TRASH
STORMWATER PERMIT
COMPENDIUM
' \AV

A compendium of excerpted permit language from municipal separate storm
sewer system (MS4) permits and other resources that can be used and/or
tailored for trash-specific MS4 permits.

Office of Wetlands, Oceans and Watersheds
Office of Wastewater Management
April 2021
EPA-841-R-21-001

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TABLE OF CONTENTS
TABLE OF CONTENTS
CHAPTER 1. INTRODUCTION	1
CHAPTER 2. EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS	3
Public Education and Outreach	5
Public Participation and Involvement	12
Illicit Discharge Detection and Elimination	14
Construction Site Runoff Control	17
Pollution Prevention and Good Housekeeping	18
Floatables Management Programs, Monitoring and Reporting	26
CHAPTER 3. BEST MANAGEMENT PRACTICES FOR REDUCING TRASH IN
STORMWATER	39
CHAPTER 4. CASE STUDIES	47
New York City (NYC) Case Study	47
Fairfax County, VA Case Study 	50
BMP REFERENCES	55
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1 INTRODUCTION
CHAPTER 1. INTRODUCTION
This compendium is one in a series of documents developed by EPA as a resource for stormwater
permit writers.1 The purpose of this compendium is to provide Phase I and Phase II Municipal
Separate Storm Sewer System (MS4) permit writers with tools and information they can use in
developing trash-related provisions for MS4 permits.
Trash that is improperly disposed of - either intentionally or inadvertently - can enter fresh water
and coastal ecosystems. This "aquatic trash" may eventually make its way to the ocean. Up to 80
percent of trash in the world's oceans comes from land-based sources.2 This trash has become a
pervasive problem, presenting a challenge to water quality and habitat protection, in addition to
causing aesthetic blight, ecological effects, economic impacts, and possible human health risks.
Effective stormwater management implemented through MS4 permits is an important tool for
preventing trash from entering or accumulating in inland and coastal waters and keeping it out of
the ocean.
In the following three chapters, this compendium provides examples of provisions in existing
permits that can serve as models for addressing trash reduction in MS4 permits; presents
information on best management practices (BMPs) in trash reduction; and presents two MS4
permit case studies showcasing clear, specific and measurable trash-related provisions and the
related municipal floatables programs.
Overall, the compendium is intended to illustrate opportunities for permit writers to address trash
through MS4 permits. It is a snapshot of existing permit provisions and information on available
BMPs. Permit writers can use this document as a guide for developing MS4 permit provisions
related to trash in multiple ways, including:
i.	Utilizing the example trash provisions included in existing MS4 permits as a starting
point from which to develop similar requirements.
ii.	Learning more about BMPs and identifying information about BMPs that can be shared
with permit holders, including information on cost, maintenance, and effectiveness.
iii.	Applying lessons learned from case studies of past successes in developing strong trash-
related MS4 permit provisions towards the development of new permits and
comprehensive floatables programs.
1	See Municipal Separate Storm Sewer System Permits, Compendium of Clear, Specific & Measurable Permitting
Examples, Office of Wastewater Management, Water Permits Division, November 2018.
https://www.epa.gov/sites/production/files/2018-ll/documents/fmal compendium intro document rev-ll-15-18.pdf
2	Eunomia, Plastics in the Marine Environment (June 2016), http://www.eunomia.co.uk/reports-tools/plastics-in-
themarine-environment/.
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1 INTRODUCTION
EPA anticipates that as permits are reissued in the coming months and years and BMPs evolve,
the information in this compendium will need to be updated to include new examples or modified
information. EPA has an interest in ensuring the accuracy of the information contained in this
document, and therefore welcomes input on any aspect of this compendium at any time.
The Agency expects to update the compendium as needed based on comments received and new
information. EPA notes that the inclusion of any particular permit example should not be read as
an Agency endorsement of the entire approach taken in that permit, nor should it be read as
EPA's independent determination that the permit terms meet the Phase I and/or Phase II MS4
requirements. This includes the permit standard for regulated small MS4s "to reduce the
discharge of pollutants from [the] MS4 to the maximum extent practicable, to protect water
quality, and to satisfy the appropriate water quality requirements of the Clean Water Act."
In addition, this document does not contain or impose any legally binding requirements on EPA,
states, or the regulated community, and does not confer legal rights or impose legal obligations
upon any member of the public. EPA made every attempt to ensure the accuracy of the examples
included in this document. In the event of a conflict or inconsistency between this compendium
and any statute, regulation, or permit, it is the statute, regulation, or permit that governs, not the
compendium.
For more information about the National Pollutant Discharge Elimination System (NDPES)
Stormwater Program visit: www.epa.gov/npdes/stormwater.
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
CHAPTER 2. EXAMPLE TRASH PROVISION LANGUAGE
FROM MS4 PERMITS
The main objective of this chapter is to provide excerpts of MS4 trash-related permit provisions
that can be used as a resource for EPA and state permitting authorities. It illustrates how MS4
permits can be used to reduce trash loads in stormwater in
many ways. This chapter presents permit language related
to trash from 21 Phase I and Phase II MS4 permits (see
Exhibit 1). The first five sections of the chapter present
example language organized by the following minimum
control measures (see text box): Public Education and
Outreach, Public Participation and Involvement, Illicit
Discharge Detection and Elimination (IDDE),
Construction Site Runoff Control, and Pollution
Prevention and Good Housekeeping. The final section
highlights example language from permits that include
details on floatables management programs and the
associated monitoring and reporting strategies for trash
reductions.
The EPA regulations specify that permit provisions must
be expressed in "clear, specific, and measurable" terms.
See 40 CFR 122.34(a). In essence, each permit provision
must include sufficient detail so that the permittee, the
permitting authority, and the public have a common
understanding of what is expected of the permittee so that
compliance can be determined. For instance, requirements
that are sufficiently clear, specific, and measurable should
establish, among other things, what specific actions the
permittees are required to take, the dates by which such
actions should be taken or other quantitative component of
the requirement (e.g., minimum number of inspections
conducted, or outfalls surveyed), and possibly the method
for assessing effectiveness.
All permit language in this document is presented in
italics. For emphasis, yellow highlighting indicates permit
language that appears to meet this standard of "clear,
specific, and measurable." Additional language in italics that is intended to reduce the amount of
trash entering stormwater, but that may not be considered "clear, specific, or measurable," is also
included to provide more context for the requirement. Those considering using any of these latter
examples in their respective permits should therefore be aware that modifications may be
necessary for them to meet the regulation's "clear, specific, and measurable" requirement.
Each Phase II MS4 permit requires the
inclusion of terms and conditions that
address six minimum control measures
(MCMs) for stormwater management:
Public Education and Outreach, Public
Participation and Involvement, Illicit
Discharge Detection and Elimination
(IDDE), Construction Site Runoff Control,
Post-Construction Site Runoff Control,
and Pollution Prevention and Good
Housekeeping. See 40 CFR 122.34(b).
These measures are also often
incorporated into Phase I MS4 permits.
Research into trash-related provisions in
MS4 permits (both Phase I and Phase II)
found that they frequently appear in the
Public Education and Outreach and the
Pollution Prevention and Good
Housekeeping sections of MS4 permits
as these measures are well-suited for
addressing trash reduction through BMP
maintenance and through targeted
behavior change aimed at litter
prevention.
No trash-related provisions were found
in Post-Construction Site Runoff Control
sections of MS4 permits. In cases where
trash is of particular concern for state
and local waterways, however, post-
construction control measure provisions
may represent an opportunity for permit
writers to evaluate the potential for
enhanced trash control at land
development projects.
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
Exhibit 1. List of Permits Reviewed and Included in Chapter 2
EPA
REGION
PERMITTING
AUTHORITY
MS4 PERMIT NAME
PHASE*
PERMIT
TYPE**
PERMIT
EXPIRATION***
PUBLIC EDUCATION &
OUTREACH
PUBLIC PARTICIPATION
IDDE
CONSTRUCTION
POLLUTION PREVENTION &
GOOD HOUSEKEEPING
PROGRAMS, MONITORING
& REPORTING
1
Rl DEM
Phase II General Permit
II
G
12/19/08
X

X

X

1
CTDEP
Phase II General Permit
II
G
06/30/22
X

X

X

1
US EPA Rl
MA MS4 General Permit
II
G
6/30/22



X


2
NJ DEP
Tier A Municioal Stormwater
General Permit
II
G
12/31/22




X

2
NY DEC
New York Citv
1
1
07/31/20

X



X
2
PR EPA Reg 2
Commonwealth wide Small
MS4s
II
G
06/30/21




X

3
VA DEQ
Fairfax Countv
1
1
03/31/20
X
X
X


X
3
MD DOE
Baltimore Citv
1
1
12/26/18





X
4
GADNR
Statewide Small MS4s
II
G
12/05/22



X


4
ADEM
Citv of Mobile
1
1
9/30/19
X



X
X
6
TXCEQ
Statewide Small MS4s
II
G
1/23/24


X

X

9
CA SWRCB****
Statewide Small MS4s
II
G
06/30/18




X
X
9
CA SWRCB
Coastal Watersheds of Los
Angeles County
1
1
12/28/17




X

9
CA SWRCB
Caltrans State-wide Permit
1
1
06/30/18





X
9
CA SWRCB
San Francisco Bav Municipal
Regional Stormwater Permit
1
1
12/31/20

X



X
9
HI DOH
Citv and Countv of Honolulu
II
G
1/15/20





X
10
OR DEQ
Oregon State-Wide Permit
II
G
02/29/24
X





10
WA DOE
Western Washington
Municipal Stormwater Permit
II
G
07/31/24
X





10
US EPA R10
Boise/Garden Citv Area MS4
Permit
1
1
01/31/18
X



X

10
US EPA R10
Citv of Coeur d'Alene
II
1
1/31/14

X




10
US EPA R10
Joint Base Lewis-McChord MS4
II
1
09/30/18




X

*l=Phase 1,
ll=Phase II










**G=General, 1=1 ndividual










***Permit examples are included in this document from both current permits and those that have been administratively continued.

