SWM-PS 990617Regional Strategy for Managing
Storm Water Quality in North Central Texas
North Central Texas Council of Governments
Adopted on [Future Date]
The North Central Texas Council of Governments is the state - designated water quality management planning agency for
the urbanized portion of the Dallas — Fort Worth Metroplex. For the past thirty years, NCTCOG has conducted an active
planning and services program with its 200 member local governments on water quality issues. Since 1989, NCTCOG
has worked with the seven largest cities and two TxDOT districts in the region to develop and implement a regional
strategy to address the 1990 National Pollutant Discharge Elimination System ( NPDES) Phase I Rule for storm water.
Storm water runoff has become the Focus of many nation -wide regulatory efforts to address remaining water quality
problems. Original NPDES efforts to improve water quality through reducing pollutants in industrial wastewater and
municipal sewage treatment plant discharges have been very successful, but failure to meet water quality standards
continues to be a widespread problem. Storm water runoff from urban areas and agricultural land has been determined to
be a major cause of water quality impairment, including the inability of surface waters to meet their state - designated uses
to support recreation, aquatic life, and domestic water supply.
An expanded, watershed - based, regional effort is now underway to include the additional cities and counties in the Dallas -
Fort Worth- Denton urbanized area than are impacted by emerging regulations for storm water, total maximum daily loads
(TMDLs), and drinking water source water protection initiatives by state and federal agencies. On the recommendation of
the Regional Storm Water Management Coordinating Council, NCTCOG's Executive Board adopted this strategy.
Policy Position on Managing Urban Storm Water Quality
Local government agencies; in North Central Texas are dedicated to protecting the region's
waters by addressing both the quantity and quality of storm wafer runoff from urban areas. The
agencies within the urbanized areas of this region are committed to implementing a cooperative
and comprehensive program to manage storm water runoff to maximize the utilization of the
region's lakes, streams, and rivers for drinking water supply, recreation, fish and wildlife habitat,
and economic opportunity.
State and Federal Mandates to Address Urban Storm Water Quality
In addition to this Policy, the Regional Strategy is designed to address the following statutory requirements regarding
urban storm water quality:
Section 402(p) of the Clean Water Act, NPDES Phase I and Phase II Rules — Phase I, initiated in 1990, requires
municipalities of 100,000 population or greater to obtain permits for their separate storm water systems. Phase II is
designed to address storm water discharges from the separate storm water systems of jurisdictions within urbanized
areas having population under 100,000 and other jurisdictions designated by the EPA. These rules require regulated
municipalities to develop management programs to reduce the discharge of pollutants from their separate storm water
systems to the "maximum extent practicable." The Texas Natural Resource Conservation Commission ( TNRCC) has
assumed delegation of the storm water program from EPA and will continue to develop state regulations under the Texas
Pollutant Discharge Elimination System ( TPDES) program.
Section 303(d) of the Clean Water Act — requires states to: 1) identify and list waters that do not meet water quality
standards, 2) establish priority rankings for the waterbodies listed, and 3) develop total maximum daily loads (TMDLs) for
targeted waters, taking into account the severity of the pollution and the water useage The TNRCC has included stream
segments in the NCTCOG region on the 303(d) list and is addressing these segments through TMDL development,
targeted monitoring, special water quality studies, and source water protection efforts.
Safe Drinking Water Act Source Water Protection — requires each state to develop a source water assessment and
protection (SWAP) program which: (1) delineates the boundaries of the areas providing source waters for public drinking
water systems, and (2) identifies (to the extent practicable) the origins of regulated and certain unregulated contaminants
Final Draft -June 17, 1999
in the delineated area to determine the susceptibility of public water systems to such contaminants. Public water systems
may be required by TNRCC to implement a mandatory Best Management Practice (BMP) program or to pursue regulatory
options to control nonpoint source contamination of surface waters within the designated area should voluntary BMP
efforts and education programs fail.
Section 319(h) of the Clean Water Act — requires states to address water pollution by developing nonpoint source
pollution assessment reports that identify nonpoint source pollution problems and the sources responsible for the water
quality problems. States must then develop watershed management programs to control nonpoint source pollution.
Section 26.177 of the Texas Water Code — requires cities with 10,000 inhabitants or more, where water pollution
attributable to non - permitted sources in the city has been identified, to establish water pollution control and abatement
programs. The TNRCC will use water quality assessment studies such as those conducted through the Clean Rivers
Program, the State Water Quality Inventory, and the TMDL process to identify problem watersheds. Targeted cities are
responsible for the "development and execution of reasonable and realistic plans" to control storm water discharges and
urban runoff. Cities must also develop an inventory of all significant waste discharges (permitted and non - permitted) into
and adjacent to water within the city, and conduct regular monitoring of such discharges.
