MCMs - Minimum Control Measures

The Small Municipal Separate Storm Sewer Systems (MS4) permit requires six Minimum Control Measures (MCMs) be implemented to assist with improving quality and quantity of stormwater. MCMs are carried out by the District’s Partner Agencies. The MCMs are described below:
MCM0:  Stormwater Program Operation/Administration
(MCM0, consists of the District’s operational and administrative activities and is not included in the six MCMs required by the permit)
Purpose: Provide administrative and operational services complying with Ohio Environmental Protection Agency’s (EPA’s) General Permit for Stormwater Discharges from MS4, also known as the MS4 Permit.
Responsible Parties: Hamilton County Storm Water District (District), Hamilton County Engineer’s Office (HCEO)
District and Co-Permittee Permit Compliance Activities:
  • Program and Policy Development: The District developed a new 2021 Stormwater Management Program (SWMP) Plan with the release of the 2021 MS4 permit. The SWMP Plan is a written document required by Ohio EPA that defines the specific actions the District and each of its Co-Permittees must take to meet the MS4 permit requirements during the 2021–2026 permit cycle. District actions are completed through its partner agencies with as-needed consultant support. The District also maintains a variety of policies and protocols that provide additional details regarding implementation of the SWMP Plan. The District recently revised and enacted regulations as required by the MS4 permit under MCMs 3, 4, and 5. District regulations are required to address all requirements of the latest Ohio EPA Construction General Permit and/or the MS4 permit. Municipal Co-Permittees must enact District regulations through ordinance or resolution or create regulations that meet or exceed the requirements of the District’s regulations.
 
  • Activity Tracking, Reporting, and Recordkeeping: The District tracks all permit compliance activities and periodically collects data from its Co-Permittees and partner agencies. Data is evaluated and compiled annually for the entire District between January – March; and submitted to Ohio EPA on April 1 of each year. The District report is available for download on the District website; other records are available upon request.
 
  • Financial Management: The District develops annual budgets for District and partner agency expenditures. The District also develops a billing file to allocate costs to properties within District boundaries—based on their stormwater contribution—which is proportionate to the area of impervious surfaces on the property (e.g., pavement, buildings, and other land cover that does not allow precipitation to soak into the soil). Communities are billed in one of two ways—either directly (for stormwater services) or as special assessments on property tax bills (depending on the annual Level of Service [LOS] election form selection). The annual LOS form offers municipal Co-Permittees the choice to perform their own MCM 3, 4, or 5 program compliance activities, or to have the District conduct those activities for the municipality.
 
  • Coordination: The District provides guidance and training to Co-Permittees to meet MS4 permit requirements. A formal Oversight Board guides regulatory and policy actions of the District. Oversight Board meetings are open to the public and serve as an opportunity for you to provide input pertaining to District programs and topics. The District coordinates with its partner agencies every quarter to assess progress toward MS4 Permit compliance as well as coordinate activities and develop new opportunities to provide cost-effective services to your communities.
MCM 1: Public Education & Outreach 
Purpose: Develop and implement a public education program for distributing educational materials to the community and conducting equivalent outreach activities about the impacts of stormwater discharges, including steps that the public can take to reduce pollutants in stormwater runoff.
Responsible Parties: Hamilton County Conservation District (HCCD); Co-Permittees
District and Co-Permittee Permit Compliance Activities:
  • Media-Based Outreach: The District and HCCD develop content and stormwater messaging for multiple internet-based outreach mechanisms, including social media outlets, streaming services, digital advertising, electronic newsletters, digital educational materials, and websites. Internet-based content can reach all District Co-Permittees. Using mass media outlets, shared resources, and partnerships with other organizations, including your community, the District is able to raise awareness about water quality issues and encourage the public to change its behavior.
  • Education and Outreach: The District, through HCCD, provides educational events and presentations—both in-person and virtual—to various audiences, including residents, developers, and businesses. The education and outreach events focus on themes of general stormwater awareness, water quality, property management (e.g., materials storage, pet waste, leaf collection), stormwater control installation, stream and watershed awareness, and development regulations. HCCD is now providing education and outreach events covering sustainable landscaping and urban agriculture. These events help educate residents about stormwater and water quality issues, and how particular issues can be remediated through proper sustainable landscaping and urban agriculture. HCCD can provide your community with additional information about possible education and outreach events to be hosted in your jurisdiction. Contact HCCD for more information.
  • Kindergarten – College Education: The District’s long-standing stormwater kindergarten – college educational program was developed following state curriculum requirements. HCCD offers in-person and virtual classroom education opportunities to students from all Co-Permittee school districts (public or private schools), as well as homeschooling groups. Educational programming can also be presented at local libraries and in non-school settings for various youth and scout groups. Contact HCCD for kindergarten – college education presentation opportunities.

