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HomeMy WebLinkAboutNCS000481_ANNUAL REPORT_20070216lhlel�le_e� STORMWATER DIVISION CODING SHEET M54 PERMITS PERMIT NO. DOC TYPE ❑ FfNALPERMIT ANNUALREPORT. ❑ APPLICATION ❑ COMPLIANCE ❑ OTHER DOC DATE ❑ YYYYMMDD a •, a TOWN OF MAIDEN NORTH CAROLINA 28650 P.O. BOX 125 • (828) 428-5000 FAX (828) 428-5017 • TDD 800-735-2962 February 16, 2007 Mr. Mikb Randall v Department of l-'-nvironment and Natural Resources ;z -71 Division of Water Quality � m W Stormwater Permitting Unit a 1617 Mail Service Center 0 Raleigh, North Carolina 27699-1617 Y.o Dear Mr. Randall: "Phis letter is to document that the Town of Maiden Annual Report for Year 1 of Permit NCS000481 was submitted to you electronically on February 16, 2007 to your e-mail address: mike.randall @nemail.net The following certification is made as required in the reporting and record keeping section of the.permit: "I 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." If you have any questions, please contact Town Planner Andrea Lytle at (828) 485-4238. Sincerely, m .. " Kevin Sanders Interim Town Manager t Town of Maiden Phase 11 Stormwater Permit Report — Year I PERMIT NO. NCS 000481 Introduction The Town of Maiden Storniwaler Management Plan (SWMP) was developed and SUbinitted on April 29, 2004 along with a National Pollutant Discharge F1liillination System (NPDFS) Phase 11 permit application for the municipal separate storm sewer system (MS4). Permit Number NCS 000481 was issued to the Town of Maiden in Fall 2005 by the North Carolina Departnient of' I-'nvironment and Natural Resources (NCDENR) under authority ol' the North Carolina hnvironnlental Management Commission and the Federal Water Pollution Control Act. The perinit was effective December 1, 2005, and allows the discharge of stormwater from the MS4 under the NPD1S regulations to the various receiving waters and their tributaries within the Catawba River basin in accordance with the provisions ol'the permit. Purpose of Report Part III, the Program Assessment section of the Permit requires the SWMP to be reviewed and updated on an annual basis. The Program Assessment section also requires that a report be subrilitted to NCDIINR on an annual basis by February lof each year to doCL1111e111 the previous year's activities From December to December. The stated purpose of' this report is a detailed description of the status oi' inlplenientation of. the SWMP. Report Format Each oF'.lhe S1X 111ini111L1m meaSUreS 01'thC; pUrnit is listed in detail (Objectives followed by BM1' table). Illfornlatlon to document the details and activities performed to ILllflll the requirements of each nlininuml measure are also included. PUBLIC EDUCATION AND OUTREACH Objectives for Public Education and Outreach (a) Distribute educational materials to the community. (b) Conduct public outreach activities. (c) Raise public awareness on the causes and impacts of stormwater pollution. (d) Inform the public on steps they can take to reduce or prevent stormwater pollution. BMPs for Public Education and Outreach The permittee shall implement the following BMPs to meet the objectives of the Public l3ducation and Outreach Program and shall notily the Division prior to modification of any goals. BMP Measurable Goals (a) lstablish a Public Develop a public education program and implement Education and Outreach within 12 months of the permit issue date. Incorporate Program outreach elements for significant min (b) Informational Web Site Develop and maintain internet web site. Post newsletter articles on stormwater, information on water quality, stormwater projects and activities, and ways to contact stormwater management program slat" f. (c) Public education materials Develop general stormwater educational material to far schools, homeowners, appropriate target groups as likely to have a significant and/or businesses 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. (d) Public education material Distribute written educational material to a broad public dissemination audience. Possibilities include, but are not limited to utility mailouts and at special events. Implementation The Town of Maiden has complied with the requirements of this BMP through written and electronic educational material, public meetings and presentations. -2- 'i Written Educational Materials • Town Newsletter — Approximately ten (10) articles related to stormwater appeared in the Town of Maiden's newsletter which is mailed to approximately 1,600 households quarterly. The articles discussed stormwater pollution and its ef'f'ccts, the requirements of the Phase 11 Program and offered suggestions to citizens about how to reduce stormwater pollution. Other related articles mentioned hazardous waste collection events, leaf collection (bagging instead of raking leaves into the storm drain) and community clean-up events. • Bookmark — "Town staff developed a bookmark using information distributed by the US Environmental Protection Agency describing the importance of' stormwater and actions homeowners and the general public can take to prevent stormwater pollution. This bookmark was made available to the public at Town Hall and was