****The CA Phase II General Permit was amended in December 2017 to include TMDLs. The SWRCB hasn't posted the final order, although it is in
effect. The 2017 amendment did not affect the permit language cited in this document. See:
httDs://www.waterboards.ca.sov/water issues/Drosrams/stormwater/docs/Dhase ii municioal/conformed order 2013 0001 dwa unofficial
draft.pdf
The EPA reiterates that the agency does not make an independent determination here about
whether any permit provision included in the document meets the 40 CFR 122.34(a) requirement
to establish "clear, specific, and measurable" permit terms. The EPA reminds permit writers to
independently evaluate whether the language meets the 40 CFR 122.34(a) requirement, and to
make adjustments as needed if it does not. For further assistance in determining whether permit
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
language meets the clear, specific, and measurable requirement, permitting authorities may
consider consulting the related discussion in the final "MS4 General Permit Remand Rule"
(specifically, 81 FR 89335, December 9, 2016) and more generally the EPA's National Pollutant
Discharge Elimination System: Compilation of Writing Tips and Best Practices''
Moreover, the "clear, specific, and measurable" requirement must be included within the permit
provision as opposed to being developed and established by the permit holder without permitting
authority approval.
The summary sentence at the beginning of each permit provision serves as a short description of
what the permit provision includes. The purpose of this summary is to allow readers to more
easily digest and parse through the relevant material.
Note that numeric effluent limitations have been used in some MS4 permits to control trash. Part
3 of EPA's Compendium of MS4 Permitting Approaches series, Water Quality-Based
Requirements, presents examples where permits have adopted numeric or quantitative
requirements. Permits developed in the context of these numeric limits tend to have more specific
language for controlling trash. Examples of language from two permits that include numeric
limits in the form of Total Maximum Daily Loads (TMDLs) are included below - the LA
Individual MS4 Permit language on Pollution Prevention and Good Housekeeping and the
Baltimore City Individual MS4 Permit language requiring inventorying trash reduction strategies.
PUBLIC EDUCATION AND OUTREACH
Trash provisions that have been included in the Public Education and Outreach sections of MS4
permits aim to increase awareness of nexus between trash and stormwater. The goal is to
encourage proper disposal of trash and behavior change by the general public. Less litter will lead
to less trash in the waterways. To accomplish this objective, one effective strategy is to start by
targeting the source by engaging the public and encouraging stewardship of their waterways.
The Phase II regulations require small MS4 permits to identify and implement the minimum
elements of a public education program about the impacts of stormwater discharges on local
waterways and the steps that citizens, businesses, and other organizations can take to reduce the
contamination of stormwater (40 CFR 122.34(b)(1),(2)). Phase I MS4 permittees are also
required to describe their proposed public education programs as part of their initial permit
application, and it is common for individual Phase I permits to include specific requirements for
addressing public education and outreach (40 CFR 122.26(d)(2)(iv)(B)(6) and (D)(4)). While
neither the Phase I or Phase II regulations specifically mandate trash-related public education and
outreach, a number of states have included requirements for trash education and outreach in their
MS4 permits.
Education and awareness programs are intended to help change human behavior in ways that can
reduce the amount of trash-related pollution that is introduced into the MS4 system. In addition to
education, encouraging public participation in local stormwater events, like town meetings and
stream cleanups, can lead to program improvements as well as enabling people to identify and
report a pollution-causing activity, such as spotting an illicit discharge. Public education efforts
specifically targeted at trash control represent opportunities to enhance the public's understanding
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
of how trash control efforts can benefit water quality and to improve compliance with the
applicable regulatory requirements.
EPA has highlighted examples from existing MS4 permits that focus on public education and
outreach in its Compendium ofMS4 Permitting Approaches - Part 1: Six Minimum Control
Measures (EPA, 2016), and has provided sample permit language in the MS4 Permit
Improvement Guide (EPA, 2010). Although trash control is not the sole focus of the example
permit provisions in these publications, they illustrate how public education and outreach can be
effectively employed for trash control. The following types of requirements are among the
elements included in examples from these publications. Bold text is added to identify specific
opportunities for addressing trash and litter control.
•	Select a minimum number of focus areas that are known trash hot spots for the MS4's
education program and identify the target audience that will be the focus of the education
(e.g., general public, commercial and industrial facilities, developers, general contractors,
engineers, and landscapers). For example, New Jersey's small MS4 general permit
requires that each permittee achieve a certain number of public education points annually
by conducting specific activities that are each assigned a point value. See Part IV.F.4 and
Attachment E.
•	Select a minimum number of specific trash/litter control related BMPs to target for
focused outreach and set a fixed percentage of the available audience as a target for
adopting those BMP(s).
•	Specify the number of outreach events to conduct and/or the specific number and type of
materials related to trash control to be distributed to the general public, or to specific
target groups.
•	Conduct a public awareness survey a minimum number of times during the permit term to
gauge the awareness of litter control themes or concepts in the public or in specific target
groups.
•	Measure the adoption of trash/litter reduction behaviors or practices that are part of the
education and outreach program through direct evaluations, surveys, interviews, etc.
•	Target a stormwater awareness campaign around trash/litter reduction and measure
success tied to the environmental outcome (e.g. less trash in catch basins following an
education campaign).
The following examples of MS4 permit provisions show how some of the above permit
approaches have been applied to make trash control an area of emphasis for public education
programs.
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
Rhode Island General MS4 Permit: Section IV.B.l.
Summary:
Permittee shall implement a litter disposal public education program within the first year of the
permit period.
Excerpt from permit:
a.	Permit Requirement. The operator must implement an ongoing public education program to
distribute education material to the community over the term of the permit...
b.	Decision Process/Milestones. The operator must document the decision process for the
development of a storm water public education and outreach program. If documented
strategies are not in place... the operator must include development of the strategies within
the first year of the program as a measurable goal...
5. Outreach strategy, including the mechanism(s) (e.g., printed brochures, newspapers,
media, workshops, etc.) that will be used to target audiences. Materials for
outreach/education may include, but are not limited to, pamphlets: fact sheets;
brochures: public service announcements; storm drain stenciling and newspaper
advertisements. Topics should include, but are not limited to, litter disposal, pet waste, ...
Connecticut General MS4 Permit: Section 6.A.1.A
Summary:
Existing permittees shall implement a public education program within the first year of permit
period that addresses impacts of illicit discharges and improper disposal of waste in the MS4.
Newly authorized permittees shall implement a public education program within the second year
of the permit period.
Excerpt from permit:
Implement a public education program to distribute educational materials to the permittee 's
community (i.e. residents, business and commerce, students, staff, contractors, etc.) or conduct
equivalent outreach activities about the sources and impacts of stormwater discharges on
waterbodies and the steps that the public can take to reduce pollutants in stormwater runoff. The
education program shall include, but not be limited to, information on ... impacts of illicit
discharges and improper disposal of waste into the MS4...
(i)	Permittees previously authorized ... shall begin implementation of this measure
within the first year following the effective date of this permit and continue until
permit expiration. ...
(ii)	Permittees not previously authorized ... shall begin implementation of this measure
within the second year following the effective date of this permit and continue until
permit expiration. Permittees shall utilize the one year period following the effective
date of this permit to acquire and/or develop the content of the outreach materials.
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
Western Washington General MS4 Permit: S5.C.2
Summary:
Permittees shall implement a public education campaign focusing on a specific behavior change
for a targeted audience and provide stewardship opportunities related to trash reduction.
Excerpt from permit:
The SWMP shall include an education and outreach program designed to:
•	Build general awareness about methods to address and reduce impacts from stormwater
runoff.
•	Effect behavior change to reduce or eliminate behaviors and practices that cause or
contribute to adverse stormwater impacts.
•	Create stewardship opportunities that encourages community engagement in addressing
the impacts from stormwater runoff...
The minimum performance measures are :
a. Each Permittee shall provide an education and outreach program for the area served by the
MS4. The program design shall be based on local water quality information and target
audience characteristics to identify high priority target audiences, subject areas, and/or
BMPs....
ii. Behavior change. To effect behavior change, Permittees shall select, at a minimum, one
target audience and one BMPs:...
(a) Target Audiences: Residents, landscapers and property managers/owners,
developers, school age children, or businesses.
BMPs:...
•	Dumpster and trash compactor maintenance
•	Litter and debris prevention. ...
(b)	No later than July 1. 2020, each Permittee shall conduct a new evaluation of the effectiveness
of an ongoing behavior change campaign (required under S5.C.l.a.ii and S5.C.1.C of the
2013 Permit). Permittees shall document lessons learned and recommendations for which
option to select from S5.C.2.a.ii.(c).
Permittees that select option S5.C.2.a.ii.(c)3, below, may forgo this evaluation if it will not
add value to the overall behavior change program.
(c)	Based on the recommendation from S5.C.2.a.ii.(b), by February 1. 2021, each Permittee shall
follow social marketing practices and methods, similar to community-based social marketing,
and develop a campaign that is tailored to the community, including development of a
program evaluation plan. Each Permittee shall:
1.	Develop a strategy and schedule to more e ffectively implement the existing campaign; or
2.	Develop a strategy and schedule to expand the existing campaign to a new target
audience or BMPs: or
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
3. Develop a strategy and schedule for a new target audience and BMP behavior change
campaign.
(d)	No later than April 1, 2021, begin to implement the strategy developed in S5.C.2.a.ii.(c).6
(e)	No later than March 31, 2024, evaluate and report on:
1.	The changes in understanding and adoption of targeted behaviors resulting from the
implementation of the strategy; and
2.	Any planned or recommended changes to the campaign in order to be more effective;
describe the strategies and process to achieve the results.
(f)	Permittees shall use results of the evaluation to continue to direct effective methods and
implementation of the ongoing behavior change program. Stewardship. Each Permittee shall
provide and advertise stewardship opportunities and/or partner with existing organizations
(including nonpermittees) to encourage residents to participate in activities or events planned
and organized within the community, such as: stream teams, storm drain marking, volunteer
monitoring, riparian plantings, and education activities.
City of Mobile Individual MS4 Permit: Part II.B.2
Summary:
Permittee shall label storm drains, post signage about litter ordinances, and educate the public on
stormwater activities. Permittee shall include a description of the events in the annual report.
Excerpt from permit:
b. The Permittee shall include within the SWMPP the following information:...
3) Plans to specifically address the reduction of litter, floatable s and debris from entering
the MS4, to include at a minimum;
a.	Labeling storm drain inlets and catch basins with "no dumping" message:
b.	Posting signs referencing local codes that prohibit littering and illegal dumping at
designated public access points to open channels, creeks and other relevant
waterbodies: ...
5)	Plans to in form individuals and groups on how to become involved in the storm water
program... The target audiences and subject areas for the education program ... should
include the following...:
a. General Public:
i. On a quarterly basis, at a minimum, the general public shall be educated on the
general impacts litter has on water bodies and ways to reduce the litter...
6)	Evaluate the effectiveness of the public education program
7)	Organize and participate in activities that target the removal of litter, floatables and
debris from area waterways. The minimum number and the waterways these activities
will target will be addressed in the SWMPP.
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
c.	The Permittee shall report each year in the annual report the following information:
1)	A description of the activities used to involve groups and/or individuals in the
development and implementation of the SWMPP;
2)	A description of the individuals and groups targeted and how many groups
and/or individuals participated;
3)	A description of the communication mechanisms or advertisements used to
inform the public and the number of applications that were distributed i.e.
number ofprinted brochures, copies of newspapers, workshops, public service
announcements, etc.
4)	Results of the evaluation plan as required in Part II.B. 2. b. 6.; and
5)	A list of the activities required in Part II.B.2.b. 7 and the amount of litter,
floatables and debris removed during each activity.
d.	The current SWMPP and latest annual report should be posted on the Permittee's
website.
Due date: with annual reporting requirement
Fairfax County Individual MS4 Permit: Part l,B.2J.l.F
Summary:
Permittee shall include outreach programs, activities, and the effectiveness of litter prevention
program in annual report.
Excerpt from permit:
Promote and publicize the use of the permittee 's litter prevention program
Specific Reporting Requirements:
Beginning with the annual report due October 1. 2016, each annual report shall include a list of
permittee public outreach and education activities and the estimated number of individuals
reached through the activities. An evaluation of program effectiveness, as outlined in the MS4
Program Plan with recommendations for future changes shall also be included.
Boise/Garden City Individual MS4 Permit: Section II.B.6.B
Summary:
Permittees shall implement a public education campaign focusing on a specific behavior change
for a targeted audience and assess the effectiveness of the campaign.
Excerpt from permit:
(i) No later than September 30. 2014, the Permittees must implement or participate in an
education, outreach and public involvement program using a variety of methods to target
each of the audiences and at least one or more of the topics listed below:
1) General Public...
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•	Source control best management practices and environmental stewardship, actions
and opportunities for pet waste control/disposal vehicle maintenance, landscaping
and vegetative buffers...
3) Homeowners, homeowner's associations, landscapers, and property managers...
•	Litter and trash control and recycling programs
(ii) The Permittees must assess or participate in an e ffort to assess understanding and
adoption of behaviors by the target audiences. The resulting assessments must be
used to direct storm water education and outreach resources most effectively.
(Hi) The Permittees must track and maintain records of public education, outreach and
public involvement activities.
Oregon General MS4 Permit: Schedule A - Section 3.A.
Summary:
Permittee shall develop and implement public education campaign targeting three audiences and
addressing significant stormwater issues.
Excerpt from permit:
i.	Implementation Dates
(A)	Existing Registrants
No later than February 28, 2020, Existing Registrants must implement the required
components described in Schedule A.3.a.ii-vi. [see below]
(B)	New Registrants
Upon the effective date of this permit. New Registrants must begin to develop [and]
implement the required components described in Schedule A.3.a.ii-vi; required
components must be fully implemented by September 1, 2023.
ii.	Education and Outreach Program
The permit registrant's public education and outreach program must include educational
efforts targeting the three audiences listed in Schedule A.3.a.iv...
ii. Stormwater Education Activities
The permit registrant must distribute or offer at least two (2) educational messages or
activities per year...
iv. Target Audiences and Topics
The permit registrant must at minimum, conduct education and outreach to each target
audience identified below at least once during the permit term, construction site
operators must be targeted at least twice. The permit registrant must focus its efforts on
conveying relevant messages using the Target Topics identified below or stormwater
issues of significance in their community:
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
(A)	Target Audience:
1.	General public, homeowners, homeowner association, schoolchildren, and
businesses (including home-based and mobile business).
2.	Local elected officials, land use planners and engineers.
3.	Construction site operators (See Schedule A.S.v below).
(B)	Target Topics:...
4.	Best management practices for litter and trash control...
vi. Tracking and Assessment
The permit registrant must track implementation of the Public Education and Outreach
requirements. In each corresponding Annual Report, the permit registrant must assess their
progress toward implementation of the program, including the evaluation of at least one
education and outreach activity corresponding to the reporting timeframe for the associated
Annual Report.
PUBLIC PARTICIPATION AND INVOLVEMENT
Permit provisions that address Public Participation and Involvement include such actions as storm
drain stenciling, Adopt-A-Stream or Highway programs, and cleanups. Public participation and
involvement provisions are inherently linked to public education and outreach in their objectives
- to create a heightened awareness of stormwater issues and engage the community in taking
ownership of stormwater issues through programs, activities, and education. It is possible to
increase the effectiveness of public education and awareness by coupling them with tangible
actions and behavior changes that local communities implement to reduce litter, either at the
source or within the waterways.
Public involvement provisions also encourage the public to comment on stormwater management
plans and ensure that the public has adequate access to stormwater management information
online or in print.
Coeur D'Alene Individual MS4 Permit: Section II.B.2.
Summary:
Permittee shall establish Adopt-A-Street programs, cleanups, stormwater pollution concerns
hotline, and storm drain stenciling.
Excerpt from permit:
c) At least once per year, the permittee must organize and promote citizen participation in each
of its Adopt a Street and Annual Litter Pick-up programs...
e) Within three years of the permit effective date, the permittee will create, maintain, and
promote a "hotline " telephone number to receive, track, and respond as necessary to
in formation submitted by the public regarding storm water pollution concerns.
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
f) The permittee must organize promote and conduct a storm drain stenciling program. Within
two years of the effective date of this permit, at least 100 storm drains, catch basins or inlets
throughout the permittee 's jurisdiction must be stenciled per year.
San Francisco Bay Individual MS4 Permit: Section C.7.D
Summary:
Permittee shall host stream cleanups, storm drain stenciling, and Adopt-A-Stream programs, and
report activities in annual report.
Excerpt from permit:
i.	Task Description: Public outreach shall include a variety of pollution prevention messages
such as... trash. Public outreach events may include venues such as fairs, shows, and
workshops. Citizen involvement events may include venues such as creek/shore clean-ups,
adopt-an-inlet/creek/beach programs, volunteer monitoring, storm drain inlet marking,
riparian restoration activities, community grants.
ii.	Implementation Level: Each Permittee shall annually participate and/or host a mix of public
outreach and citizen involvement events according to its population, as shown in the table
below:
PERMITTEE POPULATION
< 10,000
10,001 - 40,000
40,001 -100,000
100,001 -175,000
175,001 - 250,000
> 250,000
Non-population based Permittees
NUMBER OF EVENTS
10
III.
Reporting: In each Annual Report each Permittee shall list the events (name of event, event
location, and event date) participated in: identify whether the event is public outreach or
citizen involvement; and assess the effectiveness of efforts with appropriate measures, (e.g..
success at reaching a broad spectrum of the community, number ofparticipants compared to
previous years, post-event effectiveness assessment/evaluation results, quantity/volume of
materials cleaned up and comparisons to previous efforts).
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Fairfax County Individual MS4 Permit: Part I.B.2.J.1.B
Summary:
Permittee shall promote public involvement in clean up events.
Excerpt from permit:
Continue to promote individual and group involvement in local water quality improvement
initiatives including the promotion of local restoration and clean-up projects, programs, groups,
meetings and other opportunities for public involvement
New York City Individual MS4 Permit: Section IV.B.2.C
Summary:
Permittee shall create and implement a public involvement strategy and stewardship opportunities
related to trash reduction.
Excerpt from permit:
Develop and implement a public involvement/participation program that: Describes the public
involvement/participation activities... Such activities may include, but are not limited to, a water
quality hotline (report spills, dumping, construction sites of concern, etc.), stewardship activities
like beach cleanups, wetland restorations and volunteer water quality monitoring.
The permit provision above, while not explicitly related to trash reduction does touch on trash-related
activities, such as beach cleanups and a hotline to report illegal dumping. New York City's MS4 permit
dedicates an entire section to outlining and describing a floatables management program, which
provides more stringent and relevant trash reduction strategies. [See example language in Floatables
Management Programs, Monitoring and Reporting section of this Chapter.l
ILLICIT DISCHARGE DETECTION AND ELIMINATION
Illicit Discharge Detection and Elimination (IDDE) provisions must include a plan to identify and
remove any sources of non-stormwater from entering the system, a map of the storm sewer
system, and training programs for the public and businesses on the hazards of illegal discharges,
among other required actions (40 CFR 122.34(b)(3)). Often, these provisions target the detection
and elimination of illegal discharges to the MS4 system and illegal dumping through hotlines,
mapping of the storm sewer system, outfall inspection and screening, and ordinances. According
to Phase II regulations, "... a short list of parameters may include conductivity, ammonia,
surfactant and pH. Some MS4s have found it useful to measure for fecal coliform or E. coli in
" The term "illicit discharge" is defined in the regulations as "any discharge to a municipal separate storm sewer that is
not composed entirely of storm water except discharges pursuant to a NPDES permit (other than the NPDES permit
for discharges from the municipal separate storm sewer) and discharges resulting from firefighting activities." (140
CFR 122.26(b)(2)
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
their testing program. Observations of physical characteristics of the discharge are also helpful
such as flow rate, temperature, odor, color, turbidity, floatable matter, deposits and stains, and
vegetation" (64 FR 68757 December 8, 1999). Persistent trash sources would also be considered
an illicit discharge to the MS4 system requiring correction.
Although it is not common for IDDE provisions to explicitly identify trash as an area of
emphasis, targeting sources of trash and litter introduction in the sewer system is within the broad
scope of the definition of "illicit discharge," which focuses on the discharge of all non-
stormwater into the sewer system. As such, the IDDE section of MS4 permits represents an
opportunity for permitting authorities to address trash where it is of particular concern for state
and local waterways.
Rhode Island General MS4 Permit: Section IV.B.3.A.2
Summary:
Permittee shall create and implement an ordinance or other regulatory mechanism addressing
litter.
Excerpt from permit:
The operator must effectively prohibit and en force, through an ordinance or other regulatory
mechanism available to the operator, non-storm water discharges into the system ...and must also
address ... litter... The mechanism must include sanctions for non-compliance. The ordinance or
other regulatory mechanism must provide for appropriate enforcement procedures and actions. If
a regulatory mechanism does not exist by the time an application is required, development and
adoption of such a mechanism must be included as part of the SWMPP.
Connecticut MS4 General Permit: Section 6.A.3.B
Summary:
Permittee shall create and implement a regulation addressing litter in the first year of the permit
period for existing permittees and within the first two years for new permittees.
Excerpt from permit:
Establish the necessary and enforceable legal authority by statute, ordinance, rules and
regulations, permit, easement, contract, order or any other means, to eliminate illicit discharges.
(i) The legal authority shall:
a.	prohibit illicit discharges to its storm sewer system and require removal of such
discharges consistent with subsection (3)(A), above; and
b.	Control the discharge of spills and prohibit the dumping or disposal of materials
including... trash...
c.	authorize fines or penalties and/or recoup costs incurred by the permittee from anyone
creating an illicit discharge or spilling or dumping as specified in subsection (3)(A),
above. For state and federal institutions, where this provision may conflict with existing
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rules, regulations, policies, chain of command or other circumstances, alternate
provisions for enforcement may be utilized.
d. provide any additional legal authorities specified in Section (A)(7)(a) of Appendix B.
(ii) Existing 2004 MS4 permittees must establish and implement this legal authority within one
year of the effective date of this permit. New MS4 permittees must establish and implement
this legal authority on or before two (2) years of the effective date of this permit.
(Hi) New MS4 permittees must establish and implement this legal authority on or before two (2)
years of the effective date of this permit.
Texas General MS4 Permit: PART III. Section B.2.A.
Summary:
Permittee shall develop a strategy for detecting and eliminating illegal dumping.
Excerpt from permit:
(I) All permittees shall develop, implement and en force a program to detect, investigate, and
eliminate illicit discharges into the small MS4. The program must include a plan to detect
and address non-stormwater discharges, including illegal dumping to the MS4 system.
Existing permittees must assess program elements that were described in the previous permit,
modify as necessary, and develop and implement new elements, as necessary, to continue
reducing the discharge of pollutants from the MS4 to the MEP. New elements must be fully
implemented by the end of this permit term and newly regulated permittee shall have the program
fully implemented by the end of this permit term.
Fairfax County Individual MS4 Permit: Part I.B.2.E.3
Summary:
Permittee shall remove floatables from stormwater management facilities as part of the
prohibition of discharges to the MS4 not authorized by this permit.
Excerpt from permit:
The permittee shall continue to implement a program to reduce the discharge of floatables (e.g.
litter and other human-generated solid refuse) in accordance with Part I.C.3 ... [See Floatables
Management Programs, Monitoring and Re port inn Section below]
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CONSTRUCTION SITE RUNOFF CONTROL
Construction Site Runoff Control provisions include requirements for sediment and erosion
control, minimizing the discharge of other pollutants, and site plan review for construction sites.
The prevention and cleanup of trash and debris from construction sites that discharge stormwater
into a regulated MS4 can be addressed as part of the construction site runoff provisions in MS4
permits
Massachusetts General MS4 Permit: Section 2.3.5.C
Summary:
Permittee shall include litter control in construction site runoff control program and report
tracking information in annual report.
Excerpt from permit:
The permittee shall develop and implement a construction site runoff control program that
includes...:
i. ...In addition to addressing sediment and erosion control, the ordinance must include
controls for other wastes on constructions sites such as demolition debris, litter and sanitary
wastes...
iv.	Requirements for construction site operators within the MS4 jurisdiction to control wastes,
including but not limited to, discarded building materials, concrete truck wash out,
chemicals, litter, and sanitary wastes. These wastes may not be discharged to the MS4.
v.	... The procedures for site inspections conducted by the permittee shall include the
requirement that inspections occur during construction of BMPs as well as after construction
of BMP s to ensure they are working as described in the approved plans... This tracking
information shall be included as part of each annual report required by part 4.4.
Georgia General MS4 Permit: Part 4.2.4
Summary:
Permittee shall develop and evaluate construction ordinances that include litter control.
Excerpt from permit:
3. 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 water quality impacts;...
Table 4.2.4(a) 1. Legal Authority (Best Management Practices for Existing Permittees):
Evaluate, and if necessary, modify the existing E&S ordinance. Ensure either the E&S or
litter ordinance requires construction site operators to control waste at the construction
site, such as discarded building materials, concrete truck washout, chemicals, litter, and
sanitary waste....
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Table 4.2.4(b) 1. Legal Authority (Best Management Practices for New Permittees):
Develop an ordinance(s) that requires construction site operators to implement E&S
controls and control waste at the construction site, such as discarded building materials,
concrete truck washout, chemicals, litter, and sanitary waste.
POLLUTION PREVENTION AND GOOD HOUSEKEEPING
Pollution Prevention and Good Housekeeping provisions are commonly used in MS4 permits to
address trash in waterways. Permits are required to include pollution prevention and good
housekeeping provisions for municipally-owned facilities, which includes training programs for
employees, and operation and maintenance procedures. Pollution Prevention and Good
Housekeeping measures also focus on the proper maintenance and operation of controls so that
they are operating at their full effectiveness. Standard operating procedures, or SOPs, may be
written in association with the permit to further detail operation and maintenance of BMPs.
Trash-related permit provisions typically include structural and non-structural controls that
prevent trash from either entering the storm sewer system or moving further downstream once in
the waterways. Non-structural controls (also called institutional controls) include BMPs intended
to either prevent trash from entering the system or remove it from the system, such as street
sweeping, plastic bag bans, and stream cleanups. Structural controls include litter traps, outfall
netting, catch basins and other physical devices designed to capture trash either before it enters
the system or once it has already entered it. More information on BMPs can be found on EPA's
website (see National Menu of Best Management Practices (BMPs) for Stormwater Documents).
The trash provisions included below all relate to BMPs used to address trash.
Rhode Island General MS4 Permit: Section IV.B.6.1
Summary:
Permittee shall implement an operation and maintenance program for catch basin cleaning and
street sweeping as well as establishing litter reduction structural controls.
Excerpt from permit:
Hi. Procedures for implementation of a regular catch basin inspection and cleaning program to
inspect all catch basins annually commencing by the third year of the program, document the
results of the inspection, and clean structures as necessary. ...
vi.	Procedures for the development and implementation of a regular street and road sweeping
program that includes sweeping of all streets and roads within the regulated area annually,
to be fully implemented by the third year of the program. The operator is required to sweep
all streets and roads within the regulated area annually unless a lesser frequency can be
justified based on at least two consecutive years of data indicating the street or road does not
require annual sweeping...
vii.	Description of maintenance activities, maintenance schedules, and long-term inspection
procedures for controls to reduce floatable s and other pollutants from the MS4 must include
one or more floatable control options which could include, but are not limited to storm sewer
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grate retrofits, increased number of litter receptacles in areas frequented by pedestrian
traffic, trash netting and/or other equivalent technologies.
viii. Procedures for the proper disposal of waste removed from MS4s and waste from other
municipal operations, including accumulated sediments, floatables and other debris.
Puerto Rico General MS4 Permit: Section 2.4.7.1
Summary: Permittee shall develop procedures for management of trash containers, dumpsters,
and other waste management.
Excerpt from permit:
Within one (1) year from the authorization under this permit, the permittee shall develop, if not
already developed, written operations and maintenance procedures for the municipal activities
listed below... These written O & M procedures shall be included as part of the SWMP as
specified in Section 1.11.
The permittee shall ensure staff training to meet developed procedures.
a.	Parks and open space: ... Establish procedures for management of trash containers at parks
(i.e., scheduled cleanings; sufficient number).
b.	Buildings and facilities where pollutants are exposed to stormwater runoff: ...Develop
management procedures for dumpsters and other waste management equipment.
Puerto Rico General MS4 Permit: Section 2.4.7.l.D
Summary:
Permittees shall establish a schedule for cleaning and inspecting catch basins and report in the
annual report number of catch basins cleaned and inspected.
Excerpt from permit:
1.	The permittee shall establish within one (1) year of the authorization under this permit a
written program detailing the activities and procedures the permittee will implement so that
the MS4 infrastructure is maintained in a timely manner to reduce the discharge of pollutants
from theMS4...
2.	The permittee shall optimize routine inspections, cleaning and maintenance of catch basins
such that the following conditions are met:...
ii. Prioritize inspection and maintenance for catch basins located near construction
activities. Clean catch basins in such areas more frequently if inspection and
maintenance activities indicate excessive sediment or debris loadings...
Hi. Establish, for other catch basins, a schedule for the frequency of routine cleaning that
will ensure that no catch basin at any time will be more than 50percent full. A catch
basin sump is more than 50 percent full if the contents within the sump exceed one half
the distance between the bottom interior of the catch basin to the invert of the deepest
outlet of the catch basin...
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vi.	The permittee shall document in the SWMP and in the first annual, report its plan for
optimizing catch basin cleaning, inspection plans, or its schedule for gathering
information to develop the optimization plan. Documentation shall include metrics and
other information used to reach the determination that the established plan for cleaning
and maintenance is optimal for the MS4. The permittee shall keep a log of catch basins
cleaned or inspected.
vii.	The permittee shall report in each annual report the total number of catch basins,
number inspected, number cleaned, and the volume or mass of material removed from
each catch basin draining to impaired waters and the total volume or mass of material-
removed from all catch basins...
6. The permittee shall report in the annual report on the status of the inventory required by this
section and any subsequent updates; the status of the O&M programs for the permittee-
owned facilities and activities... and the maintenance activities associated with each.
Los Angeles Individual MS4 Permit: Section VI.D.4.C.VII
Summary:
Permittee shall map, inspect, and label catch basins.
Excerpt from permit:
(3) Catch Basin Cleaning:
(a)	In areas that are not subject to a trash TMDL, the LACFCD shall determine priority
areas and shall update its map or list of catch basins with their GPS coordinates and
priority:
Priority A: Catch basins that are designated as consistently generating the highest
volumes of trash and/or debris.
Priority B: Catch basins that are designated as consistently generating moderate
volumes of trash and/or debris.
Priority C: Catch basins that are designated as generating low volumes of trash and/or
debris. The map or list shall contain the rationale or data to support priority
designations.
(b)	In areas not subject to a trash TMDL, the LACFCD shall inspect its catch basins
according to the following schedule:
Priority A: A minimum of 3 times during the wet season (October 1 through April 15) and
once during the dry season every year.
Priority B: A minimum of once during the wet season and once during the dry season
every year.
Priority C: A minimum of once per year. Catch basins shall be cleaned as necessary on
the basis of inspections. At a minimum, LACFCD shall ensure that any catch basin that is
determined to be at least 25%full of trash shall be cleaned out. LACFCD shall maintain
inspection and cleaning records for Regional Water Board review...
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(4) Catch Basin Labels and Open Channel Signage
(a) LACFCD shall label all catch basin inlets that they own with a legible "no dumping"
message.

