDEQ did not consider it necessary to include an MS4 NPDES WLA for mercury in their
statewide TMDL. For this reason, mercury data is not analyzed under the City’s TMDL
Watershed Plan.

11.5 Monitoring Plan for Assigned MS4 NPDES Regulated Waste Load Allocation

As part of the TMDL watershed plan the City developed a monitoring plan for each pollutant of
concern with an assigned MS4 NPDES regulated WLA within each watershed with an approved
TMDL within the City’s jurisdiction. The purpose of the monitoring plan is to guide activities
for data collection and assessment of pollutants of concern as well as to evaluate the
effectiveness of achieving the regulated waste load allocation (WLA) identified within the
TMDL. In developing the monitoring plan, sample locations were selected to assess surface
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water quality conditions within each TMDL watershed. Additional information concerning the
monitoring plan is provided in the City’s TMDL Watershed Plan referenced in section 11.2.

11.6 Identification of Additional Measures

As part of the TMDL watershed plan, the City identified additional measures for implementation
within the City’s MS4 permit program that are designed to achieve the assigned MS4 NPDES
regulated WLA and to reduce the TMDL pollutant of concern to the MEP within the watershed
to which the TMDL applies. The plan also discusses how the additional measures are designed
to reduce the TMDL pollutant of concern. Additional information concerning these measures is
provided in the City’s TMDL Watershed Plan referenced in section 11.2.

11.7 Implementation of Additional Measures

The TMDL watershed plan was updated to discuss the implementation of the additional
programs and measures identified in sub-section 11.6. Additional information concerning these
measures is provided in the City’s TMDL Watershed Plan referenced in section 11.2 above.

11.8 Tracking Incremental Success

BMP data parameters were identified to track incremental success within the TMDL watershed
plan. These parameters and corresponding data for the report period are shown in sub-section
11.10 below.

11.9 Measurable Goals

Table 11-3 describes the various Total Maximum Daily Load (TMDL) Program BMPs and the
Measurable Goals for each BMP by permit term year. These BMPs pertain to the City’s existing
TMDL watershed plan that was developed under the City’s previous NPDES MS4 permit.

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Table 11-3: BMP Measurable Goals for Total Maximum Daily Load (TMDL) Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5+
Identify, describe
and map
watershed, outfalls,
and streams

Within 24 months the permittee shall prepare a plan that:
• Identifies the watershed(s) subject to an approved
TMDL with an approved Waste Load Allocation
(WLAs) assigned to the permittee,
• Includes a description of the watershed(s),
• Includes a map of watershed(s) showing streams &
outfalls
• Identifies the locations of currently known major
outfalls within its corporate limits with the potential of
contributing to the cause(s) of the impairment to the
impaired segments, to their tributaries, and to
segments and tributaries within the watershed
contributing to the impaired segments and
• Includes a schedule to discover and locate other major
outfalls within its corporate limits that may be
contributing to the cause of the impairment to the
impaired stream segments, to their tributaries, and to
segments and tributaries within the watershed
contributing to the impaired segments.
None Develop TMDL
Watershed Plan
per requirements
of the MS4
permit by Feb
28, 2015.
Update TMDL Watershed Plan as necessary. (On-going, years
3 – 5+)
Existing measures

Within 24 months the Permittee’s plan:
• Shall describe existing measures being implemented
by the Permittee designed to achieve the MS4’s
NPDES WLA and to reduce the TMDL pollutant of
concern to the MEP within the watershed to which the
TMDL applies; and
• Provide an explanation as to how those measures are
designed to reduce the TMDL pollutant of concern.
• The Permittee shall continue to implement the existing
measures until notified by DWQ.
None Identify existing
measures within
TMDL plan by
Feb 28, 2015.
Continue to implement existing measures per TMDL plan.
(On-going, years 3 – 5+)
Assessment of
available
monitoring data
Within 24 months the permittee’s plan shall include an
assessment of available monitoring data. Where long-term
data is available, this assessment should include an
analysis of the data to show trends.

