Storm Water Management Programs
The Six Minimum Control Measures (MCMs)
The MS4 Permit consists of six Minimum Control Measures (MCMs), also referred to as stormwater management programs: Public Education and Outreach, Public Involvement and Participation, Illicit Discharge Detection and Elimination (IDDE), Construction Site Pollutant Control, Post-Construction Storm Water Management and Pollution Prevention. Consistent with the U.S. EPA's Remand Rule and s. NR 216.07, Wis. Adm. Code, MS4 permits require all MS4 permittees to develop written program procedures for each of its six MCMs describing how it complies with the permit’s requirements. To access additional information, resources, and examples for each MCM, please click the desired MCM below.
Additionally, while each MCM contains specific actions (e.g., permit conditions) that every MS4 permittee must implement to reduce pollutants to the Maximum Extent Practicable (MEP), MS4 permittees must also establish and work towards their own program's measurable goals.
Measurable Goals
MS4 permit conditions are developed to meet the MS4 permit standard: reduce pollutants to the maximum extent practicable (MEP), protect local water quality, and meet CWA Standards. MS4 Permittees satisfy the MS4 permit standard by complying with the WPDES permit and successfully implementing the stormwater management programs.
Storm water quality is impacted by various urban activities. While many of these urban activities occur in every community, the extent of these activities and the practices needed to best mitigate impacts from these activities vary. For example, cars (and other vehicles) can introduce stormwater pollutants such as heavy metals and petroleum products. To mitigate these impacts, many communities implement street sweeping. However, as some communities experience greater volumes, one community may require more street sweeping than others.
Additionally, although practices used to mitigate stormwater pollutants may be the same throughout communities, how practices are implemented varies, which can affect how effective a practice is. For example, Community A and Community B experience similar volumes of traffic and, therefore, similar levels of pollutants. Although both communities implement the same street sweeping practices (i.e., the same equipment, frequency and timing), Community A allows cars to be parked on the street while Community B does not. As such, Community A may not be able to sweep the curb line, making its street-sweeping efforts less effective than Community B. Consequently, to reduce pollutants to the Maximum Extent Practicable (MEP), Community A may have to implement additional practices.
Variation among communities highlights the importance of program measurable goals. Though every community may experience similar urban activities and implement similar practices to reduce MEP, every community must evaluate its own programs and look for ways to improve them. After identifying potential improvements, the permittee should establish a measurable goal to work toward. Making the goal measurable is important to evaluate if the actions taken to reach the goal were successful.
Written Program Procedures
Each permittee shall have a written stormwater management program (SWMP) that describes in detail how the permittee intends to comply with the permit requirements for each of the six MCMs. Clear procedures should assist in consistent implementation, strengthen the permittee's ability to enforce its programs and identify program improvements. The written procedure could be a flow chart, spreadsheet, text-only document or a combination of various formats – whichever works best for the permittee.
The MS4 BMP menu provides examples of written program procedures for each of the six MCMs. Please note that sharing these examples is intended to give formatting ideas, structure, etc. The examples provided may not satisfy your community's MS4 Permit requirements as they may have different permit conditions. Additionally, MS4 Permittees demonstrate compliance differently, so procedures that work for one community may not work for another.
The Six Minimum Control Measures (MCMs)
MCM #1: Public Education and Outreach (s. NR 216.07 (1) Wis. Adm. Code)
(s. NR 216.07 (1) Wis. Adm. Code)
Each permittee shall implement a written public education and outreach program to increase awareness of how the combined actions of human behavior influence stormwater pollution and its effects on the environment. The public education and outreach program may incorporate cooperative efforts with other entities (i.e., education consortiums) not regulated by this permit provided a mechanism is developed and implemented to track the results of these cooperative efforts. Each permittee must ensure it demonstrates compliance with all permit conditions including a program measurable goal.
Helpful Information And Resources:
Written Program Procedure Examples
As MS4 permittees demonstrate compliance differently and MS4 permittees may have different MS4 permit conditions, the following written program procedures are intended to provide ideas on various formats. Therefore, please note the provided examples may not be appropriate, as is, for your community. Additionally, the following examples are written program procedures that have been submitted to the DNR by MS4 permittees. However, the MS4 permittee names have been removed to keep them anonymous.
Classroom Educational Resources
- Chloride Pollution Lesson High School Level – Introduction to chloride pollution, allows students to work with environmental data sets.
- Stormwater Education For Kids – Stormwater activity sheets developed by the University of Nebraska-Lincoln.
