HomeMy WebLinkAboutStormwater Management Plan - 2020 Update
Graphic: Surcharging storm sewer utility structure City of Bozeman and Montana State University
Stormwater Management Plan
2017 - 2021 MS4 General Permit Term
Updated February 24, 2021 Graphic: Stormwater treatment unit installation
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Table of Contents
Program Administration Section 1.0
Capital Project Program
Public Education Program
Illicit Discharge Detection and Elimination Program
Construction Site Management Program
Post-Construction Program
Good Housekeeping Program
Sampling and Evaluation Program
Stormwater Management Plan Updates
Section 2.0
Section 3.0
Section 4.0
Section 5.0
Section 6.0
Section 7.0
Section 8.0
Section 9.0
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Section 1.0
Program Administration
Graphic 1.0.2: Failed stormwater pipe Graphic 1.0.1: Street-flooding resulting from clogged infrastructure
SECTION 1.0 - PROGRAM ADMINISTRATION 2
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SECTION 1.0 - PROGRAM ADMINISTRATION 3
1.1 Introduction
This Stormwater Management Plan (SWMP) describes the City of Bozeman (City) and Montana State
University’s (University), collectively known as the MS4, structural and administrative Best Management
Practices (BMPs) engineered, implemented, maintained, and enforced to meet the following objectives:
Protect public safety;
Improve water quality; and
Comply with environmental regulations.
This SWMP is an iterative and evolving document with updates occurring annually. The MS4 tracks
updates in SWMP Section 9.0. SWMP Section 1.0 details the following components necessary to
administer the MS4’s Program, including:
Background Information (1.2)
City Program Framework (1.3)
University Program Framework (1.4)
Stormwater Management Team (1.5)
MS4 Coordination (1.6)
Collaborative Organizations (1.7
Additional Regulatory Responsibilities (1.8)
Annual Report (1.9)
Public Comments (1.10)
1.2 Background Information
The MS4 is an incorporated town located in Gallatin County, Montana, and has a population of 61,953 as
of 2016 (City population 45,250, University population 16,703). The MS4’s primary land-use type is
residential and commercial, with isolated industrial areas. Other notable geographical details include:
Elevation: 4820 ft.
Climate: Cold continental, with warm and dry summers, cold and dry winters
Average Temperature: 44.6 ˚F
Average Precipitation: 18.4 inches (University rain gauge)
The MS4 is located at the headwaters of the Upper Missouri Watershed and possesses relatively pristine
surface water quality that supports several beneficial uses, including aquatic life, drinking water,
agriculture, and recreation. Numerous waterways originate within and pass through the MS4.
The MS4’s most notable waterway is Bozeman Creek (aka Sourdough Creek), which originates in the
Gallatin Mountains south of its jurisdictional boundary. Flowing north, Bozeman Creek enters the MS4 at
its southeastern border and continues until its confluence with the E. Gallatin River. The Montana
Department of Environmental Quality (MDEQ) determined that Bozeman Creek has various impairments
from natural and anthropogenic sources when developing its 2013 Lower Gallatin Planning Area Total
Maximum Daily Load Report (TMDL).
The second most notable waterway is Mandeville Creek, a small spring feed watercourse that originates
south of Bozeman. Flowing north, Mandeville Creek enters the MS4 at its south-central boundary and
continues until its confluence with the E. Gallatin River. The MDEQ determined that Mandeville Creek also
has various impairments from natural and anthropogenic sources when developing its TMDL.
SECTION 1.0 - PROGRAM ADMINISTRATION 4
Numerous perennial and intermittent spring creeks flow through the MS4 in a web of channels, irrigation
ditches, and pipes. The MDEQ has not completed an assessment of these waterways.
The MS4’s water resources represent a significant community value and are the backbone of its tourism,
recreation, and neighboring agricultural industries. A growing threat to these invaluable resources is
stormwater runoff, which occurs when rainfall and snowmelt flow over developed surfaces, such as yards,
roadways, parking lots, and rooftops. Stormwater picks up pollutants before entering storm sewers, such
as drains, pipes, and ditches, and eventually discharges into the MS4’s waterways. Stormwater runoff can
result in property damage, public health threats, and environmental degradation if not proactively
managed. Specific pollutants of concern include:
Sediment: Sourced from barren ground, construction sites, road sand, unpaved roads and trails,
gravel parking lots, windblown dust, and vehicle grime, resulting in suffocated aquatic habitat and
alterations to stream channel morphology.
Nitrogen and Phosphorous: Sourced from improper lawn fertilizer application, grass clippings, and
yard debris, resulting in oxygen-depleting algae blooms.
E.coli: Sourced from substandard septic systems and pet waste, resulting in toxic conditions for
the public and wildlife.
Floatables: Sourced from littering, overfilled garbage cans, and unsecured loads, resulting in
clogged infrastructure, impaired aesthetic value, and endangered wildlife.
Oil, Grease, Metals, and Detergents: Sourced from improper vehicle maintenance, car spills, and
car washing, resulting in toxic conditions for humans and wildlife.
Temperature: Sourced from extensive and continuous impervious areas, resulting in harmful
impacts to coldwater fisheries.
To counter stormwater runoff’s impact, the United States Congress established the National Pollutant
Discharge Elimination System (NPDES) as a part of the Clean Water Act (CWA) in 1972 to preserve and
restore the health of the United States’ Waters. The U.S. Environmental Protection Agency (EPA) is the
lead organization tasked with the implementation and oversight of the CWA. In Montana, the MDEQ has
primacy, allowing for further state-scale interpretation, enactment, and enforcement.
The NDPES program regulates water pollution through a series of permits focused on point sources, such
as industrial facilities, wastewater plants, and stormwater discharges. The driving permit behind the
development and implementation of this SWMP is the MDEQ’s Phase 2 General Permit for Stormwater
Discharges Associated with Small Municipal Separate Storm Sewer Systems (MS4 Permit), which requires
the City and University to implement a variety of programs to mitigate polluted discharges to waterways.
The MDEQ designates the City as a traditional permittee and the University as a non-traditional permittee.
Both parties are co-permittees because their storm sewers are connected, and they work together on
various administrative programs. The MDEQ requires the MS4 to complete the following:
Prepare and submit individual Notices of Intent (NOI).
Receive authorizations to discharge from MDEQ by January 1, 2017.
Prepare and submit individual Annual Reports.
Develop, implement, and update this SWMP throughout the MS4 Permit term.
Also, the MDEQ requires the MS4 to administer a program that works to accomplish the following:
Educate the public (SWMP Section 3.0)
Engage citizens through involvement and participation (SWMP Section 3.0)
Detect and eliminate illicit discharges and connections (SWMP Section 4.0)
Regulate construction sites (SWMP Section 5.0)
SECTION 1.0 - PROGRAM ADMINISTRATION 5
Regulate stormwater facilities constructed with new and re-development (SWMP Section 6.0)
Mitigate polluted discharges from municipal facilities and operations (SWMP Section 7.0)
Collect and analyze water quality and stormwater runoff data (SWMP Section 8.0)
The following sections of this SWMP outline the MS4’s work within each of these programs.
1.3 City Program Framework
On June 25, 2012, the City adopted Ordinance 1831, creating a Stormwater Utility, providing revenue
collection for the operation and maintenance of the City’s stormwater system. Funding was initially
allocated to inventory, map, and assess the condition of the City’s storm sewer. This effort was in response
to findings identified during a 2011 MDEQ MS4 Permit audit, which included one violation, 16 program
deficiencies, and 23 improvement recommendations.
On March 3, 2014, the City presented the results of their inventory, mapping, and assessment effort to
City Commissioners. The City inventoried over ten thousand individual assets, many of which were
clogged, cracked, buried, or in disrepair. Also, a program administration review identified significant
shortfalls. Commissioners directed the City to develop options for addressing known issues.
On April 21, 2014, the City presented three levels of service, differing primarily on the timeline required
to address issues and the annual funding level. Commissioners decided to implement a program that
included a funding level of $1.2 million annually for operations, treatment, and deferred maintenance.
On February 23, 2015, the City adopted a new level of service and a rate model to collect service fees
based on individual property’s impact on the stormwater system.
On December 1, 2015, the City implemented the final piece of the new rate model allowing a fully funded
and functional Stormwater Utility for the first time in its history. The City’s utility rate model includes the
following components:
Flat Charge: Charged evenly across the service area. Properties with a water meter receive a flat
monthly charge per meter. Properties that have impervious area, but do not have a water meter
also receive a flat charge. The funding pays for deferred maintenance projects.
Variable Charge: Charged proportional to the amount of impervious area individual properties
have. Impervious area does not allow water to soak into the ground during rain events creating
stormwater runoff. Larger areas result in more impact on public storm sewers and waterways.
Utility Credit: Properties that have installed quantity and quality-based stormwater infrastructure
controls receive a billing credit as these properties impact the stormwater system less than those
without stormwater infrastructure.
The City’s utility rate model includes the following funding allocations:
Approximately $450,000 annually for deferred maintenance, which includes costs associated with
the replacement and cleaning of storm sewer assets.
Approximately $550,000 annually for operations and maintenance, which includes expenses
related to personnel, reoccurring system maintenance, supplies, and equipment.
Approximately $200,000 annually for system enhancements, which includes costs associated with
stormwater treatment projects to remove pollutants before discharging to waterways.
The Stormwater, Building, Strategic Services, and Finance Divisions work collaboratively to update the
rate model regularly as new development occurs. The workflow includes:
1. Developers submit site plans to the Building Division through electronic permit software.
2. Staff reviews and uploads site plans to a shared group folder on the City’s internal drive.
SECTION 1.0 - PROGRAM ADMINISTRATION 6
3. Strategic Services Staff checks the folder regularly, imports site plans into GIS, digitizes impervious
area, and updates the polygon’s Equivalent Residential Unity (ERU) attribute.
4. Finance sends water meter notice to Staff when a project is nearing completion.
5. Stormwater Staff review impervious area data based on the address information provided by
Finance and calculates an ERU total, including percentage credit, if applicable.