Goals
The goals of this expanded Regional Strategy for Managing Urban Storm Water Quality are to:
• protect the health and welfare of citizens and the environment
• effectively address state and federal regulations
• foster regional cooperation and share professional knowledge and experience
• lessen the expenditures of each local government by conducting cooperative activities wherever possible
• facilitate the collection and distribution of information to agencies
• provide training to governmental staff and the development community
• negotiate as one collective entity with the! EPA and state
• facilitate consistency in the collection and interpretation of water quality data
• identify "regionally appropriate and cost effective" Best Management Practices
• achieve proportionate share of pollution reduction among all pollutant contributors in a watershed
• reserve implementation decisions for each governmental agency.
Cooperative Initiatives
Local governments, through the North Central Texas Council of Governments, will implement this Regional Strategy by
developing and implementing, to the greatest extent possible, a cooperative program comprised of the following major
elements:
Local Government Participation and Oversight
Guidance for the development and implementation of the regional program is provided by the Regional Storm
Water Management Coordinating Council ( RSWMCC), an advisory body comprised of local government
officials. The membership structure of the Council is designed to be representative of the various sizes of
communities and the geographic distribution of entities among regionally defined watersheds.
Through the regional program, roundtable discussions are held in each watershed to provide an opportunity
for exchange of information between program participants, RSWMICC members, and NCTCOG staff.
RSWMCC members are then able to reflect the interests of their watershed in regular meetings held to guide
the regional strategy. In addition, regular forums are conducted to provide information to all participants and
other interested parties on special topics, including specific elements of the regulations.
Regional Storm Water Resource Center
The field of storm water quality management is relatively new and is changing continuously. In order for
governmental agencies to make unformed decisions, they must have access to cutting -edge information from
Final Draft —June 17, 1999
around the country, as well as information on what their neighbors are doing. In addition, agency staffs need
to be able to effectively communicate proposed policies to their managers, councils, and the public.
Resource Center staff at NCTCOG could research, acquire, and catalog storm water management
information including manuals, guidebooks, public education materials, reports, and articles, as well as
drainage criteria manuals and storm water management programs from regulated cities. Local governments
in the region could be periodically surveyed on their storm water management programs and the findings
would be reported to local agencies. The Resource Center could maintain an updated Internet presence and
provide custom - generated maps, charts, and other presentation materials to participants.
AMPublic Participation in Program Development
Involvement of the public iin the development of programs to control the quality of storm water is important to
the ultimate success of the programs. Individual citizens, members of the development and construction
community, representatives of environmental organizations, and representatives of other civic and interest
groups need to be given the opportunity to participate in the program formulation process.
A concerted effort could be undertaken to identify and inform interest groups throughout the Metroplex of the
efforts underway. Stakeholders could be invited to fully participate at the watershed meetings, attend regional
forums, and to provide comments at meetings of the RSWMCC. When appropriate the RSWMCC and
NCTCOG staff could provide their expertise to participating members who wish to hold public meetings in
their communities to get local input on development of their local requirements.
MOPublic Education
Education of the public on the impact of their everyday activities on the quality of storm water is a key element
of the storm water prograrn. Citizens must be made aware of the potential hazards associated with their
household practices. Education on the proper usage of lawn and garden, household, automotive, and pool
chemicals and proper disposal of these household hazardous wastes could be major elements of the public
education program. In addition, non - permitted commercial, institutional, and industrial entities whose
operations could have a significant impact on storm water quality also need to be informed of their potential
impacts and practical ways to mitigate these impacts.
Opportunities abound to reach citizens and businesses throughout the Metroplex in a coordinated program.
Regional education and outreach programs can be more economical and effective than initiatives by
individual agencies. Public: outreach activities to be promoted through the regional program could include
radio and television campaigns, public service announcements, video production, outreach programs at
schools, health fairs and festivals, brochure and flier development, web site development, and others.
- - Control of Construction Siite Storm Water Runoff
Construction activities can have a major impact on the health of the ecosystems of our streams, rivers, and
reservoirs. Sediment carried from construction sites by storm water runoff is deposited on the bottom of
streams and rivers, and collects in reservoirs, reducing their storage capacity. Practices to control the runoff
of sediment and other pollutants from construction sites have proven to be effective and are gaining
acceptance in the construction industry as the EPA and many local governments implement runoff control
requirements.