- Classroom Education On Stormwater – U.S. EPA on ways to promote the message on stormwater education.
MCM #2: Public Involvement And Participation (s. NR 216.07 (2) Wis. Adm. Code)
(s. NR 216.07 (2) Wis. Adm. Code)
Each permittee shall implement a written public involvement and participation program that provides opportunities for the public to effectively participate in the development, implementation, and modification of the permittee’s stormwater management program. Delivery mechanisms may include public workshops, presentations of stormwater information, government events (public hearings, council meetings, etc.), citizen committee meetings or the use of websites. Each permittee must ensure it demonstrates compliance with all permit conditions including a program measurable goal.
Helpful Information And Resources:
Written Program Procedure Examples
As MS4 permittees demonstrate compliance differently and MS4 permittees may have different MS4 permit conditions, the following written program procedures are intended to provide ideas on various formats. Therefore, please note the provided examples may not be appropriate, as is, for your community. Additionally, the following examples are written program procedures that have been submitted to the DNR by MS4 permittees. However, the MS4 permittee names have been removed to keep them anonymous.
MCM #3: Illicit Discharge Detection and Elimination (IDDE) (s. NR.216.07 (3) Wis. Adm. Code)
(s. NR 216.07 (3) Wis. Adm. Code)
Each permittee shall implement a written program to detect, remove, and eliminate illicit connections and discharges to the municipal separate storm sewer system. Permittees must have a regulatory mechanism that prohibits and eliminates illicit connections and discharges, dry weather outfall screening procedures at the frequency stated within its MS4 Permit, investigation and response procedures, and enforcement response procedures to eliminate the source once the responsible party is identified. Each Permittee must ensure it demonstrates compliance with all permit conditions including a program measurable goal.
Regulatory Mechanism
Each permittee must have an ordinance or other regulatory mechanism that, at a minimum prohibits illicit discharge, spilling or dumping of non-stormwater substances or material into the permittee's MS4 or waters of the state and identifies non-stormwater discharges that are not considered illicit or flows that are not considered illicit discharges. The regulatory mechanism must also provide the MS4 permittee inspection and maintenance authority.
Reporting A Spill Or Release Of Hazardous Substance
The MS4 Permit requires that the permittee immediately notify the DNR in accordance with ch. NR 706, Wis. Adm. Code, if the permittee identifies a spill or release of a hazardous substance into or from its MS4, which results in the discharge of pollutants into waters of the state. The DNR shall be notified via the 24-hour toll-free spill hotline at 800-943-0003. Permittees shall cooperate with the DNR in efforts to investigate and prevent such discharges from polluting waters of the state.
Helpful Information And Resources:
Written Program Procedure Examples
As MS4 permittees demonstrate compliance differently and MS4 permittees may have different MS4 permit conditions, the following written program procedures are intended to provide ideas on various formats. Therefore, please note the provided examples may not be appropriate, as is, for your community. Additionally, the following examples are written program procedures that have been submitted to the DNR by MS4 permittees. However, the MS4 permittee names have been removed to keep them anonymous.
- Example 1 Illicit Discharge Detection And Elimination
- Example 2 Illicit Discharge Detection And Elimination
- Example 3 Illicit Discharge Detection And Elimination
Dry Weather Outfall Field Screening Resources
- What Are Bio Sheens? – Describes the difference between bio sheens and oil films.
- DNR Illicit Discharge Detection And Elimination Guidance – Provides guidance for outfall screenings and action level parameters sampled during outfall screenings.
MCM #4: Construction Site Pollutant Control (s. NR 216.04(4) Wis. Adm. Code)
(s. NR 216.04(4) Wis. Adm. Code)
Each permittee shall implement and enforce a written program that reduces the discharge of sediment and construction materials from construction sites. Each permittee must ensure compliance with all permit conditions, including a program measurable goal.
Regulatory Mechanism
Each permittee must maintain and enforce its municipal ordinance from all construction sites with one acre or more of land disturbance, and sites of less than one acre if they are part of larger common plan of development or sale.
- DNR Model Ordinance – The model ordinances within this guidance, and also located in chapter 152, Appendix A and B, contains the performance standards in ss. NR 151.11 (6m) and 151.122 through 151.126, Wis. Adm. Code, as applicable for construction site erosion and sediment control and post-construction stormwater management.
Helpful Information And Resources:
See Additional MS4 Resources for common questions on the Construction Site Pollutant Control Program.