(b) The LACFCD shall inspect the legibility of the catch basin stencil or label nearest the
inlet prior to the wet season ever}'year.

(c) The LACFCD shall record all catch basins with illegible stencils and re-stencil or re-
label within 180 days of inspection.
(d) The LACFCD shall post signs, referencing local code(s) that prohibit littering and illegal
dumping, at designated public access points to open channels, creeks, urban lakes, and
other relevant waterbodies.
Connecticut General MS4 Permit: Section 6.A.6. C. I
Summary:
Permittee shall establish procedures for trash management in parks.
Excerpt from permit:
Permittee-owned or -operatedproperties, parks, and other facilities that are owned, operated, or
otherwise the legal responsibility of the permittee shall be maintained so as to minimize the
discharge ofpollutants to its MS4,... [including establishing] procedures for management of trash
containers at parks (scheduled cleanings; sufficient number).
City of Mobile Individual MS4 Permit: Section II.B.7.A
Summary:
Permittee shall implement trash BMPs and develop a plan to reduce trash from the MS4.
Excerpt from permit:
2) Develop strategies for the implementation of BMPs to reduce litter, floatables and debris
from entering the MS4 and evaluate these BMPs annually to determine their effectiveness. If
a BMP is determined to be ineffective or infeasible, then the BMP must be modified. The
Permittee shall also develop a plan to remove litter, floatable and debris material from the
MS4, including proper disposal of waste removed from the system.
Although this permit provision does not include any specific BMPs, the City of Mobile permit
includes an extensive description of a floatables program and the necessary components. More
information on BMPs and which to implement are included in the floatables program provision.
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City of Mobile Individual MS4 Permit: Section II.B.7
Summary:
Permittee shall report amount of trash collected from the MS4 in the annual report.
Excerpt from permit:
c. The Permittee shall report each year in the annual report the following information:
1.	Any updates to the municipal facility inventory:
2.	An estimated amount of floatable material collected from the MS4 as required by Part II.
B. 7. a. (2):
3.	Any updates to the inspection plan: and
4.	Any updates to the SOP of good housekeeping practices.
Joint Base Lewis-McChord Individual MS4 Permit: Section II.B.6
Summary:
Permittee shall inspect and maintain catch basins and report progress in the second year of the
permit period.
Excerpt from permit:
Within two years from the effective date of this permit, the Permittee must update and implement
its operations and maintenance (O&M) program to prevent or reduce pollutants in runoff from
the Permittee 's MS4 and from ongoing municipal operations. The written description of the
program must be included in the SWMP document. At a minimum...:
d) Inspection of Catch Basins. The Permittee must inspect all catch basins and inlets owned or
operated by the Permittee at least once before the end of the permit term. The Permittee must
clean catch basins if inspection indicates cleaning is needed.
• As part of the 2nd Year Annual Report, the Permittee must report the total number of
Permittee-owned or operated catch basins to be inspected annually in compliance with
this Part: subsequent Annual Reports must document the Permittee 's progress toward
inspecting and maintaining all catch basins prior to the permit expiration date...
f) Maintenance Practices. The Permittee must document and implement maintenance practices
to reduce stormwater impacts associated with runoff from streets, parking lots, roads or
highways, parks, open space ... The Permittee must ensure that the following activities are
conducted in a manner that is protective of receiving water quality:...
•	Street cleaning...
•	Trash management...
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New Jersey Tier A General MS4 Permit: Section IV.B.5
Summary:
Permittee shall adopt and enforce litter ordinance and certify in annual report.
Excerpt from permit:
a. Community Wide Ordinances: The Tier A Municipality shall adopt and en force the following
community wide ordinances to address improper disposal of waste:...
Hi. Adopt and enforce a litter ordinance or enforce the existing State litter statute at N.J.S.A
13:lE-99.3. See the Tier A Municipal Guidance document
(www.nj.gov/dep/dwq/tier_a_giiidance.htm) for a sample ordinance...
Attachment A - Associated Measurable Goal: Certify in each annual report the date the
ordinance was adopted and that it is being enforced. A log of enforcement actions shall be kept in
the SPPP.
New Jersey Tier A General MS4 Permit: Section IV.B.5.B
Summary:
Permittee shall report in the annual report catch basin cleaning schedule and amount of material
removed during cleanings.
Excerpt from permit:
Catch Basin and Storm Drain Inlet Inspection and Cleaning: The Tier A Municipality shall
inspect storm drain inlets and any associated catch basins that it owns or operates and
remove sediment, trash, or debris when present. Each catch basin and inlet shall be inspected
at least once every five years. The Tier A Municipality shall clean any municipally owned or
operated storm drain inlet or catch basin as frequently as necessary to eliminate recurring
problems and restore proper function.
Attachment A - Associated Measurable Goal: Certify in each annual report that a catch basin
and storm drain inlet inspection and cleaning schedule is being maintained, and a log indicating
the number of municipally owned and operated catch basins and inlets within the municipality,
the number of catch basins and inlets inspected, and the number cleaned is being maintained.
Maintain records documenting the amount of materials collected in wet tons during cleaning
activities in the SPPP. Include totals in the Annual Report.
California General Small MS4 Permit: Section E.ll.F and E.ll.G
Summary:
Permittee shall assess priority catch basins based on amount of trash collected in the second year
of the permit period and begin maintenance of all high priority storm drain systems on an ongoing
schedule within the third year of the permit period.
Excerpt from permit:
E.ll.f. Storm Drain System Assessment and Prioritization
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(i)	Task Description: Within the second year of the effective date of the permit, the Permittee
shall develop and implement procedures to assess and prioritize MS4 storm drain system
maintenance, including but not limited to, catch basins, pipe and pump infrastructure, above-
ground conveyances, including receiving water bodies within the Permittee's urbanized area
and detention basins.
(ii)	Implementation Level: The Permittee shall assess/prioritize storm drain system facilities for
cleanout - Assign a priority to MS4 storm drain facilities within the Permittee's urbanized
areas based on accumulation of sediment, trash and/or debris. In particular, assign high
priority to catch basin meeting any of the following criteria:
1) Catch basins known to accumulate a significant amount of sediment, trash, and/or
debris:...
3) Catch basin collecting runoff from area that do not receive regular sweet sweeping...
E.ll.G. Maintenance of Storm Drain System
(i)	Task Description: Within the third year of the effective date of the permit, the Permittee shall
begin maintenance of all high priority storm drain systems on an ongoing schedule.
(ii)	Implementation Level: The Permittee shall begin maintenance of storm drain systems
according to the procedures and priorities developed according to this Section. At a
minimum the Permittee shall:
(a)	Inspect storm drain systems - Based on the priorities assigned, develop and implement a
strategy to inspect storm drain systems within the Permittee's jurisdiction. At a minimum,
inspect all high priority catch basins and systems annually.
(b)	Clean storm drains - Develop and implement a schedule to clean high priority catch
basins and other systems. Cleaning frequencies shall be based on priority areas, with
higher priority areas receiving more frequent maintenance.
(c)	Labeling catch basins - Ensure that each catch basin in high foot traffic areas includes a
legible storm water awareness message (e.g., a label, stencil, marker, orpre-cast
message such as "drains to the creek" or "only rain in the drain "). Catch basins with
illegible or missing labels shall be recorded and relabeled within one month of
inspection.
(d)	Maintain surface drainage structures - High priority facilities shall be reviewed and
maintained annually as needed. Non-priority facilities shall be reviewed as needed.
Removal of trash and debris from high priority areas shall occur annually prior to the
rainy season.
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Texas General MS4 Permit: Part III.B.5.C
Summary:
Permittee shall conduct street sweeping or implement trash reduction strategies.
Excerpt from permit:
(2) Operation and Maintenance Program to Reduce Discharges of Pollutants from Roads
Permittees who operate level 3 or 4 small MS4s shall implement an O&Mprogram that
includes at least one of the following: a street sweeping and cleaning program, or an
equivalent BMP such as an inlet protection program, which must include an implementation
schedule and a waste disposal procedure ...If a street sweeping and cleaning program is
implemented, the permittee shall evaluate the following permittee-owned and operated areas
for the program: streets, road segments, and public parking lots including, but not limited to,
high traffic zones, commercial and industrial districts, sport and event venues, and plazas, as
well as areas that consistently accumulate high volumes of trash, debris, and other
stormwater pollutants.
a.	Implementation schedules - If a sweeping program is implemented, the permittee shall
sweep the areas in the program (for example, the streets, roads, and public parking lots)
in accordance with a frequency and schedule determined in the permittee 's O&M
program.
b.	For areas where street sweeping is technically infeasible (for example, streets without
curbs), the permittee shall focus implementation of other trash and litter control
procedures or provide inlet protection measures to minimize pollutant discharges to
storm drains and creeks.
Boise/Garden City Individual MS4 Permit: Section II.BAD.
Summary:
Permittee shall conduct and evaluate effectiveness of street sweeping activities or implement
trash reduction strategies.
Excerpt from permit:
(iv)	For areas where sweeping is technically infeasible, the Permittees with street, road, and/or
public parking lot maintenance responsibilities must document in the 1st Year Annual Report
each area and indicate why sweeping is infeasible. The Permittee must document what
alternative sweeping schedule will be used, or how the Permittee will increase
implementation of other trash/litter control procedures to minimize pollutant discharges to
the MS4 and to receiving waters.
(v)	The Permittees with street, road, and/or public parking lot maintenance responsibilities must
estimate the effectiveness of their street sweeping activities to minimize pollutant discharges
to the MS4 and receiving waters, and document the following in each Annual Report:
• Identify any significant changes to the designated road/street/parking lot inventory and
map, and the basis for those changes:
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•	Report annually on types of sweepers used, swept curb and/or lane miles, dates of
sweeping by general location and frequency category, volume or weight of materials
removed and a representative sample of the particle size distribution of swept material;
•	Report annually on any public outreach efforts or other means to address excess leaves
and other material as well as areas that are infeasible to sweep.
FLOATABLES MANAGEMENT PROGRAMS, MONITORING AND
REPORTING
As shown in the example language above, there are a variety of strategies that can be used to
prevent trash from entering the storm sewer system. While some permits incorporate trash
provisions in sections of the permit devoted to addressing one of the six minimum control
measures, others include a separate section entirely dedicated to a floatables management
program. This section highlights permits that require specific floatables management programs
within the permit and sections that detail reporting and monitoring requirements for all permit
conditions, which would include trash provisions.
While the permit requirements are presented as stand-alone sections, they may also be adapted
and incorporated into clear, specific, and measurable provisions and included in permit sections
addressing the six minimum control measures in lieu of a comprehensive floatables program.
Caltrans Individual MS4 Permit: Section E.2.H.4.C
Summary:
Permittee shall include in the annual report status updates on trash reduction strategies including
estimated annual volumes of trash and litter removed as a result of street sweeping, public
education campaigns, and Adopt-A-Highway programs.
Excerpt from permit:
The Department shall report on the trash and litter removal activities that are currently
underway or are initiated after adoption of this Order. Activities include, but are not limited to,
storm drain maintenance, road sweeping, public education and the Adopt-A-Highway program.
Reporting and assessment of these or future activities shall follow protocols established by the
Department 2012-0011-DWO 51 September 19, 2012 and shall include estimated annual volumes
of the trash and litter removed. Results shall be submitted as part of the Annual Report in a
summary^ format by District. Prior year's data shall be included to facilitate an analysis of trends.
The Caltrans MS4 permit covers all highways and roads maintained by the California Department of
Transportation. Departments of Transportation are considered non-traditional small MS4 permit
holders. EPA published a Transportation Stormwater Compendium, which provides additional permit
language and resources tailored for transportation-specific MS4 permits.
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
City of Mobile Individual MS4 Permit: Part II.B.l
Summary:
Permittee shall report annually on the maintenance, inspection, and amount of trash removed by
structural controls, including catch basins and litter traps.
Excerpt from permit:
a.	Structural Controls...
Hi. The Permittee shall maintain an inventory of structural controls and maintain a tracking
system for inspections and maintenance of the control structures
iv. The Permittee shall report each year in the annual report the following structural control
information:...
3.	The estimated amount of floatable, litter, sediment, and debris that is removed...
b.	Catch Basins...
ii. The Permittee shall include in the SWMPP and implement the following catch basin
maintenance activities:...
2.	Inspection and maintenance of a minimum of five percent of the catch basins
annually...
4.	Track the estimated amount of debris/litter removal...
iv. The Permittee shall report each year in the annual report the following catch basin
information:
1. The number of inspections performed on catch basins, to include follow-up
inspections and the inspection documentation...
3.	The estimated amount of debris/litter removed
c.	Litter Traps
i.	The litter traps shall be operated in a manner to retain the discharge of floatables/debris,
to the maximum extent possible;
ii.	The Permittee shall include in the SWMPP and implement the following litter trap
maintenance activities:
1.	Maintain a map of the location of the litter' traps;
2.	Inspection and maintenance of litter traps shall be performed on a weekly basis, at a
minimum, and after a significant rainfall, as defined in the SWMPP
3.	Develop and implement a litter trap inspection checklist; and
4.	Track the estimated amount of debris/litter removal.
iii.	The Permittee shall maintain an internal record keeping system to track the inventory of
litter traps, inspections and maintenance of the litter traps, and
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
iv. The Permittee shall report each year in the annual report the following litter trap
information:
1.	The number of inspections performed on litter traps, to include follow-up inspections
and the inspection documentation (i.e. checklist):
2.	A summary of the maintenance activities performed on litter traps, as well as the
frequency:
3.	The estimated amount of floatable s/debris removed;
4.	Copies of any contractual agreements for maintenance activities if not performed by
the permittee. The contractual agreement should specific maintenance activities
performed and schedule: and 5. Updated litter trap map.
d. Additional Measures for the Control of Trash (to include Floatables and Debris)
i.	The Permittee shall develop and implement a short and long term strategy and program
to attain the effective removal of trash from the City of Mobile waterways and tributaries
in such a manner to quantify the effective removal of trash per year, which shall be
included in the annual report. These strategies shall be included in the permittee's SWMP
Plan and shall be updated as necessary. This program shall address the following, at a
minimum:
1.	Direct removal of trash from waterbodies:
2.	Direct removal of trash from the MS4;
3.	Direct removal of trash prior to entry to the MS4;
4.	Prevention through disposal alternatives; and
5.	Prevention through waste reduction practices, additional enforcement, and/or
initiatives.
ii.	The Permittee shall require the following measures to be implemented in the public right
of way for any event or wherever it is anticipated that substantial quantities of trash or
litter may be generated:
1.	Arrangement for temporary protection of preventive measures to the catch basins,
where feasible: and
2.	Provide proper disposal of trash receptacles, clean up of catch basins, as needed,
and grounds of the event area within one business day subsequent to the event.
Hi. The Permittee shall ensure that trash receptacles, or similar trash capturing devices are
provided and maintained in areas identified as high trash generated areas
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
Baltimore City Individual MS4 Permit: Part IV.D.4.
Summary:
Permittee shall inventory trash reduction strategies, implement a public education campaign about
litter prevention, and report on these activities.
Excerpt from permit:
a.	Within one year of permit issuance, the City shall inventory and evaluate all current trash
and recyclable pick-up operations, litter control programs, and public outreach efforts. The
analysis shall identify opportunities for improving overall efficiency, especially in the Middle
Branch and Northwest Branch of the Patapsco River.
b.	Within one year of permit issuance, develop and implement a public education and outreach
strategy with specific performance goals, and corresponding deadlines to initiate or increase
residential and commercial recycling rates, improve trash management, and reduce littering.
The strategy shall include:
i.	Educating the public on the importance of reducing, reusing, and recycling;
ii.	Disseminating information by using signs, articles, and other media outlets;
Hi. Promoting educational programs in schools, businesses, community associations, etc.;
and
iv. Providing the strategy to interested parties upon request.
c.	Evaluating annually the effectiveness of the education program.
d.	Within one year of the Environmental Protection Agency's (EPA) approval of a trash TMDL
for the Middle Branch and Northwest Branch of the Patapsco River, implement those
program improvements identified in PART IV.D.4.a above and any additional programs
needed to address the TMDL.
e.	Submit annually, a report which details progress toward implementing the trash reduction
strategies. The report shall describe the status of trash elimination efforts including
resources (e.g., personnel and financial) expended and the effectiveness of all program
components.
New York City Individual MS4 Permit: Section IV.I
Summary:
Permittee shall determine loading rate of trash discharged into waterways, operate and maintain
structural controls, and implement a public education campaign.
Excerpt from permit:
The Permittee shall develop a floatable and settleable trash and debris management program as
part of the Stormwater Management Program Plan. The objectives of the floatable and settleable
trash and debris management program shall be to develop a methodology to determine the
loading rate of floatable and settleable trash and debris, including land-based sources, from the
MS4 to waterbodies listed as impaired for floatables in the MS4 areas, and to assess and
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
implement strategies to reduce floatable and settleable trash and debris to waterbodies listed as
impaired for floatables in the MS4 areas. The program may prioritize waterbodies and/or
drainage areas for floatable and settleable trash and debris control strategies based on the
relative significance of the MS4 contribution to floatable and settleable trash and debris loads.
The program included in the SWMP in the first permit cycle shall be designed to accomplish the
following:
1.	Evaluate the Permittee 's existing programs including best management practices and
structural and non-structural control measures for floatable and settleable trash and debris,
and their efficacy, based on existing information, and compare them with the best available
technologies identified for control of floatable and settleable trash and debris to waterbodies
listed as impaired for floatables in the MS4 areas:
2.	Identify technological advancements and best available technologies for floatable and
settleable trash and debris capture employed in other municipalities and assess their
applicability to New York City; and
3.	Propose a methodology for selecting, sizing and siting the best management practices and
controls that will be implemented to reduce floatable and settleable trash and debris for
Department review and approval.
Within two (2) years of effective date ofpermit (EDP'), the Permittee shall submit a draft
workplan to determine the loading rate of floatable and settleable trash and debris discharged,
including land-based sources, from the MS4 to waterbodies listed as impaired for floatables for
Department review and approval. The draft workplan shall include a literature search of methods
employed by other municipalities, as well as a discussion as to why the selected method is best for
conditions in New York City. The final workplan to determine the loading rate of floatable and
settleable trash and debris discharged, including land-based sources, from the MS4 to
waterbodies listed as impaired for floatables shall be included in the SWMP plan to be submitted
to the Department within three (3) years of EDP.