distributed at numerous public meetings and events. • Spanish Bookmark — The bookmark described above was translated into Spanish and distributed at Town Hall to target the Spanish-speaking public. • Candy Giveaway — Mifk Duds(D candy was tagged with a statement that said "Don't be a dud! Do your part to prevent stormwater pollution because it's our drinking water!" was distributed at public meetings where the Phase 11 Stormwater Program was discussed. One goal of Years 2 and 3 is to acid targeted educational materials explaining how stormwater impacts can be minimized in commercial operations. It is also anticipated that additional educational materials can be distributed through utility and tax bills. In additional to general information about stormwater, the "Town will concentrate on the reduction of' pollutant loading and minimization of stormwater volume, which is a locally identified threat to water quality. Presentations: • January 22, 2006 —'Town staff presented an overview of the Phase 11 Stormwater Program at the Town Council planning retreat. • March 18, 2006 — Town staff met with a local boy scout troop at nearby Murray's Mill and gave a presentation about stormwater pollution and how they could help prevent it. • October 9, 2006 — A public hearing was held at the Maiden Town Council meeting. Staff' gave a detailed PowerPoint presentation of the requirements and components of the Phase II stormwater program. This presentation allowed time for Council members and ask questions regarding the program. The public hearing was advertised twice in the local newspaper and at "Town Hall. • October 17, 2006 — A public meeting was held at the Maiden High School to give the public an opportunity to ask questions about town services and express concerns. Town staff developed and displayed an informative poster describing the effects of stormwater pollution. Small giveaways and written educational materials were distributed at the meeting. • October 25, 2006 —Town staff met with teachers from the Environmental Science program at Maiden High School to discuss the Phase 11 Stormwater Program and the incorporation of efforts to teach students about stormwater pollution. • Ongoing — Town staff has discussed with the Maiden Planning Board the implementation of the Phase 11 program on several occasions. - 3 - A goal f-or Year 2 is to host an informational session for the development community to explain the impacts of the post -construction requirements of the Phase I1 Program. ']'his meeting will probably be held at be held at a county- or regional -level. Informational Web Site: A series of webpages specifically related to stormwater was launched at the end of' November on the Town of Maiden's website (Iittp://www.i-naideiinc.coiii/storinwater.as]2x). Patterned after the website template developed by the North Carolina Cooperative Extension Service (http:llwww.bae.ncsu.edultopiclphase2lmeasLire I b.htm), the website discusses the causes and problems associated with stormwater pollution, steps homeowners and businesses can take to reduce slorinwater pollution, volunteer opportunities, details about how to report illicit discharge, children's activities and a link in Spanish to the US LPA's Spanish -language website about stormwater pollution. During the next year, it will be a priority for the Town of Maiden to improve its website by adding stormwater articles, graphics and articles front the Maiden newsletter. Phase II Stormwater Working Group Town of Maiden staff have been actively involved with the Phase II Stormwater Working Group from the local governments in Alexander, Burke, Caldwell, and Catawba Counties. This group is facilitated by the Western Piedmont Council of� Governments (WPCOG). The purpose of this group is to work together toward public education and involvement, the common development of' ordinances, and any other matters related to stormwater management. The group has formed teams to immediately work on the public education and involvement BMI's, as well as the post - construction ordinance. Events and festivals where it is practical to display materials and have handouts concerning the prevention of stormwater pollution will continue to be used to disseminate information to the public. The focus of these events and festivals must be such that discussions can be held with the public. The Riverfest festival is scheduled yearly for the second weekend in September as an example. Staff members will attend/support the lestival to meet the public and discuss stormwater pollution prevention. A display and handouts concerning stormwater pollution prevention will also be available for public education. Meetings with school officials this next year will be a priority in order to schedule presentations to the appropriate school groups. The declining circulation of the area newspapers makes the dissemination of written information more diff"ICUlt. However, we also plan to continue to use this medium to reach the public. NCDF.NR is working to complete television and radio public service announcements concerning preventing stormwater pollution. When those are available, local media will be contacted to air these public