Written Program Procedure Examples
As MS4 permittees demonstrate compliance differently and MS4 permittees may have different MS4 permit conditions, the following written program procedures are intended to provide ideas on various formats. Therefore, please note the provided examples may not be appropriate, as is, for your community. Additionally, the following examples are written program procedures that have been submitted to the DNR by MS4 permittees. However, the MS4 permittee names have been removed to keep them anonymous.
Storm Water Construction Permit
Private or municipal (i.e., public) developments must apply for DNR NOI for construction sites greater than an acre of land disturbance or sites part of a larger common plan of development.
- Construction site stormwater permit forms – Permit information and application steps.
Other DNR Permits that may be needed
- Wetland Permitting – Landowners and developers are required to avoid wetlands with their projects whenever possible. For projects that cannot avoid wetlands and involve the placement of material or excavation in wetlands, authorizations through exemptions or permits may be required.
- Wastewater General Permits – Construction site activities such as dewatering.
DNR Stormwater Construction Technical Standards
Stormwater construction technical standards are documents that specify the minimum requirements needed to plan, design, install and maintain a wide array of conservation practices aimed at preserving the land and water resources of Wisconsin during construction. They are based on current research, field experience, the best available technology.
- Stormwater construction technical standards – Provides DNR-approved technical standards to implement the performance standards of sub-ch. III or IV of ch. NR 151 for erosion/sediment control or stormwater management during construction.
Erosion Control Inspection Resources
- Wisconsin Construction Site Erosion Control Field Guide – Helpful information on temporary and permanent erosion control best management practices (BMPs). This guide is intended to aid contractors in selecting and correctly installing BMPs to reduce erosion.
- Template Construction Site Inspection Report – Municipalities are not limited to using the DNR erosion control inspection report. They may utilize what works best for documenting municipally conducted erosion control inspections.
- Template Construction Site Inspection Photolog –Municipalities are not limited to using the DNR erosion control photo log. Municipalities may utilize what works best for documenting municipally conducted erosion control inspections.
Training Opportunities
- NASECA Erosion Control Training – NASECA-WI Erosion Control Compliance Training provides Wisconsin-based rules and regulations education for Engineers, Site Managers, Site Superintendents, Contractor Superintendents and Foremen, BMP Installers and Inspectors.
Erosion Control Plan Resources:
- Erosion Control And Stormwater Management Plans – When to develop plans, what a plan should include, etc.
MCM #5: Post-Construction Storm Water Management (s. NR 216.07(5) Wis. Adm. Code)
(s. NR 216.07(5) Wis. Adm. Code)
Each Permittee shall implement and enforce a written program to control the quantity and quality of discharges from areas of new development and redevelopment, after construction is completed. Each Permittee must ensure it demonstrates compliance with all permit conditions including a program measurable goal.
Regulatory Mechanism
Each permittee must maintain and enforce the municipal ordinance to regulate post-construction stormwater discharges from new development and redevelopment.
DNR model ordinance – The model ordinances within this guidance, and also located in Chapter 152, Appendix A and B, contain the performance standards in ss. NR 151.11 (6m) and 151.122 through 151.126, Wis. Adm. Code, as applicable for construction site erosion and sediment control and post-construction storm water management.
Legal Maintenance Authority On Municipally Operated (Privately Owned) Stormwater BMPs
Maintenance authority may be obtained through written agreements (I.e., long-term maintenance agreement, easement agreement, etc.) or other legal mechanisms. Permittees must have legal maintenance authority on required private stormwater BMPs to ensure they are inspected and maintained as stated in the agreement. Many agreements require the private BMP owner to conduct inspections and maintenance, however, the permittee is responsible for ensuring the inspection and maintenance are occurring.
If the private BMP owner is not inspecting and maintaining them as required by the agreement, Permittees may choose to compel compliance by utilizing enforcement mechanisms through their post-construction stormwater management ordinance or other legal authority.
Stormwater BMP Inventory
Each permittee must update and maintain an inventory of municipally owned or operated stormwater BMPs (e.g., wet detention ponds, bioretention devices, infiltration basins and trenches, permeable pavement, proprietary sedimentation devices, vegetated swales, or any similar practices or devices used to meet a water quality requirement under this permit). The BMP inventory must include all of the information provided in the MS4 permit.
Helpful Information And Resources:
See Additional MS4 Resources for common questions on the Post-Construction Storm Water Management Program.