Within three (3) months of the Department's approval of the final workplan, the Permittee shall
propose a schedule to determine the loading rate of floatable and settleable trash and debris from
the MS4 to waterbodies listed as impaired for floatables in the MS4 areas with a completion date
from commencement of study not to exceed three (3) years. If the Permittee is unable to complete
the floatable and settleable trash and debris loading rate study in three (3) years from
commencement, the Permittee shall request an extension from the Department and provide
justification for the extension.
Within two (2) years of the Department's approval of the final workplan, the Permittee shall
commence a study to determine the loading rate of floatable and settleable trash and debris from
the MS4 to waterbodies listed as impaired for floatables in the MS4 areas, using the approved
workplan. The Permittee shall continue to implement existing or improved controls to reduce
floatable and settleable trash and debris from the MS4 areas to waterbodies with the goal of
achieving elimination of trash, debris, and floatables in the receiving waters.
The Permittee shall continue to inspect each catch basin in the NYCDEP MS4 system a minimum
of once every 36 months. Catch basins in the NYCDEP MS4 system will be cleaned as required
based on these inspections and in accordance with the Permittee 's criteria for catch basin
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
cleaning. The Permittee shall replace missing or damaged catch basin hoods in the NYCDEP
MS4 system within 90 days after the date of inspection for basins known to be hooded upon
completion of the catch basin hooding program. For all future catch basins in the NYCDEP MS4
system found by inspection to require extensive repairs before a hood can be installed, the
Permittee shall repair and install a hood within 24 months.
The Permittee shall implement an interim floatable and settleable trash and debris reduction
media campaign to further educate the public on trash and debris control issues. Within three (3)
months of EDP, the Permittee shall develop a campaign theme and an implementation schedule.
Within six (6) months of EDP, the Permittee shall begin implementation of the campaign. The
campaign shall run from six (6) months of EDP to submission of the SWMP plan, which is due
within three (3) years of EDP. The Permittee may incorporate elements of the media campaign
into the SWMP, as warranted.
The New York City MS4 permit requires specific activities related to floatables management and
reduction to be included in the permittee's stormwater management plan (SWMP).
The NYC draft work plan determining the floatables rate into the MS4 was published in August of
2017. The work plan summarizes a literature review of other municipalities' methods, including Los
Angeles, San Francisco, Washington D.C., Baltimore City, and Baltimore County. The plan then details
the proposed methodology using field monitoring, land use, catchment characteristics, and catch
basin attributes to estimate loading rate of floatables.
Fairfax County Individual MS4 Permit: Part I.C.3
Summary:
Permittee shall implement a floatables monitoring program, which includes the development of
assessment protocol for trash, data analysis of monitoring results, and annual reporting.
Excerpt from permit:
No later than 24 months after the effective date of the permit, the permittee shall develop and
implement a floatables monitoring program. The intent of the monitoring program is to determine
the loading of floatables from the MS4 to streams within Fairfax County. The permittee will
implement the floatables monitoring program as follows:
a)	Monitoring shall be conducted at five (5) monitoring sites located atMS4 outfalls and/or
streams receiving discharges from the MS4.
b)	Monitoring shall be conducted once per quarter after program implementation.
c)	The monitoring program shall include the count of floatables visually observed and length or
area of sites assessed
Specific Reporting Requirements
• The annual report due October 1, 2016 shall include an update on the development of the
floatables monitoring program.
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
•	The annual report due October 1, 2017 shall include the monitoring protocols for the
floatables monitoring program.
•	Beginning with the annual report due October 1, 2018, each following annual report shall
include a list of sites monitored, a summary of the monitoring protocols used, and a summary
of the monitoring results and analyses
Standard Operating Procedures (SOP) provide further detail on how the permit holders must implement
certain permit provisions, such as street sweeping. The Fairfax MS4 Program Plan and Annual Report has
an accompanying SOP developed by the permittee that details Fairfax County's floatables monitoring
program.
California General MS4 Permit: Section E.14.A
Summary:
Permittee shall operate and maintain BMPs as well as evaluate effectiveness of BMPs using
assessment protocols. The Program Effectiveness Assessment and Improvement Plan included in
the permit provides a minimum standard for the evaluation of BMP performance.
Excerpt from permit:
(i)	Prioritized BMPs include BMPs implemented based on pollutants of concern. Where
pollutants of concern are unidentified, prioritized BMPs are based on common urban
pollutants (i.e., sediment, bacteria, trash, nutrients). The annual effectiveness assessments
will help identify potential modifications to the program to ensure long-term e ffectiveness.
(ii)	Implementation Level -
(a) The Program Effectiveness Assessment and Improvement Plan shall include the following
elements, at a minimum as applicable:
1)	Identification of overall program goals including pollutants of concern and
prioritized BMPs
2)	Documentation of the level of implementation of storm water program elements
3)	Identification and targeting of target audience(s)
4)	Assessment of BMP performance at achieving outcome levels
5)	Assessment of pollutant source reductions achieved by individual BMPs
6)	Quantification ofpollutant loads and pollutant load reductions achieved by the
program as a whole
7)	MS4 discharge quality, where available, including analysis of the data
8)	Receiving water quality data, including analysis o f the data
9)	Identification of long-term effectiveness assessment, to be implemented beyond the
permit term
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
(b)	The Program Effectiveness Assessment and Improvement Plan shall assess BMP and
program effectiveness in terms of the following Outcome Levels:
1)	Storm water program activities
2)	Awareness
3)	Behavior
4)	Pollutant load reductions
5)	MS4 discharge quality (where assessment is supported by MS4 discharge quality
data)
(c)	The Program Effectiveness Assessment and Improvement Plan shall identify assessment
methods for privately owned BMPs.
(d)	The Program Effectiveness Assessment and Improvement Plan shall identify assessment
methods the Permittee will use to quantitatively assess BMP performance at reducing
pollutant loads wherever feasible, using the following or equivalent methods:
1)	Direct quantitative measurement of
pollutant load removal for BMPs that lend
themselves to such measurement (e.g.,
measuring sediment collected through
street-sweeping activities):
2)	Science-based estimates of pollutant load
removal for BMPs where direct
measurement of pollutant removal is
overly challenging (e.g., removal of heavy
metals through a bioswale):
3)	Direct quantitative measurement of
behaviors that serve as proxies of
pollutant removal or reduction (e.g., the
percentage of construction sites
demonstrated by inspection to be in
compliance with permit conditions) : or
4)	Visual comparison (e.g., using
photographs to compare the amount of
trash in a creek between one year and the
next).
San Francisco Individual MS4 Permit: Provision C.10
Summary:
Permittees shall demonstrate compliance with trash discharge prohibitions and trash-related
Receiving Water Limitations through the timely implementation of control measures and other
actions to reduce trash loads from municipal separate storm sewer systems.
The Program Effectiveness Assessment and
Improvement Plan is an approach for
assessing the effectiveness of the required
BMPs for the prioritized pollutants of concern
(POC). The Plan is essential in ensuring that
relevant BMPs are installed and maintained
and in tracking of their effectiveness over
time. Although trash is explicitly mentioned
only once in the Effectiveness Plan, it applies
to all permit provisions addressing POCs in
the California MS4 permit, including several
trash provisions detailed in this compendium
(Section E.ll.F and Section E.ll.G).
Specifically, permittees who have prioritized
trash as a POC would apply this approach to
the assessment of the effectiveness of the
required BMPs.
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Excerpt from permit:
C.lO.ci. Trash Reduction Requirements
Permittees shall implement trash load reduction control actions in accordance with the following
schedule and trash generation area management requirements, including mandatory minimum
full trash capture systems, to meet the goal of 100 percent trash load reduction or no adverse
impact to receiving waters from trash by July 1, 2022.
i.	Schedule - Permittees shall reduce trash discharges from 2009 levels, described below, to
receiving waters in accordance with the following schedule:
a.	70 percent by July 1, 2017: and
b.	80 percent by July 1, 2019.
In addition, Permittees should achieve 60 percent reduction by July 1. 2016. This is not a
mandatory deadline; rather, it shall be used as a performance guideline to meet the mandatory
July 1. 2017 deadline. Permittees that do not attain the 60 percent performance guideline shall
submit documentation of a plan and schedule of implementation of additional trash load
reduction control actions that will attain the July 1. 2017 deadline. ...
ii.	Trash Generation Area Management - Permittees shall demonstrate attainment of the
C.lO.a.i trash discharges percentage-reduction requirements by management of mapped
trash generation areas within their jurisdictions delineated on Trash Generation Area Maps
included with their Long Term Trash Reduction Plans, submitted in Februarys 2014, in
accordance with the requirements and accounting set forth in this provision. ...
a.	Permittees shall implement trash prevention and control actions, including fill trash
capture systems or other trash management actions, or combinations of actions, with
trash discharge control equivalent to or better than full trash capture systems, to reduce
trash generation to a Low trash generation rate or better. Actions equivalent to full trash
capture means actions that send no more trash down the storm drain system than a full
trash capture device would allow, which is essentially no trash discharge except in very
large storm flows. The C.lO.a.i percent reductions shall be demonstrated by percent of
2009 Very High, High, and Moderate trash generation areas reduced to lower trash
generation categories or Low trash generation by the C.lO.a.i mandatory deadlines.
b.	Permittees shall ensure that lands that they do not own or operate, but that are plumbed
directly to their storm drain systems in Very High, High, and Moderate trash generation
areas are equipped with full trash capture systems or are managed with trash discharge
control actions equivalent to or better than full trash capture systems. The efficacy of the
latter shall be assessed with visual assessments in accordance with C.lO.b.ii. If there is a
full trash capture device downstream of these lands, no other trash control is required.
Permittees shall map the location, or otherwise record the location, of all such lands
greater than 10,000ft2 that are plumbed directly to their storm drain systems by July 1,
2018, including the trash control status of these areas. This information shall be retained
by the Permittees for inspection upon request.
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Hi. Mandatory Minimum Full Trash Capture Systems - Permittees shall install and maintain a
mandatory minimum number of full trash capture devices, to treat runoff from an area
equivalent to 30 percent of retail/wholesale land area, as documented by the Association of
Bay Area Governments, which drains to the storm drain system within their jurisdictions. A
city Permittee with a population less than 12,000 and retail/wholesale land less than 40
acres, or a population less than 2,000, is exempt from this fill trash capture requirement.
Table 2 in Attachment E contains the minimum amount of drainage areas that must be treated
with full trash capture devices by each city or county Permittee, and the minimum number of
trash capture devices required to be installed and maintained by flood management agency
Permittees.
A full capture system is any single device or series of devices that traps all particles retained by a
5 mm mesh screen and has a design treatment capacity of not less than the peak flow rate
resulting from a one-vear, one-hour, storm in the sub-drainage area or designed to carry at least
the same flow as the storm drain connected to the inlet. The device(s) must also have a trash
reservoir large enough to contain a reasonable amount of trash safely without overflowing trash
into the overflow outlet between maintenance events... Types of systems certified by the State
Water Resources Control Board are deemed full capture systems. A stormwater treatment facility
implemented in accordance with Provision C.3 is also deemed a full capture system if the facility,
including its maintenance prevents the discharge of trash to the downstream MS4 and receiving
waters and discharge points from the facility, including overflows, are appropriately screened or
otherwise configured to meet the full trash capture screening specification for storm flows up to
the full trash capture one year, one hour storm hydraulic specification (C. 10.a. Hi.).
C.lO.b. Demonstration of Trash Reduction Outcomes
i.	Full Trash Capture Systems - Permittees shall maintain, and provide for inspection and
review upon request, documentation of the design, operation, and maintenance of each of
their full trash capture systems, including the mapped location and drainage area served by
each system.
ii.	Other Trash Management Actions - Permittees shall maintain, and provide for inspection
and review upon request, documentation of non-full trash capture system trash control
actions that verifies implementation of each action. Permittees shall also conduct assessment
of the action that verifies effectiveness of the action or combination of actions and maintain,
and provide for inspection and review upon request, documentation of assessments. ...
iv.	Source Control - Permittee jurisdiction-wide actions to reduce trash at the source,
particularly persistent trash items, may be valued toward trash load reduction compliance by
up to ten percent load reduction total for all such actions. ...
v.	Receiving Water Monitoring - Permittees shall conduct receiving water monitoring and
develop receiving water monitoring tools and protocols and a monitoring program designed,
to the extent possible, to answer the following questions:
• Have a Permittee 's trash control actions effectively prevented trash within a Permittee 's
jurisdiction from discharging into receiving water(s)?
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•	Is trash present in receiving water(s), including transport from one receiving water to
another, e.g., from a creek to a San Francisco Bay segment, at levels that may cause
adverse water quality impacts?
•	Are trash discharges from a Permittee 's jurisdiction causing or contributing to adverse
trash impacts in receiving water(s)?
•	Are there sources outside of a Permittee 's jurisdiction that are causing or contributing to
adverse trash impacts in receiving water(s)? ...
b. Report and Proposed Monitoring Program - Permittees shall report progress in the 2018
Annual Report, and submit a preliminary report by July 1. 2019 and a final report by July 1.
2020 on the proposed trash receiving water monitoring program. The progress report is not
required if the Permittees conduct this work through an independent third party, approved by the
Executive Officer, that provides input and participation by interested parties and scientific peer
review of the tools and protocols and testing results and proposed receiving monitoring program.
C.lO.c. Trash Hot Spot Selection and Cleanup
Trash Hot Spots in receiving waters shall be cleaned annually to achieve the multiple benefits of
abatement of impacts and to learn more about the sources and transport routes of trash loading.
C.lO.d. Trash Load Reduction Plans
Each Permittee shall maintain, and provide for inspection and review upon request, a Trash
Load Reduction Plan, including an implementation schedule to meet the C.lO.a Trash Load
Reduction requirements. A summary of any new revisions to the Plan shall be included in the
Annual Report. The Plan shall describe trash load reduction control actions being implemented
or planned and the trash generation areas or trash management areas where the actions are or
will be implemented, including jurisdiction-wide actions, such as source control ordinances.
C. 10.fi Reporting
Each Permittee shall provide the following in each Annual Report:
i.	A summary of trash control actions within each trash management area, including the types
of actions, levels of implementation, areal extent of implementation, and whether the actions
are ongoing or new, including initiation date.
ii.	Upon request by the Executive Officer, an updated trash generation area map or maps, which
include trash management areas, including the locations and associated drainage areas and
of full trash capture systems and other trash control actions, and the location of Trash Hot
Spots, with highlight or other indication of any revisions or changes from the previous year
map(s). These maps can be used to illustrate progress toward achieving the trash reduction
requirements in C. 10.a.i. ...
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iv.	An accounting of its non-fiill trash capture system trash control actions assessments by
providing a summary description of assessments in each of its trash management areas,
including the number and dates of observations.
v.	An accounting of progress toward or attainment of C.lO.a.i trash discharge reduction
performance guidelines and mandatory deadlines using the C.lO.a.ii trash generation area
mapping methodology and formula.
a.	If a Permittee cannot demonstrate attainment of the 2016 performance guideline, it shall
submit a detailed plan and schedule of implementation of additional trash load reduction
control actions that will attain the 2017 mandatory deadline.
b.	If a Permittee cannot demonstrate attainment of the 2017 or 2019 mandatory trash load
reduction deadline, it shall submit a report of non-compliance with the associated Annual-
Report, or in advance of the Annual Report, that describes actions to comply with the
mandatory reduction deadline in a timely manner. The report shall include a plan and
schedule for implementation of full trash capture systems sufficient to attain the required
reduction. A Permittee may submit a plan and schedule for implementation of other trash
management actions to attain the required reduction in an area where implementation of
a full trash capture system is not feasible. In such cases, the report shall include
identification of the area and documentation of the basis of the Permittee 's determination
that implementation of a full trash capture system is not feasible.
vi.	In the 2018 Annual Report, progress on development and testing of the receiving water
monitoring program.
vi. The volume removed for the most recent five years of hot spot cleanup for each of its
trash hot spots, or for the years of cleanup if a new trash hot spot location has been
selected. ...
City and County of Honolulu MS4 Permit: Section D.l.F.VII
Summary:
Permittee shall implement its Trash Reduction Plan including conducting a trash hotspots
assessment to determine baseline loading, identify and implement control measures to meet
quantitative trash reduction goals, and report on its actions.
Excerpt from permit:
Trash Reduction Plan. The Permittee shall continue to implement its Trash Reduction Plan, dated
June 2012 unless required to be revised by DOH. The Trash Reduction Plan shall be included
within the SWMP and any revisions reported in the Annual Report. Trash means all improperly
discarded waste material excluding vegetation, except for yard/landscaping waste that is
illegally disposed of in the storm drain system.
Examples of trash include, but are not limited to, convenience food, beverage, and other product
packages or containers constructed of aluminum, steel, glass, paper, plastic, and other natural
and synthetic materials. The Trash Reduction Plan shall assess the issues and identify control
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measures to be implemented and monitoring activities to determine compliance with this permit,
including, at a minimum the following:
•	Plan to determine a quantitative estimate of the debris currently being discharged (baseline
load) from the MS4, including methodology used to determine the load.
•	Description of control measures currently being implemented as well as those needed to
reduce debris discharges from the MS4 consistent with short-term and long-term reduction
targets.
•	A short-term plan and proposed compliance deadline for reducing debris discharges from the
MS4 by 50% from the baseline load.
•	A long-term plan and proposed compliance deadline for reducing debris discharges from the
MS4 to zero.
•	Geographical targets for trash reduction activities with priority on waterbodies listed as
impaired for trash on the State's CWA Section 303(d) list.
•	Trash reduction-related education activities as a component ofPart D.l.a.
•	Integration of control measures, education and monitoring to measure progress toward
reducing trash discharges.
•	An implementation schedule for compliance with the short-term and long-term discharge
limits in the shortest practicable timeframe.
•	Monitoring plan to aid with source identification and loading patterns as well as measuring
progress in reducing the debris discharges from the MS4.
•	The Annual Report shall include a summary> of its trash load reduction actions (control
measures and best management practices) including the types of actions and levels of
implementation, the total trash loads and dominant types of trash removed by its actions, and
the total trash loads and dominant types of trash for each type of action.
The Permittee shall comply with the following implementation schedule as provided in its
Trash Reduction Plan:
TASK
COMPLETION DATE
Short-Term Plan
Trash Hotspot Assessment (THA)

