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HomeMy WebLinkAboutNCS000403_Draft SWMP_20221116Draft Stormwater Management Plan Town if Elon NCS000403 November 2022 OF 0 �° VA y EST. ' 7843 OF� H��/- Table of Contents PART1: INTRODUCTION........................................................................................................................ 1 PART 2: CERTIFICATION........................................................................................................................ 2 PART 3: MS4 INFORMATION.................................................................................................................. 3 3.1 Permitted MS4 Area..................................................................................................................... 3 3.2 Existing MS4 Mapping................................................................................................................. 3 3.3 Receiving Waters.......................................................................................................................... 4 3.4 MS4 Interconnection.....................................................................................................................4 3.5 Total Maximum Daily Loads (TMDLs)....................................................................................... 5 3.6 Endangered and Threatened Species and Critical Habitat............................................................ 5 3.7 Industrial Facility Discharges....................................................................................................... 5 3.8 Non-Stormwater Discharges......................................................................................................... 6 3.9 Target Pollutants and Sources....................................................................................................... 7 PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION ..................................... 8 4.1 Organizational Structure............................................................................................................... 8 4.2 Program Funding and Budget.....................................................................................................10 4.3 Shared Responsibility/Contracted Services................................................................................10 4.4 Co-Permittees..............................................................................................................................11 4.5 Measurable Goals for Program Administration.......................................................................... I I PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM.........................................................12 PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM...........................................15 PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM..............................16 PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM.......................................19 PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM........................................19 PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ................ 24 List of Tables Table 1: Summary of MS4 Mapping Table 2: Summary of MS4 Receiving Waters Table 3: Summary of Approved TMDLs Table 4: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality Table 5: NPDES Stormwater Permitted Industrial Facilities Table 6: Non-Stormwater Discharges Table 7: Summary of Target Pollutants and Sources Table 8: Summary of Responsible Parties Table 9: Shared Responsibilities (N/A) Table 10: Co-Permittee Contact Information (N/A) Table 11: Program Administration BMPs Table 12: Summary of Target Pollutants & Audiences Table 13: Public Education and Outreach BMPs Table 14: Public Involvement and Participation BMPs Table 15: Illicit Discharge Detection and Elimination BMPs Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program (N/A) Table 17: Construction Site Runoff Control BMPs Table 18: Qualifying Alternative Program(s) for Post -Construction Site Runoff Control Program (N/A) Table 19: Summary of Existing Post -Construction Program Elements (N/A) Table 20: Post Construction Site Runoff Control BMPs Table 21: Pollution Prevention and Good Housekeeping BMPs PART 1: INTRODUCTION The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which the Town of Elon will comply with its National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit and the applicable provisions of the Clean Water Act to meet the federal standard of reducing pollutants in stormwater runoff to the maximum extent practicable. This SWMP identifies the specific elements and minimum measures that the Town of Elon will develop, implement, enforce, evaluate and report to the North Carolina Department of Environmental Quality (NCDEQ) Division of Energy, Minerals and Land Resources (DEMLR) in order to comply with the MS4 Permit number NCS000403 as issued by NCDEQ. This permit covers activities associated with the discharge of stormwater from the MS4 as owned and operated by the Town of Elon and located within the corporate limits of the Town of Elon. In preparing this current SWMP, the Town of Elon has evaluated its MS4, the permit requirements of it's MS4, and previous Comprehensive Stormwater Management Plans to develop a comprehensive 5-year SWMP that will meet the community's needs, address local water quality issues and provide the minimum measures necessary to comply with the permit. The SWMP will be evaluated and updated annually to ensure that the elements and minimum measures it contains continue to adequately provide for permit compliance and the community's needs. Once the SWMP is approved by NCDEQ, all provisions contained and referenced in this SWMP, along with any approved modifications of the SWMP, are incorporated by reference into the permit and become enforceable parts of the permit. Any major changes to the approved SWMP will require resubmittal, review and approval by NCDEQ, and may require a new public comment period depending on the nature of the changes. DRAFT NCS000403 SWMP Town of Elon November 2022 Page 1 PART 2: CERTIFICATION By my signature below I hereby certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. I am also aware that the contents of this document shall become an enforceable part of the NPDES MS4 Permit, and that both the Division and the Environmental Protection Agency have NPDES MS4 Permit compliance and enforcement authority. ❑ I am a ranking elected official. 