None Conduct a
review and
assessment of
available
monitoring data
by Feb 28, 2015.
Continue to review and assess monitoring data as it becomes
available. (On-going, years 3 – 5+)
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Monitoring Plan

Within 36 months the permittee shall develop and submit
to the Division a Monitoring Plan for the permittee’s
assigned NPDES regulated WLA as specified in the
TMDL. The permittee shall maintain and implement the
Monitoring Plan as additional outfalls are identified and as
accumulating data may suggest. Following any review and
comment by the Division the permittee shall incorporate
any necessary changes to monitoring plan and initiate the
plan within six months. Modifications to the monitoring
plan shall be approved by the Division. Upon request, the
requirement to develop a Monitoring Plan may be waived
by the Division if the existing and proposed measures are
determined to be adequate to achieve the MS4’s NPDES
WLA to MEP within the watershed to which the TMDL
applies.

None None Develop
monitoring
plan for each
TMDL
watershed for
the TMDL
pollutants of
concern by
Feb 28, 2016.
Complete monitoring
activities specified in
the plan by June 30,
2017. Assess
monitoring data
collected under the
monitoring plan to
determine
effectiveness of
Water Quality
Programs by
December 31, 2017.
Update monitoring
plan as necessary
based on data review
and assessment
activities.

Complete monitoring
activities specified in
the plan by June 30,
2018. Assess
monitoring data
collected under the
monitoring plan to
determine
effectiveness of
Water Quality
Programs by
December 31, 2018.
Update monitoring
plan as necessary
based on data review
and assessment
activities.

Additional
Measures
Within 36 months the permittee’s plan shall:
• Describe additional measures to be implemented
by the permittee designed to achieve the
permittee’s MS4’s NPDES WLA and to reduce
the TMDL pollutant of concern to the MEP within
the watershed to which the TMDL applies; and
• Provide an explanation as to how those measures
are designed to achieve the permittee’s MS4’s
NPDES regulated WLA to the MEP within the
watershed to which the TMDL applies.

None None Determine
additional
measures that
may be needed
to achieve
assigned MS4
NPDES
regulated
WLA and
address TMDL
pollutant of
concern by
Feb 28, 2016.
Continue to evaluate and update additional
measures per TMDL plan, as needed. (On-
going, years 4 – 5+)
Implementation
Plan
Within 48 months the permittee’s plan shall:
• Describe the measures to be implemented within
the remainder of the permit term designed to
achieve the MS4’s NPDES WLA and to reduce
the TMDL pollutant of concern to the MEP and
• Identify a schedule, subject to DWQ approval, for
completing the activities.

None None None Develop an
implementation plan
for identified
additional measures
that may be needed to
achieve assigned
MS4 NPDES
regulated WLA and
address TMDL
Continue to
implement additional
measures per the
plan.
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pollutant of concern
by Feb 28, 2017.
Incremental
Success

The permittee’s plan must outline ways to track and report
successes designed to achieve the MS4’s NPDES regulated
WLA and to reduce the TMDL pollutant of concern to
MEP within the watershed to which the TMDL applies.

None None None Develop a
methodology to track
and report data and
successes for
identified additional
measures that may be
needed to achieve
assigned MS4
NPDES regulated
WLA and address
TMDL pollutant of
concern by June 30,
2017.
Continue to track and
report successes per
the plan.
Reporting The permittee shall conduct and submit to the Division an
annual assessment of the program designed to achieve the
MS4’s NPDES WLA and to reduce the TMDL pollutant of
concern to the MEP within the watershed to which the
TMDL applies. Any monitoring data and information
generated from the previous year are to be submitted with
each annual report.

