v>EPA
United States
Environmental Protection
Agency
Office of Water EPA 833-F-00-006
(4203) January 2000 (revised December 2005)
Fact Sheet 2.4
Storm water Phase II
Final Rule
Stormwater Phase II
Final Rule
Fact Sheet Series
Overview
1.0 - Stormwater Phase II Final
Rule: An Overview
Small MS4 Program
2.0 - Small MS4 Stormwater
Program Overview
2.1 - Who's Covered? Designation
and Waivers of Regulated Small
MS4s
2.2 - Urbanized Areas: Definition
and Description
Minimum Control Measures
2.3-Public Education and
Outreach
2.4-Public Participation/
Involvement
2.5 - Illicit Discharge Detection
and Elimination
2.6 - Construction Site Runoff
Control
2.7 - Post-Construction Runoff
Control Minimum Control Measure
2.8 - Pollution Prevention/Good
Housekeeping
2.9 - Permitting and Reporting:
The Process and Requirements
2.10 - Federal and State-Operated
MS4s: Program Implementation
Construction Program
3.0 - Construction Program
Overview
3.1 - Construction Rainfall
Erosivity Waiver
Industrial "No Exposure"
4.0 - Conditional No Exposure
Exclusion for Industrial Activity
Public Participation/ Involvement
Minimum Control Measure
This fact sheet profiles the Public Participation/Involvement minimum control measure, one
of six measures the operator of a Phase II regulated small municipal separate storm sewer
system (MS4) is required to include in its Stormwater management program to meet the
conditions of its National Pollutant Discharge Elimination System (NPDES) permit. This fact
sheet outlines the Phase II Final Rule requirements and offers some general guidance on how to
satisfy them. It is important to keep in mind that the small MS4 operator has a great deal of
flexibility in determining how to satisfy the minimum control measure requirements.
Why Is Public Participation and Involvement Necessary?
EPA believes that the public can provide valuable input and assistance to a regulated small
MS4's municipal Stormwater management program and, therefore, suggests that the public
be given opportunities to play an active role in both the development and implementation of the
program. An active and involved community is crucial to the success of a Stormwater
management program because it allows for:
• Broader public support since citizens who participate in the development and decision
making process are partially responsible for the program and, therefore, may be less
likely to raise legal challenges to the program and more likely to take an active role in
its implementation;
• Shorter implementation schedules due to fewer obstacles in the form of public and legal
challenges and increased sources in the form of citizen volunteers;
• A broader base of expertise and economic benefits since the community can be a
valuable, and free, intellectual resource; and
• A conduit to other programs as citizens involved in the Stormwater program
development process provide important cross-connections and relationships with other
community and government programs. This benefit is particularly valuable when trying
to implement a Stormwater program on a watershed basis, as encouraged by EPA.
What Is Required?
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Fact Sheet 2.4 - Public Participation/Involvement Minimum Control Measure
Page 2
What Are Some Guidelines for Developing and
Implementing This Measure?
Operators of regulated small MS4s should include the public
in developing, implementing, updating, and reviewing their
stormwater management programs. The public participation
program should make every effort to reach out and engage all
economic and ethnic groups. EPA recognizes that there are
challenges associated with public involvement. Nevertheless,
EPA strongly believes that these challenges can be addressed
through an aggressive and inclusive program. Challenges and
example practices that can help ensure successful participation
are discussed below.
Implementation Challenges
The best way to handle common notification and recruitment
challenges is to know the audience and think creatively about
how to gain its attention and interest. Traditional methods of
soliciting public input are not always successful in generating
interest, and subsequent involvement, in all sectors of the
community. For example, municipalities often rely solely on
advertising in local newspapers to announce public meetings
and other opportunities for public involvement. Since there
may be large sectors of the population who do not read the
local press, the audience reached may be limited. Therefore,
alternative advertising methods should be used whenever
possible, including radio or television spots, postings at bus or
subway stops, announcements in neighborhood newsletters,
announcements at civic organization meetings, distribution
of flyers, mass mailings, door-to-door visits, telephone
notifications, and multilingual announcements. These efforts,
of course, are tied closely to the efforts for the public education
and outreach minimum control measure (see Fact Sheet 2.3).
