Establishing a Comprehensive Stormwater Program Plan

Municipal stormwater programs vary enormously in their ability to plan for the future. Some stormwater program plans account for all current and needed future activities and effectively articulate why these elements are critical to success. However, creating a comprehensive plan that addresses both short- and long-term goals and needs can be a central challenge for many programs, particularly in small to medium-sized communities.

Contents

• Why long-term program planning is important.
• What to include in a comprehensive stormwater program plan.
• How to develop a comprehensive stormwater program plan.
• How to define your future needs.
• Where to find guidance on future needs.
• Resources

Why long-term program planning is important

It is important to plan beyond the 5-year NPDES permit term. Similar to the wastewater, drinking water, and transportation sectors, program managers in the stormwater sector should take a longer-term view of program goals, needs, costs and benefits, and likely investments. This will help align your plan with important considerations such as:

• Infrastructure life cycles: Infrastructure planning, funding, design, and construction is a lengthy process representing long-term investments of public or private funds.
• Community growth planning: A longer-term view will help align your stormwater plan with other community planning efforts, such as development master plans, that often identify where and how communities will grow and redevelop over a 10- to 20-year period.
• Financial planning horizons: Investing in new infrastructure (in addition to existing program activities and asset maintenance) can involve long-term public-private project agreements or financing arrangements to repay loans or bonds.
• Regulatory compliance: Many NPDES stormwater permits require communities to demonstrate what specific projects and activities they will implement over time and how those actions will result in meeting water quality protection mandates. The implementation timeframes in some permits include compliance schedules that exceed the current 5-year permit term.
• Leadership changes: Elected leaders turn over based on election cycles, which can lead to changes of department heads. A long-term stormwater plan can provide stability and continuity for the program, especially when the plan was developed with significant public involvement and reflects the desires of residents and local businesses—not just municipal leaders and staff.
• Environmental changes: Anticipating longer-term factors that impact stormwater systems—like population increases and changes in precipitation patterns that lead to street flooding—will likely improve the stormwater program’s resilience in the face of these changes.

Comprehensive Planning Leads to Sustainable Funding

A comprehensive plan is critical to building a viable funding strategy. It will help you:

• Describe and assess your program’s purposes, activities, priorities, and assets.
• Explain why your work is critical, how you will effectively do it, and why you need dedicated funding.
• Persuade the public and key opinion leaders about the value that sound stormwater management brings to a community.
• Identify issues and concerns to address and key people to engage when you mount your funding initiative in earnest.

What to include in a comprehensive stormwater program plan

A comprehensive plan combines regulatory compliance activities with:

• A rigorous accounting of current program assets, infrastructure, resources, and services.
• A description of current and future water quality and human health challenges and goals.
• A list of existing assets, plans, and infrastructure to maintain and replace as needed.
• A projection of future program needs and how they will be addressed along with implementation schedules.
• An evaluation of the community’s development policies, codes, and ordinances, with an eye toward identifying opportunities to implement incentive programs for residents and businesses.
• A process to evaluate opportunities to improve stormwater management for existing public properties and facilities, as well as robust plans to optimize stormwater management for new public projects that can serve as examples to the private development community.
• A process for assessing the performance of specific projects that includes costs, cost savings, and environmental benefits.
• A process to evaluate the plan periodically to determine if you should make any adjustments.

How to develop a comprehensive stormwater program plan

1. Assess where you are now:
   • Identify your community’s goals regarding water quality protection, flood risk reduction, improvement of community spaces like parks and streets, and/or water supply augmentation.
   • Describe relevant water quality or human health issues that you need to address, such as restoring polluted waters, protecting beaches, enhancing creeks and wetlands, and protecting valued habitat.
   • Describe the community’s existing stormwater systems and assets, as well as their performance.
2. Analyze opportunities:
   • Determine how you will communicate with and involve stakeholders in your process.
   • Identify, evaluate, and select stormwater management alternatives based on the goals you established in step 1. This enables you to evaluate a range of options for future work to improve how your community manages stormwater and associated assets.
3. Move toward implementation:
   • Establish a process for proposing funding plans and strategies.
   • Consider costs, timeline, and potential funding strategies, and decide what types of funding approaches to pursue.
   • Determine how you will evaluate your plan and project implementation activities; adjust as you go.