Written Program Procedure Examples
As MS4 permittees demonstrate compliance differently and MS4 permittees may have different MS4 permit conditions, the following written program procedures are intended to provide ideas on various formats. Therefore, please note the provided examples may not be appropriate, as is, for your community. Additionally, the following examples are written program procedures that have been submitted to the DNR by MS4 permittees. However, the MS4 permittee names have been removed to keep them anonymous.
Examples Of BMP Inventories
DNR Stormwater Post-Construction Technical Standards
Stormwater construction technical standards are documents that specify the minimum requirements needed to plan, design, install and maintain a wide array of conservation practices aimed at preserving the land and water resources of Wisconsin during construction. They are based on current research, field experience, the best available technology, and are a primary component to many federal, state and local conservation programs.
- Stormwater Post-Construction Technical Standards – Provides DNR-approved technical standards to implement the performance standards of sub ch. III or IV of ch. NR 151 for erosion/sediment control or stormwater management during construction.
Stormwater Management Plans – Operation And Maintenance Of Stormwater BMPs
To ensure stormwater BMPs are maintained and functioning as designed, operation and maintenance plans should be developed for each BMP. These plans identify an inspection schedule and criteria, documentation, and maintenance needs. For privately owned BMPs, operation and maintenance plans may be located in the written maintenance agreement.
- Stormwater Management Plans – What a stormwater management plan is, what a plan should contain, etc.
- Managing Accumulated Sediment From Stormwater Ponds – Information on Wis. Adm Code NR 528. The rule covers wet and dry detention ponds and infiltration basins, but not landscape ponds on private property.
- Milwaukee Metropolitan Green Infrastructure Operations And Maintenance Implementation Framework – MMSD developed six implementation framework alternatives considering the most efficient, cost‐effective approach, but also an acceptable strategy for maintaining GI across Southeast Wisconsin.
- Root-Pike Watershed Initiative Network (WIN) Pond Playbook – The Playbook stops pond owners from running in circles with habitual mowing, dredging and algae treatments. Physical copies are available upon request by contacting Root Pike WIN.
MCM #6: Pollution Prevention (s. NR 216.07(6) Wis. Adm. Code)
(s. NR 216.07(6) Wis. Adm. Code)
Each Permittee shall implement a pollution prevention program to prevent or reduce pollutant runoff from the MS4 to the waters of the state. Each Permittee must ensure it demonstrates compliance with all permit conditions including a program measurable goal. The Pollution Prevention Program consists of sub-programs (Storm Water Pollution Prevention Plans (SWPPPs) for municipal properties, street sweeping and catch basin cleaning, management of leaves and grass clippings, winter road management, nutrient management, and a training component.
Below each sub-program, example written program procedures are provided. However, as MS4 Permittees demonstrate compliance differently and MS4 Permittees may have different MS4 permit conditions, the following written program procedures are intended to provide ideas on various formats. Therefore, please note the provided examples may not be appropriate, as is, for your community. Additionally, the following examples are written program procedures that have been submitted to the DNR by MS4 permittees. However, the MS4 permittee names have been removed to keep them anonymous.
Municipal Properties
Municipal properties that have the potential to generate stormwater pollution shall have a Storm Water Pollution Prevention Plan (SWPPP) for each property under the Permittee's control. In general, a SWPPP identifies potential sources of stormwater pollution, best management practices associated with the property (structural or non-structural), and other good housekeeping activities and requires SWPPP inspections, spill prevention and response procedures, and training.
Helpful Information And Resources:
- See Additional MS4 Resources for common questions on the Pollutant Prevention Program.
Examples Of Municipal SWPPPs (Storm Water Pollution Prevention Plans)
Collection Services
Many municipalities conduct collection services such as leaf collection, street sweeping, and catch basin cleanings. These non-structural BMPs help reduce pollutants in stormwater runoff. Factors such as frequency, times of the year, placement of materials, and parking restrictions are important to consider to optimize pollutant removal.
Permittees must have written program procedures describing implementation for each collection service conducted. If a collection service is not conducted within a community, it is recommended that the Permittees submit a document explaining why the service is not conducted to more easily demonstrate permit compliance.
Helpful Information And Resources:
For more information, see specific information and resources for each type of collection service below.
- See Additional MS4 Resources for common questions on the Construction Site Pollutant Control Program
Examples Collection Services Written Program Procedures
1. Leaf And Other Yard Waste Collection
Leaf collection is a common collection service offered by municipalities. However, leaf collection services can be conducted in a variety of ways. For example, residents may be instructed to place loose leaves on the terrace or street, others may be instructed to bag their leaves for pickup. The written program procedure should describe how the leaf collection is implemented in its community.