In addition, advertising and soliciting help should be targeted at
specific population sectors, including ethnic, minority, and low-
income communities; academia and educational institutions;
neighborhood and community groups; outdoor recreation groups;
and business and industry. The goal is to involve a diverse
cross-section of people who can offer a multitude of concerns,
ideas, and connections during the program development process.
Possible BMPs
There are a variety of practices that could be incorporated into
a public participation and involvement program, such as:
• Public meetings/citizen panels allow citizens to discuss
various viewpoints and provide input concerning
appropriate stormwater management policies and BMPs;
• Volunteer water quality monitoring gives citizens first-
hand knowledge of the quality of local water bodies and
provides a cost-effective means of collecting water
quality data;
• Volunteer educators!speakers who can conduct workshops,
encourage public participation, and staff special events;
• Storm drain stenciling is an important and simple activity
that concerned citizens, especially students, can do;
• Community clean-ups along local waterways, beaches, and
around storm drains;
• Citizen watch groups can aid local enforcement authorities
in the identification of polluters; and
• "Adopt A Storm Drain " programs encourage individuals
or groups to keep storm drains free of debris and to monitor
what is entering local waterways through storm drains.
What Are Appropriate Measurable Goals?
Measurable goals, which are required for each minimum control
measure, are intended to gauge permit compliance and
program effectiveness. The measurable goals, as well as the
BMPs, greatly depend on the needs and characteristics of the
operator and the area served by the small MS4. Furthermore, they
should be chosen using an integrated approach that fully addresses
the requirements and intent of the minimum control measure.
EPA has developed a Measurable Goals Guidance for Phase II
MS4s that is designed to help program managers comply with the
requirement to develop measurable goals. The guidance presents an
approach for MS4 operators to develop measurable goals as part of
their stormwater management plan. For example, an MS4 could
conclude as part of its Illicit Discharge Detection and Elimination
program that a certain section of town has a high incidence of used
motor oil dumping. The watershed has numerous automotive
businesses including small repair shops, large auto dealerships, gas
stations, and body shops. In addition, there are several large
apartment complexes with areas that could be used as "do-it-
yourself oil change areas. The MS4 organizes a public meeting in
the watershed to not only educate residents about stormwater issues
and permit requirements, but also to ask for input regarding
possible dumping areas and to determine if the community needs
an oil recycling facility or some other way to safely dispose of used
motor oil. In this way, the MS4 might better understand who the
target audience is for illegal dumping control while implementing a
valuable service for the watershed community.
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Fact Sheet 2.4 - Public Participation/Involvement Minimum Control Measure
Page 3
For Additional Information
Contacts
"^ U.S. EPA Office of Wastewater Management
http://www.epa.gov/npdes/stormwater
Phone: 202-564-9545
"^ Your NPDES Permitting Authority. Most States and
Territories are authorized to administer the NPDES
Program, except the following, for which EPA is the
permitting authority:
Alaska
District of Columbia
Idaho
Massachusetts
New Hampshire
New Mexico
American Samoa
Guam
Johnston Atoll
Midway and Wake Islands
Northern Mariana Islands
Puerto Rico
Trust Territories
"^ A list of names and telephone numbers for each EPA
Region and State is located at http ://www. epa. gov/
npdes/stormwater (click on "Contacts").
Reference Documents
"^ EPA's Stormwater Web Site
http://www.epa.gov/npdes/stormwater
• Stormwater Phase II Final Rule Fact Sheet Series
• Stormwater Phase II Final Rule (64 FR 68722)
• National Menu of Best Management Practices for
Stormwater Phase II
• Measurable Goals Guidance for Phase II Small
MS4s
• Stormwater Case Studies
• And many others
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