As with any other aspect of the construction process, uniformity of policies to control storm water runoff from
construction sites throughout the Metroplex is very beneficial to contractors, developers, and engineers who
often work in many different communities. Regional uniformity also strengthens the position of the region as a
whole to compete with other areas of the country. The regional' program could continue to offer training
classes to local government storm water inspectors. This training program
developers, engineers, and contractors involved in construction act g t es inorderr to ed ca educate the private
sector on runoff control techniques. The Construction BMP Manual, which is recommended for adoption by
all jurisdictions, could be periodically updated to reflect the latest changes in construction Best Management
Practices. Additional materials such as a model ordinance for control of storm water from construction
activities could be developed.
Management of Storm Water Impacts associated with Development
In addition to the temporary impacts of construction activities on the quality of storm water, development of
land typically causes permanent impacts on both storm water quantity and quality. The amount of runoff from
developed land will generally exceed that of undeveloped land and has been shown through the DFW
Final Draft — June 17, 1999
regional monitoring program to contain higher levels of pollutants such as oil and grease, metals, nutrients,
and sediment. Reducing the amount of pollutants in storm water discharge at the source through proper
planning and design is often more efficient and cost - effective than trying to address polluted storm water after
it has entered the storm sewer system. The impact of development has been addressed in other regions of
the country through 1) source controls such as reducing impervious surface, using natural drainageways
instead of concrete channels, and maintaining buffers along streams; and 2) treatment controls such as
ponds or basins for large developments.
There are at least three key areas where local governments, working cooperatively and with the private
sector, could improve their own development management processes to integrate storm water quality and
quantity goals : 1) comprehensive planning, where storm water quality and quantity are addressed together
as part of the overall long -range planning process of each community; 2) development policies and standards,
where the full range of local requirements from building codes to subdivision rules are re- examined; and 3)
capital improvements programming and impact fees, where local governments themselves are "developers"
of the community infrastructure.
Illicit Discharge Detection and Elimination
Discharges from storm sewers often include waste from non -storm water sources, including improper or
illegal connections from homers or businesses and infiltration of flow from broken sewer mains. Illicit
discharges are so -named because storm sewers are not designed to accept and process raw sanitary wastes
or discharges of wastewater from automobile service stations, car washes, or light industrial facilities.
The regional program could assist local jurisdictions in the detection and elimination of illicit discharges
through the following: 1) technical assistance in mapping major storm sewer outfalls (geographic information
system (GIS) and global position system (GPS) training and support); 2) technical assistance in detecting
illicit discharges in dry weather flows (field- screening training and support); 3) tracking of citizen complaints
through the Stop Illegal Dumping regional hotline 4) development of a model ordinance to prohibit illicit
discharges; and 5) assistance with education of the public on the hazards associated with illegal discharges
(to be addressed as a component of the public education measure described above).
Municipal Pollution Prevention
° Local governments must lead by example if they are to succeed in changing the practices and habits of
businesses and residents. Toward this end, the goal of governments must be to prevent or reduce pollutant
runoff from municipal operations including streets, highways, municipal parking lots, maintenance facilities,
storage yards, and waste transfer stations. Agencies must also remove floatables and other pollutants
discharged from storm sewers and develop procedures for proper disposal of those wastes.
Through the regional program, a regional guidance manual could be developed, to be adopted by individual
entities, which would provide for cost - effective control of pollutants from a wide range of municipal operations.
In addition, a training program and educational materials could be developed for training municipal /agency
employees on the requirements and resulting benefits of the pollution prevention program.
Regional Cooperative Monitoring
Information on the quality of storm water discharges and receiving waters is the most definitive method for
e' °a apa, determining the success of a storm water management program. Baseline water quality data prior to
implementation of the program followed by periodic and strategic monitoring provide a measure of program
performance. Several monitoring efforts are currently underway, including the Phase I regional monitoring
program and Trinity River Authority sampling under the Clean Rivers Program.
The Phase I regional monitoring program is one of the most extensive storm water quality monitoring
programs in the nation and provides the needed baseline information. Continuation of this program would
serve to document management program effectiveness. The regional program could also facilitate the
sharing of monitoring data among government agencies by fosterincl cooperation in the sample collection,
quality assurance protocols, and analysis of water samples.