service announcements. The various materials that have been developed by such organizations as NCDIINR will continue to be used in the appropriate media and settings to work toward public education and outreach. -4- PUBLIC INVOLVEMENT AND PARTICIPATION Objectives for Public Involvement and Participation (a) Provide opportunities for the public, including major economic and ethnic groups, to participate in program development and implementation. (b) Comply with applicable state and local public notice requirements. BMPs for Public Involvement and Participation The permittee shall implement the following 13MPs to meet the objectives of the Public Involvement and Participation Program and shall notify the Division prior to modification of any goals. BMP Measurable Goals (a) Administer a Public Develop and implement it Public Involvement and Involvement Program Participation Program. (b) Allow the public an Conduct at least one public meeting to allow the opportunity to review and public an opportunity to review and comment on the comment on the stormwater Stormwater Plan. Plan (c) Organize a volunteer Organize and implement a volunteer stormwater community involvement related program designed to promote ongoing citizen program participation. (d) I'stablish a Citizens' Develop a citizens' groups) for input on stormwater Group(s) issues and the stormwater program. Implementation The "Town Council of the Town of Maiden held a public hearing on October 9, 2006 to allow the public an opportunity to review and comment on the Stormwater Plan. At the meeting, 'Town staff gave a detailed PowerPoint presentation of the requirements and components of the Phase It Prograin. This presentation allowed time for Council members and ask questions regarding the program. The public hearing was advertised twice in the local newspaper and at Town Ha]I Town staff began to organize a volunteer program that will be improved in Year 2 and subsequent years. On March 18, 2006, Town staff met with a local boy scout troop at nearby Murray's Mill and gave a presentation about stormwater pollution and how they could help prevent it. The scouts discussed the importance of water quality and what activities they could do to help. They also collected trash and worked on stream restoration projects during the day. It is anticipated this cleanup effort will be continued in Year 2 and subsequent years. - 5 - Town staff also advertised the Spring and Fali litter sweeps sponsored by the North Carolina Department of'1_ransport ation in the Town quarterly newsletter. Interested persons were invited to contact Town staff in order to volunteer. No persons expressed interest in the event. It is anticipated that greater advertisement will be necessary in Year 2 and subsequent years in order to recruit volunteers. On October 25, 2006, Town staff met with teachers from the Environmental Science program at Maiden High School to discuss the Phase II Stormwater Program and the incorporation ofefforts to teach students about stormwater pollution. ]'own staff and the department head walked the cross-country trail that is under construction at the high school. Two grants were received to assist in the construction of the trail and the school received permission from the Town Council to use the adjacent sewer right-of-way as part of the trail. "Town staff supported the school's application for a Hometown Helper grant award to assist in construction efforts. It is anticipated in the future that town staff' will work with teachers and students to facilitate field laboratory experiments and water quality. A Stormwater Advisory Group formed late in Year 1 but has not met yet. Although the group was advertised at Planning Board and Town Council meetings and in the Town newsletter, Town staff had difficulty finding citizens that wanted to serve on the committee. It is anti6patcd that the group will meet twice annually, unless the members desire to meet more often. We will continue to research ways to increase the involvement of the community in general, as well as bL1SlnCSS and professional groups in the second permit year. Use o[ existing groups Such as the Planning Board will be considered. -6- � i 4 ILLICIT DISCHARGE DETECTION ANll ELIMINATION Objectives for Illicit Discharge Detection and Elimination (a) Detect and eliminate illicit discharges, including spills and illegal dumping. (b) Address significant contributors of pollutants to the MS4. The permittee may require specific controls for a category of discharges, or prohibit that discharge completely, if one or more of these categories of sources are identified as a significant contributor of' pollutants to the storm sewer system. (c) Implement appropriate enforcement procedures and actions. (d) Develop a storm sewer system map showing all outfalls and waters receiving discharges. (e) Inform employees, businesses, and the general public of hazards associated with illegal discharges and improper disposal of waste. BMI s for Illicit Discharge Detection and Elimination The permittee shall implement the following 13MPs to meet the objectives of the Illicit Discharge Detection and Elimination Program. -7- BM Measurable Goals (a) Developllmplenient Illicit Develop and implement an Illicit Discharge Detection and Discharge Detection and Elimination Program. Include provisions for program Elimination Program assessment and evaluation. (b) Establish and maintain Establish and maintain adequate legal authorities to prohibit appropriate legal authorities illicit discharges and enforce the approved Illicit Discharge Detection and Elimination Program. (c) Develop a Storm Sewer Identify outfall locations and map stormwater drainage system System Base Map components. At a minimum, mapping components includes outfalls, drainage areas, and receiving streams. (d) Implement illicit Implement inspection program to detect dry weather flows at discharge detection system outfalls. Establish procedures for tracing the sources of procedures illicit discharges and for removing the sources. Develop procedures Ibr identification of priority areas likely to have Illicit discharges. Continue to Identify, locate, and update Illtlp of drainage system components on a priority basis per approved Illicit Discharge Program. (c) Conduct employee cross- Conduct training for city staff on detecting and reporting illicit training discharges. (1) Provide public education Inform public employees, businesses, and the general public of hazards associated with illegal discharges and improper disposal of waste that cause adverse water duality impacts. (g) Establish a public Establish and publicize a reporting mechanism for the public to reporting mechanism report illicit discharges. Implementation On September 26, 2006, '['own staff received permission via email from Mike Randall to amend its stormwater management plan to state that an Illicit Discharge Detection and hllminatlon Ordinance (legal authority — 13MP (b)) would not be adopted until Year 3. The purpose of' this request was to enable the town to focus on other requirements of the Phase I1 Storm�,vater Program. In its request, Town staff committed to "follow up on any complaints of illicit discharge and work with property and business owners to achieve voluntary compliance. In rare cases where no solution can be reached, town staff will contact state DENR officials for assistance and advice." The Town contracted with the Western Piedmont Council of Governments in Year 1 to develop a storm sewer map identifying outfall locations and mapping stormwater drainage system components. The map includes outfalls, drainage areas and receiving streams. Maiden will continue to update this map as appropriate in Year 2 and in subsequent years. Em Several Town staff (including Public Works employees) participated in the Illicit Discharge Detection and Elimination training sponsored by the North Carolina Cooperative Extension Service on September 14, 2006. Staff learned about the most common examples of illicit discharges, how to identify them and what actions to take upon identification. In this training, town staff also received information about "Good Housekeeping for Municipal Operations". In Year 2 and in subsequent years, Town staff will use the information gathered in these workshops to establish formal procedures to trace and remove the sources of illicit discharge as well as procedures for identifying target areas. During Year 2 and subsequent years, the staff will work to develop procedures for routine field inspections of priority areas to identify sources of illicit discharge. Information about illicit discharges was published in the Town's quarterly newsletter and discussed at public meetings. Future efforts will target homeowners and businesses about the hazards associated with illegal discharges and improper disposal of waste. A public reporting mechanism was established on the Town of Maiden's stormwater webpage. Respondents can call the Maiden "Town Hall, email the staff, call the 1-800-STOPMUD hotline or complete the online reporting form sponsored by NCDENR. For emergencies on nights, holidays or weekends, respondents are directed to call the Maiden Police Department. Spanish-speaking residents are encouraged to email the town staff. -9- CONSTRUCTION SITE RUNOFF CONTROLS Objectives for Construction Site Runoff Controls (a) Reduce pollutants in storinwater runoff from construction activities disturbing one or more acres of land surl'ace and those activities less than one acre that are part of a larger common plan of development. (b) Provide procedures for public input, sanctions to ensure compliance, requirements for construction site operators to implement appropriate erosion and sediment control practices, review of site plans which incorporates consideration of potential water quality impacts, and procedures for site inspection and enforcement of control measures. (c) Establish 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. BM Ps for Construction Site Runoff Controls The permittee shall implement the following BMPs to meet the objectives of. t11e Construction Site Runoff Control Program and shall notify the Division prior to modification of any goals. BMP Measurable Goals (a) Implement a program and Develop a regulatory mechanism and implement a establish a regulatory program requiring erosion and sediment