Preventing Stormwater Pollution at Your Public Works Facility
An Overview of the RI Storm Water Phase II Program
For Rhode Island Municipal Officials
The Storm Water Pollution Problem
Stormdrains and roadside drainage ways lead directly to local waters without treatment. When rain
falls onto pavement and other impermeable surfaces, it picks up pollutants, such as oil, road sand
and sediment from construction sites, fertilizers, animal waste and trash. Illicit connections of sanitary
sewers, many of them unidentified, can also contribute raw sewage high in disease-causing bacteria.
The storm sewer system merely collects this contaminated water and discharges it directly to the
nearest stream, lake or bay.
According to the U.S. Environmental Protection Agency, stormwater pollution is now the major water
quality problem in the United States. In Rhode Island, it is the major source of contamination to the
water we drink, fish and swim in. With our urban population and sensitive coastal waters, our waters
are among the most threatened and often most severely degraded by stormwater pollution.
Since passage of the Clean Water Act in 1972, Rhode Island cities and towns have invested millions
of dollars to upgrade wastewater treatment facilities, oversee pre-treatment of industrial wastes, and
eliminate sewage discharges from boats. These efforts have led to significant water quality
improvements. Massive retrofits of combined sewers now underway deep beneath the streets of
Providence will further reduce wet weather sewage overflows. Yet while combined sewer overflows to
the upper bay are well known, this is a problem of older sewerage systems only.
Stormwater pollution is now a statewide problem for all urban and developing areas, particularly as
growth moves out of the city centers and into our forests and rural areas. In fact, in recent years, up
to 75% of RI beach closures annually have been traced to stormwater pollution and related sources,
with only about 25% related to combined sewer overflows. New efforts are now needed to address
remaining stormwater pollution problems if we are to protect our high quality drinking water supplies,
continue to enjoy recreational waters, and restore impaired waters.
The Rhode Island Storm Water Phase II Program
Managing stormwater pollution calls for fundamental change on many levels - in land use design and
development practices, in management of public facilities and infrastructure, and in our individual
behaviors. The RI Department of Environmental Management’s Storm Water program has been
working to gradually phase in these changes through the RI Pollution Discharge Elimination System
(RIPDES) permit program.
Beginning in 1990, the Phase I storm water program regulated discharges from municipalities with
storm water drainage systems, known as Small Municipal Separate Storm Sewer Systems or MS4s,
serving populations over 100,000. Owners of these MS4s, certain industries, and construction sites
over 5 acres had to develop and implement stormwater plans.
In 1999, Phase II applied the same laws to smaller jurisdictions and to construction sites disturbing
one or more acres. In 2003 all municipalities with Small Municipal Separate Storm Sewer Systems
(MS4s) were required to submit an RIPDES Storm Water Phase II permit application and prepare a
Storm Water Management Program Plan (SWMPP) that describes how the municipality will manage
stormwater to reduce the discharge of stormwater pollutants to the maximum extent practicable. The
plan describes how the town will implement a storm water management program that incorporates six
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Preventing Stormwater Pollution at Your Public Works Facility
elements, or “minimum measures” that are expected to significantly reduce stormwater pollution when
applied together.
Each municipality’s Storm Water Management Program Plan sets measurable goals for each
minimum measure to track the success of the program, with an action plan and implementation
schedule. When new information becomes available on controlling pollution of impaired waters based
on a water quality assessment known as a Total Maximum Daily Load (TMDL), RIDEM may require
the municipality to take additional pollution control actions based on TMDL recommendations and to
update their Storm Water Management Plan accordingly.
Who Is Covered by Phase II?

Municipalities with small municipal separate storm sewer systems (MS4) located either partly or
completely within an urbanized or densely populated area with a population density of greater
than 1,000 persons per square mile. In Rhode Island, this includes all cites and towns except:
Foster, Hopkinton, Little Compton, New Shoreham and Richmond. These lightly developed
communities will require permits by March 10, 2008 unless demonstrating effective protection of
Special Resource Protection Waters (SRPWs), and Impaired Waters.

Operators of small construction activities that disturb equal to or greater than 1 (one) and less
than 5 (five) acres of land. Sites disturbing 5 acres or more were previously regulated.

Federal, State, and Quasi-State facilities serving an average daily population of equal to or
greater than 1,000 persons. This includes for example, the University of Rhode Island and the
Newport Naval Base.

Department of Transportation (DOT) MS4s in urbanized areas, densely populated areas, and
areas qualifying as a divided highway.

Federal, State and municipally-owned industrial facilities such as public works facilities and
highway garages.
Minimum Requirements of a Community Stormwater Program
Phase II communities must take action on the following six required elements, or “minimum
measures” to reduce stormwater pollution.
1. Public Education and Outreach
Implement a public education program to distribute educational materials in the community or conduct
equivalent outreach activities to inform citizens about the impacts of polluted runoff and actions they
can take to prevent pollution.
2. Public Participation and Involvement
Provide opportunities for citizens to participate in program development and implementation.
Comply with applicable State and local public notice requirements and effectively publicize public
hearings and/or encourage citizen representation on a storm water management panel.
3. Illicit Discharge Detection and Elimination
Develop and implement a plan to detect and eliminate illicit discharges to the storm sewer system,
including illegal dumping into the MS4.