Phase 1 Surveys
6/30/2014
Phase 2 Surveys/Complete Baseline Load Study
6/30/2016

Phase 3 Surveys
6/30/2018

THA Report
6/30/2019
Short-Term Reductions (meet 50% of baseline load)
6/30/2023
Long-Term Plan
Implementation & Monitoring Strategy
6/30/2024
Long-Term Reductions (zero discharge/100% reduction of
the baseline load)
6/30/2034
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3 BEST MANAGEMENT PRACTICES FOR REDUCING TRASH IN STORMWATER
CHAPTER 3. BEST MANAGEMENT PRACTICES FOR
REDUCING TRASH IN STORMWATER
This chapter of the compendium provides a tabular summary of a variety of available BMPs for
reducing trash m stonnwater. For each BMP. Exhibit 2 provides a general description;
information on costs, both capital and operations and maintenance (O&M) costs; effectiveness in
reducing trash in stonnwater; and sources for this information. This summary is not a
comprehensive review of all BMPs, however, it is included in this compendium as a resource to
assist permit writers by serving as an overview of the wide range of BMPs available, as well as an
indication of their costs and effectiveness. Where EPA becomes aware of BMPs that may have
been left out, or that emerge in the coming years, this chapter will be modified accordingly to
address these BMPs.
Structural controls:
Physical barriers that collect trash before it enters the
waterway or remove trash from within a waterway.
Non-Structural controls:
BMPs can be implemented at all stages of the trash life cycle. They can reduce trash by
preventing litter through source control or by collecting trash, either before it enters the
stormwater system by establishing upstream maintenance routines or once it is in the waterway
by installing in-stream structures that remove trash loads. Although BMPs are functionally
diverse, all BMPs can generally be categorized as a
structural control or non-structural control.
Non-structural BMPs include services and maintenance
that will reduce litter and source control through
legislative actions such as bag bans and litter fees, and
Booms can capture large amounts oj
education and public outreach.	fmsh .; riyer huffaj[ fo aMress mot
Each type of trash	cause of problem.
control has its
associated advantages and disadvantages. Structural controls
result in high load reductions but may fail to address the root
cause of trash in waterways and can be costly to install and
maintain. They are usually designed for specific flow rates and
by pass at higher flows. On the other hand, non-structural
controls focus on preventing trash from entering waterways
but do not remove trash that is already in a waterway.
Implementing both structural and non-structural controls
across the full trash life cycle is a strategy that can maximize
the impact of trash reduction efforts. Hie specific nature of the
New Jersey's "Stop the Drop "program
is one of many creative anti-litter
campaigns.
39 | Page