For more information visit: Hamilton County Conservation District Education

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MCM 2: Public Involvement & Participation 
Purpose: Respond to citizen requests for stormwater information and provide stormwater control recommendations. Involve the public in stormwater-related activities and the implementation of a stormwater management plan.
Responsible Parties: Hamilton County Conservation District (HCCD), Hamilton County Public Health (HCPH), Co-Permittees
District and Co-Permittee Permit Compliance Activities:

  • Public Reporting: The District and its Partner Agencies interface with your community’s residents and respond to hundreds of citizen complaints and inquiries each year. Complaints and inquiries can be reported in two ways:
    1. Calling the District Hotline at (513) 946-7000 or Partner Agency staff
    2. Online via the District or HCCD websites or by direct email to Partner Agency staff.

The District tracks and responds to all complaints and inquiries that include stormwater-related inquiries and complaints, reports of potential illicit discharges, and general requests for assistance.

  • Public Involvement Activities: The District and HCCD provide community residents with opportunities to attend and participate in stormwater and watershed awareness activities. Public involvement activities can include soil fertility testing, rainwater harvesting, rain garden installations, stormwater management, stream cleanup and restoration, water quality monitoring, storm drain labeling, and best management practice (BMP) installation demonstrations. One of the largest events the District supports is Save Local Water’s annual Rain Barrel Art Event, which helps to educate the community about using rain barrels as a form of water conservation and stormwater management. Each year, the District plans and/or facilitates events that are held both regionally and locally within the District’s Co-Permittee.
  • SWMP Plan Development: The District updates its stormwater Management Program (SWMP) Plan at the start of each 5-year MS4 permit term. The District revised the latest 2022 SWMP Plan version during 2021 and submitted the final document on April 1, 2022 to Ohio EPA. The 2022 SWMP Plan will guide the District and its Co-Permittees in meeting MS4 permit requirements for the current permit cycle (2021–2026). The 2022 SWMP Plan is available on the District’s website. 
  • Public Access to District Information: The District maintains a website to provide community residents with access to District regulations, public notices, permit compliance documents, policy guidance, District reports, and other stormwater-related information. Having these documents and information accessible to the public helps to increase the awareness of District residents, businesses, stream corridor property owners, and the development community about stormwater topics.

For more information visit: Hamilton County Conservation District 
MCM 3: Illicit Discharge Detection and Elimination:
​Purpose: To eliminate illicit discharges to the Municipal Separate Storm Sewer System (MS4) through a cost-effective blend of system surveillance methods and enforcement of applicable legal authorities.
Responsible Parties: Hamilton County Public Health (HCPH), Hamilton County Planning and Development (HCPD), and Co-Permittees
District and Co-Permittee Permit Compliance Activities:
  • Storm Sewer System Map: Using survey-grade GPS and a custom web-based GIS Field Editor application, HCPD—with assistance from HCPH—maps the District’s public and private stormwater infrastructure. The field application syncs to the District’s online mapping tool where MS4 assets, the sanitary sewer system, and Home Sewage Treatment Systems (HSTSs) can be incorporated. If your community has chosen to perform your own mapping services, then the District will not have your MS4 infrastructure in the map. Incorporating your mapping data with the District’s map is beneficial for your community as you can specifically see which MS4 structures direct stormwater flows in and out of your community and help trace illicit discharges. If your community has selected to do its own mapping services, it is their responsibility to ensure that all MS4 permit requirements are met. The District also updates MS4 facility drainage maps to detect, trace, and eliminate any discharges from these facilities. The District maps are accessible to representatives from all Co-Permittee communities and are included in the Facility stormwater Plan (FSWP).
  • Home Sewage Treatment System (HSTS) Management: Mapping HSTSs and their connections to the storm sewer system complements routine inspections performed under local health code and is a primary surveillance mechanism of the District’s illicit discharge detection and elimination program. A comprehensive list of all permitted HSTSs was completed and is maintained by HCPH, in partnership with the District. The District produced an online map using ArcGIS/CAGIS that displays HSTS locations, basic information for each system, and the latest inspection results (HCPH HSTS Online Map). HCPH performs routine inspections of HSTSs to ensure they are operating properly and reduce the discharge of untreated wastewater to the MS4. If systems fail their routine inspection, owners are notified and given a date to have issues resolved. If compliance is not achieved HCPH will initiate enforcement actions.
  • Illicit Discharge Detection and Elimination (IDDE): The District maintains a successful field screening program to identify and eliminate illicit discharges to the MS4. The District is currently developing a more efficient process for detecting the location of illicit discharges by using improved data sets and more targeted surveillance. HCPH conducts routine business inspections to ensure water quality issues are addressed. IDDE complaints/ inquiries can be reported via the District Hotline, phone calls and emails to Partner Agency staff, and through the District and Hamilton County Conservation District websites. These reporting mechanisms receive hundreds of IDDE-related inquiries every year; the District and its Co-Permittees investigate all valid issues and work toward elimination of any identified illicit discharges. If your community has selected to perform its own services, it is their responsibility to ensure that your community is meeting all requirements of the District Article II regulation and MS4 permit.

