Yes, the County and the Towns agree upon a rate for services each year and a Work Plan is developed to meet the Phase II permit program requirements. For work that is performed for a particular Town (say a facility inspection), that Town is charged for the time. For work that is associated with a program measure that applies throughout all jurisdictions (such as the public involvement program), the time is divided between each jurisdiction based upon their impervious area, which represents each jurisdiction's contribution to storm water run-off.
1. Why did Mecklenburg County and the six Towns decide to "co-permit" together under a single Phase II permit?
The decision to co-permit was made to share the effort and cost required to implement the six minimum measures, to ensure consistency in Storm Water Programs throughout Mecklenburg County, and to simplify administration and implementation of each program. Since the majority of the minimum measures are program-based, a single program can be used throughout each of the seven jurisdictions rather than have seven different programs. Instead of each Town hiring staff to implement the Phase II programs, the Towns rely on over 30 County staff to assist in implementing the various programs. Implementing a single, coordinated Phase II program is easier for the County to administer than implementing seven different programs.
2. Do the Towns pay the County to administer the Phase II programs?
How much do the Towns pay for administration of their Storm Water Program?
On average, the Towns pay approximately $3.20 per resident (based on Census figures) per year. The Towns use revenue from their jurisdiction's storm water fees to pay the County to administer their Phase II storm water programs.
Have any of the co-permittees wanted to implement a program element differently than the other permittees?
Yes, as part of the Illicit Discharge Detection and Elimination Program, one Town decided to use Town GIS staff to perform field mapping of the inlets and outlets for their MS4 system. This information was then downloaded and incorporated into the overall Phase II mapping system. One important lesson learned about this approach was that additional coordination was necessary to ensure that the Town's GIS layers and coordinates were compatible with the overall Phase II mapping system.
Has cooperation between the different Towns been difficult?
Building trust between County staff and the Towns was key to this permitting approach. Previous partnerships with the Towns to deliver other services (such as land development / engineering review of plans) established a level of confidence and trust between the County and the Towns.
Phase I and Phase II permits in North Carolina contain requirements for a Comprehensive Storm Water Management Program Report (or Storm Water Plan) that includes components of the permit application package and the report submitted at the time of application. Do you have a written report or are you relying on the information submitted in your application?
We have a written Storm Water Management Program Report that fulfills this requirement in our permit. Since our permit was issued 3 years after submittal of our application, some of the information submitted in our application was obsolete and needed to be updated. Having a separate Storm Water Plan allows us the flexibility to update our programs (as the need arises), document the updates, and inform the North Carolina Division of Water Quality (NCDWQ) of the changes. Since the provisions of the Storm Water Plan are incorporated by reference into our permit, the County felt it important that plan be easily updated to maintain compliance with our permit.
What are the major components of your written Storm Water Plan?
The purpose of the plan is to document the Best Management Practices (BMPs) or activities we are performing to meet the six minimum program measures in our permit. For each program measure, the report contains a description of each BMP implemented as part of the program. For each BMP, the report lists a measurable goal, schedule of implementation, and the role of the person implementing the measure. In addition, copies of regulations and ordinances (as required by the permit) are included as appendices to the report.
Phase I and Phase II Permits contain annual reporting requirements. NCDWQ has an internet-based electronic Storm Water Program Assessment Report that can be completed on-line. Have you used this reporting mechanism and how user-friendly is it?
Our first annual report (required by our permit) was submitted in August 2006. We did use the electronic report submittal developed by NCDWQ. Since this was the first reporting event that the electronic submittal was available, we worked closely with NCDWQ in completing this report and helped identify some of the "bugs" in the system. Staff took nearly 100 hours to gather the information and complete the annual report electronically. This time included gathering information from each of the co-permittees, determining which information in the report was required to be submitted and which information was optional, coordination with NCDWQ regarding use of the electronic system, and data entry into the system. Staff anticipates that the effort required to complete future reports will be less than the effort required to complete the initial report.
Mecklenburg County's Phase II Permit
Phase II Storm Water Management Plan
Illicit Discharge Detection and Elimination Policies and Procedures (Manual for City of Charlotte, Mecklenburg County, Cornelius, Davidson, Huntersville, Matthews, Mint Hill and Pineville)
For more information, contact:
County Water Quality Program Manager
Charlotte-Mecklenburg Storm Water Services