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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
trash problem within a locality should determine the most effective combination of trash
reduction interventions.
Capital cost, BMP effectiveness, maintenance needs and associated costs, and location are all
important factors to consider when selecting BMPs. Capital costs, maintenance, and effectiveness
for BMPs are all described in Exhibit 2 below. The frequency and cost of maintenance are
particularly important to consider for structural BMPs, as failing to properly maintain them can
cause serious problems, namely flooding. Large capital investments, such as vacuum trucks or
street sweepers, may also be necessary to clean and maintain devices. The costs and effectiveness
of BMPs are site specific, and the amount of rainfall, quantity of trash and debris, population
density, and other local needs are all factors to consider when choosing what strategies are best
suited to meeting the particular needs of the community. Other considerations include conducting
land-use and litter studies to map trash hot-spots and optimize placement and ensuring that
structural BMPs that require frequent cleaning and other maintenance are installed in places
accessible to crews and equipment.
Exhibit 2. Best Management Practices
BMP
DESCRIPTION
COST*
EFFECTIVENESS
SOURCES**
Structural Controls
Catch Basin
Inserts
Category of devices that
filter runoff entering a catch
basin. A filter medium (such
as a basket or net) is
suspended in the catch
basin and captures leaves,
sediment, and trash as it
enters the water system.
Numerous devices are
designed not only to
capture trash and debris,
but also fine sediment and
soluble contaminants.
Two types of inserts,
Connector Pipe and Basin
insert devices, are detailed
in the following two rows.
The costs associated with
different modifications
vary. Simple trash
buckets can cost as little
as $200, while installing
vortex valves in catch
basins can cost as much
as $1,400 per basin.
Cost per cleaning event is
$300-$440. Specific
frequency of
maintenance depends on
location, device and
season. Weekly
maintenance can be
necessary.
Effectiveness of catch
basins is dependent on
keeping the units cleaned
out; a clogged catch
basin can cause flooding
and reintroduce captured
trash into the
stormwater system.
Inserts should be placed
in catch basins that are
easy for maintenance
crews to access with a
vacuum tuck. Travel
distance and parking
availability should be
considered.
LA High Trash-
Generation Areas and
Control Measures 2002-
Duke Environmental
Law and Policy Clinic
2018-
Orange Countv Catch
Basin Technical
Appendix-
Connector Pipe
Screen (type of
catch basin
insert)
Metal screen assembly
installed inside a catch
basin in front of the outlet
pipe. The unit is designed to
retain all trash and gross
solids larger than 5 mm
(0.197 in) inside the catch
basin and retains large
volumes of sediment as
well.
$250-$500 depending on
size.
Regular maintenance
required. Inspection
necessary after every
significant storm.
Cleaning takes 5-10 min
per basin.
Vacuum truck required
for cleaning screen costs
approximately $400,000.
The San Francisco
Estuary Partnership
found that "all screens
collected trash
effectively. Some minor
problems with mud
getting into the catch
basins but otherwise the
screens performed well."
Bav Area-Wide Trash
Capture Demonstration
Project4
SF Trash Capture
Control Devices
Appendix-
Duke Environmental
Law and Policy Clinic
Structural Controls
2018 6
Commercial Truck
Trader7
40 | Page

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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
BMP
DESCRIPTION
COST*
EFFECTIVENESS
SOURCES**
Curb Inlet
Basket (type of
catch basin
insert)
Rectangular or round catch
basin inserts fabricated in
stainless steel or fiberglass
with screens fabricated with
similar materials. The
inserts filter water as it
passes through various
levels of increasingly fine
pore opening screens and
collects trash, leaves, and
sediment. Some baskets
include media filters that
may treat water for other
pollutants of concern.
$500 to $1,000
depending on inlet
material of construction,
size and geometry.
Cleanouts typically cost
between $30 and $50 per
catch basin.
Vacuum truck required
for cleaning screens costs
between $135,000 and
$165,000.
Bay area project reported
the device was effective
at capturing trash but
required frequent
maintenance.
Regular maintenance,
necessary to maintain
effectiveness. Cleaning
recommended when
basin is 40% full.
Necessary to replace
inserted media every 3-5
years.
SF Trash Capture
Control Devices
Appendix5
Commercial Truck
Trader8
Catch Basin
Hoods
Device attached to the
inside of a catch basin or
manhole designed to
prevent the outflow of
floating debris and oil.
$400 to $7,000
depending on size.
Regular cleaning
required.
A New York City (NYC)
study found that hooded
catch basins capture
approximately 85
percent of the litter,
while unhooded catch
basins capture only 30
percent of litter.
Effectiveness is
dependent on being
properly maintained;
hoods are ineffective
when they become
clogged with debris.
NYC Storm water
Management Plan-
USGS Catch Basin Hood
Studv 2009—
Stormwater Snout Price
List11
In-stream
Booms and
Nets
Floating in-stream barriers
that capture floatable trash
in slow-moving rivers. Trash
must be removed manually
using skimmer vessel or
boom truck.
Price varies significantly
with site conditions.
In NYC, the one-time
capital costs for an
installed litter boom
ranged from $200,000 to
$300,000. Oakland and
Los Angeles reported
much lower initial capital
costs ranging from
$50,000 to $90,000.
The Los Angeles system
cost $620,00 annually for
operation, maintenance,
and monitoring. Trash
harvested cost $1,500
per ton. Oakland
reported $75,000 in
annual O&M costs.
The Los Angeles Public
Works Department
tested the effectiveness
of the litter boom and
estimated performance
of the technology to be
80%.
A study of a four-boom
containment system in
NYC estimated that the
boom captured 75% of
floatable material.
Santa Clara BMP
Toolbox-
Skimmer
Skimmer vessels are used to
collect floating trash. Used
in conjunction with a
containment boom or other
equipment.
Boston purchased a
custom trash skimmer for
roughly $260,000.
Ease of maneuvering
through waterways and
customizable features
makes this BMP flexible
and effective. Almost
always operated in
conjunction with other
equipment (see in-
stream booms and nets).
Santa Clara BMP
Toolbox12
Boston Herald13
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
BMP
DESCRIPTION
COST*
EFFECTIVENESS
SOURCES**
End-of-Pipe
Net
Mesh bags located at
outfalls of municipal sewer
systems to collect debris
that has traveled through
the storm water system.
Prices vary depending on
net size and the flow it
must withstand
One town in Australia
installed nets on 750mm
and 450mm pipes for
$21,000.
O&M costs are
dependent on the
capacity of the system
and frequency of storm
events. Greensboro
Hampton, VA found that
cleaning was necessary
every three months and
cost $2,000 per cleaning
event.
NYC study found
floatables-capture
efficiency is 90% to 95%,
depending on weather
conditions and
operational
NYC Storm water
Management Plan9
Machado Lake CA -
Trash TMDL—
Kwinana, Australia15


considerations.
Effective in capturing
large volumes of trash.
Some users report issues
with nets coming loose
or breaking while others
reported they did not
have issues even during
large storm events
Duke Environmental
Law and Policy Clinic
20182
Fixed Inlet
Screen
Fixed inlet screen over
storm drains made of
stainless steel. Stops large
debris from entering storm
drain system.
$100 to $400 depending
on size.
Requires regular clearing
either manually or by
street sweeper truck.
Tracking of California's
Trash Project found that
67 percent to 69 percent
less trash entered inlets
with inlet screens in San
Jose and Oakland.
The possibility of
increased ponding is a
potential concern.
SF Trash Capture
Control Devices
Appendix5
LA Assessment of
Screen Covers-
Duke Environmental
Law and Policy Clinic
Structural Controls
201817
Automatic
Retractable
Screen
Device mounted inside curb
inlet openings. It remains
closed during dry season
and low water flow but
opens automatically during
continuous heavy water
flow. Can be calibrated to
open automatically for
specific water flow levels to
avoid flooding.
$500-$2,300 depending
on size.
Requires regular clearing
either manually or by
street sweeper truck.
Works as an upgraded
version of the fixed inlet
screen that avoids
ponding issues.
Regular maintenance
required to remain
effective.
SF Trash Capture
Control Devices
Appendix5
Hydrodynamic
Separators
Also known as a "vortex
separator" or "swirl
concentrator." Contains
large cylindrical separation
chambers in which storm
water enters, creating a
vortex to separate trash,
debris, oil, and other
pollutants from storm
water. Heavier material
settles to the bottom of the
storage sump, and
floatables remain on the
surface of the water.
Price varies significantly
based on site specific
conditions. Estimates
range from $5,000 to
$65,000.
Annual maintenance
costs vary. Charlotte, NC
clean theirs 1-2 times per
years, at a cost of $2,000
per cleaning event.
Effective in capturing
large volumes of trash.
Maintenance needed -
recommended at least
annually.
Care must be taken in
selecting a hydro-
dynamic separator as not
all are designed to
capture floating trash.
Duke Environmental
Law and Policv Clinic
20192
Duke Environmental
Law and Policy Clinic
Structural Controls
2018118
Increased Trash
Can
Accessibility
Increase the number and
density of trash cans within
a municipality. Distance to
the nearest trash
Capital cost per can is
approximately $120 and
the O&M cost per can
annually is $1,100.
Keep America Beautiful
reports that people
observed littering were
on average about 29 feet
from a trash receptacle,
LA High Trash-
Generation Areas and
Control Measures 20021
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
BMP
DESCRIPTION
COST*
EFFECTIVENESS
SOURCES**

receptacles affects degree
of littering.
Philadelphia spent $5.6
million servicing wire
wastebaskets in 2018.
the rate of littering
decreased to 12% when
people were within
about 10 feet.
A Philadelphia study
showed that when the
number of trash
receptacles decreased,
more staff time had to be
spent collecting litter,
driving up costs.
Philadelphia Trash
Receptacle Placement
Study—
KAB National Studv on
Littering Behavior in
America—
Philadelphia PlanPhillv-
Increased
Cigarette
Receptacles
Increase number and
density of cigarette
receptacles in public areas.
Cigarette butts are one of
the largest sources of litter.
Cigarette receptacles are
most effective close to
parking lots and rest areas.
A review of available
vendors shows capital
cost of cigarette
receptacles is about $30-
$200 each.
Cigarette receptacle
maintenance costs are
generally rolled in with
trash can maintenance
costs.
Oceanside, San Diego
found a 5.5% increase in
proper cigarette disposal
at sites with ash
receptacles and collected
170 pounds of cigarette
butts in four years.
LDDA/KAB Cigarette
Litter Prevention
Program—
Solar Smart
Waste and
Recycling
System
Solar powered trash
cans/recycling bins (smart
cans) that act as trash
compactors can hold 5x
more than regular trash
cans and can send
notifications when they are
full to optimize trash
collecting resources. The
software platform, with
collection notifications and
smart can fleet metrics, is a
key part of this
intervention.
Solar power rubbish
compacting bins cost
$4,600 including
notification software and
ashtray features.
Philadelphia has a fleet
of 975 bins. Capital cost
for the system was $7
million. The city initially
anticipated saving $13.5
million in personnel costs
over 10 years, but the
actual savings has been
roughly half that -$6.6
million - because of the
high maintenance costs.
Seattle conducted an in-
depth benefit-cost
analysis and decided
against the system.
Positive:
Smart cans hold 180
gallons of trash and
therefore reduce
collections by 70% to
80%.
Somerville, MA went
from emptying bins three
times a day to twice a
week in highly trafficked
areas.
Negative:
Philadelphia reported the
technology often failed
to alert staff when the
trash compactors were
near capacity. The city
also incurred an
unforeseen expense in
the form of a five-person
squad dedicated to
repairing the
compactors.
Seattle Benefit-Cost
Analysis of Solar Trash
Compactors-
Philadelphia High-Tech
Trash Cans Review—
Full Capture
Vortex
Separation
System (VSS)
Diverts the incoming flow of
storm water and pollutants
into a pollutant separation
and containment chamber.
Solids within the separation
chamber are kept in
continuous motion and are
prevented from blocking
the screen so that water
can pass through the screen
and flow downstream.
Three different capacities
in cubic feet per second
(cfs):
$17,400 for 1-2 cfs
$60,000 for 6-8 cfs
$120,000 for 19-24 cfs
Maintenance costs
decrease significantly as
the size of the system
Studies have shown that
VSS systems remove
virtually all trash
deposited into a storm
drain system.
Machado Lake CA -
Trash TMDL12
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
BMP
DESCRIPTION
COST*
EFFECTIVENESS
SOURCES**


increases, but the annual
servicing costs of a unit
are roughly $2,500.


