The SWQMP-Part C must address six (6) minimum control measures (MCM). Each minimum control measure must include a detailed program description, a timetable for implementation, milestones, and a summary of measurable goals. The measurable goals shall demonstrate results that relate to an environmental benefit.

The six minimum control measures provide the minimum conditions for the storm water program, but the rule also provides flexibility to account for variability of local conditions. The program created to address each control measure should be relatively unique to the MS4 entity or MS4 area. The detailed program description should be based on the unique local conditions and reflective of local implementation timetables.

Additional information and details related to each of the six minimum control measures can be found in 327 IAC 15-13-12 through 17 (scroll to pages 81-86) and the Rule 13 Guidance Document [PDF].

Public Education and Outreach

The purpose of the Public Education and Outreach Minimum Control Measure is to inform residents, visitors, public service employees, commercial and industrial facility operators, and construction site personnel that are located or operate within the MS4 area about the impacts stormwater runoff can have on water quality and ways they can minimize their impact on stormwater quality.

A community that is informed and knowledgeable is critical to the success of the local storm water program. An understanding of stormwater issues will help gain public support for the program. Other benefits include, but are not limited to greater compliance with the program and support for local funding initiatives

MS4s are encouraged to utilize existing programs and resources to further the efficiency of delivery of this minimum control measure. It is not necessary to develop all program elements from a grass roots approach, The MS4s are encouraged to partner with other entities within and adjacent to the MS4 area and utilize materials developed by local, state, and federal agencies.

According to the Rule, a certification form, Public Education (State Form 51279) [PDF], for the public education and outreach minimum control measure must be signed and submitted to the Indiana Department of Environmental Management in accordance with the Compliance Schedule. This certification submittal is necessary to establish the initial implementation of the control measure and only needs to be submitted during the first 5-year permit term.


Public Participation and Involvement

Provisions should be developed and utilized that allow opportunities for constituents within the MS4 area to participate and provide input in the development and implementation of the stormwater management program. A community that is active and involved will be critical to the success of the program. Citizens and business leaders that participate are more than likely to take an active role in program implementation, provide local broad base expertise, and serve as a conduit to local programs, citizen groups, etc.

To demonstrate sufficient opportunity, stormwater program development and implementation meetings should be open to the public, with proper notification provided. Public comments, input, and involvement should be solicited by some means, such as complaint hotlines or outreach. Efforts to involve all interested constituents should be documented and may be part of the public education outreach minimum control measure. An MS4 entity shall comply with applicable public notice requirements.

According to the Rule, a certification form, a certification form, Public Participation (State Form 51273) [PDF], for the public participation and involvement, minimum control measure must be signed and submitted to the Indiana Department of Environmental Management in accordance with the Compliance Schedule. This certification submittal is necessary to establish the initial implementation of the control measure and only needs to be submitted during the first 5-year permit term.


Illicit Discharge Detection & Elimination

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An MS4 operator is required to develop and implement a strategy to detect and eliminate illicit discharges into the MS4 conveyance system.

An illicit discharge is defined as any discharge to an MS4 conveyance that is not composed entirely of stormwater, except naturally occurring floatables, such as leaves or tree limbs. Sources of illicit discharges include sanitary wastewater, septic tank effluent, car wash wastewater, oil disposal, radiator flushing disposal, laundry wastewater, roadway accident spillage, and household hazardous wastes.

Illicit discharges can significantly contribute to high pollutant loadings into MS4 conveyances systems. These discharges include heavy metals, toxics, oil and grease, solvents, nutrients, and bacteria.

This minimum control measure requires the MS4 to develop a strategy that will be enforceable through the development or revision of an ordinance or some other regulatory mechanism that addresses illicit discharges. MS4 entities that do not have the ability to create or enforce ordinances will need to either create an enforceable policy document or enter into a legal agreement with another entity to implement this control measure.

The strategy should include detection procedures, illicit discharge notification procedures, enforcement procedures, implementation and procedural schedules, and resources that will be used to implement the illicit discharge control measure program.

According to the Rule, a certification form, a certification form, Illicit Discharge (State Form 51271) [PDF], for the illicit discharge, minimum control measure must be signed and submitted to the Indiana Department of Environmental Management in accordance with the Compliance Schedule. This certification submittal is necessary to establish the initial implementation of the control measure and only needs to be submitted during the first 5-year permit term.


Construction Site Storm Water Runoff Control

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An MS4 operator is required to develop, implement, manage, and enforce an erosion and sediment control minimum control measure for construction activities. The program and ordinance must at a minimum meet the requirements of 327 IAC 15-5, Rule 5 (scroll to page 10). 327 IAC 15-5 is the State of Indiana construction/land disturbance regulation. The primary purpose of Rule 5 is to reduce pollutants, principally sediment that is associated with construction activities. Rule 5 requires all sites where land disturbance is one (1) or more obtain a general permit from the state.