Basic Framework for a Comprehensive Plan

• Summary: Include an upfront summary that enables the public and busy decision-makers to quickly gain a good sense of your plan. Consider adding easy-to-understand graphics, infographics, and pictures.
• Updates to existing plan: Your existing plan is the logical starting point for developing a more comprehensive plan. However, it might take significant time to fully account for your expanded goals, strategies, assets, and future needs.
• Program goals and objectives: Explain why sound stormwater management is necessary, then describe how to accomplish it and what specific projects and activities need funding.
• Customer research: Broaden your program goals and purpose beyond water quality to include other stormwater management benefits. Listen to your customers to understand what motivates them. Some communities care a great deal about a revitalized riverfront, flood control, or increasing property values, while others might be more interested in the value of clean beaches or swimming areas to improve tourism.
• Program strategy: Describe the general areas where your program invests time and resources. Show how program implementation benefits your customers now and in the future. Acknowledge the risks customers face for non-implementation.
• Assets, activities, and projects: Inventory your existing assets, activities, and projects so you can discuss your future operation and maintenance needs.

How to define your future needs

A comprehensive plan needs to project future program needs, such as the following:

• You might detect new water quality problems associated with stormwater pollutants.
• Infrastructure might decay and require renovation or replacement.
• Flooding might occur in unexpected places, increasing demands to better manage wet weather flows.
• Your customers’ demands might change—for example, they might want greater investment in green spaces, changes in urban landscapes, or more bike paths and other community amenities.

Projecting future program needs is not a simple task. You need to ensure your plan accounts for future work to:

• Operate, maintain, and—as needed—replace assets you have now.
• Continue operating and, as needed, adjust your “people programs” (outreach, inspections, customer service, etc.).
• Develop and implement new projects and program initiatives to address new requirements and opportunities.

Where to find guidance on future needs

If your community has not engaged in longer-term program planning before, preparing a comprehensive program plan will require more effort. Even if you have done this before, you can find useful information on future program needs from the following resources:

• Master plans: Many cities’ master plans, capital improvement plans, comprehensive plans, and community development plans provide critical information concerning future development and redevelopment that can help you identify new capital improvement needs for stormwater management infrastructure.
• Water resource and watershed management plans: Many cities have conducted comprehensive water resource or watershed management planning processes to support more integrated approaches to resource restoration and protection.
• Local hazard mitigation plans: These plans list all the potential hazards and natural disasters that a community might experience and describe actions that the community will take to reduce or mitigate those threats. Integration of stormwater into local hazard mitigation plans can open the door to FEMA funding sources.
• Green infrastructure plans: Cities are increasingly using green infrastructure planning methods to develop strategies to protect, maintain, increase, and connect green spaces, waterways, and valuable habitat. Because many green infrastructure approaches prove effective in managing stormwater issues, green infrastructure plans can provide a detailed list of future projects to design, fund, and implement over time.
• Combined sewer system long-term control plans: Cities that have both combined sewer and separate stormwater systems often develop detailed long-term control plans that account for system assets and activities, future system needs and alternatives, and specific plans for future infrastructure investments. These plans often provide much of the information a comprehensive stormwater program plan requires.
• NPDES permits and stormwater pollution prevention plans: Your NPDES permit may establish requirements to address challenging pollution control issues that will require investment in improved controls over time. Many permits require permittees to develop stormwater management plans that project future project needs and implementation schedules.
• Successful long-term plans: Several cities have developed comprehensive long-term program plans, often based on asset management planning systems and long-term planning processes.

Recordkeeping Tip

Keep your long-term planning documents separate from your MS4 permit submittal documents. Permit submittal documents should reflect activities you have already completed or expect to soon complete. Aspirational plans should not be in submittals directly related to a permit. If they are, they can become liabilities under permit enforcement provisions, anti-backsliding, or third-party lawsuits.

Case Study: Successful Water Resource and Watershed Management Plans

The city of Minneapolis, Minnesota, developed a Water Resource Management Plan containing detailed evaluations of water resource issues, needs, and local programs that address water resource protection.

Richland County, South Carolina, formed the Gills Creek Watershed Association, which cultivated a sense of ownership among local residents and led to the creation and implementation of management plans.

Flooding is one of the most common natural disasters that communities face, and the impacts can be significant and costly. The link between stormwater and flooding, and their associated planning and management requirements, provide communities with an opportunity to consider multi-benefit solutions such as green infrastructure.