Inclined Screen
and Linear
Gross Solids
Removal
Devices
Trash is retained in a
storage area of the vault
located at the bottom of
the inclined screen or linear
screen cage. Flows enter
the device through a trough
and weir that distribute
inflow across the top of the
inclined screen. The trough
captures the heavier solids
such as gravel and sand.
Flows exit the device by
passing through the inclined
screen or linear cage.
One CA study analyzed
three inclined screens
where construction costs
ranged from $150,000-
$240,000.
The same California
study looked at three
linear devices which
ranged in cost from
$85,000-$280,000.
Should be cleaned once a
year.
The inclined screen
device was found to
remove 66% to 100% of
litter by weight (and by
volume). Capacity is
scaled to accommodate a
once-per-year removal
cycle.
The linear radial device
was found to remove
90% to 98% of litter by
weight (and 75% to 92%
of litter by volume).
Capacity is scaled to hold
one year's estimated
accumulation of trash.
CA - Design and
Performance of
Highwav Runoff Litter
Devices—
Baffle Box
Concrete or fiberglass
structures that use a two-
chamber design to remove
pollutants, primarily trash
and suspended solids, by
slowing the flow velocity
through the box, thereby
allowing solids and
associated pollutants to
settle to the bottom of the
box.
They are best suited for
retrofitting into existing
storm pipes.
Prices vary widely around
about $20,000-$30,000.
Sewers that are
retrofitted with baffles
can cost less than
$20,000 to install.
Must be cleaned out
every two to three
months in the dry
season, and every month
in the wet season. The
average cleaning cost for
a baffle box is $450. An
average vacuum truck
can clean two baffle
boxes per day.
A California study found
that baffle boxes remove
87% to 98% of litter.
Regular maintenance
required.
CA - Design and
Performance of
Highwav Runoff Litter
Devices24
Machado Lake CA -
Trash TMDL12
Non-structural Controls
Single-Use
Product Bans
(e.g. Plastic
Bag, Plastic
Straw or
Styrofoam
Food Container
Bans)
Ban single-use products
such as plastic bags (SUPB),
plastic straws, or styrofoam
food containers. Plastic bag
bans are the most
widespread and studied.
Stores charge a fee
(typically 5-10 cents) for
multi-use plastic bags
(thicker, more durable, and
often made of recycled
materials) or paper bags.
San Francisco saved
roughly $845,000 in
avoided plastic bag
cleanup and single-use
plastic bag (SUPB) waste
processing. New York
City estimated a cost
savings of $11.5 million
associated with its PBB.
San Jose's PBB generated
an 89% decrease in
plastic bag litter in storm
drains, 60% decrease in
creeks and river, and 59%
decrease in streets.
San Diego achieved 86%
reduction of single-use
plastic bags.
San Jose Plastic Bag Ban
Implementation Results
Report-
Equinox Plastic Bag Ban
Impacts Study-
Container
Deposit
Legislation
(CDL)aka
"Bottle Bills"
When a retailer buys
beverages, a deposit is paid
to the distributor for each
container. Consumers pay
the deposit to retailers
when buying the beverage
and receive refunds when
empty containers are
returned. Distributors
Typically, CDLs involve a
5- or 10-cent charge to
consumers on glass,
aluminum, and plastic
beverage bottles.
Consumers receive this
deposit back when the
bottle is returned.
Studies conducted pre-
and post-bottle bill in
seven states showed
reductions in beverage
container litter ranging
from 69% to 84%, and
reductions in total litter
ranging from 30% to
65%.
Reducing Plastic
Pollution through
Economic Incentives-
Bottle Bill, org22
44 | Page

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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
BMP
DESCRIPTION
COST*
EFFECTIVENESS
SOURCES**

reimburse the retailer or
redemption center the
deposit amount for each
container, plus a handling
fee.
Unredeemed deposits
are either returned to
the state, retained by
distributors, or used for
program administration.


Street
Sweeping
Street sweeping trucks are
deployed to clean street
curbs on a set schedule.
There are various types of
street sweepers, including
mechanical sweepers and
air sweepers.
Capital cost of street
sweepers: $200,000-
$350,000 depending on
type of sweeper.
O&M costs of $15 to $75
per curb mile with a
median cost of $25. A
pilot study in Seattle
estimated $44 per curb
mile.
A California study found
that the median street
trash reduction from
sweeping was 90% and
that in 18 quantitative
events virtually no trash
was observed in storm
drain outlets after street
sweeping.
NYC estimated that
existing street sweeping
practices remove
approximately 55% of
litter from the streets.
Effectiveness is
dependent on parking
restrictions in sweeping
areas (ability to sweep to
curb).
CA Storm water Cost
Survev—
Seattle Street Sweeping
Study—
MN DOT Street
Sweeping Best
Practices—
NYC Storm water
Management Plan8
Public
Education
Campaigns
Public education campaigns
aim to inform the public
about the effects of littering
and improper disposal of
waste. Information is
shared through many
avenues, including the
Internet, billboards, and
public transit posters.
Effective campaigns often
promote recycling and
reuse. Cities and states
often use a memorable
catchphrase in a variety of
communication vehicles like
advertisements, school
curriculum materials, and
events.
Average reported cost
varies widely by activities
included and location.
California communities
spend, on average,
$85,000 annually ($0.65
per resident) on public
education relating to
litter and waste disposal.
Public education
campaigns have been
shown to lead to
significant increases in
recognition of litter as a
major problem.
"Don't Mess with Texas"
Anti-Litter campaign tied
to 34% reduction in
visible roadside litter
since 2009.
Other examples of
programs include "Stop
the Drop" campaign in
New Jersey and a "Litter
Free School Zones"
program in Nebraska.
NRDC CA Cost of Litter
Reduction Studv—
7 Top Litter Prevention
Campaigns Around the
World-
Keep Nebraska
BeautifulM
Cities Use Creative
Campaigns to Stop
Littering—
Community
Cleanup Events
Shoreline cleanups, park
cleanups, etc.
Officially sponsored events
that encourage individuals,
schools, businesses, and
other organizations to get
involved in cleaning up
targeted areas.
These also include efforts
organized to facilitate
cleanup after specific
community activities such
as festivals or sporting
events.
Varies based on size,
location, and specifics of
event.
Main costs are associated
with publicizing the event
and staff time spent
organizing and facilitating
volunteer labor.
Cities and states report
cleanup events to be
important and large-
impact contributors to
trash control.
The 2018 California
Coastal Cleanup Day
resulted in collection of
nearly 820,000 pounds of
debris.
CA Coast Cleanup
Commission—
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2 EXAMPLE TRASH PROVISION LANGUAGE FROM MS4 PERMITS
BMP
DESCRIPTION
COST*
EFFECTIVENESS
SOURCES**
Adopt-A-
Highway,
Adopt-A-
Stream, etc.
Volunteer programs for
people or organizations
through which they commit
to picking up litter a certain
number of times a year
(usually 2 to 4), along a
designated section of road,
highway, stream, or other
locations.
In 2014, the Michigan
DOT estimated the value
of the volunteer time
spent picking up litter on
state highways at $6.2
million with an estimated
DOT cost to administer
the program of $270,000
(excluding staff costs).
Despite the lack of
consistent data on the
costs and benefits of
these programs research
has shown that areas
with Adopt a Highway
Programs have 13% to
31% less litter than areas
without programs.
VT Program
Evaluation—
Storm drain
Stencils
Stencils are painted onto
storm drains, reminding
people that litter and
pollutants that enter the
storm drain often go
directly into waterways. In
some cases, stencils identify
which body of water the
storm drain leads to.
A review of available
vendors showed that
stencils cost between $5
to $45 depending on
complexity and vendor.
Pre-made markers cost
$150-$450 (depending
on size, quality, and if a
custom message is
added).
A study in Washington
found that 71 percent of
people who saw a
stenciled storm drain
knew that storm
drainpipes lead directly
to the nearest water
body, compared to only
40 percent of those who
had not seen storm drain
stencils.
Stencils must be regularly
repainted/ refreshed to
remain effective.
Wl Storm Drain
Stenciling Impacts-
Uncovered
Load
Ordinances
Ordinances requiring that
trucks and other vehicles
cover their loads to prevent
items from falling or
blowing onto the road.
Sometimes called "tarp
laws."
Municipalities charge
uncovered or unsecure
load fees. Walker County
charges $25 per vehicle
for violations.
Could save money by
reducing time needed to
clean up litter on roads
and highways.
Items originating from
uncovered trucks are the
single largest source of
roadside litter.
Ohio Litter Studv39
Walker Countv News
Uodate40
*Uriless otherwise noted, all costs have been adjusted to 2019 dollars. Capital costs were adjusted using the RS means index and
O&M costs were adjusted using the US price index.
**Sources are listed in the BMP references section at the end of this document. In addition, the California Statewide Trash
Amendments include a list of certified trash full capture systems. While the "full-capture" designation is specific to California, this
BMP list is a helpful resource that can be accessed here.
46 | Page

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4 CASE STUDIES
CHAPTER 4. CASE STUDIES
This chapter of the compendium presents two case studies of municipal floatables and trash
programs that were developed to address clear, specific, and measurable trash provisions in MS4
permits. These case studies are intended to provide insights on how trash provisions can influence
the development of floatables and trash programs, including how permit holders have
implemented the provisions in developing trash reduction programs.
The case studies included in this chapter - New York City, NY and Fairfax County, VA -
represent examples of municipal floatables and trash programs developed under differing
circumstances. The NYC MS4 permit and program are driven in part by New York State's
narrative water quality goal of zero trash and the listing of multiple water segments as impaired
by trash. By contrast, the Fairfax County MS4 permit and program were developed outside of
specific regulatory forcing agents, such as a water quality goal or the presence of impaired water
segments. Public awareness of the problem of trash in waterways was an important driver in both
the NYC and Fairfax County case studies.
Each case study summarizes the MS4 permit history and context and the related key elements of
the MS4 floatables and trash program and provides links to the full permit language relevant to
floatables and trash in Chapter 2.
EPA may update this chapter of the compendium with additional case studies in the future.
NEW YORK CITY (NYC) CASE STUDY 4
The NYC Phase I MS4 permit contains a wide breadth of floatable and settleable trash and
debris-related stormwater provisions (see Chapter 2 for permit language). The tasks associated
with the provisions have specific objectives, however, they are flexible in terms of their
implementation and execution.
The NYC permit addresses trash through the requirement for the MS4 to develop and implement
an independent floatables and debris control program and dictates specific actions the permittee
must include in its SWMP. The main objective of the floatables control program in the 2015-2020
4 Sources:
Personal communication, Pinar Balci and Kristin Ricigliano, New York City Department of Environmental Protection.
March 14, 2019.
Personal communication, Selvin Southwell, New York State Department of Environmental Conservation. June 4,2019.
NYC SWMP Plan, Chapter 9, Section 9.2, Evaluation of Existing Programs, Section 9.4, Review of Available
Technologies and Controls, Municipal Separate Storm Sewer Systems of New York City. August 2018.
Work Plan to Determine the Loading Rate of Floatable and Settleable Trash and Debris Discharged from the MS4.
NYC Stormwater Management Program, Appendix 9.1. August 2018.
NYC MS4 Permit, Appendix 2, Impaired Water Segments and Pollutants of Concern.
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permit cycle is to take a series of steps in order to determine and understand the magnitude and
characteristics of the trash load from the MS4 areas draining to floatables-impaired waterbodies.
During future permit cycles, the City will use the information gathered in the current permit term
to implement targeted BMPs to reduce the discharge of floatables and debris caused by storm
events.
Permit History and Context
The NYC permit's focus on stormwater pollution from trash follows previous, successful efforts
to require reductions in trash through the city's combined sewer overflow (CSO) program. The
CSO program works toward achieving New York State's narrative water quality standard of zero
trash in all waterways. An additional factor driving the focus on trash in both the City's MS4 and
combined sewer areas is the fact that New York State has designated 23 water segments in NYC
as impaired for floatables (Appendix 2, NYC MS4 Permit).
The CSO floatables control program initiated the ongoing conversation in NYC about trash in
discharges to waterways. The program developed targeted structural and non-structural floatables
controls, paving the way for the provisions on controls included in the MS4 permit. Requirements
in the MS4 permit target source control and complement the floatables control efforts happening
citywide. Through implementation of programmatic strategies such as street sweeping, catch
basin hooding, end-of-pipe netting/booming/skimming operations, and combined sewage
treatment at Wastewater Resource Recovery Facilities, NYC captures or removes citywide
approximately 96 percent of floatables originating as street litter. (See Section 9.2 of the SWMP
Plan). NYC also implements a host of education, outreach, and stewardship programs, which seek
to reduce the generation of litter.
Permit Provisions and Floatable and Settleable Trash Program
The NYC permit primarily addresses trash in stormwater through requirements for the SWMP,
including a dedicated section on the control of floatables and marine debris. For the 2015-2020
permit cycle, the permittee is required to monitor and evaluate trash-related programmatic efforts,
identify technological improvements and opportunities relevant to NYC, and develop a
methodology for selecting effective trash-related BMPs.
The program, as outlined in the permit and further detailed in the NYC SWMP, lays out the main
trash control actions that the City will implement within the permit cycle. These actions include
two main initiatives:
1.	Calculating the quantitative loading rate; and
2.	Carrying out an interim public education campaign.
Calculating Quantitative Load
NYC is developing a study to estimate the loading rate of floatables from MS4 outfalls to
waterbodies listed as impaired for floatables. The results of the study will include a
characterization of the type of trash entering the MS4 and an estimate of the loading rate. The
City will use this information to guide BMP selection and siting in the future.
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During the 2015-2020 permit cycle, the City has focused on the development of the loading rate
calculation methodology. In developing this methodology, the City relied on its own institutional
knowledge about trash-reduction strategies, industry experts (including staff from the NYC
department of sanitation, an engineering firm with experience with floatables and a robust
knowledge of past stormwater work in NYC, and other municipalities with floatables experience),
and past studies of trash loadings completed in NYC and other similar municipalities.
Stakeholders, including a group of active environmental NGOs and passionate citizens, shared
their observations on the loadings of floatables for specific waterbodies and their knowledge of
methodologies implemented elsewhere helped develop a contextual methodology for NYC.
The selected methodology combines field measurements and model analyses. NYC presented a
draft work plan to the public for input, and after incorporating public feedback, submitted the
final work plan to the state of NY. In the upcoming years, NYC plans to collect field
measurements of trash loadings.
NYC also collected information on the BMPs used in municipalities nationwide and assessed
their applicability. NYC currently implements, or has previously evaluated, nearly all of the types
of floatables controls that are in use in other similar municipalities (See Section 9.4 of the SWMP
Plan).
Using the loading rate results and review of BMPs, it is NYC's objective to then be able to make
evidence-based decisions on what BMPs the City should implement, and where the City should
site them, for the most effective floatables control. The current permit does not require specific
BMPs, but instead allows NYC the flexibility to decide which ones would be most advantageous
based on its research.
Interim public education campaign
While the City worked on developing the loading rate study, it conducted a short-term public
awareness campaign that allowed for interim progress in addressing trash on the streets. With the
support of local partners, including the New York Aquarium, the City implemented the DonY
Trash Our Waters campaign in two neighborhoods. The EPA Region 2 Trash Free Waters
program provided additional support by convening a stakeholder working group of academics,
consultants, and designers to provide input on the media campaign.
Implementation of the public awareness campaign has resulted in some noteworthy
accomplishments. The social media portion of the campaign generated over 4 million impressions
and resulted in over 54,000 visits to NYC's educational webpage on the topic of trash free waters.
To better understand the effectiveness of the campaign, NYC conducted a post-campaign survey
of 1,000 New Yorkers that asked questions about littering attitude and behavior, as well as their
awareness and understanding of the DonY Trash Our Waters Campaign. According to the survey,
citywide, 31% of New Yorkers recalled seeing the campaign images. Based on responses to open-
and close-ended questions, the public generally understood the campaign messages highlighting
the negative impact of litter on marine animals and the call to dispose of trash properly. When
asked whether the images made them (or would make them) less likely to litter, a majority
responded yes (58% citywide).
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Next Steps and Future Developments
With the current permit cycle ending on July 31, 2020, NYC is preparing for the next phase of
requirements that will be proposed in its MS4 permit renewal application, which is due in
February 2020. For the next permit cycle, NYC is planning to propose implementing the
approved loading rate study and continue implementing the existing programs that have resulted
in high capture rates of floatables (96% cited above). The study will provide information on the
loading rate from MS4 areas draining to floatables-impaired waterbodies that will enable NYC to
make data-driven decisions about future BMP selection and implementation.
FAIRFAX COUNTY, VA CASE STUDY 5
Fairfax County is a growing, urban/suburban area that faces many of the same litter and trash
problems as other cities and counties in the country. The County's individual MS4 permit
contains trash-related provisions that identify several clear, specific, and measurable requirements
focusing on monitoring, annual reporting, and public education and participation. These permit
provisions, along with public interest in reducing trash on land and in local waterways, are
important drivers behind the County's floatables program. Fairfax County does not have any
waters listed as impaired for trash and believes it can continue to implement a successful
floatables program without a regulatory forcing agent.
The implementation of the Fairfax County floatables program has been enhanced and facilitated
by cooperation from other entities within the County government, particularly the Stormwater
and Solid Waste business areas in the Department of Public Works and Environmental Services,
and a partnership with a local non-profit organization, Clean Fairfax Council. These cooperative
partners have provided expertise to augment the resources available through the stormwater
program. (See Exhibit 3)
5 Sources:
Fairfax Comity Individual MS4 Permit 2015
Fairfax Comity 2018 MS4 Program Plan and Annual Report: Appendix PI 3 Floatables Monitoring SOP
Fairfax Comity 2018 Program Plan and Annual Report: List of Comity's Public Outreach and Education Activities and
the Estimated Number of Individuals Reached Through the Activities
Personal Communication, Heather Ambrose and Emily Burton, MS4 Program Fairfax County Department of Public
Works and Environmental Services. 6/28/2019.
Personal Communication, Kate Bennet, former manager of Fairfax County's MS4 program. 7/19/2019.
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4 CASE STUDIES

f

Permit Provisions
Monitoring
Annual reporting
Public
Awareness
County Wide Focus
Cross-department effort
Local NGO partnerships

