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Fairfax County, Va., a community holding a Phase I Municipal Separate Storm Sewer System permit, moved in 2011 to execute a unique compliance methodology.

Responding to the comprehensive nature of the permit, the county decided to form a multidisciplinary team across organizational boundaries. Katherine Bennett, the county’s MS4 program coordinator, presented a synopsis of the effort at an American Public Works Association conference in August.

The Environmental Protection Agency plans to expand its regulatory authority over stormwater discharges in 2014; meanwhile, Fairfax County continues to operate under a 2002 permit. It’s not alone: of the 11 Phase I permits in existence in Virginia, only Arlington County, Va.’s has been renewed. Other permit renewals are planned in a sequential manner.

While concerned about the feasibility of some proposed requirements, the county has been proactive in preparing for what it hopes will be an eventual renewal.

“Part of the requirement is that we continually improve our program, and we’ve done that,” Bennett said. Administrators recognized the coming paradigm shift in stormwater management from drainage to water quality protection and identified the need for a more comprehensive approach to permit compliance. Stormwater management has broad and challenging implications not just for county operations, but for businesses and residents as well. Businesses whose activities are exposed to stormwater can be impacted by the industrial and high-risk facilities requirements because runoff from those sites may carry harmful pollutants.

The county also works with residents to implement retrofits to reduce the amount of stormwater pollution discharging from their properties, and with businesses and residents when illicit discharges to the storm sewer system are detected. While these illicit discharges are rare, when they do occur, they are often related to accidental cross-connections with sanitary sewer made during building renovations, Bennett said. Public education is aimed at increasing residents’ awareness and understanding of these and other stormwater issues.

The multidisciplinary approach was especially useful due to the size of the Fairfax County community. In her opinion, as MS4 permits incorporate more and more requirements, improved coordination will be key to achieving compliance.

“In looking at the anticipated new requirements, we realized there was a need for better coordination across county agencies. We brainstormed with stormwater leadership and our consultant, amec, to develop the systems approach,” Bennett said.

“The effort’s success depended heavily on county leadership supporting the systems approach, management staff maintaining focus on implementing it, and operations staff understanding their value in the process and bringing their practical experience to it. The agencies involved include public works (wastewater, solid waste, capital facilities, land development services and stormwater), planning and zoning, transportation, vehicle services, facilities management, code compliance, fire marshal, health department, park authority and public schools,” she added. The planning process for the anticipated requirements got underway in 2011.

The county used the roadways permit element as a pilot study for the systems approach. Most roadways in the county are maintained by the state so this permit requirement focuses largely on parking lots at county facilities. Stakeholders brought in for the collaboration included the park authority, public schools, capital facilities and facilities management, and the team identified the actions needed to transition from the current requirements to the anticipated new ones. Many more entities have participated in subsequent permit elements, resulting in a planning effort that has “really been county-wide. County leadership, at the highest levels, has been very supportive of the approach.”

Currently, four of those elements are left to plan. Those are more of the cross-cutting ones, built on elements that have been addressed by the other teams. They include employee training and public education, and will help raise awareness about other permit requirements and program areas.

Many, including industrial and high-risk facilities, and roadways, have moved into the implementation phase even though at this point the county’s permit has not yet been renewed. Because most of the permit elements build on existing requirements, the county believes its method — which has received very positive response — is on track. Looking to Arlington’s final permit also provided an additional measure of reassurance regarding the requirements for the next Fairfax County permit.

“But you do worry about striking the right balance between improving your existing program and planning for anticipated requirements that could still change. It is a challenge to set meaningful stormwater program goals without being overly prescriptive, but it allows your program to respond to changing conditions and requirements,” Bennett said.

“The effort’s success depended heavily on county leadership supporting the systems approach, management staff maintaining focus on implementing it, and operations staff understanding their value in the process and bringing their practical experience to it. The agencies involved include public works (wastewater, solid waste, capital facilities, land development services and stormwater), planning and zoning, transportation, vehicle services, facilities management, code compliance, fire marshal, health department, park authority and public schools,” she added. The planning process for the anticipated requirements got underway in 2011.

The county used the roadways permit element as a pilot study for the systems approach. Most roadways in the county are maintained by the state so this permit requirement focuses largely on parking lots at county facilities. Stakeholders brought in for the collaboration included the park authority, public schools, capital facilities and facilities management, and the team identified the actions needed to transition from the current requirements to the anticipated new ones. Many more entities have participated in subsequent permit elements, resulting in a planning effort that has “really been county-wide. County leadership, at the highest levels, has been very supportive of the approach.”

Currently, four of those elements are left to plan. Those are more of the cross-cutting ones, built on elements that have been addressed by the other teams. They include employee training and public education, and will help raise awareness about other permit requirements and program areas.

Many, including industrial and high-risk facilities, and roadways, have moved into the implementation phase even though at this point the county’s permit has not yet been renewed. Because most of the permit elements build on existing requirements, the county believes its method — which has received very positive response — is on track. Looking to Arlington’s final permit also provided an additional measure of reassurance regarding the requirements for the next Fairfax County permit.

“But you do worry about striking the right balance between improving your existing program and planning for anticipated requirements that could still change. It is a challenge to set meaningful stormwater program goals without being overly prescriptive, but it allows your program to respond to changing conditions and requirements,” Bennett said.