Case Study: Cecil County, Maryland

The Conservation Fund has helped many communities, like Cecil County, Maryland, develop green infrastructure plans.

Case Study: Philadelphia, Pennsylvania

Philadelphia, Pennsylvania’s, long-term control plan provides detailed information concerning its initiatives to expand green infrastructure approaches to wastewater and stormwater management.

Case Study: Successful Long-Term Plans

The city of San Diego, California, prepared a series of long-term water quality improvement and asset management plans that guide its long-term initiative to make large investments in improving how the city manages stormwater and meets regulatory and other water management objectives.

The city of Grand Rapids, Michigan, developed a detailed Stormwater Master Plan that combines a detailed accounting of current program assets and activities with a long-term action plan for a 20-year period.

Resources

Refer to the following additional resources for more guidance on long-term planning .

When a Bandaid’s Not Enough: Implementing Stormwater Utilities in the Great Lakes Basin

Author: American Rivers | Developed/Updated on Date: 2019

This Stormwater Utility Toolkit contains materials to ensure local leaders, city and county staff, and partners have the tools necessary to create a stormwater utility that is supported by the entire community. These tools are designed to give the language and structure needed for jumpstarting a public engagement process. These tools are designed to be edited and personalized to fit communities’ policies, values, and personalities.

This toolkit contains:

• A stormwater utility overview and technical resources
• A strategy for building public support for a stormwater utility
• Sample outreach materials
• Draft press release
• Social media posts
• Website language
• Tips for running successful public meetings
• Sample stormwater utility ordinance language

Water Resource Management Plan

Author: Minneapolis, MN | Developed/Updated on Date: September 5, 2019

The Water Resources Management Plan is a comprehensive report on the programs and practices of the sanitary and stormwater drainage systems that directly impact water resources in Minneapolis.

Stormwater Master Plan

Author: City of Grand Rapids, MI | Developed/Updated on Date: January 20, 2014

The Stormwater Master Plan (SWMP) has many purposes but is primarily intended to establish standards with respect to the use and operation of the City of Grand Rapids’ stormwater system; to mitigate flooding; to reduce pollution and sedimentation of the system, adjacent properties, and the environment; and to improve the water quality of our rivers, lakes, and streams. Specifically, the objectives of the SWMP are to:
1. Protect human life, health, and safety through stormwater management.
2. Effectively utilize public funds for flood and stormwater pollution control projects.
3. Minimize the need for rescue and relief efforts associated with flooding.
4. Reduce the level of pollutants discharged by the Grand Rapids Stormwater System.
5. Provide for the wise use and development of flood-prone areas so as to maximize beneficial use without increasing flood hazard potential and/or degrading water quality.
6. Ensure a functional drainage system that will not result in excessive maintenance costs.
7. Encourage the use of best management practices to improve water quality.
8. Encourage the reduction of existing flooding problems in conjunction with new development.
9. Protect public and private property from the accumulation of mud, dirt, water, debris, and other materials.
10. Comply with federal and state laws regarding stormwater discharges, floodplain management, and erosion and sediment control.

Storm Smart Cities: Integrating Green Infrastructure into Local Hazard Mitigation Plans

Author: U.S. EPA | Developed/Updated on Date: March 2018

This Storm Smart Cities guide examines how communities can integrate green infrastructure into their local hazard mitigation plans. It provides a case study of green infrastructure integration efforts in the City of Huntington, West Virginia, and the West Virginia Region 2 Planning & Development Area.

This guide serves several purposes. It:
• Provides an overview of local hazard mitigation planning.
• Captures an approach used to establish a planning team.
• Identifies lessons learned and important considerations for other communities interested in pursuing this approach.
• Provides a crosswalk between the steps in local hazard mitigation planning, considerations for integrating green infrastructure, and examples from the Huntington, West Virginia, Case Study.

Regional and Municipal Stormwater Management: A Comprehensive Approach

Author: Harvard Law School | Developed/Updated on Date: June 2014

This report analyzes options for addressing stormwater pollution at both the regional and municipal level. The report recommends that municipalities adopt green infrastructure as a stormwater pollution reduction strategy and provides exemplary code provisions that best encourage local green infrastructure development. The report also recommends that municipalities consider addressing stormwater pollution in a more comprehensive manner through participation in a regional program. Of the numerous options for regionalizing stormwater management, we recommend a hybrid approach that collects a fee for basic maintenance/installation costs and sets up a cap and trade system. The hybrid system combines the benefits of a cap and trade program with the funding sources of a fee program, helps to ensure the goal of decreased stormwater pollution in a comprehensive and cost-effective manner, and best deals with the differences in legal codes between municipalities. By accounting for differences in municipalities, a hybrid approach allows for growth by making it easier to add new municipalities and large property owners to the program.