Develop a storm sewer map, showing the location of all outfalls and the names and location of
all waters of the State that receive discharges from those outfalls;
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
Adopt an ordinance or other regulatory mechanisms to prohibit non-storm water discharges into
the MS4, and ensure program can take appropriate enforcement actions;

Implement procedures to receive and consider complaints about pollution problems, trace and
remove the source, and evaluate the program.

Inspect all catch basins and manholes for illicit connections and non-stormwater discharges.

Complete two dry weather surveys, one between January 1 and April 30, and one between July
1 and October 31.

Coordinate activities with physically interconnected MS4s when illicit discharges are detected or
reported.

Educate public employees, businesses, and the general public about the hazards associated
with illegal discharges and improper disposal of waste.
4. Construction Site Runoff Control
Implement and enforce an erosion and sediment control program for construction activities that
disturb one acre or more of land, with procedures for review of construction plans that consider
potential water quality impacts, site inspection, and enforcement of control measures.

Adopt an ordinance or other regulatory mechanism to require proper erosion and sediment
controls, and control of other wastes on construction sites, and penalties to ensure compliance.

Review 100% of construction plans and Storm Water Pollution Prevention Plans, issue and track
permits for construction projects disturbing one acre or more not reviewed by other State
programs.

Implement procedures to receive and consider information about construction site stormwater
runoff from the public.

Inspect 100% of all construction projects within the regulated area that discharge or have the
potential to discharge to the MS4. Enforce erosion and sediment control measures and other
measures for control of waste at construction sites.

Implement procedures for referral to the State of non-compliant construction site operators.
5. Post-Construction Runoff Control
Develop, implement, and enforce a program to address discharges of post-construction storm water
runoff from new development and redevelopment areas using strategies which include a combination
of structural and/or nonstructural BMPs. Applicable controls could include for example, preventative
actions such as protecting sensitive wetlands, or the use of structural BMPs such as grassed swales
or porous pavement.

Adopt an ordinance or other regulatory mechanism requiring the implementation of postconstruction runoff controls from new development and redevelopment to the extent allowable
under State or local law.

Review 100% of plans for development projects disturbing one or more acres not reviewed by
other State Programs, and coordinate with existing State programs requiring post-construction
storm water management.

Implement procedures for referral to the State of new discharges of storm water associated with
industrial activity.

Inspect post-construction BMPs and 100% of all development disturbing one or more acres of
land and within the regulated area that discharges to the MS4.
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
Establish procedures to identify, track and enforce long-term operation and maintenance of
BMPs for new construction and redevelopment.

Identify existing structural BMPs.
6. Pollution Prevention and Good Housekeeping
Develop and implement a program with the goal of preventing or reducing pollutant runoff from
municipal operations. This must include employee training on how to incorporate pollution prevention/
good housekeeping techniques into municipal operations such as regular street sweeping and catchbasin cleaning, park and open space maintenance, reduction in the use of pesticides or street salt,
fleet and building maintenance, new construction and land disturbances, and storm water system
maintenance.

Identify, locate and describe all municipally owned structural BMPs.

Inspect and clean stormwater BMPs.

Inspect and clean catch basins annually.

Minimize erosion of road side shoulders and ditches by stabilizing those areas.

Identify and report annually the known discharges causing scouring at outfall pipes or outfalls
with excessive sedimentation and describe all corrective actions.

Sweep all streets and roads within the regulated area annually.

Establish maintenance activities, schedules and long-term inspection for stormwater controls to
reduce floatables.

Properly dispose of waste removed from the MS4.

Municipally owned non-industrial facilities must develop and implement best management
practices for Operation & Maintenance and Good Housekeeping, and take corrective actions to
eliminate and/or minimize the discharge of pollutants to waters of the State.

Report and track inspections, comprehensive site evaluations, corrective actions implemented
and scheduled improvements to minimize the discharge of pollutants at industrial facilities owned
and operated by the municipality.

Implement employee training programs that will be used to prevent and reduce storm water
pollution.

Implement procedures for assessing potential water quality impacts to existing and new
stormwater flow management projects.
Sources and Additional Information
Rhode Island Pollutant Discharge Elimination System (RIPDES) Stormwater Program
http://www.dem.ri.gov/programs/benviron/water/permits/ripdes/stwater/index.htm
EPA Stormwater Program
http://www.epa.gov/ne/topics/water/stormwater.html
NRDC Stormwater Strategies, Community Responses to Runoff Pollution. 1999.
http://www.nrdc.org/water/pollution/storm/stoinx.asp
Prepared by the University of Rhode Island Cooperative Extension NEMO program under the Rhode
Island Storm Water Phase II Education and Outreach Program, funded by the Rhode Island
Department of Transportation in partnership with the Department of Environmental Management
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