0 I am a principal executive officer for the permitted MS4. ❑ I am a duly authorized representative for the permitted MS4 and have attached the authorization made in writing by a principal executive officer or ranking elected official which specifies me as (check one): ❑ A specific individual having overall responsibility for stormwater matters. ❑ A specific position having overall responsibility for stormwater matters. Signature: DO NOT SIGNDRAFT Print Richard Roedner Name: Title: Town Manager Signed this day November of 2022. DRAFT NCS000403 SWMP Town of Elon November 2022 Page 2 PART 3: MS4 INFORMATION 3.1 Permitted MS4 Area This SWMP applies throughout the corporate limits of the Town of Elon, including all regulated activities associated with the discharge of stormwater from the MS4. The map below shows the corporate limits of Town of Elon as of the date of this document. Corporate Limits are shown on the Map Below in Red 3.2 Existing MS4 Mapping The current MS4 mapping includes mapping of Storm drain piping, Streams, Pumpstations, Outfall Locations and Industrial Permitted sites. DRAFT NCS000403 SWMP Town of Elon November 2022 Page 3 Table 1: Summary of Current MS4 Mapping Percent of MS4 Area Mapped** 100 % No. of Major Outfalls* Mapped 20 total *An outfall is a point where the MS4 discharges from a pipe or other conveyance (e.g. a ditch) directly into surface waters. Major outfalls are required to be mapped to meet permit requirements. A major outfall is a 36-inch diameter pipe or discharge from a drainage area > 50-acres; and for industrial zoned areas a 12-inch diameter pipe or a drainage area > 2-acres. ** Elon's entire stormwater system is mapped currently but due to rapid growth this is an ongoing tasks 3.3 Receiving Waters The Town of Elon MS4 is located within the Cape Fear River Basin and discharges directly into receiving waters as listed in Table 2 below. Applicable water quality standards listed below are compiled from the following NCDEQ sources: o Waterbody Classification Map o Impaired Waters and TMDL Map o Most recent NCDEQ Final 303(d) List Table 2: Summary of MS4 Receiving Waters Receiving Water Name Stream Index / AU Number Water Quality Classification 303(d) Listed Parameter(s) of Interest Dry Creek 16-13 WS-V; NSW NA Gunn Creek 16-19-7 WS-V; NSW NA Unnamed Tributary to Dry Creek (Joins Dry Creek north of Town's ETJ 16-19-7 WS-V; NSW N/A Michael's Branch 16-19-5-1 WS-V; NSW N/A Unnamed Tributary to Travis Creek (Cable Branch) 16-12 WS-V; NSW Benthos 3.4 MS4 Interconnection The Town of Elon's MS4 is interconnected with the NCDOT MS4 within NCDOT owned right of ways. DRAFT NCS000403 SWMP Town of Elon November 2022 Page 4 3.5 Total Maximum Daily Loads (TMDLs) The TMDL(s) listed in Table 3 below have been approved within the MS4 area, as determined by the map and list provided on the NCDEQ Modeling & Assessment Unit web page. The table also indicates whether the approved TMDL has a specific stormwater Waste Load Allocation (WLA) for any watershed directly receiving discharges from the permitted MS4, and whether a Water Quality Recovery Program has been implemented to address the WLA. Table 3: Summary of Approved TMDLs Water Body Name TMDL Pollutant(s) of Concern Stormwater Water Waste Quality Load Recovery Allocation Program (Y/N) (Y/N) Jordan Lake TMDL Nitrogen, Phosphorus N Y The Jordan Lake TMDL is the subject of extensive rulemaking, of which the Town of Elon complies with and will comply with future rulemaking regarding. 3.6 Endangered and Threatened Species and Critical Habitat Significant populations of threatened or endangered species and/or critical habitat are not identified within the regulated MS4 urbanized area. Based upon a review of the Endangered and Threatened Species and Species of Concern by County for North Carolina Map and Listed species believe to or known to occur in North Carolina map as provided by the U.S. Fish and Wildlife Service, the species listed in Table 4 have the potential to occur within the regulated MS4 urbanized area. Of those species listed, Table 4 summarizes the species that may be significantly impacted by the quality of surface waters within their habitat. Table 4: Potential Federally Listed Species/Habitat Impacted by Surface Water Quality Scientific Name Common name Species Group Federal Listing Status Helianthus Schweinitzil Schweinitz's Sunflower Flowering Plants Endangered Danus Plexippus Monarch Butterfly Insects Candidate Fusconaia Masoni Atlantic Pigtoe Clams Proposed Threatened Notropis Mekistocholas Cape Fear Shiner Fishes Endangered 3.7 Industrial Facility Discharges The Town of Elon MS4 jurisdictional area includes the following industrial facilities which hold NPDES Industrial Stormwater Permits, as determined from the NCDEQ Maps & Permit Data web page. DRAFT NCS000403 SWMP Town of Elon November 2022 Page 5 Table 5: NPDES Stormwater Permitted Industrial Facilities Permit Number Facility Name NCS000403 Town of Elon — Small MS4 NCGNE0993 Engineering Controls International, LLC 3.8 Non-Stormwater Discharges The water quality impacts of non-stormwater discharges have been evaluated by the Town of Elon as summarized in Table 6 below. The unpermitted non-stormwater flows listed as incidental do not significantly impact water quality. The Town of Elon has evaluated residential and charity car washing and street washing for possible significant water quality impacts. Street washing discharges are addressed under the Pavement Management Program in Part 10 of this SWMP. The Division has not required that other non-stormwater flows be specifically controlled by the Town of Elon. Wash water associated with car washing that does not contain detergents or does not discharge directly into the MS4 is considered incidental. However, these types of non-stormwater discharges that do contain detergents have been evaluated by the Town of Elon to determine whether they may significantly impact water quality. Currently runoff from car washing in The Town of Elon would be considered incidental. Table 6: Non-Stormwater Discharges Non-Stormwater Discharge Water Quality Impacts Water line and fire hydrant flushing Incidental Landscape irrigation Incidental Diverted stream flows Incidental Rising groundwater Incidental Uncontaminated groundwater infiltration Incidental Uncontaminated pumped groundwater Incidental Uncontaminated potable water sources Incidental Foundation drains Incidental Air conditioning condensate Incidental Irrigation waters Incidental Springs Incidental Water from crawls ace pumps Incidental Footing drains Incidental Lawn watering Incidental Residential and charity car washing Possible Flows from riparian habitats and wetlands Incidental Dechlorinated swimming pool discharges Incidental Street wash water Possible Flows from firefighting activities Incidental DRAFT NCS000403 SWMP Town of Elon November 2022 Page 6 3.9 Target Pollutants and Sources In addition to those target pollutants identified below, the Town of Elon is not aware of other significant water quality issues within the permitted MS4 area. The education program will target total suspended solids and nutrient loading because turbidity, sedimentation, and nutrients are the pollutants of concern in downstream waters. In addition, floatables, trash, and debris will also be targeted. The education program will also address the proper use and disposal of typical household chemicals, garden chemicals, and used motor oil. Table 7 below summarizes the