6. Stormwater Staff provides Finance Staff with an ERU value and credit value.
7. Finance Staff updates software and generates a bill for customers.
Table 1.3.1 shows impervious area additions per year (single-family units and public roads excluded):
Table 1.3.1: Impervious Area Additions
Calendar Year Impervious Area (Acres) Site Plans
2017 75 86
2018 73 100
2019 68 98
2020 66 97
2021 - -
Budget creation and approval occurs annually to allocate collected funds, including the following details:
Fiscal Year 2018 Budget (July 1, 2017 - June 30, 2018)
Percent Allocation: 100%
Resource Justification: Budget approval process completed June 26, 2017.
Program Effectiveness: See SWMP Sections 2.0 - 8.0.
Resource Variation: Proposed addition of one FTE (Stormwater Specialist), approved.
Success Determination: See SWMP Sections 2.0 - 8.0.
Staff: 6.5 FTEs
Table 1.3.3: FY18 Budget Totals
Fiscal Year Budget
Salaries and Benefits $451,548
Operating $161,466
Capital $650,000
Debt Service $225,346
Transfers $0.00
Total Budget: $1,488,360
0
2
4
6
8
10
$0
$500,000
$1,000,000
$1,500,000
$2,000,000
2018 2019 2020 2021 # of StaffAnnual BudgetFiscal Year
Stormwater Division Budget and Staff Levels
Annual Budget
Dedicated Staff
Graphic 1.3.2: Stormwater Division Budget and Staff Levels Graph
SECTION 1.0 - PROGRAM ADMINISTRATION 7
Fiscal Year 2019 Budget (July 1, 2018 - June 30, 2019)
Percent Allocation: 100%
Resource Justification: Budget approval process completed June 25, 2018.
Program Effectiveness: See SWMP Sections 2.0 - 8.0.
Resource Variation: Proposed addition of one FTE (Project Manager), approved.
Success Determination: See SWMP Sections 2.0 - 8.0.
Staff: 6.5 FTEs
Table 1.3.4: FY19 Budget Totals
Fiscal Year Budget
Salaries and Benefits $408,583
Operating $240,373
Capital $635,000
Debt Service $160,346
Transfers $0.00
Total Budget: $1,444,302
Fiscal Year 2020 Budget (July 1, 2019 - June 30, 2020)
Percent Allocation: 100%
Resource Justification: Public budget approval process completed June 24, 2019.
Program Effectiveness: See SWMP Sections 2.0 - 8.0.
Resource Variation: 4% rate increase to pay for new FTE and inflation.
Success Determination: See SWMP Sections 2.0 - 8.0.
Staff: 7.5 FTEs
Table 1.3.5: FY20 Budget Totals
Fiscal Year Budget
Salaries and Benefits $580,938
Operating $268,372
Capital $650,000
Debt Service $161,211
Transfers $0.00
Total Budget: $1,660,521
Fiscal Year 2021 Budget (July 1, 2020 - June 30, 2021)
Percent Allocation: 100% dedicated to stormwater programs and projects.
Resource Justification: Public budget approval process completed in June 2020. Staff gave a
public presentation regarding past, current, and future work, and answered questions.
Program Effectiveness: See performance measures in SWMP Sections 2.0 - 8.0.
Resource Variation: 4% rate increase to pay for inflation, increased capital needs/cost, and to
fund a new position. No significant changes have occurred from the FY20 budget cycle.
Success Determination: The City was successful in receiving requested resources. See SWMP
Sections 2.0 - 8.0 for more information regarding ongoing and planned programs and projects.
Staff: 8.5 FTEs
SECTION 1.0 - PROGRAM ADMINISTRATION 8
Table 1.3.6: FY21 Budget Totals
Fiscal Year Budget
Salaries and Benefits $640,866
Operating $317,907
Capital $700,000
Debt Service $194,735
Transfers $0.00
Total Budget: $1,853,508
1.4 University Program Framework
In the current permit cycle, the University has managed six projects of an acre or larger, which have
influenced stormwater quantity and quality. Those projects are:
American Indian Hall: Over One Acre, Active, 2021 Planned Completion
Romney Oval Renovation Project: Over One Acre, Active, 2021 Planned Completion
Romney Hall Renovation project: Under One Acre, Active, 2021 Planned Completion
Norm Asbjornson Hall Construction: Over One Acre Project, Complete 2020
Hyalite Hall: Over One Acre Project, Complete 2020
Montana Hall Elevator and Renovation project: Under One Acre, Complete 2020
Lambert Field Renovations: Over One Acre, Complete 2019
Rendezvous Dining Hall Construction: Over One Acre, Complete 2019
College and 11th Treatment Unit: Under One Acre, Complete 2019
In 2020, the University has devoted approximately 640 hours to stormwater maintenance, management,
and improvements and tracks work activities and labor using a work order system. Under the general
guidance of the Engineering and Utilities Manager, the Environmental Service Manager coordinates and
ensures MS4 Permit compliance.
1. Current Staff:
Engineering and Utility Manager: Directional and political support (40 hours per year)
Director - Facilities Services: Overall program coordination. Administers and supports
environmental compliance programs; manages support personnel; identifies and advocates
for infrastructure projects; conducts sampling, training, inspections, permit reviews, data
collection, and reporting; manages reoccurring infrastructure maintenance, structural
inspections, repairs, and replacements (300 hours/year)
Support Staff and Contracted Services: Groundskeepers, laborers, plumbers, and street
sweeping (300 hours/year)
The following representatives make up the University’s stormwater management team. Regular
communication occurs, allowing for the exchange of necessary information:
1. Megan Sterl, Engineering and Utility Manager
Program Administration
2. EJ Hook, Director, Facilities Services (Primary SWMP Coordinator)
Public Education Program (SWMP Section 3.0)
Illicit Discharge Detection and Elimination Program (SWMP Section 4.0)
Construction Site Management Program (SWMP Section 5.0)
Post Construction Program (SWMP Section 6.0)
Good Housekeeping Program (SWMP Section 7.0)
SECTION 1.0 - PROGRAM ADMINISTRATION 9
Current funding is not a line item but included in the general campus maintenance operations budget for
Facilities Services. As allowable and necessary funds from Facilities Services General Operating budget are
allocated to specific stormwater improvement projects.
Fiscal Year 2018 Approved Budget (July 1, 2017 - June 30, 2018)
Percent Allocation: 100%
Resource Justification: Budget approval process completed June 29, 2017
Program Effectiveness: See SWMP Sections 2.0 - 8.0.
Resource Allocation Variation: $25,000 for College and 11th improvement project design
Success Determination: See SWMP Sections 2.0 - 8.0.
Staff: 0.3 FTEs
Table 1.4.1: FY18 Budget Totals
Fiscal Year Budget
Operating $124,000
Capital -
Total Budget: $124,000
Fiscal Year 2019 Approved Budget (July 1, 2018 - June 30, 2019)
Percent Allocation: 100%
Resource Justification: Budget approval process completed June 29, 2018
Program Effectiveness: See SWMP Sections 2.0 - 8.0.
Resource Allocation Variation: $150,000 for College and 11th improvement project
installation
Success Determination: See SWMP Sections 2.0 - 8.0.
Staff: 0.3 FTEs
Table 1.4.2: FY19 Budget Totals
Fiscal Year Budget
Operating $124,000
Capital $150,000
Total Budget: $274,000
Fiscal Year 2020 Approved Budget (July 1, 2019 - June 30, 2020)
Percent Allocation: 100%
Resource Justification: Budget approval process completed June 29, 2019
Program Effectiveness: See SWMP Sections 2.0 - 8.0.
Resource Allocation Variation: None
Success Determination: See SWMP Sections 2.0 - 8.0.
Staff: 0.3 FTEs
Table 1.4.3: FY20 Budget Totals
Fiscal Year Budget
Operating $126,500
Capital -
Total Budget: $126,500
Fiscal Year 2021 Approved Budget (July 1, 2020 - June 30, 2021)
SECTION 1.0 - PROGRAM ADMINISTRATION 10
Percent Allocation: 100%
Resource Justification: Budget approval process completed June 29, 2019
Program Effectiveness: See SWMP Sections 2.0 - 8.0.
Resource Allocation Variation: None
Success Determination: See SWMP Sections 2.0 - 8.0.
Staff: 0.3 FTEs
Table 1.4.3: FY20 Budget Totals
Fiscal Year Budget
Operating $126,500
Capital -
Total Budget: $126,500
1.5 Stormwater Management Team
The MS4 has three Stormwater Management Teams described in Graphic 1.5.1 and the following section.