Floatables
Program
/

J
Trash Control and
Reduction
Exhibit 3: The MS4 permit provisions, along with public awareness of the trash problem and support for trash reduction,
have combined to establish an atmosphere in which the floatables program can be implemented effectively. The floatables
program, supported by cross-departmental efforts in the comity and partnerships with local NGOs, has helped control litter
and trash in Fairfax Comity.
Permit History and Context
Compared to the previous MS4 permit, the Fairfax County 2015 permit marked a significant shift
towards the regulation of trash as a source of stormwater pollution. The County's previous permit
included a requirement "to document the effectiveness of the litter control programs," but allowed
this documentation to "be accomplished through the "Adopt a Stream "program " (Fairfax
Permit 2000 Part I.B.I.k.2 (C.3.c). Therefore, the County had been using the Adopt a Stream
program to document litter control instead of instituting a stand-alone trash monitoring program.
However, as the Adopt a Stream program was no longer being implemented, new permit
provisions were needed in the 2015 permit to address trash control. These provisions included
requirements to develop a floatables monitoring program to determine the loadings of floatables,
and to promote and publicize the County's litter prevention program. There is significant public
awareness of trash and litter issues in the County and Fairfax County is currently continuing to
implement the floatables monitoring program as it begins the application process for its next MS4
permit.
Elements of the Fairfax County Floatables Program
Annual Report
The County develops an annual report that describes the ongoing activities performed to satisfy
the County's MS4 permit requirements. The annual report is presented as a table in which an
MS4 Action ID is assigned to each permit requirement. There is a row for each requirement that
shows the party responsible for the action, the County's program plan elements for complying
with each requirement, specific reporting requirements, and a report on the activities performed.
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4 CASE STUDIES
As shown below, the 2018 report includes four action IDs for floatables monitoring.
MS4 Action
Permit Requirement
Responsible
2018 Program Plan Elements
Due
Date

Annual
Timeline
Specific Reporting
ID
Party
(July 1, 2017 through June 30, 2018)
Permit Year

Requirement




1 2
3
4
5


C.3. Floatables Monitoring



C.3.
No later than 24 months after the effective date
of the permit, the permittee shall develop and
implement a floatables monitoring program. The
intent of the monitoring program is to determine
the loading of floatables from the MS4 to
streams within Fairfax County. The permittee
will implement the floatables monitoring program
as follows:
SWPD
Fairfax County developed and implemented a
floatables monitoring program by March 31, 2017.
March 31, 2017 ~
~
~
~

C.3.a.
Monitoring shall be conducted at five (5)
monitoring sites located at MS4 outfalls and/or
streams receiving discharges from the MS4.
SWPD
Monitoring sites were selected to allow
determination of the loading of floatables from the
MS4 to streams within Fairfax County.
October 1, 2016 ~
~
~
~
The annual report due
October 1, 2016 shall
include an update on the
development of the
floatables monitoring
program.
C.3.b.
Monitoring shall be conducted once per quarter
after program implementation.
SWPD
Floatables monitoring is be conducted once per
quarter in accordance with the protocols provided
in Appendix P13.

October 1, 2017 *
~
~
The annual report due
October 12017 shall
include the monitoring
protocols for the floatables
monitoring program.
C.3.C.
The monitoring program shall include the count
of floatables visually observed and length or
area of sites assessed.
SWPD
Floatables monitoring includes the count of
floatables visually observed and the length or area
of sites assessed.


October 1, 2018 ~
~
Beginning with the annual
report due October 1, 2018:
each following annual report
shall include a list of sites
monitored, a summary of
the monitoring protocols
used, and a summary of the
monitoring results and
analyses.
Floatables Program Standard Operating Procedures
The permit requires that "no later than 24 months after the effective date of the permit, the
permittee shall develop and implement a floatables monitoring program. The intent of the
monitoring program is to determine the loading of floatables from the MS4 to streams within
Fairfax County" (FairfaxMS4 Permit 2015 Part I.C.3). The monitoring and reporting
requirements are significant parts of the SOP and the most substantial trash-related change from
the previous permit.
The floatables SOP "describes Fairfax County's site selection, field reconnaissance, and floatables
monitoring protocols for evaluating the loading of floatables from the County's MS4 and provides
a framework for full compliance with the above MS4 pennit requirements" (Fairfax County SOP
2018). Fairfax County is updating its SOP to include language to address trash removal following
the trash monitoring events.
Monitoring and Reporting
The permit specifies that "monitoring shall be conducted at five (5) monitoring sites located at
MS4 outfalls and/or streams receiving discharges from the MS4... once per quarter... [and] shall
include the count of floatables visually observed and length or area of sites assessed" (Fairfax
MS4 Permit 2015 Part I.C.3). The permit gave Fairfax County two years after the pennit
effective date to select five monitoring sites. In order to obtain a representative sample of the
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4 CASE STUDIES
level of trash, the County started by using a land use survey to identify the most common land
uses in Fairfax County and selected sites from five of the top land use categories to "characterize
the loading rate of floatables from the County's MS4" (Fairfax County SOP 2018).6
As mentioned earlier, the County partnered with a local NGO, the Clean Fairfax Council, to
satisfy the monitoring requirement because of the Council's expertise and experience with litter
advocacy throughout the County. In exchange, the County provided funding for a portion of a
full-time job at the Council to support the floatables monitoring program.
The permit requires quarterly monitoring of five sites in years three through five of the permit.
The Clean Fairfax Council uses the regional monitoring protocol, developed by the Metropolitan
Washington Council of Governments (MWCOG), to assess the amount of trash at each site. The
protocol calls for counting each piece of trash in a 100-foot stretch in the designated area.
The County oversees the data analysis of the accumulated monitoring information. The goal is to
identify trends and draw conclusions about how to reduce sources of trash in the County. The
County plans to continue implementing the floatables program in upcoming years in order to
obtain sufficient data to allow for the development of long-term trends.
Education and Public Participation
The permit requires that the County "continue to promote individual and group involvement in
local water quality improvement initiatives including the promotion of local restoration and
clean-up projects, programs, groups, meetings and other opportunities for public involvement"
(FairfaxMS4 Permit Part I.B.2.J.1). One change from the previous permit to the 2015 permit
was an increased focus on changing behavior to prevent littering; the permit specifies that the
County must "promote and publicize the use of the permittee's litter prevention program "
(FairfaxMS4 Permit Part I.B.2.J.1). The Virginia Litter Tax, a 1976 law that raises roughly $2
million per year (Clean Virginia Waterways, 2014) helps provide money for community clean-
ups, recycling, and litter education. Clean Fairfax Council, Northern Virginia Soil and Water
Conservation District, and Fairfax County Park Authority conduct community clean-up events
throughout the year.
The County uses a number of strategies to educate citizens and businesses, encourage changes in
their behavior, and involve them in efforts to decrease trash and litter in the County. Some of
these include outreach at local events like farmers markets, meetings with social and civil
organizations, participation in radio and TV messages, presentations at schools and
environmental conferences, and advertising campaigns. The permit specifies that "beginning with
the annual report due October 1, 2016, each annual report shall include a list of permittee public
outreach and education activities and the estimated number of individuals reached through the
activities " (Fairfax MS4 Permit Part I.B.2.J. 1). Examples from the 2018 report include:
6 The categories selected were low density residential, commercial, institutional, medium density residential, and high
density residential. Open land was in the top five land use categories, but Fairfax County did not select this category
for monitoring because there is no trash found in open space and there is no target audience to direct outreach efforts
to for this category.
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4 CASE STUDIES
•	Storm drain marking: 1,306 storm drains were labeled, with 150 project leaders and
volunteers and 5,361 households educated
•	Conservation Currents Newsletter: Over 2,100 recipients
•	Enviroscape© watershed model presentations: 58 presentations to 1,520 students and
•	Green Breakfast seminars: 5 seminars to 256 attendees
Pilot Testing of Best Management Practices
As part of a pilot program, the County has installed two end-of-pipe trash nets and is in the design
phase of installing one in-stream floating trash collector. Because these devices are not being
implemented in response to any permit provisions, information on their effectiveness is not
included in the County's annual report. Both BMPs are in their pilot phases and the County has
indicated that they intend to evaluate how well they perform and how difficult they are to
maintain before considering broader implementation. While the County views these technologies
as promising techniques for removing trash from waterways, it is unsure of the degree of
maintenance that may be required to prevent unintended consequences, such as flooding and
collection of large amounts of leaf debris in the fall. These pilots are examples of how Fairfax
County is attempting to address litter through means beyond specific regulatory requirements.
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BMP REFERENCES
BMP REFERENCES
1	LA Department of Public Works. 2002. High Trash-Generation Areas and Control Measures.
January 2002.
2	Lauer, Nancy. 2018. Structural Litter Controls in Managing Stormwater Transported Litter in
North Carolina and the Southeast. Duke Environmental Law and Policy Clinic. May 22, 2018.
3	Orange County Public Works. 2011. Technical Guidance Document Appendices: Catch Basin
Insert Fact Sheet. May 19, 2011.
4	San Francisco Estuary Partnership. 2014. Bay Area-Wide Trash Capture Demonstration Project:
Final Project Report. May 8, 2014.
5	San Francisco Estuary Partnership. 2014. Appendix I: Trash Capture Devices Offered Through
the Project. May 8, 2014.
6	Duke Environmental Law and Policy Clinic. 2018. Implementation of structural litter controls:
Case studies from U.S. municipal stormwater permitting and planning. April 30, 2018.
7	Commercial Truck Trader. 2019. Vacuum Trucks for Sale. August 2019.
8	Commercial Truck Trader. 2019. Vacuum Trucks for Sale. August 2019.
9	NYC Environmental Protection. 2015. NYC Stormwater Management Plan. August 1, 2015.
10	Smith, Kirk. Effectiveness of Catch Basins Equipped with Hoods in Retaining Gross Solids and
Hydrocarbons in Highway Runoff, Southeast Expressway, Boston, Massachusetts, 2008-09.
2009. United States Geological Survey.
11	Best Management Products. 2019. BMP Snout List of Prices.
12	Santa Clara Valley Urban Runoff Pollution Prevention Program. 2007. Litter Booms.
13	Cohan. 2018. $250G boat to help take out the trash in Merrimack River. Boston Herald. August
25,2018.
14	California Regional Water Quality Control Board Los Angeles Region. 2007. Trash Total
Maximum Daily Load for Machado Lake in the Dominguez Channel Watershed. July 11, 2007.
15	Surfer Today. 2018. City of Kwinana Collects 815 Pounds of Garbage Using Drainage Nets.
August 10, 2018.
16	City of Los Angeles Sanitation Department of Public Works. 2006. Technical Report:
Assessment of Catch Basin Opening Screen Covers. June 2006.
17	Duke Environmental Law and Policy Clinic. 2018. Implementation of structural litter controls:
Case studies from U.S. municipal stormwater permitting and planning. April 30, 2018.
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4 CASE STUDIES
18	City of Philadelphia. 2018. Trash Receptacle Placement: Philadelphia Behavioral Science
Research Protocol. August 2017-May 2018.
19	Keep America Beautiful. 2009. Littering Behavior in America: Results of a National Study.
January, 2009.
20	PlanPhilly. 2018. With No Cash for Trash, City Mulls Partnerships with Private Groups.
October 1, 2018.
21	Longmont Downtown Development Authority. 2018. Keep Downtown Beautiful. June 2018.
22	Culgin, Mangan, Pool. 2013. Benefit-Cost Analysis of BigBelly Solar Trash Compactors in
City of Seattle Parks. The Evans School Review. Spring 2013.
23	Bykofsky, Stu. 2017. 'BigBelly' High-Tech Trash Cans in Philly Didn't Work Out as Planned.
Philadelphia Daily News. June 26, 2017.
24	Endicott, Berger, Stone. 2002. Design and Performance of Non-Proprietary Devices for
Highway Runoff Litter Removal. American Society of Civil Engineers 9th International
Conference on Urban Drainage. September 8-13, 2002.
25	Romanow, Kerrie. 2012. Memorandum: Bring Your Own Bag Ordinance Implementation
Results and Actions to Reduce EPS Foam Food Ware. San Jose Transportation and Environment
Committee. November 20, 2012.
26	Equinox Center. 2013. Plastic Bag Bans: Analysis of Economic and Environmental Impacts.
October 23, 2013.
27	Schuyler, Hardesty, Lawson, Opie, Wilcox. 2018. Reducing Plastic Pollution through
Economic Incentives. Envirobites: Environmental Science Research for Everyone. April 13,
2018.
28	Bottle Bill Resource Guide. 2019. What is a Bottle Bill? Accessed November 2020.
29	Currier, Jones, Moeller. 2005. NPDES Stormwater Cost Survey. Office of Water Programs
CSU Sacramento. January 2005.
30	Seattle Public Utilities, Herrera Environmental Consultants. 2009. Seattle Street Sweeping Pilot
Study: Monitoring Report. April 22, 2009.
31	Kuehl, Marti, Schilling. 2008. Resource for Implementing a Street Sweeping Best Practice.
Minnesota Department of Transportation: Local Road Research Board. February 2008.
32	Stickel, Jahn, Kier. 2013. Waste in Our Water: The Annual Cost to California Communities of
Reducing Litter That Pollutes Our Waterways. National Resources Defense Council. August
2013.
33	Zero Waste Scotland. 2019. 7 Top Litter Prevention Campaigns from Around the World. 2019.
34	Keep Nebraska Beautiful. 2019. Litter Free School Zones. 2019.
35	The Park Catalog. 2017. Cities Use Creative Campaigns to Stop Littering. November 16, 2017.
36	California Coastal Commission. 2018. California Coastal Cleanup Day. 2018.
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37	Vermont Agency of Transportation. 2016. Evaluation of Adopt a Park and Ride Program &
Adopt a Highway Program: Final Report. January 15, 2016.
38	Packer, Shepard. 1999. Storm Drain Stenciling: Impacts on Urban Water Quality. Wisconsin
Department of Natural Resources. Winter 1999.
39	Davey Resource Group and Ohio Department of Natural Resources. 2004. Ohio Statewide
Litter Study. June 2004.
40	Legge, Joe. 2019. Landfill Hours Updated as Enforcement Begins for Unsecured and
Uncovered Loads. April 13, 2019.
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