None Prepare an annual assessment of activities and data analysis for the TMDL
watershed plan. Provide this information in the NPDES MS4 permit annual report.
(On-going, years 2 – 5+)
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11.10 Program Assessment and Reporting

The overall TMDL Program and Watershed Plan were successfully accomplished during the
annual report period. Table 11-4 shows a summary of the various BMPs implemented and
corresponding data results per TMDL watershed for the report period. BMPs that apply to the
City or a program as a whole, such as television advertisements, cannot be differentiated by
watershed and are therefore reported as “Citywide.” Additional information concerning these
BMPs is provided in the City’s TMDL Watershed Plan referenced in sub-section 11.2.

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Table 11-4: TMDL Program Summary for FY2021
TMDL WATERSHED BMP Citywide Irwin Lake Wylie Little Sugar Long McAlpine McKee Steele Sugar
Public Education and Outreach
Television advertising spots 310
Radio advertising spots 353
Social media posts 986
Social media engagements 14,819
Public requests to stormwater hotline – WQ related 445
School presentations 2 3 4 2 4 01. 01. 6
Students educated at school presentations 16 221 121 148 141 01. 01. 215
Public presentations 29
Citizens educated at public presentations 1,211
Public events 5
Attendees interacted with at public events 50
Website page views 417,437
Website unique page views 176,924
Utility bill inserts 152,981 64,881 316,633 86,535 334,394 11,506 48,566 62,719
CMCSI education workshops conducted (in-person) 0
Persons trained on CMCSI 257
Environmental notices and brochures distributed 14
Flow Free (Fats Oils & Grease-FOG) brochures distributed 3,333
Flow Free (FOG) presentations 2
Citizens educated during Flow Free (FOG) presentations 160
1. Activity not conducted in this watershed during fiscal year 2021.

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TMDL WATERSHED BMP Citywide Irwin Lake Wylie Little Sugar Long McAlpine McKee Steele Sugar
Public Involvement
Storm drains marked 261 01. 85 95 37 01. 55 53
Adopt-A-Stream trash removed (lbs.) 11,779 01. 25,246 01. 4,905 01. 900 2,999
Adopt-A-Stream miles cleaned 17 01. 49 01. 26 01. 0.35 9
Big Spring Clean trash removed (lbs.) 01. 01. 01. 01. 01. 01. 01. 01.
Big Spring Clean stream miles cleaned 01. 01. 01. 01. 01. 01. 01. 01.
Volunteer Monitoring samples collected 4 01. 45 01. 13 01. 22 01.
Volunteer Monitoring visual observations 4 01. 21 01. 01. 01. 01. 01.
Trees planted during tree planting volunteer events 245
Adopt-A-Street bags of trash collected 2,422
Adopt-A-Street bags of recyclables collected 262 Adopt-A-Street miles cleaned 402
1. Activity not conducted in this watershed during fiscal year 2021.

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TMDL WATERSHED BMP Citywide Irwin Lake Wylie Little Sugar Long McAlpine McKee Steele Sugar
Illicit Discharge Detection and Elimination (IDDE)
Stream walk miles inspected 74 01. 01. 92 01. 18 01. 01.
Stream walk outfalls inspected 196 01. 01. 50 01. 64 01. 01.
Dry weather flows detected 69 01. 01. 5 01. 2 01. 01.
Dry weather flows sampled 8 01. 01. 01. 01. 1 01. 01.
Stream walk IDDE problems detected/corrected 8 01. 01. 5 01. 1 01. 01.
Multi-family sewer system inspections 1 01. 27 01. 13 01. 01. 4
Multi-family community personnel educated 50
Stormwater pollution ordinance violations/NOVs issued 20 5 29 6 15 01. 2 10
Stormwater pollution ordinance penalty enforcements
issued 3 01. 1 01. 1 01. 1 1
Septic system failures detected/corrected 01. 01. 01. 7 3 01. 01. 01.
Municipal employees trained on IDDE 1,034