SWMP Team: Meets weekly and is comprised of the following positions:
1. Stormwater Program Coordinator: SWMP Coordinator and Bozeman Municipal Code (BMC)
Section 40 Article 4 Enforcement Agent. Leads the SWMP Team, SWMP Subject Matter Experts,
and coordination with SWMP Support Divisions. The Coordinator develops and manages the
Graphic 1.5.1: Organization Chart
SECTION 1.0 - PROGRAM ADMINISTRATION 11
implementation of SWMP and MS4 Permit compliance activities, administers environmental
compliance programs, manages personnel, prepares budgets, develops policies, coordinates
infrastructure projects, and maintains the rate model. Primary permit responsibilities include:
Program Administration (SWMP Section 1.0)
Capital Project Program (SWMP Section 2.0)
Public Education Program (SWMP Section 3.0)
Illicit Discharge Detection and Elimination Program (SWMP Section 4.0)
Construction Site Management Program (SWMP Section 5.0)
Post Construction Program (SWMP Section 6.0)
Good Housekeeping Program (SWMP Section 7.0)
Sampling and Evaluation Program (SWMP Section 8.0)
2. Stormwater Program Specialist: Develops and implements water quality monitoring, BMP
effectiveness research, and data analysis. Primary permit responsibilities include:
Public Education Program (SWMP Section 3.0)
Illicit Discharge Detection and Elimination Program (SWMP Section 4.0)
Good Housekeeping Program (SWMP Section 7.0)
Sampling and Evaluation Program (SWMP Section 8.0)
3. Stormwater Project Manager: Plans and manages stormwater conveyance, flood control, and
treatment capital projects, implements the City’s asset maintenance efforts, and regulates
drainage infrastructure. Primary permit responsibilities include:
Capital Project Program (SWMP Section 2.0)
Post Construction Program (SWMP Section 6.0)
Good Housekeeping Program (SWMP Section 7.0)
4. Two Stormwater Program Technicians: Perform permit reviews, site inspections, and reporting
tasks. Primary permit responsibilities include:
Construction Site Management Program (SWMP Section 5.0)
The SWMP Team tracks phone call and email questions, requests, and complaints received from the public
to gauge programmatic needs and workloads, including:
SECTION 1.0 - PROGRAM ADMINISTRATION 12
Table 1.5.1: Correspondence Tracking Totals
Correspondence Type Count
2018 2019 2020 2021 Total
Resident: Flooding Inquiry or Report 7 15 2 - 24
Resident: Construction Inquiry or Report 22 19 9 - 50
Resident: Water Quality Inquiry or Report 2 2 2 - 6
Resident: Pollution Inquiry or Report 14 6 3 - 23
Resident: Basin Inquiry or Report 14 12 10 - 36
Resident: Outreach Inquiry or Report 2 12 2 - 16
Resident: Rate Model Inquiry 4 6 5 - 15
Professional: Post-Const. Program 47 60 52 - 159
Professional: Pollution Program 4 18 7 - 29
Professional: Const. Program 112 295 465 - 872
Professional: Project Management 16 181 72 - 269
Professional: Education Program 14 57 32 - 103
Professional: Division Administration 9 36 43 - 88
Professional: Water Quality Program 11 8 16 - 35
Professional: Service or Product Solicitation 17 19 9 - 45
Referral to other division 5 6 4 - 15
Total: 300 752 733 - 1,785
SWMP Subject Matter Experts (SME): The SME group meets as necessary to discuss programmatic issues
and is comprised of the following positions:
1. Engineering Division: Team of three positions that review and regulate new and redevelopment
projects utilizing established engineering standards. The positions include the Development
Review Manager and a variety of staff engineers. Primary permit responsibilities include:
Post Construction Program (SWMP Section 6.0)
2. Operations and Maintenance: Team of five positions that operate and maintain the public storm
sewer network, including the inspection, maintenance, and repair of infrastructure. This group
also inspects underground pipes to identify illicit discharges and illegal connections. This team
includes a Superintendent, Assistant Superintendent, Foreman, and two Operators. Primary
permit responsibilities include:
Illicit Discharge Detection and Elimination Program (SWMP Section 4.0)
Good Housekeeping Program (SWMP Section 7.0)
3. Streets Division: Numerous positions that operate the City’s street sweeping, spring and fall
cleanups, and surface inlet grate obstruction removal and replacement activities. This team
includes a Superintendent, Assistant Superintendent, and numerous Operators. Primary permit
responsibilities include:
Good Housekeeping Program (SWMP Section 7.0)
SWMP Support Divisions: Group engaged by the SWMP Team as needs arise. Support Divisions do not
typically participate in reoccurring meetings unless invited to discuss a particular topic.
1.6 MS4 Coordination
The MS4s works collaboratively on various programs, including:
SECTION 1.0 - PROGRAM ADMINISTRATION 13
Participation in monthly meetings.
University payment of City stormwater fees, rate model update to occur during Q1 of each
calendar year and an updated total should be in place by July 1.
Performance tracking and reporting.
Infrastructure project development and implementation.
Inspection forms, training, methodologies, and program documentation sharing.
Pollution event response and resolution, as requested.
Stormwater treatment unit maintenance: The City removes debris collected by University
stormwater mechanical treatment units and incorporates totals into SWMP Section 8.0 annually,
including:
University Field House Downstream Defender Mechanical Separation Unit
11th and College Contech CDS Mechanical Separation Unit
Water Sampling and Analysis Program: The City manages the University’s portion of this program,
including purchasing equipment, collecting samples/data, and analyzing results for the following:
Urban Runoff Monitoring
In-Stream Wet Weather Monitoring
Sediment Reduction Monitoring
Long-Term Trend Monitoring
Post Construction Program: The City completes six high-priority stormwater facility inspections
on MSU property annually, and provides completed reports.
The City provides the University an updated SWMP by February 1 of each calendar year.
1.7 Collaborative Organizations
The MS4 collaborates with a variety of organizations, including:
Montana Stormwater Committee (MSC): An organization formed in 2016 comprised of public and
private stormwater industry representatives that provides a unified voice for state scale policy
changes, rules, issues, and initiatives. The MSC meets monthly to discuss relevant topics. Their
most recent accomplishment includes the development of Montana’s first American Society of
Civil Engineers Stormwater Report Card, resulting in a statewide score of D.
National Municipal Stormwater Alliance (NMSA): An organization formed in 2015 comprised of
stormwater industry professionals that provides a unified voice for national scale policy changes,
rules, issues, and initiatives.
Montana Department of Environmental Quality (MDEQ): A state agency that administers and
enforces the Montana Clean Water Act. MDEQ provides compliance training, conferences, and
enforcement in cases where the MS4’s resources become exhausted.
Gallatin Local Water Quality District (GLWQD): A Gallatin County public agency that conducts
water quality sampling and community education.
Montana State Extension Water Quality: A University Extension agency that provides water
quality sampling and community education.
Montana Water Environment Association (MWEA): A Montana organization that represents
water, wastewater, and stormwater professionals. MWEA is a member of the Water Environment
Federation (WEF), which has over 34,000 members worldwide. WEF is working to raise knowledge
regarding stormwater infrastructure, policy, and science at the national level.
Gallatin Watershed Council (GWC): An education-based nonprofit organization that works to
improve waterway health by implementing the Gallatin Watershed Restoration Plan.
SECTION 1.0 - PROGRAM ADMINISTRATION 14
1.8 Additional Regulatory Responsibilities
The following MPDES permits also fall under the purview of the MS4:
General Permit for Stormwater Discharges Associated with Construction Activity (MTR100000):
Construction projects that disturb one acre or more of land must obtain a stormwater discharge
authorization from the MDEQ. The MS4 implements a Construction Management Program
detailed in SWMP Section 5.0
Multi-Sector General Permit for Stormwater Discharges Associated with Industrial Activity
(MTR000000): The MS4’s Water Reclamation Facility (WRF) and Landfill obtain authorizations to
discharge stormwater from their facilities. MS4 Staff assist WRF and Landfill personnel with
required inspections, BMP development, training, reporting, and records keeping.
1.9 Annual Report
The MS4 submits individual Annual Report Forms, an updated SWMP, and relevant documents to the
MDEQ by March 1 of each year.
1.10 Public Comments
The MS4 considers and responds to all public comment related to the SWMP. To facilitate, a public
comment form exists on the MS4’s website and is available year round. Also, the MS4 publically notices
the SWMP after making annual updates in the Bozeman Daily Chronicle the second and third Sundays of
March during each calendar year. Dates include:
2019: March 17th and 24th
2020: March 15th and 22nd
2021: March 14th and 21st
The MS4 has received the following comments:
Table 1.10.1: Public Comments
# Date Participant Comment MS4 Response
1 2019
Adopt-A-
Drain
Participant
I look at the City in an entirely different way now.
Whenever I look at the street, I see the headwaters of a
creek (In person feedback).
Noted comment and
will request their
participation in the
2020 Adopt-A-Drain
Program.
2 7/23/19
Adopt-A-
Drain
Participant
I cannot believe the debris-filled the whole bucket! You are right how much more aware I have become about the
drains and my street surroundings. I even found a pair of
swimming goggles near the drain, kind of weird and ironic,
who was swimming in the drains!?”.
Noted comment and will request their
participation in the
2020 Adopt-A-Drain
Program.
3 7/23/19
Adopt-A-
Drain
Participant
Thank you, I will put the bucket on the front porch! And
yes please share my email.
And to add to the email...with this new Storm Drain
awareness and understanding, I feel like I should be
cleaning all the drains that I see that are filled with debris
and to let others know how important it is to keep them
free of debris. I have always been a big supporter of clean
waterways and trying to do my part for the environment
Noted comment and
will request their
participation in the
2020 Adopt-A-Drain
Program.
SECTION 1.0 - PROGRAM ADMINISTRATION 15
but actually being involved in a community program like
Adopt A Drain makes it more real and more personal.
Thank you so much for being the architect of this great
program!!
One more note, the drain on the corner of 3rd and Short
does look pretty congested inside not sure though.
4 9/27/19
Adopt-A-
Drain
Participant
Of the 563.7 pounds, 563.4 was construction debris!
Noted comment and
will request their
participation in the
2020 Adopt-A-Drain
Program.
5 1/2/20
Adopt-A-
Drain
Participant
Thank you for the update!
Sorry I fell off the map. The last bit of debris that I
removed, I accidentally threw away. I was amazed at how
once you clean the drain there is not much that needs to
be done until the Fall. Also the drain looked amazing after
you guys cleaned the insides out.
It is an amazing program! Thank you for doing it and
keeping our drains clean.
I look forward to doing it again this year.
Noted comment and
will request their
participation in the
2020 Adopt-A-Drain
Program.
6 1/3/20
Adopt-A-
Drain
Participant
Frank! Thanks so much for the update on how much we all saved from going down the drain! I still have a full bucket
of debris; what should I do with it? And should I continue
cleaning my drain? Bravo to you and the others for a great
experiment!
Noted comment and will request their
participation in the
2020 Adopt-A-Drain
Program.
7 1/3/20
Adopt-A-
Drain
Participant
My only feedback is that I forget to check/clean “my”
drain. I’ll create reminders in my calendar. I’ll also create
a reminder and post a photo and comment about my drain
on NextDoor every now and then.
What’s your goal for 2020? Let’s blow the lid off!!
Noted comment and
will request their participation in the
2020 Adopt-A-Drain
Program.
8 1/10/20
Adopt-A-
Drain
Participant
Thanks for the update – that is a lot of debris. Our only
problem is that the compostable bags are hard to make
stay up and open in the buckets. We are glad that
compostable bags are being used – I wonder if there is some kid of giant rubber band that could be put around
the bag to hold it up.