Another typical municipal service offered is the collection of yard waste, such as grass clippings and brush. Where some municipalities collect these materials, others may offer drop-off locations for residents. Permittees often bring these yard waste materials to a municipal property for composting activities or temporary staging. Therefore, yard waste materials should be included in the municipal property's SWPPP and appropriate BMPs to manage this yard waste material should be implemented.
Please note that if municipalities are conducting composting activities, it is important to determine if a composting permit is needed.
Helpful Information And Resources:
- Municipal Phosphorus Reduction Credit For Leaf Management Programs – The purpose of this guidance is to clarify the specific conditions and methods for which numeric credit may be taken by Wisconsin MS4s in demonstrating progress toward TMDL waste load allocations (WLAs).
- Composting Rules And Regulations In Wisconsin – Section NR 502.12 of the Wisconsin Administrative Code requires facilities that compost yard waste or food scraps have a DNR-issued license if they have more than 50 cubic yards of materials on-site at any time, with some exceptions for on-farm composting.
2. Street Sweeping
Implementing street sweeping practices on a set frequency helps reduce debris and other pollutants in stormwater runoff. Street sweeping material collected is considered a regulated waste and, therefore, should be handled and disposed of appropriately. BMPs shall be employed to prevent contamination throughout temporarily staging materials and final disposal. The Permittee's written program procedure should describe how street sweeping is implemented in its community.
Helpful Information And Resources:
- Exemption Of Low Hazard Waste from Solid Waste Regulations – Information and application process for low hazard waste exemption for the reuse of collected street sweeping materials.
3. Catch Basin Cleaning
Storm water inlets with sumps require regular cleaning and therefore, a maintenance schedule is recommended. Similar to street sweeping material, catch basin material is considered a regulated waste, therefore material should be handled and disposed of appropriately. BMPs shall be employed to prevent contamination throughout temporarily staging materials and final disposal. The permittee's written program procedure should describe how catch basin cleaning is implemented in its community.
Winter Road Management
Each municipality should have a written procedure describing its winter road management activities. This helps ensure the winter road management strategies are consistently implemented and can help identify additional salt reduction strategies. Permittees should look at their MS4 permit for winter road management permit requirements.
Helpful Information And Resources:
Examples Winter Road Management Written Program Procedures
Other Resources:
- Salt And Storm Water – Informational page with winter salt certification training opportunities, and other educational resources on chloride pollution.
- SEWRPC Long-Term Chloride Study – Ongoing efforts on SEWRPC's chloride impact study for the Southeastern Wisconsin Region.
- WisDOT Winter Maintenance – Provides explanations and links which provide information on into Wisconsin's snowplowing guidelines and safe highways – less salt report.
- Road Salt Storage: WisDOT Trans 277 – Learn more about the applicability of Trans 277. The purpose of Trans 277 is to prevent contamination of Wisconsin’s surface and groundwater with chlorides from road salt storage facilities and practices.
- Smart Salting Resources
- Wisconsin Salt Wise – Information on smart salt trainings, educational resources and more.
- Smart Salting Assessment Tool, MPCA – The SSAT is a free, web-based tool that can be used to assist public and private winter maintenance organizations in determining where opportunities exist to improve practices, make reductions in salt use and track progress.
- Minnesota Statewide Chloride Resources – Provides information on chloride pollution, examples of model chloride ordinances, policies and contracts.
Turf Management
The application of turf and garden fertilizers on five acres or more of municipally controlled properties shall be made in accordance with a site-specific nutrient application schedule based on appropriate soil tests. The nutrient application schedule shall be designed to maintain the optimal health of the turf or garden vegetation. A common example of a municipally owned property over 5 acres or more receiving nutrient applications may be athletic fields. The Permittee's written program procedure should describe how turf management is implemented in its community.
Helpful Information And Resources:
- Turf Nutrient Management – DNR Technical Standard contains criteria to minimize nutrient entry into surface and groundwater resources through proper application of nutrient inputs while maintaining a turf density of 70% or greater.
Municipal Separate Storm Sewer System (MS4) Map (s. NR 216.07(7) Wis. Adm. Code)
(s. NR 216.07(7) Wis. Adm. Code)
Each Permittee must have an accurate MS4 map and ensure it demonstrates compliance with all permit conditions.