The program developed by the MS4 must include procedures for construction plan review, site inspection, and, when necessary, enforcement. An MS4 entity must create or revise a policy, ordinance, or other regulatory mechanisms to provide the necessary legal authorities to control, and, when necessary, penalize the source of noncompliance to the MS4 entity specifications created for construction runoff. MS4 entities that do not have the ability to create or enforce ordinances will need to either create an enforceable policy document or enter into a legal agreement with another entity to implement this control measure.

Except for state permitting process references and submittal deadlines of construction plans and permit applications, the ordinance or other regulatory mechanisms may be stricter than the requirements of Rule 5. The permitting process must include a requirement for the construction project site owner to submit a copy of the application directly to the Indiana Department of Environmental Management. Additional information on the relationship between Rule 5 and an MS4 construction program is described in more depth in Construction/Land Disturbance Storm Water Permitting (327 IAC 15-5, Rule 5).

The program must include requirements for the use of erosion and sediment control measures, as well as measures to properly manage and control other pollutants that may be associated with construction activities. The Indiana Storm Water Quality Manual provides principles of managing a construction site and standards and specifications on various storm water quality measures

MS4 area personnel that are involved in the implementation of the construction site runoff control MCM must receive relevant stormwater training. This training can be conducted “in-house” by MS4 staff or some other trainer and must occur, at a minimum, annually.


Post-Construction Storm Water Runoff Control

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An MS4 operator is required to develop, implement, manage, and enforce an erosion and sediment control minimum control measure for construction activities. The program and ordinance must at a minimum meet the requirements of 327 IAC 15-5, Rule 5 (scroll to page 10). 327 IAC 15-5 is the State of Indiana construction/land disturbance regulation. The primary purpose of Rule 5 is to reduce pollutants, principally sediment that is associated with construction activities. Rule 5 requires all sites where land disturbance is one (1) or more obtain a general permit from the state.

The program developed by the MS4 must include procedures for construction plan review, site inspection, and, when necessary, enforcement. An MS4 entity must create or revise a policy, ordinance, or other regulatory mechanisms to provide the necessary legal authorities to control, and, when necessary, penalize the source of noncompliance to the MS4 entity specifications created for construction runoff. MS4 entities that do not have the ability to create or enforce ordinances will need to either create an enforceable policy document or enter into a legal agreement with another entity to implement this control measure.

Except for state permitting process references and submittal deadlines of construction plans and permit applications, the ordinance or other regulatory mechanisms may be stricter than the requirements of Rule 5. The permitting process must include a requirement for the construction project site owner to submit a copy of the application directly to the Indiana Department of Environmental Management. Additional information on the relationship between Rule 5 and an MS4 construction program is described in more depth in Construction/Land Disturbance Storm Water Permitting (327 IAC 15-5, Rule 5).

The program must include requirements for the use of erosion and sediment control measures, as well as measures to properly manage and control other pollutants that may be associated with construction activities. The Indiana Storm Water Quality Manual provides principles of managing a construction site and standards and specifications on various storm water quality measures

MS4 area personnel that are involved in the implementation of the construction site runoff control MCM must receive relevant stormwater training. This training can be conducted “in-house” by MS4 staff or some other trainer and must occur, at a minimum, annually.

According to the Rule, a certification form, Construction (State Form 51272) [PDF], for the construction site runoff control minimum must be signed and submitted to the Indiana Department of Environmental Management in accordance with the Compliance Schedule. This certification submittal is necessary to establish the initial implementation of the control measure and only needs to be submitted during the first 5-year permit term.


Municipal Operations Pollution Prevention and Good Housekeeping

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The final minimum control measure addresses the stormwater discharges that are associated with operations internal to the MS4. This measure requires the MS4 to evaluate and alter operations internally to ensure a reduction in the pollutants that are generated from municipal operations.

Below are several items that are required to be addressed for this minimum control measure:

    • Maintenance of the MS4 conveyances is essential to reducing the potential for pollutants and are addressed through periodic litter pick-up, cleaning, and maintenance of stormwater systems, pavement sweeping, roadside shoulder, and conveyance system maintenance, and remediation measures for scoured outfalls.
    • Reduce or eliminate the discharge of pollutants from roads, parking lots, maintenance and storage yards, and waste transfer stations.
    • Develop procedures for the proper disposal of materials removed from storm sewer systems, conveyances channels, and operational areas.
    • Consider modification of flood management projects to address stormwater quality in addition to quantity. This approach may also be suitable for retrofitting existing flood management structures.
    • MS4 area personnel that are involved in the internal operational activities must receive relevant stormwater training. This training can be conducted “in-house” by MS4 entity staff or some other trainer and must occur, at a minimum, annually.

A certification form, Pollution Prevention and Good Housekeeping (State Form 51281) [PDF], for the pollution prevention and good housekeeping minimum control measure program, must be signed and submitted to the Indiana Department of Environmental Management in accordance with the Compliance Schedule. This certification submittal is necessary to establish the initial implementation of the control measure and only needs to be submitted during the first 5-year permit term.