Noted comment and
will request their
participation in the
2020 Adopt-A-Drain
Program.
9 5/27/20
Adopt-A-
Drain
Participant
Thank you so much for your email Frank! We hope you are
doing well. I would love to volunteer again this year,
count me in! I do have all the equipment from last year, I
am pretty sure. If I don't I will let you know. I have noticed
that quite a few drains around town have been Spring cleaned by the city, which is great!! Thank you again for
doing this wonderful program!
Noted comment and
will request their
participation in the
2021 Adopt-A-Drain
Program.
SECTION 1.0 - PROGRAM ADMINISTRATION 16
10 10/1/20 General
Comment
Deer droppings, leaves, and lawn clippings can be
prevented from going into stormwater drains by collecting
this material and placing it in an area where it is unlikely to
wash into gutters during a rain or while snow is melting. Ever since I began living in my single-family home in
Bozeman, I have placed lawn clippings, deer droppings,
and some leaves into a compost pile in my large vinyl
lidded compost bin in the back yard. Other leaves I have
either used as mulch around flowers and vegetables in the
garden or else placed in a plastic garbage bin for green-
clippings pickup by the city sanitation services once or
twice a year.
Composting has enabled my family to divert a large
amount of kitchen waste and green clippings waste from
the landfill and instead transform it into fertilizing compost
with the aid of earthworms and microorganisms. This
compost spurs soil fertility and makes flowers and veggies
more healthy. It is a good alternative to chemical fertilizer
such as ammonium nitrate, which can kill or "burn" plants
if applied in too heavy a concentration, and which can
discourage earthworms' aeration and enrichment of the
soil.
Responded to the
resident and noted
the comment on
10/13/2020.
11
9/1/20
to
12/1/20
General
Comments Stormwater survey sent to 16,000 utility account holders.
Review the survey
results and integrate
collected information
into future decision-
making.
Section 2.0
Capital Project Program
Graphic 2.0.2: Permeable pavers installed at City Hall Graphic 2.0.1: Stormwater treatment unit installation
SECTION 2.0 - CAPITAL PROJECT PROGRAM 2
Blank Page
SECTION 2.0 - CAPITAL PROJECT PROGRAM 3
2.1 Introduction
The MS4’s Capital Project Program works to:
Increase storm sewer capacity;
Preserve the integrity of underground pipes and surface conveyances;
Replace failed or failing infrastructure assets; and
Meet water quality requirements set by the MDEQ.
SWMP Section 2.0 details the following components necessary to administer the MS4’s Capital Project
Program, including:
Total Maximum Daily Load Action Plan (2.2)
Planned Projects (2.3)
Ongoing or Completed Projects (2.4)
Pollutant Reduction Totals (2.5)
Performance Measures (2.6)
2.2 Total Maximum Daily Load Action Plan
The MS4 works to reduce stormwater impacts on local waterways, prioritizing the following:
Bozeman Creek due to its total stormwater discharge points and impairments identified in the
2013 Lower Gallatin Planning Area TMDLs & Framework Water Quality Improvements Plan
(TMDL), including:
Total Suspended Solids (TSS): Contributions from the MS4 require a 37% or 81 tons/year
reduction. The TMDL does not hold the MS4 to numeric TSS load limits. Instead, the TMDL
states that the MS4 will meet its Waste Load Allocation (WLA) by “adhering to the (MS4)
permit requirements to minimize pollutant loads.” The MS4 implements the following BMPs
to reduce TSS, including:
o Stormwater Management Program implementation (SWMP Sections 1.0 - 8.0)
o Mechanical separation unit installation at select direct discharge outfalls that drain
large urban basins and lack treatment (SWMP Sections 2.3, 2.4, and 2.5).
o Public Education Program implementation (SWMP Section 3.0), including, but not
limited to, the Adopt-A-Drain Program (SWMP Section 3.4.1), Construction Training
(SWMP Section 3.4.8), and Lawn Care Targeted Outreach (SWMP Section 3.4.12).
o Construction Site Management Program implementation (SWMP Section 5.0),
including the prioritization and elevated inspection rates for construction-sites within
the Bozeman Creek Watershed (SWMP Section 5.4).
o Post-Construction Program implementation (SWMP Section 6.2), including the
enforcement of water quality and flood control standards for new and
redevelopment projects (SWMP Section 6.2).
o Good Housekeeping Program implementation (SWMP Section 7.0), including regular
municipal storm sewer cleaning, spring/fall cleanups, and street sweeping (SWMP
Sections 2.5 and 7.2), Facility Stormwater Pollution Prevention Plan execution, and
Activity Stormwater Pollution Plan training.
o Sampling and Evaluation Program implementation (SWMP Section 8.0), including the
collection and analysis of stormwater runoff, in-stream water quality, BMP
effectiveness, and long-term monitoring data (SWMP Section 8.0).
SECTION 2.0 - CAPITAL PROJECT PROGRAM 4
Total Nitrogen: Contributions from the MS4 require a 0% reduction. The TMDL does not hold
the MS4 to numeric Total Nitrogen load limits. Instead, the TMDL states that the MS4 will
meet its WLA by “adhering to the (MS4) permit requirements.” The MS4 implements the
following BMPs to reduce Total Nitrogen, including:
o Stormwater Management Program implementation (SWMP Sections 1.0 - 8.0).
o Mechanical separation unit installation at select direct discharge outfalls that drain
large urban basins and lack treatment (SWMP Sections 2.3, 2.4, and 2.5).
o Public Education Program implementation (SWMP Section 3.0), including, but not
limited to, the Adopt-A-Drain Program (SWMP Section 3.4.1), Construction Training
(SWMP Section 3.4.8), and Lawn Care Targeted Outreach (SWMP Section 3.4.12).
o Illicit Discharge Detection and Elimination Program implementation (SWMP Section
4.0), including the identification and resolution of illegal discharges (SWMP Sections
4.3, 4.4, and 4.5), and the investigation of outfalls (SWMP Section 4.7).
o Construction Site Management Program implementation (SWMP Section 5.0),
including the prioritization and elevated inspection rates for construction-sites within
the Bozeman Creek watershed (SWMP Section 5.4).
o Post-Construction Program implementation (SWMP Section 6.2), including the
enforcement of water quality and flood control standards for new and
redevelopment projects (SWMP Section 6.2).
o Good Housekeeping Program implementation (SWMP Section 7.0), including regular
municipal storm sewer cleaning, storm sewer inspection (CCTV), spring/fall cleanups,
and street sweeping (SWMP Sections 2.5 and 7.2), Facility Stormwater Pollution
Prevention Plan execution, and Activity Stormwater Pollution Plan training.
o Sampling and Evaluation Program implementation (SWMP Section 8.0), including the
collection and analysis of stormwater runoff, in-stream water quality, BMP
effectiveness, and long-term monitoring data (SWMP Section 8.0).
E. coli: Contributions from the MS4 require a 0% reduction. The TMDL does not hold the MS4
to numeric E. coli load limits. Instead, the TMDL states that the MS4 will meet its WLA by
“adhering to the (MS4) permit requirements.” The MS4 implements the following BMPs to
reduce E. coli, including:
o Stormwater Management Program implementation (SWMP Sections 1.0 - 8.0).
o Public Education Program implementation (SWMP Section 3.0), including, but not
limited to, the Dog Waste Campaign (SWMP Section 3.4.4).
o Illicit Discharge Detection and Elimination Program implementation (SWMP Section
4.0), including the identification and resolution of illegal discharges (SWMP Sections
4.3, 4.4, and 4.5), and the investigation of outfalls (SWMP Section 4.7).
o Good Housekeeping Program implementation (SWMP Section 7.0), including regular
storm sewer inspection (CCTV), Facility Stormwater Pollution Prevention Plan
execution, and Activity Stormwater Pollution Plan training.
Mandeville Creek due to its total stormwater discharge points and impairments identified in the
TMDL, including:
Total Nitrogen and Total Phosphorous: Contributions from the MS4 require a 0% reduction.
The TMDL does not hold the MS4 to numeric Total Nitrogen and Total Phosphorous load
limits. Instead, the TMDL states that the MS4 will meet its WLA by “adhering to the (MS4)
permit requirements.” The MS4 implements the following BMPs to reduce Total Nitrogen and
Total Phosphorous, including:
SECTION 2.0 - CAPITAL PROJECT PROGRAM 5
o Stormwater Management Program implementation (SWMP Sections 1.0 - 8.0).
o Mechanical separation unit installation at select direct discharge outfalls that drain
large urban basins and lack treatment (SWMP Sections 2.3, 2.4, and 2.5).
o Public Education Program implementation (SWMP Section 3.0), including, but not
limited to, the Adopt-A-Drain Program (SWMP Section 3.4.1), Construction Training
(SWMP Section 3.4.8), and Lawn Care Targeted Outreach (SWMP Section 3.4.12).
o Illicit Discharge Detection and Elimination Program implementation (SWMP Section
4.0), including the identification and resolution of illegal discharges (SWMP Sections
4.3, 4.4, and 4.5), and the investigation of outfalls (SWMP Section 4.7).
o Post-Construction Program implementation (SWMP Section 6.2), including the
enforcement of water quality and flood control standards for new and
redevelopment projects (SWMP Section 6.2).
o Good Housekeeping Program implementation (SWMP Section 7.0), including regular
municipal storm sewer cleaning, storm sewer inspection (CCTV), spring/fall cleanups,
and street sweeping (SWMP Sections 2.5 and 7.2), and Activity Stormwater Pollution
Plan training.
o Sampling and Evaluation Program implementation (SWMP Section 8.0), including the
collection and analysis of stormwater runoff, in-stream water quality, BMP
effectiveness, and long-term monitoring data (SWMP Sections 8.4, 8.5, 8.6, and 8.7).
The East Gallatin due to its impairments identified in the TMDL, including:
Total Nitrogen and Total Phosphorous: Contributions from the MS4 require a 0% reduction.