water quality pollutants identified throughout Part 3 of this SWMP, the likely activities/sources/targeted audiences attributed to each pollutant and identifies the associated SWMP program(s) that address each. In addition, the Town of Elon has evaluated schools, homeowners and businesses as target audiences that are likely to have significant stormwater impacts. Table 7: Summary of Target Pollutants and Sources Target Pollutant(s) Likely Source(s)/Target Audience(s) SWMP Program Addressing Target Pollutant s /Audience s Litter Residents, Businesses, Schools Public Education & Outreach Sediment Residents, Businesses Public Education & Outreach Nitrogen and Phosphorous Fertilizer/Residents Public Education & Outreach DRAFT NCS000403 SWMP Town of Elon November 2022 Page 7 PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION 4.1 Organizational Structure Table 8: Summary of Responsible Parties Position Name Phone No. Fax No. Email Town Manager Richard Roedner 336-584-3601 336-584-5334 rroedner(a)elon.gov Town Clerk DiAnne Enoch 336-584-3601 336-584-5334 denoch .elon.gov Public Works Director Donnie Wood 336-584-9600 336-584-8307 dwood elon.gov Town Planner Lori Oakley 336-584-3601 336-584-5334 loaklev(aDelon.gov Town Attorney Bob Hagemann 919-783-2987 RHagemann@poVnerspruill. com DRAFT NCS000403 SWMP Town of Elon November 2022 Page 8 Town / Josh Johnson, P.E. (336) 226-5534 (336) 226-3034 josh awck.com Stormwater Engineer Stormwater Phil Ross (336)226-5534 (336) 226-3034 pross(a)awck.com Coordinator General contacts for stormwater should be referred to Richard Roedner & Josh Johnson Designated Stormwater Administrator — Josh Johnson, P.E. — Contracted. SWMP Component Responsible Position Staff Name Department Stormwater Program Town Manager See Table 8 Administration / Engineering Administration Stormwater Engineer (Contracted) SWMP Management Town Manager See Table 8 Administration / Engineering Stormwater Engineer Contracted Public Education & Town Manager See Table 8 Administration / Engineering Outreach Stormwater Coordinator (Contracted) / Stormwater Stormwater Smart Smart Contracted Public Involvement & Town Manager See Table 8 Administration / Engineering Participation Stormwater Coordinator (Contracted) / Stormwater Stormwater Smart Smart Contracted Illicit Discharge Town Manager See Table 8 Administration / Engineering Detection & Stormwater Engineer (Contracted) / Public Works Elimination Public Works Director Construction Site Stormwater Engineer See Table 8 Engineering (Contracted) / Runoff Control Public Works Director Public Works Post -Construction Planning Director See Table 8 Planning / Engineering Stormwater Stormwater Manager (contracted) Management Pollution Town Manager See Table 8 Administration / Engineering Prevention/Good Stormwater Engineer (Contracted) / Public Works Housekeeping for Public Works Director Municipal Operations Municipal Facilities Stormwater Engineer See Table 8 Engineering (Contracted) / Operation & Public Works Director Public Works Maintenance Program Spill Response Program Stormwater Engineer See Table 8 Engineering (Contracted) / Public Works Director Public Works MS4 Operation & Stormwater Engineer See Table 8 Engineering (Contracted) / Maintenance Program Public Works Director Public Works DRAFT NCS000403 SWMP Town of Elon November 2022 Page 9 Municipal SCM Stormwater Engineer See Table 8 Engineering (Contracted) / Operation & Public Works Director Public Works Maintenance Program Pesticide, Herbicide & Public Works Director See Table 8 Public Works Fertilizer Management Program Vehicle & Equipment Public Works Director See Table 8 Public Works Cleaning Program Pavement Management Stormwater Engineer See Table 8 Engineering (Contracted) / Program Public Works Director Public Works Total Maximum Daily Town Manager See Table 8 Administration / Engineering Load (TMDL) Stormwater Engineer (Contracted) Requirements 4.2 Program Funding and Budget In accordance with the issued permit, the Town of Elon shall maintain adequate funding and staffing to implement and manage the provisions of the SWMP and comply with the requirements of the NPDES MS4 Permit. The budget includes the permit administering and compliance fee, which is billed by the Division annually. The Town of Elon funds it's Stormwater Programs through a Stormwater Fee. The Town collects a flat fee of $2/month or $4/bimonthly from utility all utility users. The total stormwater budget for 2022-2023 was $135,000. The Town uses its budget to pay for its Water Quality Programs including its NPDES Phase II and Jordan Lake Programs. The Town has also used excess funding from the stormwater fund to fund other stormwater or water quality projects. This includes investigating drainage complaints from residents and investigating potential inflow/infiltration/exfiltration between the collections system and the MS4. 4.3 Shared Responsibility/Contracted Services The Town of Elon implements 5 of the 6 minimum control measures, with the 6t' measure being construction site runoff controls which is implemented through NC DEMLR's Erosion and Sediment Control program. The Town of Elon contracts with Stormwater Smart for assistance with Public Education and Public Involvement and Outreach. Stormwater Smart is not directly responsible for any items but rather assists the Town of Elon. The Town of Elon contracts engineering services with Alley, Williams, Carmen, and King, Inc. Alley, Williams, Carmen, and King is not directly responsible for any items but rather assists the Town of Elon. DRAFT NCS000403 SWMP Town of Elon November 2022 Page 10 4.4 Co-Permittees The are no other entities applying for co-permittee status under the NPDES MS4 permit number NCS000403 for the Town of Elon. Table 10 summarizes contact information for each co-permittee. 4.5 Measurable Goals for Program Administration The Town of Elon will manage and report the following Best Management Practices (BMPs) for the administration of the Stormwater Management Program. Table 11: Program Administration BMPs Permit 2.1.2 and Part 4: Annual Self -Assessment Ref. Measures to evaluate the performance and effectiveness of the SWMP program components at least annually. Results shall be used by the permittee to modify the program components as necessary to accomplish the intent of the Stormwater Program. The self -assessment reporting eriod is the fiscal year Jul 1 — June 30 . BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 1 Annual Self -Assessment Perform an annual evaluation of 1. Prepare, certify and 1. Annually 1. Yes/No SWMP implementation, suitability of submit the Annual Self- Permit Years 1 — 4 SWMP commitments and any Assessment to NCDEQ proposed changes to the SWMP prior to August 31 each utilizing the NCDEQ Annual Self- year. Assessment Template. Permit 1.6: Permit Renewal Application Ref. Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the NPDES MS4pen-nit. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 2 Permit Renewal Application Audit stormwater program 1. Participate in an 1. TBD — Typically 1. Yes/No implementation for compliance with NPDES MS4 Permit Permit Year 4 the permit and approved SWMP; and Compliance Audit, as utilize the results to prepare and scheduled and performed submit a permit renewal application by EPA or NCDEQ. 2. Self -audit and 2. Permit Year 5 2. Yes/No/Partial document any stormwater program components not audited by EPA or NCDEQ utilizing the DEQ Audit Template. Submit Self - Audit to DEMLR DRAFT NCS000403 SWMP Town of Elon November 2022 Page 11 Table 11: Program Administration BMPs 3. Certify the stormwater 3. Permit Year 5 3. Date of permit renewal permit renewal application submittal application (Permit renewal application form, Self -Audit, and Draft SWMP for the next 5-year permit cycle) and submit to NCDEQ at least 180 days prior to permit expiration. PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM The Town of Elon will implement a Public Education and Outreach Program to distribute educational materials to the community or conduct equivalent outreach activities about the impacts of storm water discharges on water bodies and steps the public can take to reduce pollutants in storm water runoff. The target audiences and identified pollutants listed in Part 3.9 of this SWMP, which will be addressed by the Public Education and Outreach Program, are summarized in Table 12 below. In addition, the Town of Elon is required to inform businesses and the general public of the hazards associated with illicit discharges, illegal dumping and improper disposal of waste. Table 12: Summary of Target Pollutants & Audiences Target Pollutants/Sources Target Audience(s) Litter Residents, Businesses, Schools Sediment Residents, Businesses Nitrogen and Phosphorous Fertilizer/Residents The Town of Elon will manage, implement, and report the following public education and outreach BMPs. The Town partners with Stormwater SMART, an education and outreach organization hosted by the Piedmont Triad Regional Council (PTRC). Stormwater SMART is a cooperative group that is funded by several Piedmont municipalities. It was created in 2005 to provide education and outreach for MS4 Permittees (like the Town Of Elon) and concentrates on direct education of school children and residents. Piedmont Triad Regional Council Stormwater Smart Danica Heflin 1398 Carrollton Crossing Drive, Kernersville, NC 27284 (336) 904-0300 DRAFT NCS000403 SWMP Town of Elon November 2022 Page 12 Table 13: Public Education and Outreach BMPs Permit 3.2.2 and 3.2.4: Outreach to Targeted Audiences Ref. Measures to identify the specific elements and implementation of a Public Education and Outreach Program to share educational materials to the community or conduct equivalent outreach activities about the impacts of stormwater discharges on water bodies and how the public can reduce pollutants in stormwater runoff. The permittee shall provide educational information to identified target audiences on pollutants/sources identified in table 12 above; and shall document the extent of exposure of each media, event or activity, including those elements implemented locally or throu h a cooperative agree ent. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 3 Maintain a Stormwater education plan Maintain education plan. Include in Develop Public 1. Annually Report target Plan the BMPs, schedule, targeted Education and Permit Years 1-5 audiences identified audiences, and measurable goals. Engagement for each target Summarize plan and implementation Plan, documenting the pollutant progress in each annual report existing outreach and education program implemented by Town staff, including process for identifying target audiences for each pollutant and source. 4 Educational Stormwater Mailers, Brochures and Posters Distribute Public Education Materials 1. Distribute public 1. Annually 1. Report number of to identified user groups. Materials education materials, as Permit Years 1-5 educational may be supplied through outside described in the Public materials distributed. Stormwater information sources. Education and Engagement Plan. Permit 2.1.7, 3.2.3 and 3.6.5(c): Web Site Ref. Measures to provide a web site designed to convey the program's message(s) and provide online materials including ordinances, or other regulatory mechanisms, or a list identifying the ordinances or other regulatory mechanisms, providing the legal authority necessary to implement and enforce the requirements of the permit and SWMP. The web page shall also provide developers with all relevant post -construction requirements, design standards, checklists and/or other materials. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 5 Town's Stormwater Webpage Update and maintain the Town's 1. Verify Town's 1. Annually 1 Yes, No, Partial Stormwater Webpage. stormwater webpage is Permit Years 1-5 current. 2. Document Number of 2.Annually 2.Report number of hits Contacts. Permit Years 1-5 towebsite. DRAFT NCS000403 SWMP Town of Elon November 2022 Page 13 6 School Programs Maintain school children education 1. Track the number of 1.Fall and Spring 1. Report the number of program. Focus on basic messages children reached and the Permit Years 1-5 students reached. regarding clean water and the things subject covered they can do at home to help. Permit 3.2.5: Stormwater Hotline Ref. Measures for a stormwater hotline/helpline for the purpose of public education and outreach. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 7 Helpline/ Hotline All stormwater related calls will be 1. Number of Calls 1. Continuously 1. Total annual number forwarded to the Town Manager who received. Permit Years 1- 5 of calls will then distribute the information to other employees. 8 Festivals, Local Fairs and Events Participate in local festivals annually 1. Distribute education 1. Annually 1. Report number of by providing a stormwater information. Permit Years 1-5 Events and materials information booth starting. Provide distributed. bilingual messages on the importance 2. Document Number of 2.Annually 2.Report number of of clean water and on specific Contacts. Permit Years 1-5 individuals contacted. activities that can be carried out to help keep stormwater clean. DRAFT NCS000403 SWMP Town of Elon November 2022 Page 14 PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM This SWMP identifies the minimum elements and implementation of a Public Involvement and Participation Program that complies with applicable State, Tribal and local public notice requirements. The Town of Elon will manage, implement and report the following public involvement and participation BMPs. Table 14: Public Involvement and Participation BMPs Permit 3.3.1: Public Input Ref. Mechanisms for public involvement that provide for input on stormwater issues and the stormwater program. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 9 Public Stormwater Program Meeting A public meeting will be held 1. Gather information 1. Permit Years 2 and 4 1. The number of Bi -annually to discuss the from the public to participants for each implementation of the permit. This improve the program. meeting will be reported. meeting will provide the public with the opportunity to be involved with the stormwater program. Permit 3.3.2: Volunteer Opportunities Ref. Measures to provide volunteer opportunities designed to promote ongoing citizen participation. A B C D BMP Description of BMP Measurable Goal(s) Schedule for Annual Reporting No. Implementation Metric 10 Volunteer Stormwater Program The Town will promote various 1. The number of 1.Fall and Spring 1. The number of volunteer stormwater programs participants for each Permit Years 1-5 participants for each annually. These may include Big program will be reported program will be reported Sweep, Adopt -A -Stream programs, annually. annually. and Storm Drain Stenciling. 11 Helpline / Hotline The Town will promote and 1. Maintain the 1. Fall and Spring 1. Report number of maintain a stormwater stormwater Permit Years 1-5 calls handled by hotline(s) or helpline(s) for the administration helpline helpline by type of public to request information to receive public call about stormwater, public complaints. involvements & participation, and to report illicit connection and discharges, etc. The stormwater helpline will be the primary Town phone number with calls routed to the Town Manager or his designee. DRAFT NCS000403 SWMP Town of Elon November 2022 Page 15 PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM The Town of Elon will develop, manage, implement, document, report and enforce an Illicit Discharge Detection and Elimination Program which shall, at a minimum, include the following illicit discharge detection and elimination BMPs. Table 15: Illicit Discharge Detection and Elimination BMPs Permit 3.4.1: MS4 Map Ref. Measures to develop, update and maintain a municipal storm sewer system map including stormwater conveyances, flow direction, major outfalls and waters of the United States receiving stormwater discharges. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 12. Storm sewer system map showing outfalls and the receiving body of water. Maintain system map in support of 1. Additional Outfalls 1. Annually 1. Report number of inspection program. The map will and Storm System Piping Permit Years 1-5 major outfalls note outfalls and receiving body of added to mapping. water for each outfall. 2. 2. 2. Provide overview map of receiving streams and major outfalls. Permit 3.4.2: Regulatory Mechanism Ref. Measures to provide an IDDE ordinance or other regulatory mechanism that provides legal authority to prohibit, detect, and eliminate illicit connections and discharges, illegal dumping and spills into the MS4, includin enforcement procedures and actions. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 13. Review Illicit Discharge Ordinance Maintain adequate ordinance or other 1. Maintain and enforce 1. Biannually 1. Report changes to legal authorities to public ordinances. Permit Years 2 & 4 IDDE program. prohibit illicit connections and Update, if necessary, to discharges and enforce the maintain legal approved IDDE program. authority. DRAFT NCS000403 SWMP Town of Elon November 2022 Page 16 Table 15: Illicit Discharge Detection and Elimination BMPs Permit 3.4.3: IDDE Plan Ref. Measures to maintain and implement a written IDDE Plan to detect and address illicit discharges, illegal dumping and any non-stormwater discharges identified as significant contributors of pollutants to the MS4. The plan shall provide standard procedures and documentation to: a) Locate priority areas likely to have illicit discharges, b) Conduct routine dry weather outfall inspections, c) Identify illicit discharges and trace sources, d) Eliminate the source(s) of an illicit discharge, and e) Evaluate and assess the IDDE Program. A B C D BMP No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 14. Inspection/detection program to detect dry weather flows at M54 outfalls. Maintain written procedures and/or 1 Implement IDDE Plan. 1. Annually 1. Report number of dry SOPs for detecting Review and update Permit Years 1-5 weather inspections and tracing the sources of illicit IDDE Plan as needed completed and results. discharges and for removing the sources or reporting the sources to the State to be properly permitted. Permit 3.4.4: IDDE Tracking ■ Ref. Measures for tracking and documenting the date(s) an illicit discharge, illicit connection or illegal dumping was observed, the results of the investigation, any follow-up of the investigation, the date the investigation was closed, the issuance of enforcement actions, and the ability to identify chronic violators. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 15. Establish/ Maintain a tracking system for managing reported problem areas. Document the date of investigations, 1. Maintain IDDE 1. Annually 1. Report date of any enforcement action(s) or inspection records, Permit Years 1-5 investigations, any remediation that occurred notices of enforcement action(s) violations and or remediation that compliance and other occurred. program records. Permit 3.4.5: Staff IDDE Training Ref. Measures to provide training for municipal staff and contractors who, as part of their normal job responsibilities, may observe an illicit discharge, illicit connection, illegal dumping or spills. Training shall include how to identify and report illicit discharges, illicit connections, illegal dumping and spills. Each staff trainingevent shall be documented, including the agenda/materials, date, and number of staff participating. A B C D DRAFT NCS000403 SWMP Town of Elon November 2022 Page 17 Table 15: Illicit Discharge Detection and Elimination BMPs BMP Description of BMP Measurable Goal(s) Schedule for Annual Reporting No. Im lementation Metric 16. Train employees on how to inspect for illicit connections Conduct in person or virtual training 1. Conduct employee 1. Annually 1. Report number of for appropriate municipal staff on training and document Permit Years 1-5 staff who completed detecting and reporting illicit attendance. IDDE training and types connections and discharges. of training provided Permit 3.4.6: IDDE Reporting Ref. Measures for the public and staff to report illicit discharges, illegal dumping and spills. The mechanism shall be publicized to facilitate reporting and shall be managed to provide rapid response by appropriately trained personnel. A B C D BMP No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 17. Maintain Program to report discharges to personnel and the public Maintain and publicize reporting 1. Maintain reporting 1. Annually 1. Report number of mechanism(s) for the helpline and email Permit Years 1-5 calls and emails public to report illicit connections address. received and discharges PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM In accordance with 15A NCAC 02H .0153, the Town of Elon relies upon the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 as a qualifying alternative program to