controls at iechanism for erosion and constr1.101011S sites and providing for sanctions 10 C11SLIN sediment control compliance. (b) Develop requirements on Requirc construction site operators to implement construction site operators erosion and sediment control BMPs and to control construction site wastes that may cause adverse water quality impacts. (c) Provide educational and New materials may be developed by the permittee, or training materials for the permittee may use materials adopted from other construction site operators programs and adapted to the pernlittee's construction runoff controls prograin. (d) Institute plan reviews Review construction plans and establish procedures that incorporate water quality considerations in construction site plan reviews. (e) Establish public Establish procedures for receipt and consideration of information procedures erosion and sedimentation information submitted by t11e public. Publicize the procedures and contact M"I information. The procedures must lead directly to a site inspection or other timely follow-up action. (f) Establish inspection and Establish procedures for site inspection and enforcement procedures enforcement of control measure requirements. The procedures should include prioritizing areas of inspections based on local criteria. Implementation The Town of Maiden entered into contract with Catawba County to administer its P',rosion and Sedimentation Control Program in June 2005. Mown staff met with the county administrator of this program on October 13, 2005 to discuss administration of this program. During that meeting, it was agreed that Catawba County will send a yearly report to the Town at the end of each fiscal year detailing inspection histories and project information for all active projects within the Town of' Maiden and its ETJ. It was also agreed that the two jurisdictions Will report potential violations to each other in order to facilitate efficient inspection and action. f i % POST -CONSTRUCTION SITE RUNOFF CONTROLS Objectives for Post -Construction Site Runoff Controls (a) Manage stormwater runoff from new development / redevelopment that that drains to the MS4 and disturbs an acre or more of land surface, including projects less than an acre that are part ofa larger common plan of'developnicnt or sale. (b) Provide a mechanism to require long term operation and maintenance of 13MPs. (c) Ensure controls are in place to minimize water quality impacts. BMI's for Post -Construction Site Runoff Controls The permittee's Stormwater Management Ordinance and any subsequent amendments and the additional 13MPs below shall be implemented throughout the pormittee's jurisdictional area to meet the objectives of the Post -Construction Site R1.111off Control Program. 13MP Measurable Goals (a) Establish a Post Develop and adopt by ordinance (or similar regulatory Construction Stormwater mechanism) in year 1-2, to address post -construction Management Program runoff controls for new development and redevelopment. (b) Establish strategies which Provide a mechanism to require long-term operation include structural and non- and maintenance of structural 13MPs. Require annual structural 13MPs appropriate inspection reports of permitted structural BMPs for the MS4 performed by a qualified professional. (c) Establish a program to Control the sources of fecal coliform to the maxilnulll control the sources of fecal extent practicable. Develop and implement an coliform to the maximum oversight program to ensure proper operation and extent practicable maintenance of on -site wastewater treatment systems for domestic wastewater. Municipalities must coordinate this program with the county health department. Implementation This BMI' requires the development of an ordinance or similar regulatory mechanism to address post -construction runoff controls for new development and redevelopment by the end of Year 2. "Town staff' are working with the regional Stormwater Working Group to develop a Post - Construction ordinance that can be adopted by all municipalities in Catawba County. It is anticipated that this ordinance will be similar to the state model ordinance. "Town staff attended -12- L,� a local training session at the Western Piedmont Council of Governments with Richard Whisnant of the UNC School of Government on September 19 on the requirements for the post - construction ordinance. Once the Post -Construction ordinance is adopted, procedures for annual inspection of structural BMPs will be established. ']'his BMP also requires that the sources of fecal coliform be controlled to the maximum extent practicable. The Town ol' Maiden relies on the Catawba County Health Department to monitor the operation and maintenance of on -site wastewater treatment systems. The To\vn also benefits from the Unifour Septic Tank Program which helps low-income residents fund repairs and maintenance to Falling septic tanks. In Year 2 and subscquernt years, the Town will work with the Catawba County Health Department to develop and implement an oversight program especially along streams that have been identified as impaired due to fecal coliiorm, -13- POLLUTION PREVENTION AND GOOD I-IOUSEKEEI'ING