The TMDL does not hold the MS4 to numeric Total Nitrogen and Total Phosphorous load
limits. Instead, the TMDL states that the MS4 will meet its WLA by “adhering to the (MS4)
permit requirements.” The MS4 implements the following BMPs to reduce Total Nitrogen and
Total Phosphorous, including:
o Stormwater Management Program implementation (SWMP Sections 1.0 - 8.0).
o Mechanical separation unit installation at select direct discharge outfalls that drain
large urban basins and lack treatment (SWMP Sections 2.3, 2.4, and 2.5).
o Public Education Program implementation (SWMP Section 3.0), including, but not
limited to, the Adopt-A-Drain Program (SWMP Section 3.4.1), Construction Training
(SWMP Section 3.4.8), and Lawn Care Targeted Outreach (SWMP Section 3.4.12).
o Illicit Discharge Detection and Elimination Program implementation (SWMP Section
4.0), including the identification and resolution of illegal discharges (SWMP Sections
4.3, 4.4, and 4.5), and the investigation of outfalls (SWMP Section 4.7).
o Post-Construction Program implementation (SWMP Section 6.2), including the
enforcement of water quality and flood control standards for new and
redevelopment projects (SWMP Section 6.2).
o Good Housekeeping Program implementation (SWMP Section 7.0), including regular
municipal storm sewer cleaning, storm sewer inspection (CCTV), spring/fall cleanups,
and street sweeping (SWMP Sections 2.5 and 7.2), Facility Stormwater Pollution
Prevention Plan execution, and Activity Stormwater Pollution Plan training.
o Sampling and Evaluation Program implementation (SWMP Section 8.0), including the
collection and analysis of stormwater runoff, in-stream water quality, BMP
effectiveness, and long-term monitoring data (SWMP Sections 8.4, 8.5, 8.6, and 8.7).
Bridger Creek due to its impairments identified in the TMDL, including:
SECTION 2.0 - CAPITAL PROJECT PROGRAM 6
Nitrate: Contributions from the MS4 require a 0% reduction. The TMDL does not hold the MS4
to numeric Nitrate load limits. Instead, the TMDL states that the MS4 will meet its WLA by
“adhering to the (MS4) permit requirements.” The MS4 implements the following BMPs to
reduce Nitrate, including:
o Stormwater Management Program implementation (SWMP Sections 1.0 - 8.0).
o Public Education Program implementation (SWMP Section 3.0), including, but not
limited to, the Adopt-A-Drain Program (SWMP Section 3.4.1), Construction Training
(SWMP Section 3.4.8), and Lawn Care Targeted Outreach (SWMP Section 3.4.12).
o Illicit Discharge Detection and Elimination Program implementation (SWMP Section
4.0), including the identification and resolution of illegal discharges (SWMP Sections
4.3, 4.4, and 4.5), and the investigation of outfalls (SWMP Section 4.7).
o Post-Construction Program implementation (SWMP Section 6.2), including the
enforcement of water quality and flood control standards for new and
redevelopment projects (SWMP Section 6.2).
o Good Housekeeping Program implementation (SWMP Section 7.0), including regular
municipal storm sewer cleaning, storm sewer inspection (CCTV), spring/fall cleanups,
and street sweeping (SWMP Sections 2.5 and 7.2), Facility Stormwater Pollution
Prevention Plan execution, and Activity Stormwater Pollution Plan training.
o Sampling and Evaluation Program implementation (SWMP Section 8.0), including the
collection and analysis of stormwater runoff, in-stream water quality, BMP
effectiveness, and long-term monitoring data (SWMP Sections 8.4, 8.5, 8.6, and 8.7).
Other Notable Waterways: Numerous unassessed waterways exist that receive protections from
the MS4’s broad programmatic efforts. These waterways include, but are not limited to, Cattail
Creek, Catron Creek, Baxter Creek, Nash Spring Creek, Flat Creek, Mathew Bird Creek, Figgins
Creek, and Aajker Creek.
2.3 Planned Projects
The MS4 prepares a five-year Capital Improvement Plan (CIP) that outlines future infrastructure projects
annually. The CIP process is open for public comment, approved by the City Commission, and incorporated
into the applicable fiscal year’s budget. The MS4 accounts for the following when preparing CIPs:
Urban Waterway/Watershed Priority
Development and Land Use
Infrastructure Condition Analysis
Programmatic Goals
Available Budget
Project Coordination
The MS4 maintains the following performance metrics to track Capital Project Program progress and
identify future needs:
Pollutant Reduction Program: Comply with the MS4’s stormwater permit and improve water
quality by preventing the discharge of 81 tons of TSS into the Bozeman Creek watershed annually.
Benefit: Reduced permit noncompliance risk, improved public safety, and a healthier
environment.
Driving Policy: Bronze Level of Service, approximately $200,000 per year
Risk: Permit requirements subject to change.
SECTION 2.0 - CAPITAL PROJECT PROGRAM 7
Table 2.3.1: Pollutant Reduction Program Performance
Type 2017 2018 2019 2020 2021
Pollutant Reduction 20% 57% 56% 51% -
Pipe Rehabilitation Program: Replace 13.9 miles of structurally deficient and undersized historical
storm sewer infrastructure throughout the downtown core.
Benefit: Reduced urban flooding and improved public safety
Driving Policy: Bronze Level of Service, approximately $450,000 per year
Risk: Increasing construction costs
Table 2.3.2: Pipe Rehabilitation Program Performance
Type 2017 2018 2019 2020 2021
Pipe Rehabilitation 3% 4% 34% 40% -
Utility Operation Program: Maintain 20% (+/-2.5%) of city-owned storm sewer assets annually
(excludes MSU). Totals include inlet maintenance, manhole maintenance, pipe maintenance, and
pipe inspection.
Benefit: Reduced urban flooding, extended infrastructure lifecycles, and improved
environmental health.
Driving Policy: Bronze Level of Service
Risk: Rapid Growth
Table 2.3.3: Utility Operation Program Performance
Type 2017 2018 2019 2020 2021
Utility Operation - 21% 17% 19% -
The MS4 plans to complete the following projects:
Pipe Rehabilitation Program: Historic Pipe Replacement Program
ID: STDM04
Year: FY22, FY23, FY24, FY25, and FY26
Budget: $280,000.00, $310,000.00, $530,000.00, $735,000.00, and $767,115.00
Description: Rehabilitation of 100-year-old vitrified clay storm sewer, which has exceeded its
life cycle, does not meet modern capacity standards, and includes many structural failures.
Alternatives Considered: The infrastructure is a critical component of the City’s storm sewer
network. Delay will increase chances of collapse, road failure, and flooding.
2 Projects
Pollutant Reduction Program
12 Projects
Pipe Rehabilitation Program
5 Projects
Utility Operation Program
SECTION 2.0 - CAPITAL PROJECT PROGRAM 8
Advantages of Approval: This project is preventative and targets pipes prone to failure and
surcharging. Rehabilitation will reduce risks by addressing structural and capacity deficiencies.
Additional Operating Cost in the Future: Stormwater Personnel will complete maintenance
on a reoccurring schedule, including flushing, vacuuming, and inspection.
Pipe Rehabilitation Program: Annual Unplanned Pipe Rehabilitation and Drainage Projects
ID: STDM05
Year: FY22, FY23, FY24, FY25, and FY26
Budget: $45,000.00, $47,250.00, $49,612.00, $52,093.00, and $54,697.00
Description: An annual program that provides funding for the design and construction of
unplanned pipe, drainage, and treatment projects.
Alternatives Considered: Use of internal crews and equipment to complete work. Staff
determined the workload required would reduce capacity applied towards critical services.
Advantages of Approval: Unplanned funds allows staff to be responsive to essential needs,
increasing customer service, improving system efficiency, and reducing City liability.
Additional Operating Cost in the Future: Stormwater personnel will complete the
maintenance of rehabilitated, repaired, or new infrastructure concurrently with existing
public assets.
Pollutant Reduction Program: Downtown Mechanical Stormwater Treatment (Phase 3)
ID: STRH01
Year: FY22
Budget: $300,000
Description: Installation of two stormwater treatment units near the intersections of N. Rouse
Ave. and E. Peach St., and N. Rouse Ave. and E. Tamarack St.
Alternatives Considered: Staff has not identified an alternative treatment approach with
comparable maintenance ease, construction footprint, or pollutant removal efficiency.
Advantages of Approval: The units will collect over 20-tons of pollutants annually from 138-
acres. They will improve public safety, Bozeman Creek’s habitat, and MDEQ permit standing.
Additional Operating Cost in the Future: Staff will complete maintenance annually using
existing vacuuming equipment and drying beds. Debris will eventually be tested and disposed
at the landfill.
Utility Operation Program: Street Sweeper (#01)
ID: STOP05
Year: FY22
Budget: $250,000
Description: Replacement of a mechanical street sweeper purchased in 2015. The sweeper
has been in operation for seven years.
Alternatives Considered: Use the existing street sweeper, resulting in increased downtime
and maintenance. Industry guidance recommends replacing municipal sweepers every five
years.
Advantages of Approval: Street sweeping protects air quality, improves waterway health,
improves MDEQ stormwater permit standing, and reduces slip hazards.
Additional Operating Cost in the Future: The Stormwater Division will fund operation and
maintenance costs. The sweeper supplements the street sweeping program led by the Streets
Division.
Utility Operation Program: Sediment Disposal Facility Asphalt Repair
SECTION 2.0 - CAPITAL PROJECT PROGRAM 9
ID: STOS01
Year: FY22
Budget: $50,000
Description: Preventative maintenance of the asphalt surface located at the Sediment
Disposal Facility used for stormwater waste disposal generated from infrastructure operation.
Alternatives Considered: Prolong asphalt maintenance risking degradation of drivable
surfaces and increased deferred expense.
Advantages of Approval: The project will ensure the facility remains operational and safe.
Additional Operating Cost in the Future: None
Utility Operation Program: Administrative Vehicle (#01)
ID: STOP03
Year: FY22
Budget: $35,000
Description: Replacement of staff’s 2000 Dodge Dakota. The truck has been in operation for
22 years and served numerous divisions. Significant maintenance and safety issues exist.