meet a portion of the NPDES MS4 Permit requirements for construction site runoff control measures. The SPCA requirements include reducing pollutants in stormwater runoff from construction activities that result in land disturbance of greater than or equal to one acre and includes any construction activity that is part of a larger common plan of development that would disturb one acre or more. The contact information for the responsible party for Construction Site Runoff Controls within the Town of Elon is: NC Sedimentation and Erosion Control Program Winston-Salem Regional Office Tamera Eplin, P.E. Regional Environmental Engineer 450 west Hanes Mill Rd., Suite 300, Winston Salem, NC 27105-7407 Phone: 336/776-9800 www.deg.nc.gov DRAFT NCS000403 SWMP Town of Elon November 2022 Page 18 The Town of Elon implements minimal BMP's regarding NC Sedimentation and Erosion Control due to lack of legal authority. All calls regarding erosion control are to be referred to NC DEQ as noted above. Table 17: Construction Site Runoff Control BMPs Permit 3.5.6: Public Input Ref. Measures to provide and promote a means for the public to notify the appropriate authorities of observed erosion and sedimentation problems. A B C D BMP No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 18. Municipal Staff Training Train municipal staff who receive 1. Train municipal staff calls from the public on the protocols on proper handling of 1. Annually 1. Number of staff for referral and tracking of construction site runoff Permit Years 1-5 trained. construction site runoff control control complaints. complaints. PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM The Town of Elon operates a Post Construction Site Runoff Control Program that regulates stormwater runoff from new development and redevelopment projects that disturb greater than or equal to one acre, including projects less than one acre that are part of a larger common plan of development or sale, that are located within the Town of Elon and discharge into the MS4. These elements are designed to minimize water quality impacts utilizing a combination of structural Stormwater Control Measures (SCMs) and/or non-structural BMPs appropriate for the community and ensure adequate long-term operation and maintenance of SCMs. The Town also operates a high -density water supply watershed program that is handled similarly to its Post Construction runoff program but which includes reduced triggers and more stringent regulations. The Town's post construction ordinance is contained the Town Of Elon's Phase II Stormwater Post - Construction Ordinance. The Town maintains a stormwater design manual that is deemed equal or more stringent than the NC DEQ BMP Manual. The annual reporting metrics for the post construction program are provided in Table 20: Post Construction Site Runoff Control BMPs below. Table 20: Post Construction Site Runoff Control BMPs Permit 3.6.5(a), 3.6.5(b), and 4.1.3: Minimum Post -Construction Reporting Requirements Ref. Measures to document activities over the course of the fiscal year (July 1 — June 30) including appropriate information to accurately describe rogress, status, and results. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric DRAFT NCS000403 SWMP Town of Elon November 2022 Page 19 Table 20: Post Construction Site Runoff Control BMPs 19. Standard Reporting Implement standardized tracking, 1. Track number of low 1. Continuously 1. Number of plan documentation, inspections and density and high density Permit Years 1-5 reviews performed for reporting mechanisms to compile plan reviews performed. low density and high appropriate data for the annual self- density. assessment process. Data shall be 2. Track number of low 2. Continuously 2. Number of plan provided for each Post -Construction/ density and high density Permit Years 1-5 approvals issued for low Qualifying Alternative Program plans approved. density and high density. being implemented as listed in Tables 3. Maintain a current 3. Continuously 3. Summary of number 18 and 19. inventory of low density Permit Years 1-5 and type of SCMs added projects and constructed to the inventory; and SCMs including SCM number of low density type or low density projects constructed. location and last date. —inspection 4. Track number of SCM 4. Continuously 4. Number of SCM inspections performed. Permit Years 1-5 inspections. 5. Track number and 5. Continuously 5. Number of type of enforcement Permit Years 1-5 enforcement actions actions taken. issued. Permit 3.6.2: Legal Authority Ref. Measures to maintain adequate legal authorities through ordinance or other regulatory mechanism to: (a) review designs and proposals for new development and redevelopment to determine whether adequate stormwater control measures will be installed, implemented, and maintained, (b) request information such as stormwater plans, inspection reports, monitoring results, and other information deemed necessary to evaluate compliance with the Post -Construction Stormwater Management Program, and (c) enter private property for the purpose of inspecting at reasonable times any facilities, equipment, practices, or operations related to stormwater discharges to determine whether there is compliance with the Post -Construction Stormwater Management Program. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 20. Review the Post Construction Ordinance Review the Post Construction 1. Add additional 1.Annually 1. Report any ordinance Ordinance for compliance with NC Measures as needed Permit Years 1-5 revisions added annually. DWQ guidance and local effectiveness. Phase II Post - Construction Ordinance will incorporate Jordan Lake Nutrient Strategy Regulations in conjunction with NC Session Law and DWQ regulations. DRAFT NCS000403 SWMP Town of Elon November 2022 Page 20 Table 20: Post Construction Site Runoff Control BMPs Permit 3.6.3: Plan Review and Approval Ref. Measures to maintain plan review and approval authority, standards and procedures to: (a) Require Federal, State, and local government projects to comply with Post -Construction Program requirements throughout the entire MS4 permitted area, unless the entity is subject to its own NPDES MS4 permit or a qualifying alternative program, (b) Conduct site plan reviews of all new development and redeveloped sites that disturb greater than or equal to one acre, and sites that disturb less than one acre that are part of a larger common plan of development or sale for compliance with 15A NCAC 02H .1017 and the qualifying alternative programs that apply within your jurisdiction, (c) Ensure that each project has an Operation and Maintenance Agreement that complies with 15A NCAC 02H .1050(12), (d) Ensure that each project has an Operation and Maintenance Plan that complies with 15A NCAC 02H .1050(13), (e) Ensure that each project has recorded deed restrictions and protective covenants, that require the project to be maintained consistent with approved plans, and (f) Ensure that each SCM and associated maintenance accesses be protected in a permanent recorded easement per 15A NCAC 02H 1050 9 and (10). BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting I Implementation Metric 21. Review standards and policies that ensure structural BMPs continue to be in conformance with the state's Stormwater Management Design Manual Review local standards to remain in 1. Add additional 1. Annually 1. Report any BMP compliance with the NC DWQ BMP Measures as needed Permit Years 1-5 manual measures added Manual. Additional measures and annually. techniques may be added to the local ordinance as they are investigated. 