The District Hotline (513-946-7000) is operated by HCPH for anyone needing to report a discharge into a local waterway. .

​For more information visit Hamilton County Public Health. 
MCM 4: Construction Site Runoff Control
​Purpose: Require control of erosion, sedimentation, and other pollution during construction projects to reduce pollutants in any stormwater runoff.
Responsible Parties: Hamilton County Conservation District (HCCD)
District and Co-Permittee Permit Compliance Activities:
  • Plan Approvals: District Rules and Regulations require the developer to submit concept and improvement plans for review prior to obtaining an Earthwork Permit. Reviews and approvals are provided by HCCD for all townships and those Co-Permittees who elect to receive this service from the District. Otherwise, the Co-Permittee is responsible for plan reviews and approvals. Once the Earthwork Permit has been approved, the developer must then submit a Notice of Intent (NOI) to Ohio EPA for approval. No construction is allowed until the Ohio EPA NOI and the District Earthwork Permit are approved. Plan reviews consist of an initial applicability review based on thresholds detailed in the District’s Article III followed by a formal plan review. Ohio EPA requires plan reviewers to use a standardized checklist or objective tool, available from the District to verify compliance with all applicable District and Ohio EPA Construction General Permit requirements.
  • Site Inspections: Active construction projects within District-permitted areas should be inspected at least once per month. During inspections, District or Co-Permittee staff (if Co-Permittee staff perform their own development services) must check to see that sediment controls are in place (as planned) and functioning properly. If controls have been compromised by site activity, weather, and/or improper installation, District staff will work with site managers to remedy the situation. If the situation is still not resolved, enforcement actions will be pursued.
  • Enforcement: The District has developed and continues to implement an enforcement escalation plan that meets Ohio EPA requirements. If you are affiliated with a Co-Permittee that performs its own construction services, a written enforcement escalation plan is required by Ohio EPA; it should be on record and made available as requested. The District emphasizes education over enforcement; however, as part of the District’s enforcement escalation plan, the District will:
    • Increase frequency of inspections on sites with persisting issues
    • Issue Maintenance Required (MREQs) or Need to Install (NINs) orders if the problem can be readily fixed
    • Issue Notices of Violations (NOVs), Stop Work Orders (SWOs), and/or legal actions if problems are severe or persist
 
The District and the HCCD staff respond to construction site complaints received through the District webpage, the District Hotline (513-946-7000), and direct communication.
MCM 5 : Post-Construction  stormwater Management
Purpose: Require developers to install and subsequent property owners to maintain post-construction stormwater control facilities designed to meet Ohio EPA and District performance standards.
Responsible Parties: Hamilton County Department of Planning and Development (HCPD) and select Co-Permittees
District and Co-Permittee Permit Compliance Activities:

  • Site Plan Review: District Rules and Regulations require the developer to submit concept and improvement plans for review and approval. Reviews and approvals are provided by HCPD for all townships and those Co-Permittees who elect to receive this service from the District. Otherwise, the Co-Permittee is responsible for plan reviews and approvals. Once the plans have been approved, the developer must then submit a Notice of Intent (NOI) to Ohio EPA for approval. No construction is allowed until the Ohio EPA approves the NOI and the District/Co-Permittee approves the plans. Plan reviews consist of an initial applicability review based on thresholds detailed in the District’s Article V regulation, followed by a formal plan review using a standardized checklist or objective tool, available from the District, to verify compliance with all applicable District and Ohio
  • Inspect Sites for Proper BMP Installations: The District and Co-Permittees should (1) inspect post-construction controls during construction to ensure they are functioning as designed, (2) perform at least one final inspection to prior to issuing a Certificate of Occupancy (CO). Ohio EPA requires Inspectors to use a objective tool to ensure plans are designed to requirements, and (3) ensure that a CO is issued. Inspectors should use a standardized checklist while completing inspections on post-construction controls. The District uses a ‘punch-list’ (list of issues that must be resolved for a site to remain in compliance) system to ensure controls are properly built.
  • Long-Term Plans and Agreements for Post-Construction Controls: Long-term operation and maintenance (O&M) plans and agreements need to be put in place once construction of a post-construction control is complete and a CO is issued. These agreements ensure the continuation of proper maintenance of all post-construction controls on-site. The District records all long-term O&M plans and agreements with the property’s record plat. District regulations require the transfer of O&M plans with changes in property ownership.
  • Inspect Post-Construction Controls per Long-Term O&M Agreement: All post-construction controls are to be inspected by the District and Co-Permittees at least once per permit term to ensure they are functioning properly. Property owners are required to submit annual inspections and reports (to the District or Co-Permittee for reporting to Ohio EPA, including public agencies who own or operate post-construction controls).
  • Enforcement: The District uses a construction ‘punch-list’ prior to more formal enforcement actions. If punch-list issues are not resolved by the time construction is finished, HP+D is able to withhold the CO from the site. If issues persist during construction or the O&M plan is not being implemented by the property owner, the District follows its enforcement escalation procedures. When problems are observed, property owners are sent a letter requiring them to address the issue(s). If problems remain unaddressed, the District has the authority to escalate enforcement to the County Prosecutor. Co-Permittees who facilitate their own post-construction development program should have an enforcement procedure in place and apply it as necessary.
For more information visit Hamilton County Planning and Development.

 
MCM 6: Pollution Prevention/Good Housekeeping for Municipal Operations
Purpose: Develop and implement an Operation and Maintenance (O&M) program that includes a training component and has the ultimate goal of preventing or reducing pollutant runoff from municipal operations.
Responsible Parties: Hamilton County Public Health (HCPH); Co-Permittees
District and Co-Permittee Permit Compliance Activities:
  • Employee Training: HCPH provides annual training opportunities to MS4 staff covering potential pollutant sources associated with your municipal operations, and a discussion of pollutant sources staff may observe while performing field activities. Facility staff are trained in best management practices for both on-site operations and field activities.
  • Facility Operation and Maintenance Program:
    • Under the Municipal Separate Storm Sewer System (MS4) permit the District and each Co-Permittee is responsible of maintaining a pollution prevention/good housekeeping O&M program that includes a Facility Stormwater Plan (FSWP); a facility specific stormwater Pollution Prevention Plan) for each applicable municipal facility and its applicable operations. Applicable facilities and operations include:
      • Vehicle maintenance facilities
      • Composting facilities
      • Impoundment lots
      • Bus terminals
      • Waste transfer stations
      • Roadway de-icing (salt, brine, and other de-icing liquid usage)
      • Pesticide, herbicide, and fertilizer application
      • Sediment and debris disposal
      • Waste disposal (Per the 2021 MS4 permit waste includes dredge spoil, accumulated sediment, floatables, street sweepings/catch basin cleanings, and other debris)
    • The District established its new FSWP program in 2020 for all MS4 facilities. The District designed the FSWPs to be a single document, tailored to each Co-Permittee facility, that is updated as operations and practices evolve and change. The FSWP consists of digital forms, GIS maps, and assessment checklists that provide recommended management practices for all facility activities and operations. The FSWP serves as a facility’s Stormwater Pollution Prevention Plan (SWPPP) as required by Ohio EPA.
  • Materials Usage and Waste Disposal: MS4 facilities should maintain records and documentation of the amount and proper disposal of wastes generated by municipal operations. Facilities should perform all material usage (e.g., salt application, pesticide and herbicide usage, application calcium chloride, etc.) and waste disposal according to standard practices as defined in the FSWP. For each material usage the facility needs to follow routine procedures; for example, for road salt application the facility staff should apply salt based on location, timing, and application calibration.
  • Flood Management: The District and its Co-Permittees should evaluate any new flood management projects for impacts on water quality. They should also evaluate existing flood management projects, as able, to possibly incorporate additional water quality protection devices and/or practices.
  • Operation and Maintenance Program for Field Operations: Maintenance departments perform routine inspections of the storm infrastructure and look for illicit discharges during regular field activities. Staff perform regular MS4 maintenance, such as addressing issues with pipes and manholes, cleaning catch basins, removing debris from bridges and culverts, etc. The District’s FSWP program covers best management practices that could be implemented during a facilities’ field operations and again serves as a facilities’ SWPPP as required by Ohio EPA.