Alternatives Considered: The Stormwater Division has four administrative employees that
share two dedicated vehicles. Not replacing would result in impacts to daily operations of the
Division.
Advantages of Approval: Provides for a reliable and safe vehicle for staff to complete daily
activities, such as pollution mitigation, equipment transport, flood response, and field
inspections.
Additional Operating Cost in the Future: The Stormwater Division will fund operation and
maintenance costs.
Pollutant Reduction Program: Downtown Mechanical Stormwater Treatment (Phase 4)
ID: STRH02
Year: FY23
Budget: $250,000
Description: Installation of two stormwater treatment units near the intersections of S. Black
Ave. and E. Cleveland St., and S. Bozeman Ave. and E. Cleveland St.
Alternatives Considered: Staff has not identified an alternative treatment approach with
comparable maintenance ease, construction footprint, or pollutant removal efficiency.
Advantages of Approval: The units will collect over 27-tons of pollutants annually from 193-
acres. They will improve public safety, Bozeman Creek’s habitat, and MDEQ permit standing.
Additional Operating Cost in the Future: Staff will complete maintenance semi-annually using
existing vacuuming equipment and drying beds. Debris will eventually be disposed at the
landfill.
Pipe Rehabilitation Program: North 9th Avenue Ditch Rehabilitation
ID: STDM06
Year: FY23
Budget: $125,000
Description: Rehabilitation of 900 feet of conveyance ditch located near N. 9th Ave. from W.
Villard St. to Durston Rd., which has sediment buildup, overgrown vegetation, and bank
erosion
Alternatives Considered: The infrastructure is a critical component of the City’s storm sewer
network. Delay will result in an increased chance of adjacent property flooding.
SECTION 2.0 - CAPITAL PROJECT PROGRAM 10
Advantages of Approval: The targeted ditch is increasingly prone to backups and flooding.
Rehabilitation will reduce risks by addressing structural and capacity deficiencies.
Additional Operating Cost in the Future: Stormwater Personnel will complete maintenance
on a reoccurring schedule, including inspection and clearing.
Pipe Rehabilitation Program: Middle Creek Ditch Rehabilitation
ID: STDM09
Year: FY24
Budget: $175,000
Description: Rehabilitation of 1,500 feet of conveyance ditch located near N. 15th Ave. from
W. Main St. to W. Beall St., which has sediment buildup, overgrown vegetation, and bank
erosion
Alternatives Considered: The infrastructure is a critical component of the City’s storm sewer
network. Delay will result in an increased chance of adjacent property flooding.
Advantages of Approval: The targeted ditch is increasingly prone to backups and flooding.
Rehabilitation will reduce risks by addressing structural and capacity deficiencies.
Additional Operating Cost in the Future: Stormwater Personnel will complete maintenance
on a reoccurring schedule, including inspection and clearing.
Utility Operation Program: Pipe Inspection Van (#01)
ID: STOP04
Year: FY25
Budget: $290,000
Description: Replacement of the pipe inspection van purchased in 2001 and refurbished in
2015. The vehicle’s chassis is heavily worn and the onboard computer system is aged.
Alternatives Considered: Continue to use the existing vehicle, which could result in downtime
and increasingly costly maintenance.
Advantages of Approval: The vehicle facilitates the City’s pipe inspection program, which
identifies maintenance needs, locates structural deficiencies, and detects illegal connections.
Additional Operating Cost in the Future: The Stormwater Division will fund operation and
maintenance costs.
Utility Operation Program: Vacuum and Jetting Truck (#01)
ID: STOP08
Year: FY26
Budget: $527,000
Description: Replacement of the Division’s vacuum and jetting truck purchased in 2015.
Alternatives Considered: Continue to use the existing vehicle, which will result in downtime
and increasingly costly maintenance.
Advantages of Approval: The vehicle facilitates infrastructure maintenance, pollution event
cleanup, and vacuum excavation for pipe repairs.
Additional Operating Cost in the Future: The Stormwater Division will fund operation and
maintenance costs.
SECTION 2.0 - CAPITAL PROJECT PROGRAM 11
2.4 Ongoing or Completed Projects
The MS4 has or is in the process of completing the following projects:
Pipe Rehabilitation Program: 2020 Storm Improvements
Purpose: Three drainage repairs to fix localized flooding issues (S. 20th Ave., O’Connell Dr., and
Spruce Dr.)
Type: Inlets, pipes, and concrete structures
Treatment Efficiency: n/a
Treatment Area: n/a
Discharge Location: Varied
Date of Completion: Winter 2020
Co-Benefit(s): Reduced erosion, improved public safety
Utility Operation Program: Stormwater Utility Cost of Service and Rate Study
Purpose: Cost of service and financial rate study to guide the future rate structure.
Type: Planning document
Expected Treatment Efficiency: n/a
Treatment Area: n/a
Discharge Location: n/a
Date of Completion: Mid-2021
Co-Benefit(s): n/a
Utility Operation Program: Stormwater Facility Plan Update
Purpose: Update the City’s 2008 Stormwater Facilities Plan to provide modern policy,
programmatic, and infrastructure recommendations for future implementation.
Type: Planning document
Treatment Efficiency: n/a
Treatment Area: n/a
Discharge Location: n/a
Date of Completion: Mid-2021
Co-Benefit(s): n/a
Pipe Rehabilitation Program: Downtown Trunk Line Rehabilitation
Purpose: Rehabilitate a historical storm sewer trunk line (Tracy to Rouse)
Type: CIPP liner
30 Projects
Pollutant Reduction Program
11 Projects
Pipe Rehabilitation Program
5 Projects
Utility Operation Program
SECTION 2.0 - CAPITAL PROJECT PROGRAM 12
Treatment Efficiency: n/a
Treatment Area: n/a
Discharge Location: Bozeman Creek
Date of Completion: Mid-2021
Co-Benefit(s): Improved public safety
Pipe Rehabilitation Program: Manley Ditch Rehabilitation
Purpose: Rehabilitate a historical irrigation drainage ditch and convey drainage from a 58-
acre urban area to the Cherry Creek Fishing Access property.
Type: Ditch rehabilitation, bio-retention treatment areas, and flood control weirs
Treatment Efficiency: n/a
Treatment Area: n/a
Discharge Location: Cherry Creek
Date of Completion: Mid-2021
Co-Benefit(s): Improved public safety, enhanced water quality
Pollutant Reduction Program: Mechanical Separation Unit (Westridge)
Purpose: Reduced pollutant loading
Type: 5’ Contech CDS
Treatment Efficiency: 50% TSS reduction
Treatment Area: ≈28 Acres
Discharge Location: Bozeman Creek tributary
Date of Completion: Winter 2020
Co-Benefit(s): Improved public safety
Pollutant Reduction Program: Rouse Stormwater Upgrades (Rouse - Main to Oak, MDT)
Purpose: Flood control, reduced pollutant loading
Type: Five Contech CDS units, various sizes
Treatment Efficiency: 50% TSS Reduction
Treatment Area: ≈94 Acres
Discharge Location: Bozeman Creek
Date of Completion: Fall 2020
Co-Benefit(s): Improved public safety, reduced erosion
Utility Operation Program: Administrative Vehicle Purchase
Purpose: Transportation for Administrative Staff
Type: 2019 Dodge Ram
Expected Treatment Efficiency: n/a
Treatment Area: n/a
Discharge Location: n/a
Date of Completion: Spring 2019
Co-Benefit(s): n/a
Pipe Rehabilitation Program: BMX Park Storm Improvements (Peach and 4th)
Purpose: Flood control
Type: 244’ of 30” RCP Pipe, three 72” manhole structures
Expected Treatment Efficiency: n/a
Treatment Area: n/a
SECTION 2.0 - CAPITAL PROJECT PROGRAM 13
Discharge Location: East Gallatin River
Date of Completion: Spring 2019
Co-Benefit(s): Reduced erosion
Pollutant Reduction Program: Mechanical Separation Unit (Church and Main)
Purpose: Reduced pollutant loading
Type: 6’ Contech CDS
Expected Treatment Efficiency: 50% TSS Reduction
Treatment Area: ≈35 Acres
Discharge Location: Bozeman Creek
Date of Completion: Fall 2019
Co-Benefit(s): Improved public safety
Pollutant Reduction Program: Mechanical Separation Unit (Black and Main)
Purpose: Reduce sediment loads
Type: Contech CDS (6’ Diameter)
Expected Treatment Efficiency: 50% TSS Reduction
Treatment Area: ≈28 Acres
Discharge Location: Bozeman Creek
Date of Completion: Spring 2019
Co-Benefits: Progress towards Bozeman Creek TSS WLA
Pollutant Reduction Program: Mechanical Separation Unit (Bozeman and Main)
Purpose: Reduce sediment loads
Type: Contech CDS (6’ Diameter)
Expected Treatment Efficiency: 50% TSS Reduction
Treatment Area: ≈29 Acres
Discharge Location: Bozeman Creek
Date of Completion: Spring 2019
Co-Benefits: Progress towards Bozeman Creek TSS WLA
Pollutant Reduction Program: Rouse Stormwater Upgrades (Oak to Story Mill , Phase 1, MDT)
Purpose: Flood control, reduced pollutant loading
Type: Inlets, manholes, pipes, and three mechanical treatment units
Expected Treatment Efficiency: 50% TSS
Treatment Area: n/a
Discharge Location: Bozeman Creek
Date of Completion: Spring 2019
Co-Benefits: Flood control and water quality
Pollutant Reduction Program: Boulevard Infiltration Structure (Mason and Tracy)
Purpose: Reduce sediment loads and flood mitigation
Type: Rain Garden
Expected Treatment Efficiency: 100% TSS Reduction
Treatment Area: ≈2 Acres
Discharge Location: Matthew Bird Creek (a tributary of Bozeman Creek)
Date of Completion: Summer 2019
Co-Benefits: Progress towards Bozeman Creek TSS WLA and flow reduction.