22. Review maintenance standards and inspection program to ensure that on -site controls continue to function as designed. Review the maintenance standards 1. Add additional 1. Annually 1. Report the number of and inspection program for local on- Measures as needed Permit Years 1-5 inspections annually site controls. 23. Maintain the education program created for land developers and the public. Provide educational materials and 1. Maintain stormwater 1. Continuous 1. Report changes to the training for developers. permitting guidance Permit Years 1-5 permitting guidance document for developers document made and designers. annually. DRAFT NCS000403 SWMP Town of Elon November 2022 Page 21 Table 20: Post Construction Site Runoff Control BMPs Permit 3.6.4: Inspections and Enforcement Ref. Measures to maintain inspection and enforcement authority, standards and procedures to: (a) Conduct post - construction inspections prior to issuing a Certificate of Occupancy or a Temporary Certificate of Occupancy. Alternatively, the project owner may provide a surety bond to guarantee compliance with the approved plan(s), (b) Ensure that the project has been constructed in accordance with the approved plan(s), (c) Ensure annual inspection of each permitted SCM to ensure compliance with the approved Operation and Maintenance Agreement, (d) Ensure inspection of low -density projects at least once during the permit term, and (e) Require that inspections be conducted by a qualified professional. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 24. Inspections and long-term maintenance of Stormwater Control Measures (SCMs) Maintain an inspection and 1. Maintain and receive 1. Annually 1. Report number of sites maintenance plan for SCM's. Annual SCM inspection reports with SCMs SCM Inspections performed by a and follow up on the Permit Years 1-5 qualified professional. SCM functioning status of Report number of sites maintenance and inspections will be SCM's where SCM inspections reviewed by the Town during the have been received permit cycle. Report SCM enforcement activities 25. Operation and Maintenance Plan Require submittal of operation and 1. Require submittal of 1. Continuously 1. Report number of sites maintenance plan(s) prior to operation and Permit Years 1-5 with newly approved certificate of occupancy and maintenance plan(s) operation and maintain records of each plan. prior to certificate of maintenance plan(s). occupancy and maintain records of each plan. DRAFT NCS000403 SWMP Town of Elon November 2022 Page 22 Permit 3.6.6: Fecal Coliform Reduction Ref. Measures to control, to the maximum extent practicable, sources of fecal coliform per 15A NCAC 02H .1017(7). At a minimum, the program shall include: (a) A pet waste management component, which may be achieved by revising an existing litter ordinance, and (b) An on -site domestic wastewater treatment system component, if applicable, which may be coordinated with local county health department, to ensure proper operation and maintenance of such systems. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 26. Pet Waste Stations at Parks Provide Pet waste stations at Town 1. Maintain Pet Waste 1. Continuously 1. Report the number of owned parks as needed Stations in Town owned Permit Years 1-5 Waste stations the Town arks maintains. 27. Coordinate with the county health department on fecal coliform contamination caused by onsite wastewater treatments stems. Coordinate with the county health 1. Contact County Health 1. Annually 1. Report the number of department on a program to minimize Department to inquire Permit Years 1-5 failed systems connected the potential for fecal coliform about failing systems to the Town's contamination by ensuring proper wastewater system. operation and maintenance of on -site wastewater treatments stems. DRAFT NCS000403 SWMP Town of Elon November 2022 Page 23 PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the Town of Elon municipal facilities and operations. Pollution prevention and good housekeeping is accomplished through the implementation of seven required programs, which collectively address the ultimate goal of preventing or reducing pollutant runoff from municipal operations such as parks and open space maintenance, fleet and building maintenance, new construction and land disturbances, and municipal storm sewer system maintenance. Pollution prevention and good housekeeping for municipal operations includes the following programs: 1. Municipal Facilities Operation and Maintenance Program 2. Spill Response Program 3. MS4 Operation and Maintenance Program 4. Municipal SCM Operation and Maintenance Program 5. Pesticide, Herbicide and Fertilizer Management Program 6. Vehicle and Equipment Maintenance Program 7. Pavement Management Program The Town of Elon will manage, implement and report the pollution prevention and good housekeeping BMPs as specified in Table 21 below for each required program. Table 21: Pollution Prevention and Good Housekeeping BMPs Permit 3.7.1: Municipal Facilities Operation and Maintenance Program Ref. Measures to manage facilities that are owned and operated by the permittee and have the potential for generating polluted stormwater runoff. The permittee shall maintain a current inventory of municipal facilities; perform facility inspections and routine maintenance; establish specific frequencies, schedules, and standard documentation; provide staff training on eneral stormwater awareness and imp ementing pollution prevention and good housekeeping ractices. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 28. Maintain Inventory and O&M Manual of Municipal Facilities and Operations Document the existing inspection and 1. Inspect and document 1. Annually 1. Report number of maintenance program for municipal municipal facility Permit Years 1-5 facilities inspected. facilities and operations that are inspections, including determined to be potential sources of any corrective action. polluted runoff. 2.Report corrective actions taken at municipal facilities or operations DRAFT NCS000403 SWMP Town of Elon November 2022 Page 24 Permit 3.7.2: Spill Response Program Ref. Measures for facilities and operations that store and/or use materials that have the potential to contaminate stormwater runoff if spilled. The permittee shall maintain written spill response procedures and train staff on spill response rocedures. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 29. Spill Response Procedures Maintain spill response procedures 1. Review and modify 1. Annually 1. Report number of spill for municipal facilities and Town -wide spill Permit Years 1-5 response procedures operations owned and operated by the response procedures as developed/maintained permittee that have been determined needed by the permittee to have significant 2. Review and modify 2. Annually 2. Report number of spill potential for generating polluted site -specific spill Permit Year 1-5 response procedures stormwater runoff. response procedures as developed/maintained needed 30. Staff Training Train Staff on proper procedures and 1. Conduct employee 1. Annually 1. Report types of protocol to handle spills training and Permit Years 1-5 training provided document attendance. and number of staff who completed PPGH training Permit 3.7.3: MS4 Operation and Maintenance Program Ref. Measures to minimize pollutants in the stormwater collection system. The permittee shall provide operation and maintenance staff training on stormwater awareness and pollution prevention, perform MS4 inspections, maintain the collection system including catch basins and conveyances; and establish specific frequencies, schedules, and standard documentation. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 31. O&M for municipally owned or maintained catch basins and conveyance systems Continue to implement/and maintain 1. Inspect and maintain 1. Annually 1. Report number of pie the O&M Program for the municipal MS4 to verify they Permit Years 1-5 and culvert replacements storm sewer system including catch function as conduits of completed annually. basins, and the conveyance system. stormwater. 2. Review the MS4 Plan, 2. Annually 2. Review plan annually and revise, if necessary. Permit Years 1-5 and report any changes. Implement inspection and maintenance programs documented in the MS4 Plan. DRAFT NCS000403 SWMP Town of Elon November 2022 Page 25 Permit 3.7.4: Municipal SCM Operation and Maintenance Program Ref. Measures to manage municipally owned, operated, and/or maintained structural stormwater control measures (SCMs) that are installed for compliance with the permittee's post -construction program. The permittee shall maintain a current inventory of SCMs, perform SCM inspections and maintenance, and shall establish specific frequencies, schedules, and documentation. A B C D L Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 32. O&M for municipally owned or maintained structural stormwater controls Maintain and implement an 1. Inspect and maintain 1. Annually 1. Report number of inspection and maintenance program SCMs so that they are Permit Years 1-5 municipal SCMs for SCMs owned and operated by function properly as Inspected the municipality designed 2. Review the SCM Plan, 2. Annually 2. Report changes to and revise, if necessary. Permit Years 1-5 SCM plan. Implement inspection and maintenance programs documented in the MS4 Plan and the 3. Report major SCM Plan. maintenance and repair actions Permit 3.7.5: Pesticide, Herbicide and Fertilizer Management Program Ref. Measures to minimize water quality impacts from the use of landscape chemicals. The permittee shall provide routine pollution prevention and chemical use, storage and handling training, and shall ensure compliance with permits and a licator certifications. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 33. Pesticide, Herbicide and Fertilizer Application Management Manage Staff Pesticide license and 1. Review staff license 1. Annually 1. Report number of staff follow all requirements to safely that they are up to date Permit Years 1-5 with license handle and apply pesticides, 2.Provide training for 2. Annually 2.Report number of staff herbicides, and fertilizers. staff on the use of Permit Years 1-5 that attended training and chemicals type of training. Permit 3.7.6: Vehicle and Equipment Maintenance Program Ref. Measures to prevent and minimize contamination of stormwater runoff from areas used for municipal vehicle and equipment maintenance and/or cleaning. The permittee shall ensure that municipal industrial facilities subject to NPDES industrial permitting comply with those permit requirements, provide routine pollution prevention training to staff, perform routine inspections, and establish specific frequencies, schedules, and documentation. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 34. Vehicle Washing and Maintenance Program DRAFT NCS000403 SWMP Town of Elon November 2022 Page 26 32. O&M for municipally owned or maintained structural stormwater controls Maintain and implement an 1. Inspect and maintain 1. Annually 1. Report number of inspection and maintenance program SCMs so that they are Permit Years 1-5 municipal SCMs for SCMs owned and operated by function properly as Inspected the municipality designed 2. Review the SCM Plan, 2. Annually 2. Report changes to and revise, if necessary. Permit Years 1-5 SCM plan. Implement inspection and maintenance programs documented in the MS4 Plan and the 3. Report major SCM Plan. maintenance and repair actions Prevent or minimize contamination 1. Review procedures for 1. Annually 1. Report number of of stormwater runoff from all areas vehicle and equipment Permit Years 1-5 facilities performing used for vehicle and equipment cleaning operations and vehicle and equipment cleaning update, if necessary. cleaning operations 2. Report actions taken to prevent or minimize stormwater runoff from vehicle and equipment cleaning, if needed. Permit 3.7.7: Pavement Management Program Ref. Measures to reduce pollutants in stormwater runoff from municipally owned streets, roads, and parking lots within the permittee's corporate limits. The permittee shall implement measures to control litter, leaves, debris, particulate and fluid ollutants associated with vehicles, and establish specific fre uencies, schedules, and documentation. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 35. Streets, Roads, and Public Parking Lots Maintenance Program The permittee shall implement BMPs 1.Evaluate options to 1. Permit Year 1. 1. Summarize options in to reduce polluted stormwater runoff implement BMPs to annual report. from municipally owned streets, reduce polluted roads, and public parking lots within stormwater runoff from the corporate limits as fiscally municipally owned feasible. streets, roads, and public parking lots. Factors for evaluation are water quality benefits, technical feasibility, safety, and fiscal responsibility. DRAFT NCS000403 SWMP Town of Elon November 2022 Page 27 2.Create program for 2. Permit Year 2. 2.Outline report in reducing polluted annual report. stormwater runoff from municipally owned streets, roads, and public parking lots. 3.Implement program for 3.Permit Years 3-5. 3. Report on program reducing polluted implementation. stormwater runoff from municipally owned streets, roads, and public parking lots. DRAFT NCS000403 SWMP Town of Elon November 2022 Page 28