Final Draft — June 17, 1999
Expanded Regional Strategy for Managing
Storm Water Quality in North Central Texas
North Central Texas Council of Governments
Adopted on [Future Date]
The North Central Texas Council of Governments is the state - designated water quality management planning agency for
the urbanized portion of the Dallas — Fort Worth Metroplex. For the past thirty years, NCTCOG has conducted an active
planning and services program with its 200 member local governments on water quality issues. Since 1989, NCTCOG
has worked with the seven largest cities and two TxDOT districts in the region to develop and implement a regional
strategy to address the 1990 National Pollutant Discharge Elimination System ( NPDES) Phase I Rule for storm water.
Storm water runoff has become the focus of many nation -wide regulatory efforts to address remaining water quality
problems. Original NPDES efforts to improve water quality through reducing pollutants in industrial wastewater and
municipal sewage treatment plant discharges have been very successful, but failure to meet water quality standards
continues to be a widespread problem. Storm water runoff from urban areas and agricultural land has been determined to
be a major cause of water quality impairment, including nonattainment of designated uses.
An expanded, watershed - based, regional effort is now underway to include the additional cities and counties in the Dallas -
Fort Worth- Denton urbanized area that are impacted by emerging regulations for storm water, total maximum daily loads
(TMDLs), and drinking water source water protection initiatives by state and federal agencies. On the recommendation of
the Regional Storm Water Management Coordinating Council, NCTCOG's` Executive Board adopted this strategy on
[Future Date].
Policy Position on Managing Urban Storm Water Qu
The North Central Texas
waters through the impler
water runoff from urban
lakes, streams, and rivers
wildlife habitat, and to sup
State and Federal Mandates to
)vernments'rs pledged to the protection of the region's
comprehensive program to address the quality of storm
purpose of-ensuring the fullest public enjoyment of its
hated uses of drinking water supply, recreation, fish and
my of the region.
Storm Water Quality
In addition to this Policy, the Regional Strategy is designed to address the following statutory requirements regarding
urban storm water quality:
Section 402(p) of the Water Pollution Control Act NPDES Phase I and Phase II Rules — Phase I, initiated in 1990,
requires municipalities of 100,000 population or greater to obtain permits for their separate storm water systems. Phase II
is designed to address storm water discharges from the separate storm water systems of urban municipalities with
populations under 100,000 and other designated municipalities. These rules require regulated municipalities to develop
management programs to reduce the discharge of pollutants from their separate storm water systems to the "maximum
extent practicable." The Texas Natural Resource Conservation Commission ( TNRCC) has assumed delegation of the
storm water program from EPA and will continue to develop state regulations under the Texas Pollutant Discharge
Elimination System ( TPDES) program.
Section 303(d) of the Water Pollution Control Act — requires states to identify and list waters that do not meet water quality
standards, to establish priority rankings for the waterbodies listed, and to develop TMDLs for targeted waters, taking into
account the severity of the pollution and the uses to be made of the waters. The TNRCC has included stream segments
in the NCTCOG region on the 303(d) list and is addressing these segments through TMDL development, targeted
monitoring, special water quality studies, and source water protection efforts. TNRCC could implement corrective
measures through a program consisting of federal, state, and local non - regulatory or incentive -based elements or they
could require modifications to local regulations or ordinances related to zoning, land use, and storm water runoff to meet
water quality standards.
Draft — February 4, 1999
Safe Drinking Water Act Source Water Protection — requires each state to develop a source water assessment and
protection (SWAP) program which: (1) delineates the boundaries of the areas providing source waters for public water
systems, and (2) identifies (to the extent practicable) the origins of regulated and certain unregulated contaminants in the
delineated area to determine the susceptibility of public water systems to such contaminants. Public water systems may
be required by TNRCC to implement a mandatory Best Management Practice (BMP) program or to pursue regulatory
options to control nonpoint source contamination of surface waters within the designated area should voluntary BMP
efforts and education programs fail.
Section 319(h) of the Water Pollution Control Act — requires states to address nonpoint pollution by developing nonpoint
source assessment reports that identify nonpoint source pollution problems and the nonpoint sources responsible for the
water quality problems. States must then develop management programs to control nonpoint source pollution.
Section 26.177 of the Texas Water Code — requires cities with 10,000 inhabitants or more, where water pollution
attributable to non - permitted sources in the city has been identified, to establish water pollution control and abatement
programs. The TNRCC will use water quality assessment studies such as those conducted through the Clean Rivers
Program, the State Water Quality Inventory, and the TMDL process to identify problem watersheds. Targeted cities are
responsible for the "development and execution of reasonable and realistic plans" to control storm water discharges and
urban runoff. Cities must also develop an inventory of all significant waste discharges (permitted and non - permitted) into
and adjacent to water within the city, and conduct regular monitoring of such discharges.