SECTION 2.0 - CAPITAL PROJECT PROGRAM 14
Pollutant Reduction Program: Mechanical Separation Unit (11th and College)
Purpose: Reduce sediment loads
Type: Contech CDS (8’ Diameter)
Expected Treatment Efficiency: 50% TSS Reduction
Treatment Area: ≈60 Acres
Discharge Location: Mandeville Creek
Date of Completion: Summer 2019
Co-Benefits: n/a
Pollutant Reduction Program: Tracy Stormwater Upgrades (College to Babcock)
Purpose: Flood control
Type: Inlets, manholes, and 2,850 ft. of pipe
Expected Treatment Efficiency: n/a
Treatment Area: n/a
Discharge Location: Bozeman Creek
Date of Completion: Summer 2018 and 2019
Co-Benefits: n/a
Pollutant Reduction Program: Mechanical Separation Unit (3rd and Main)
Purpose: Reduce sediment load to Bozeman Creek
Type: Contech CDS (6’ Diameter)
Expected Treatment Efficiency: 50% TSS Reduction
Treatment Area: ≈94 Acres
Discharge Location: Bozeman Creek
Date of Completion: Spring 2018
Co-Benefits: Progress towards Bozeman Creek TSS WLA
Pollutant Reduction Program: Mechanical Separation Unit (Grand and Main)
Purpose: Reduce sediment load to Bozeman Creek
Type: Contech CDS (6’ Diameter)
Expected Treatment Efficiency: 50% TSS Reduction
Treatment Area: ≈58 Acres
Discharge Location: Bozeman Creek
Date of Completion: Spring 2018
Co-Benefits: Progress towards Bozeman Creek TSS WLA
Pollutant Reduction Program: Mechanical Separation Unit (Tracy and Main)
Purpose: Reduce sediment load to Bozeman Creek
Type: Contech CDS (6’ Diameter)
Expected Treatment Efficiency: 50% TSS Reduction
Treatment Area: ≈32 Acres
Discharge Location: Bozeman Creek
Date of Completion: Spring 2018
Co-Benefits: Progress towards Bozeman Creek TSS WLA
Pollutant Reduction Program: Permeable Streetscape Project (7th and Peach)
Purpose: Pilot permeable paver use
Type: Basalite Pavers
SECTION 2.0 - CAPITAL PROJECT PROGRAM 15
Expected Treatment Efficiency: 100% TSS Reduction
Treatment Area: .1 Acres
Discharge Location: East Gallatin
Date of Completion: Spring 2018
Co-Benefits: Flood control and water quality
Pipe Rehabilitation Program: Baxter Lane Stormwater Upgrades
Purpose: Improve drainage for 7th and Baxter
Type: Inlets, manholes, and mains
Expected Treatment Efficiency: n/a
Treatment Area: n/a
Discharge Location: Mandeville Creek
Date of Completion: Summer 2018
Co-Benefits: Flood control and water quality
Utility Operation Program: Bozeman Creek Stream Gage Installation
Purpose: Data collection
Type: DNRC Stream Gage
Expected Treatment Efficiency: n/a
Treatment Area: n/a
Discharge Location: n/a
Date of Completion: Summer 2018
Co-Benefits: Includes port for turbidity monitoring device
Pipe Rehabilitation Program: East Olive Street Stormwater Upgrades
Purpose: Improve drainage for East Olive Street
Type: Inlets, manholes, and mains
Expected Treatment Efficiency: n/a
Treatment Area: n/a
Discharge Location: Bozeman Creek
Date of Completion: Fall 2017
Co-Benefits: Flood control and water quality
Pollutant Reduction Program: City Hall Patio Permeable Paver Project
Purpose: LID/Green infrastructure pilot project and community education
Type: Pave Drain Permeable Pavers
Expected Treatment Efficiency: 100% TSS Reduction
Treatment Area: ≈1,000 square feet
Discharge Location: Bozeman Creek
Date of Completion: Summer 2017
Co-Benefits: Progress towards Bozeman Creek TSS WLA and flood control
Pipe Rehabilitation Program: Inlet Replacements
Purpose: Reduce sediment to Bozeman Creek and flood control
Type: Standard inlet with 9” sump
Expected Treatment Efficiency: Unknown
Treatment Area: 23 inlets
Discharge Location: Bozeman Creek
SECTION 2.0 - CAPITAL PROJECT PROGRAM 16
Date of Completion: Fall 2017
Co-Benefits: Progress towards Bozeman Creek TSS WLA
Pipe Rehabilitation Program: Pipe Replacements (Black and Bozeman)
Purpose: Flood control
Type: 15” SDR
Expected Treatment Efficiency: n/a
Treatment Area: 600’
Discharge Location: Bozeman Creek
Date of Completion: Fall 2017
Co-Benefits: n/a
Pollutant Reduction Program: Mechanical Separation Unit Installation (Rouse and Griffin)
Purpose: Reduce sediment load to Bozeman Creek
Type: Contech CDS (6’ Diameter)
Expected Treatment Efficiency: 50% TSS Reduction
Treatment Area: ≈ 14 Acres
Discharge Location: Bozeman Creek
Date of Completion: Fall 2017
Co-Benefits: Progress towards Bozeman Creek TSS WLA
Pollutant Reduction Program: Mechanical Separation Unit Installation (Rouse and Bridger Center)
Purpose: Reduce sediment load to the East Gallatin River
Type: Contech CDS (5’ Diameter)
Expected Treatment Efficiency: 50% TSS Reduction
Treatment Area: ≈12 Acres
Discharge Location: Bozeman Creek
Date of Completion: Fall 2017
Co-Benefits: Progress towards WLA
Pollutant Reduction Program: Mechanical Separation Unit Installation (Rouse and Olive)
Purpose: Reduce sediment load to Bozeman Creek
Type: Contech CDS (5’ Diameter)
Expected Treatment Efficiency: 50% TSS Reduction
Treatment Area: ≈9 Acres
Discharge Location: Bozeman Creek
Date of Completion: Fall 2017
Co-Benefits: Progress towards Bozeman Creek TSS WLA
Pollutant Reduction Program: Mechanical Separation Unit Installation (Perkins and Peach)
Purpose: Reduce sediment load to Bozeman Creek
Type: Contech CDS (4’ Diameter)
Expected Treatment Efficiency: 50% TSS Reduction
Treatment Area: ≈ 22 Acres
Discharge Location: Bozeman Creek
Date of Completion: Fall 2017
Co-Benefits: Progress towards Bozeman Creek TSS WLA
Utility Operation Program: Stormwater Operations Disposal Facility
SECTION 2.0 - CAPITAL PROJECT PROGRAM 17
Purpose: Sediment dewatering and storage
Type: Asphalt pad with ecology block bays
Expected Treatment Efficiency: n/a
Treatment Area: n/a
Discharge Location: Lined wastewater pond
Date of Completion: Fall 2017
Co-Benefits: Facilitates pollutant reduction totals
Pollutant Reduction Program: Mechanical Separation Unit Installation - S. Rouse and E. Lincoln
Purpose: Reduce sediment load to Bozeman Creek
Type: Contech CDS (5’ Diameter)
Expected Treatment Efficiency: 50% TSS Reduction
Treatment Area: ≈32 Acres
Discharge Location: Bozeman Creek
Date of Completion: Fall 2016
Co-Benefits: Progress towards Bozeman Creek TSS WLA
Pollutant Reduction Program: Mechanical Separation Unit Installation - N. 11th and W. Lamme
Purpose: Reduce sediment load to Mandeville Creek
Type: Contech CDS (4’ Diameter)
Expected Treatment Efficiency: 50% TSS Reduction
Treatment Area: ≈7 Acres
Discharge Location: Mandeville Creek
Date of Completion: Fall 2016
Co-Benefits: Located adjacent to High School
Pollutant Reduction Program: Mechanical Separation Unit, Underground Infiltration Basin, Wash
Pad, and Paving Project – Shops Complex
Purpose: Reduce sediment load to Bozeman Creek
Type: Contech CDS (4’ Diameter), ADS StormTech, and Inlet Sumps
Expected Treatment Efficiency: 50% TSS Reduction for Mechanical Separation Unit and 100%
for Underground Infiltration Basin
Treatment Area: ≈2 Acres
Discharge Location: Bozeman Creek
Date of Completion: Fall 2016
Co-Benefits: Progress towards Bozeman Creek TSS WLA
Pollutant Reduction Program: Mechanical Separation Unit Installation – N. Wallace and E.
Tamarack
Purpose: Reduce sediment load to Bozeman Creek
Type: Contech CDS (8’ Diameter)
Expected Treatment Efficiency: 50% TSS Reduction
Treatment Area: ≈100 Acres
Discharge Location: Bozeman Creek
Date of Completion: November 2016
Co-Benefits: Progress towards Bozeman Creek TSS WLA
Pollutant Reduction Program: Underground Infiltration Basin – N. 7th and Baxter
SECTION 2.0 - CAPITAL PROJECT PROGRAM 18
Purpose: Reduce localized flooding; reduce sediment load to Mandeville Creek
Type: Perforated gravity main embedded in aggregate for storage
Expected Treatment Efficiency: 100% TSS Reduction
Treatment Area: ≈9 Acres
Discharge Location: Mandeville Creek
Date of Completion: Summer 2016
Co-Benefits: Joint Water Conservation and Stormwater LID pilot project.