Sanitary sewer use ordinance NOVs issued 50
Sanitary sewer system pretreatment inspections 120
Sanitary sewer system FOG inspections 3,287
Sanitary sewer system pipe miles cleaned 941
Sanitary sewer system ROW miles cleared 106
Sanitary sewer system miles re-lined 10.1
Sanitary sewer system manholes inspected 22,772
Sanitary sewer system lift stations maintained 155
Sanitary sewer system overflows corrected 152
Pet waste flagging events conducted 9
IDEP business corridor inspections 5 01. 11 1 5 01. 2 5
IDEP outfall inspections 1 01. 01. 01. 01. 01. 01. 01.
IDEP problems detected/corrected 1 01. 1 01. 1 01. 01. 01.
IDEP fecal samples collected 1 01. 01. 01. 01. 01. 01. 01.
Citizen service requests responded to 71 11 156 30 110 2 15 32
1. Activity not conducted in this watershed during fiscal year 2021.

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TMDL WATERSHED BMP Citywide Irwin Lake Wylie Little Sugar Long McAlpine McKee Steele Sugar
Construction Site Stormwater Runoff Control
Erosion control ordinance NOVs issued 35
Erosion control ordinance civil penalties issued 20
Project/site plans reviewed 1,293
Sites inspected 5,044
Post-Construction Stormwater Management
Post-Construction ordinance NOVs and CARs issued 711
Post-Construction ordinance penalties issued 7
Post-Construction education workshops conducted 1 Citizens educated at Post-Construction workshops 124
Project/site plans reviewed 162
Buffer protected/added (acres) 215
Buffer mitigation plans approved 7 01. 16 3 8 1 1 3
Buffer mitigation information requests addressed 40 100 100 30 50 30 50 50
SCMs added 15 7 17 9 6 6 12 12
SCMs inspected 87 70 146 61 202 4 85 203
Pollution Prevention/Good Housekeeping
City facilities inspected 17 01. 23 3 10 01. 2 12
City facility outfalls inspected 38 01. 42 3 15 01. 2 37
Stormwater pollution prevention plans implemented 9 01. 9 01. 3 01. 01. 6
Spill prevention response plans implemented 9 01. 9 01. 3 01. 01. 6
Catch basins top cleaned 26,603
Catch basins cleaned (entire basin) 824
Stormwater pipelines cleaned (feet) 8,395
Street sweeping (miles swept) 42,870
Street sweeping debris (tons) 907
Yard waste collected (tons) 51,054
1. Activity not conducted in this watershed during fiscal year 2021.

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TMDL WATERSHED BMP Citywide Irwin Lake Wylie Little Sugar Long McAlpine McKee Steele Sugar
Industrial Facilities
Industrial facilities inspected 14 2 6 5 01. 01. 5 7
Industrial facility outfalls inspected 28 4 7 7 01. 01. 13 17
Vehicle maintenance facilities inspected 3 01. 12 01. 1 01. 01. 4
Industrial facilities monitored 01. 01. 3 1 1 01. 01. 3
Illicit discharges or connections detected/corrected 3 01. 2 01. 01. 01. 01. 01.
Surface Water Quality Monitoring
Fixed interval TSS samples collected 13 01. 52 13 65 13 13 26
Fixed interval Turbidity samples collected 13 58 52 13 65 13 13 26
Fixed interval Dissolved Oxygen samples collected 12 72 48 12 60 12 12 26
Fixed interval Fecal Coliform samples collected 13 73 60 13 70 13 13 26
CMANN Turbidity observations/readings2. 5,996 3,312 54,798 5,016 15,594 6,360 4,186 11,756
CMANN Dissolved Oxygen observations/readings 2. 7,414 4,515 70,422 6,053 21,378 5,999 6,877 15,250
Action/watch level follow-up investigations conducted3. 01. 01. 1 01. 1 01. 01. 01.
1. Activity not conducted in this watershed during fiscal year 2021.
2. CMANN is an automated monitoring network that collects data readings typically once per hour (select sites collect readings every 15 min.). Data reported is QA/QC accepted data only.
3. Includes Fixed Interval and CMANN program investigations.

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