Goals
This Regional Strategy for Managing Urban Storm Water Quality is intended to achieve the following goals:
• to improve and maintain the quality of the region's streams, rivers and-lakes, as stated in the Policy Position
• to foster regional cooperation through watershed - oriented roundtable activities to collectively address urban storm
water quality
• to negotiate as one region with the EPA and state on the interpretation of the rules and requirements
• to reduce the administrative burden to each local government associated with1be regulatory process
• to save money for each local government by conducting cooperative activities wherever possible
• to share professional knowledge ..and experience I on this complex ` subject through a Regional Storm Water
Management Coordinating Council of affected1ocal governments and others
• to facilitate consistent quality in the collection, interpretation:and presentation of information
• to facilitate the use of available resources within the region, such as consultants and universities, in conducting
cooperative activities
• to evaluate together at the local level what controls are "regionally appropriate and cost effective" for managing urban
storm water quality
• stay informed of Best Management Practices being used throughout the country, including information on
effectiveness, cost, and maintenance requirements
• to ensure that all contributors of pollutants do their proportionate share in helping to achieve applicable standards for
surface water quality and to restore impaired water bodies
• to preserve implementation decisions for each governmental agency
(To be expanded and modified by RSWMCC)
Draft — February 4, 1999
Cooperative Initiatives
The North Central Texas Council of Governments will implement its Policy and Goals by developing and implementing, to
the greatest extent possible, a cooperative program comprised of the following major elements:
[Note: The initiatives included below are a sample of potential initiatives and are intended to stimulate discussion. These
elements will evolve during the course of strategy development over the coming months based on input from participants.
Additional Regional Initiatives, such as Source Identification, Industrial Discharges, Regional Monitoring, Phase ll
Minimum Measures, and others, may be added to the program.]
Public Education and Outreach
Education of the public on the impact of their everyday activities on the quality of storm water is a key element
of the storm water program. Citizens must be made aware of the potential hazards associated with their
household practices and educated on the proper usage of lawn and garden chemicals and proper disposal of
used motor oil and household hazardous wastes. In addition, non - permitted commercial, institutional, and
industrial entities whose operations could have a significant impact on storm water quality also need to be
informed of their potential impacts and practical ways to mitigate them.
Opportunities abound to reach citizens and businesses throughout the Metroplex in a coordinated program.
Regional education and outreach programs are more economical and effective than initiatives by individual
agencies. Examples of public outreach activities to be promoted through the regional program include radio
and television campaigns, public service announcements, video production, brochure and flier development,
web site development and hosting, and others.
;Y r Construction Site Storm Water Runoff Control
Construction activities can have a major impact on the health of our streams, rivers, and reservoirs. Sediment
carried from construction sites by storm water runoff collects in reservoirs, reducing storage capacity, and is
deposited on the bottom of streams and rivers. Practices to control the runoff of sediment and other
pollutants from construction sites have proven to be effective and are gaining acceptance in the construction
industry as the EPA and many local, governments implement runoff control requirements.
As with any other aspect of the'construction process, uniformity of policies to control storm water runoff from
construction sites throughout'the Metroplexis very beneficial to contractors, developers, and engineers who
often work in many different communities. Regional uniformity also strengthens the position of the region as a
whole to compete with other areas of.the country. The regional program will continue offer training classes to
local government storm water inspectors." This training program will also be offered to developers, engineers,
and contractors involved in construction activities in order to educate the private sector on runoff control
techniques. The regional,; program will continue to provide local governments with technical guidance,
including the Construction BMP Manual, which will be periodically updated to reflect the latest changes in
construction Best Management Practices. Additional materials such as a model ordinance for control of storm
water from construction activities will be developed.
Implementation of Regional Strategy
[This section will be expanded to include specific elements derived from the Cooperative Initiatives necessary to
accomplish the Regional Strategy, broken down by fiscal year.]
The Regional Strategy will meet the program goals as follows:
FY1999 — Development of Regional Strategy Program and dissemination of storm water program information
FY2000 — Review of federal and state regulations and development of regional and watershed initiatives
FY2001 — Continued development of regional and watershed initiatives, including coordination of Phase I permit
renewals with Phase II permit issuance
FY2002 — Final development and submission of regional and watershed initiatives
FY2002 through FY2007 — Implementation of regional and watershed initiatives
Draft — February 4, 1999