What is a Watershed?

Author: Gills Creek Watershed Association | Developed/Updated on Date: 2020

Gills Creek Watershed Association is dedicated to restoring the watershed through education, grass roots action, public and private partnerships, remediation projects, and well-managed development. The goal is to return the watershed to a living resource providing recreational opportunities, habitat for native wildlife and plants, and a national model for watershed planning and management.

Hazard Mitigation

Author: West Central Texas Council of Governments | Developed/Updated on Date: 2020

The purpose of Hazard Mitigation is to encourage and assist local units of governments to join and cooperate with one another to improve the health, safety, and general welfare of their citizens; to plan for the future development of the area embraced by the communities within the area; to assist member units in solving current problems and completing capital improvements; and to establish regional coordination and communication to help eliminate monetary waste from duplication and misapplication.

Green Infrastructure Plan

Author: The Conservation Fund | Developed/Updated on Date: 2007

The Conservation Fund has completed a Green Infrastructure Plan for Cecil County, Maryland. Based on the approach outlined in Green Infrastructure: Linking Landscapes and Communities (Benedict and McMahon, 2006), the Fund undertook a series of tasks to help Cecil County identify and protect its critical green infrastructure. Using the Fund’s green infrastructure approach to strategic conservation, the plan includes four key products:
• Green Infrastructure Network Design
• Water Quality Maintenance and Enhancement Analysis
• Ecosystem Services Assessment
• Implementation Quilt Analysis

Green City, Clean Waters

Author: Philly Watersheds | Developed/Updated on Date: 2018

Green City, Clean Waters is Philadelphia’s plan to reduce stormwater pollution currently entering the City’s combined sewer system through the use of green infrastructure. Since Green City, Clean Waters was adopted in June 2011, Philadelphia Water and private developers have added over 1,100 green stormwater tools to the landscape.

Evaluation of the Role of Public Outreach and Stakeholder Engagement in Stormwater Funding Decisions in New England: Lessons from Communities

Author: U.S. EPA | Developed/Updated on Date: June 2013

This evaluation report describes lessons about the role and design of public outreach and stakeholder engagement strategies related to community stormwater funding decisions. The evaluation is based on the experiences of eleven small and medium-sized communities, primarily—but not exclusively—in New England. The evaluation has two complementary goals: first, to evaluate whether and how public outreach and stakeholder engagement efforts (including the use of consensus-building protocols) influenced the adoption of stormwater funding mechanisms; and second, to draw on the communities’ experiences to identify lessons for other MS4 communities considering stormwater program funding solutions.

Community Solutions for Stormwater Management: A Guide for Voluntary Long-Term Planning

Author: U.S. EPA Office of Water | Developed/Updated on Date: October 2016

The purpose of this guide is to assist EPA, states, and local governments in developing new or improving existing long-term stormwater plans that inform stormwater management implemented by communities on the ground. The document describes how to develop a comprehensive long-term community stormwater plan that integrates stormwater management with communities’ broader plans for economic development, infrastructure investment, and environmental compliance. Through this approach, communities can prioritize actions related to stormwater management as part of capital improvement plans, integrated plans, master plans, or other planning efforts. Early and effective stormwater planning and management by communities as they develop will provide significant long-term cost savings while supporting resilience, economic growth, and quality of life.

Water Quality Improvement Plans

Author: City of San Diego, CA | Developed/Updated on Date: 2002–2020

The City of San Diego collaborated with other jurisdictions and stakeholders throughout the San Diego Region to develop Water Quality Improvement Plans (WQIPs) for each watershed within its jurisdiction. The goal of the WQIPs is to protect, preserve, enhance, and restore water quality of receiving water bodies. This goal will be accomplished through an adaptive planning and management process that identifies the highest-priority water quality conditions within a watershed and implements strategies to achieve improvements in the quality of discharges from the responsible agencies’ storm drain systems.