FOR MUNICIPAL OPERATIONS Objective for Pollution Prevention and Good Housekeeping for Municipal Operations (a) Prevent or reduce stormwater pollution from municipal operations. BMI's for Pollution Prevention and Good Housekeeping for Municipal Operations The permittee shall implement the following BMPs to meet the objectives of the Pollution Prevention and Good Housekeeping Program. BMP Measurable Goals (a) Develop an operation and Develop an operation and maintenance program that has maintenance program the ultimate goal of preventing or reducing pollutant runoff from municipal operations. (b) Inspection and evaluation of Develop an inventory OI all lacllltles and operations facilities, operations, and the owned and operated by the permittee with the potential MS4 system and associated for generating polluted stormwater runoff, including the structural MS4 system and associated structural I3MPs. Inspect 13MPs potential sources of polluted runoff-, the stormwater controls, and conveyance systems. Evaluate the sources, document deficiencies, plan corrective actions, and document the accomplishment ol'corrective actions. (c) Conduct staff training Conduct staff training specific for pollution prevention and good housekeeping procedures. (d) Rcview of municipality Conduct annual review of the industrial activities with a owned or operated regulated Phase I NPDES stormwater permit owned and operated industrial activities by the permittee. Rcview the following aspects: the Storinwater Pollution Prevention flan where one is required, the timeiiness of any monitoring reports required by the Phase I permit, and the results Of', inspections and subsequent 1011Ow-Lip actions at the Ii1cilltics. Implementation Town staff have begun to develop and operation and maintenance program to fulfill this BW but the most important actions that have been taken have involved staff training and the education of public officials to understand the requirements of' the Phase 11 Prograin and educating the elected officials about the requirements of this program. Town staff are still working to develop an inventory of all facilities owned and operated by the permittee with the potential for generating polluted stormwater runoff, including the MS4 system and associated structural BMPs. Another requirement is to inspect potential sources 01' polluted -14- k% ! t runoff, the stornlwater controls, and conveyance systems. At completion, the illvclltory will include an evaluation of the facilities, documentation of- deficiencies and plan for corrective actions. Documentation ol'corrective actions taken will be accomplished using the existing work order system. In addition to the monthly meetings of' the Stormwater Working Group that involved presentations from many state officials regarding the Phase II Stormwater Program; Town staff have attended many trainings and workshops during Year f including: • June 22-23, 2005 — Managing and Funding Local Government Stormwater Enterprise workshop at the UNC Institute of Government in Chapcl Hill, NC • August 25, 2005 — Phase If overview workshop with Annette Lucas from the North Carolina Cooperative l]xtension Service in Newton, NC • November 23, 2005 — Phase II Stormwater workshop at the UNC Institute of Government in Chapel Hill, NC • February 15, 2006 — Phase 11 Stormwater workshop at the UNC Institute of Government in Chapel Hill, NC • May 24, 2006 — Illicit Discharge Detection and I:linlination and Good 1-101.1sekeeping for Municipal Officials workshop sponsored by the North Carolina Cooperative F xtension Service in Kannapolis, NC • September 14, 2006 — Illicit Discharge Detection and l limination and Good Housekeeping for Municipal Officials workshop sponsored by the North Carolina Cooperative lxtension Service in Hickory, NC • October 23, 2006 — Tour of the North Carolina Arboretum in Asheville. NC to learn about Good H0Usckecping nlcaSUreS that the Town can consider Implementing at its lacililies This BMP also requires that an annual review of the industrial activities with a Phase I NPDLS slormwater permit owned and operated by the permittee be conducted. The following aspects shall be reviewed: the Stormwater Pollution Prevention Plan where one is required, the timeliness ol'any monitoring reports required by the Phase I permit, and the results of�inspections and subsequent follow-up actions at the facilities. - 15 - CONCLUSION The Town of Maiden is actively working to implement all requirements of the Phase I Stormwater Program. Year i activities were primarily directed at education of "Down staff, elected officials and the general public. Town staff attended numerous trainings and meetings of' the Stormwater Working Group to learn about different Facets of the Phase 11 Stormwater Program, share resources and coordinate efforts where possible. Development of this program has been difficult task for the municipality because adequate stall' to implement the program does not currently exist and major staff' turnover has presented a major obstacle. Year 2 and subsequent years will be devoted to improving on the deficiencies in our current program and implementing the Post -Construction ordinance. -16-