NCS000422_Black Mtn Draft SWMP v2 DEQ Comment Letter_20210219

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
BRIAN WRENN
Acting Director
VIA EMAIL ONLY
RETURN RECEIPT REQUESTED
Town of Black Mountain
Attn: Larry B. Harris, Mayor
larryat850gmail.com
160 Midland Avenue
Black Mountain, NC 28711
NORTH CAROLINA
Environmental Quality
February 18, 2021
Subject: COMMENTS ON DRAFT SWMP (NOV-2020-PC-0116)
Town of Black Mountain
NPDES MS4 Permit No. NCS000422
Buncombe County
Dear Mayor Harris:
On February 12, 2020, the North Carolina Department of Environmental Quality (DEQ) audited the Town
of Black Mountain (Town) for compliance with the subject NPDES MS4 permit. As a result, a Notice of
Violation (NOV) was issued to the Town on February 27, 2020. The NOV defined specific document
submittals and deadlines. The required Draft SWMP submittal (version 1) was received on May 4, 2020.
DEQ comments on the Draft SWMP vl were provided on November 30, 2020. DEQ received the
required second Draft Stormwater Management Plan (SWMP) submittal on February 9, 2021.
Staff have reviewed the submitted Draft SWMP v2 and have found it to be insufficient to meet the
requirements. Please consult the SWMP Template Instructions and General SWMP Guidance on
the DEO MS4 Forms & Resources web page for additional information on preparing an
approvable SWMP and address the general comments provided below. Specific comments will be
provided once an acceptable SWMP has been submitted for review.
The revised Draft SWMP is required to be signed and submitted to DEQ within thirty (30)
calendar days of receipt of this letter.
General Comments:
1. Measurable Goals must be specific, measurable, achievable, realistic and timely BMPs to define
the specific steps to bring the program into compliance over the permit term. Many provided
measurable goals are too vague to convey the task that will be performed. Define the overall goal
of the tasks in the BMP (Column A) section to provide context for the measurable goals.
2. Include frequencies in Column C - Schedule for Implementation (Once, Annually, Continuously,
etc.) and specific Permit Years that the measurable goal tasks(s) will be performed.
3. Annual Reporting Metrics in Column D must be brief and should be a reportable quantity,
Y/N/Status, etc. Results, documentation, etc. are not appropriate reporting metrics, but do
D EQ
�� North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 27699-1612
NORTH CAROLINA -
oaPartm.M ofEnvironmental n�ara 919.707.9200

identify tasks and supporting information that should be maintained on site for future compliance
audits.
Please also be aware that the SWMP will directly translate into an excel spreadsheet for the
annual assessment (annual report) that will be required once a new permit is issued. Therefore,
reporting metrics should be brief and additional documents will not be acceptable. This is to
facilitate electronic annual reporting in the future. These annual assessments will be utilized to
ensure the MS4 is on track to compliance. However, supporting documentation should be
maintained on site for the next compliance audit.
The required revised Draft SWMP v3 submittal must a hard copy with a certifying statement and original
"wet" signature by the Town's ranking elected official or designated staff member in compliance with
Part IV, Paragraph G of the current MS4 Permit.
Please submit the required signed Draft SWMP v3 to:
DEQ-DEMLR Stormwater Program
Attn: Jeanette Powell
1612 Mail Service Center
Raleigh, NC 27699-1612
Jeanette. poweakncdenr.gov
Thank you for your prompt attention to this matter. Should you have any questions, please contact me at
[phone] or Jeanette.Powell(c-r�,ncdenr.gov.
Sincerely,
Jeanette Powell
MS4 Program Coordinator
Cc via email:
Jessica Trotman, Planning Director jessica.trotmanktownofblackmountain.org
Annette Lucas, DEMLR Stormwater Program Supervisor
Stan Aiken, Asheville Regional Office
Isaiah Reed, Asheville Regional Office
DEMLR NPDES MS4 Permit Laserfiche File