Pollutant Reduction Program: Underground Infiltration Basin – Plum and Avocado
Purpose: Reduce localized flooding; reduce sediment load to East Gallatin;
Type: ADS StormTech
Expected Treatment Efficiency: 100% TSS Reduction
Treatment Area: ≈14 Acres
Discharge Location: Subsurface
Date of Completion: Fall 2016
Co-Benefits: Resolved localized flooding issue
Pollutant Reduction Program: Backwater Slough – Story Mill Park
Purpose: Reduce sediment load in Bozeman Creek
Type: Constructed wetland
Expected Treatment Efficiency: 100% TSS Reduction
Treatment Area: Entire Bozeman Creek Watershed
Discharge Location: Bozeman Creek
Date of Completion: Summer 2015
Co-Benefits: Nutrient uptake, flood mitigation, and wetland restoration
Pollutant Reduction Program: Bozeman Creek Meander Construction – Bogert Park
Purpose: Stream restoration; improve streamside vegetative cover; reduce sediment load due
to streambank erosion; flood control
Type: Excavated meander and pool addition; inset floodplain construction
Expected Treatment Efficiency: Unknown
Treatment Area: Entire Bozeman Creek Watershed
Discharge Location: Bozeman Creek
Date of Completion: Spring 2017
Co-Benefits: Education, fish habitat, stream bank stabilization, and flood control
Pollutant Reduction Program: Meander the Mandeville Construction – Bozeman High School
Purpose: Stream restoration; improve streamside vegetative cover; flood control
Type: Construction of meanders, riffles, and pools
Expected Treatment Efficiency: Unknown
Treatment Area: Entire Mandeville Creek Watershed
Discharge Location: Mandeville Creek
Date of Completion: 2016
Co-Benefits: Education, fish habitat, stream bank stabilization, and flood control
Pollutant Reduction Program: LID Infiltration Galleries – University Field House
Purpose: Reduce sediment load to Mandeville Creek
Type: LID Infiltration Galleries
SECTION 2.0 - CAPITAL PROJECT PROGRAM 19
Expected Treatment Efficiency: 100% TSS Reduction
Treatment Area: 2.4 Acres
Discharge Location: Mandeville Creek
Date of Completion: 2016
Pollutant Reduction Program: Mechanical Separation Unit Installation – University Field House
Purpose: Reduce sediment load to Mandeville Creek
Type: Hydro International Downstream Defender and Sediment Separator
Expected Treatment Efficiency: 50% TSS Reduction
Treatment Area: 3 Acres
Discharge Location: Mandeville Creek
Date of Completion: Fall 2015
Pollutant Reduction Program: Underground Infiltration – Jabs and Wilson Halls
Purpose: Reduce sediment load to Mandeville Creek
Type: Underground Infiltration Gallery
Expected Treatment Efficiency: 100% TSS Reduction
Treatment Area: 3.9 Acres
Discharge Location: Subsurface
Date of Completion: 2016
Pipe Rehabilitation Program: Gravity Main Install – 15th and Babcock
Purpose: Eliminate localized flooding issue
Type: Construction of underground stormwater main
Expected Treatment Efficiency: None
Treatment Area: None
Discharge Location: Mandeville Creek
Date of Completion: Fall 2015
Pipe Rehabilitation Program: Wallace Reconstruction and Stormwater System Improvements
Purpose: Eliminate localized flooding issue and provide treatment
Type: Construction of 3,000 feet of underground stormwater mains and new inlets
Expected Treatment Efficiency: None
Treatment Area: None
Discharge Location: Bozeman Creek
Date of Completion: 2016
Pipe Rehabilitation Program: Story Street Reconstruction and Stormwater System Improvements
Purpose: Eliminate localized flooding issue and provide treatment
Type: Construction of underground stormwater mains, new inlets, and oil/sand separators
Expected Treatment Efficiency: Unknown
Treatment Area: 10 Acres
Discharge Location: Bozeman Creek
Date of Completion: 2015
SECTION 2.0 - CAPITAL PROJECT PROGRAM 20
Graphic 2.4.2: Planned and completed pollutant reduction projects
SECTION 2.0 - CAPITAL PROJECT PROGRAM 21
Graphic 2.4.3: Planned and complete pipe rehabilitation projects
SECTION 2.0 - CAPITAL PROJECT PROGRAM 22
2.5 Pollutant Reduction Totals
The MS4 tracks pollutant reduction totals using a variety of data tracking mechanisms:
Total Suspended Solids (TSS)
Treatment Unit Maintenance: The MS4 calculates tonnage totals by measuring the depth of
debris within each unit before cleaning. The MS4 subtracts a top of debris depth
measurement from a total unit depth measurement, calculates a volume of debris (cubic feet)
using dimension information for each unit, and converts the volume to tons by using an
assumed sand weight ratio of .056 tons = 1 cubic foot of sand.
Table 2.5.1: Treatment Unit Maintenance Pollution Reduction Totals
Watershed 2017 2018 2019 2020 2021
Bozeman Creek 16 Tons 45 Tons 45 Tons 41 Tons -
Mandeville Creek 5 Tons 1 Ton 6 Tons 8 Tons -
East Gallatin River 1 Ton 4 Tons 6 Tons 6 Tons -
Total: 22 Tons 50 Tons 57 Tons 55 Tons -
Storm Sewer Maintenance: The MS4 calculates tonnage totals by calculating the depth of
debris vacuumed out of manholes and inlets before cleaning. The MS4 multiplies the area of
each assets sump by an assumed 1/2 full depth measurement, multiplies the volume by the
total assets maintained for that year, and converts the volume to tons by using an assumed
sand weight ratio of .056 tons = 1 cubic foot.
Table 2.5.2: Storm Sewer Maintenance Pollution Reduction Totals
Entity 2017 2018 2019 2020 2021
City of Bozeman 118 Tons 99 Tons 111 Tons 131 Tons -
Montana State University 47 Tons 46 Tons 48 Tons 38 Tons -
Total: 165 Tons 145 Tons 159 Tons 169 Tons -
Street Sweeping: The MS4 calculates tonnage totals for year-round and spring/fall cleanup
street sweeping operations. The Streets Division tracks cubic yard totals for each of the
activities, which is then stored in Cityworks and reported. The MS4 converts yards to tons
using an assumed weight ratio of 1.5 tons = 1 cubic yard of sand for reoccurring and spring
street sweeping and converts yards to tons using an assumed weight ratio of .18 tons = 1 cubic
yard of leaves for fall street sweeping.
Table 2.5.3: Street Sweeping Pollution Reduction Totals
Entity 2017 2018 2019 2020 2021
City of Bozeman 6,108 Tons 6,022 Tons 5,502 Tons 5,127 Tons -
Montana State University 124 Tons 224 Tons 206 Tons 195 Tons -
Total: 6,232 Tons 6,246 Tons 5,708 Tons 5,322 Tons -
SECTION 2.0 - CAPITAL PROJECT PROGRAM 23
2.6 Performance Measures
The MS4 utilizes performance measures to evaluate programmatic strategies with the goal of optimizing
limited resources, increasing efficiencies, and balancing annual workloads.
Stormwater Report Card: Final Grade generated by the MS4 that provides a consistent and
communicable method for tracking stream health improvement and permit compliance risk. The
MS4’s target level of service is to facilitate an upward trend annually, which is calculated using
the methods described in SWMP Section 8.0.
Table 2.6.1: Stormwater Report Card Score
Calendar Year Score (%) Score (Grade)
2018 61% D
2019 54% F
2020 65% D
2021 - -
Community Safety and Urban Flood Risk: Tracking mechanism utilized by the MS4 that provides a
consistent and communicable method for tracking community safety and urban flood risk. The
MS4’s target level of service is to have zero insurance claims filed annually as a result of public
storm sewer deficiencies.
Table 2.6.2: Storm Sewer Affilitated Insurance Claims
Calendar Year Filed Insurance Claims
2018 0
2019 0
2020 0
2021 -
Graphic 2.5.4: Pollutant Reduction Totals Chart
0
1,000
2,000
3,000
4,000
5,000
6,000
7,000
8,000
9,000
10,000
0
50
100
150
200
250
2017 2018 2019 2020 2021 Street Sweeping Debris Collected (tons)Debris Collected (tons)Calendar Year
Pollutant Reduction Totals
Storm SewerMaint.
TreatmentUnits
StreetSweeping(Secondary)
SECTION 2.0 - CAPITAL PROJECT PROGRAM 24
Blank Page
Section 3.0
Public Education Program
Graphic 3.0.2: Dog waste station with educational signage Graphic 3.0.1: Construction field academy
SECTION 3.0 - PUBLIC EDUCATION PROGRAM 2
Blank Page
SECTION 3.0 - PUBLIC EDUCATION PROGRAM 3
3.1 Introduction
The MS4 strives to improve waterway health, protect public safety, and comply with its MS4 Permit
through the education of the public by:
Passively engaging residents through the consistent supply of educational information; and
Actively engaging residents, providing them tools to take direct action.
SWMP Section 3.0 details the following components necessary to administer the MS4’s Public Education
Program, including:
Education Protocol (3.2)
Key Audiences (3.3)
Ongoing Initiatives (3.4)
Future and Deferred Opportunities (3.5)
3.2 Education Protocol
The MS4 educates audiences on stormwater-related issues to reduce the public’s contribution of
pollutants to waterbodies using the following strategies:
Passive Engagement (Education): Creation and distribution of educational messages, targeting
pollutant-generating activities and behaviors distributed via the following platforms:
Website
Utility bill inserts
Internet and radio advertisements
Brochures
Magazine articles
Educational signage
Vehicle wraps
Surveys
Active Engagement (Involvement and Enforcement): Customized interpersonal interactions with
various audiences, targeting pollutant-generating activities and behaviors distributed via the
following activities:
Presentations/Meetings
Trainings
Tours
Activities
Events
Penalties
3.3 Key Audiences
The MS4 targets key audiences since they conduct activities that result in stormwater pollution, including:
Table 3.3.1: Key Audiences
Targeted Audience Pollutants(s) Activity Rationale Engagement
Type Initiatives
Residents Nutrients, E.
coli, TSS
Yard
Maintenance SWMP Sec. 8.9 Passive/Active SWMP Sec. 3.4
Construction Industry TSS Construction SWMP Sec. 5.6 Passive/Active SWMP Sec. 3.4
Youth/MSU Students Nutrients, E.
coli, TSS
Education and
class projects
Paradigm shift,
trickle up impact Active SWMP Sec. 3.4
HOAs - Home Owner
Associations
Nutrients, E.
coli, TSS
Facility
Maintenance SWMP Sec. 6.8 Passive/Active SWMP Sec. 3.4
Carpet Cleaning Firms Wash Waste Dumping SWMP Sec. 4.4 Active SWMP Sec. 3.4
Pet Owners E.coli Dog waste SWMP Sec. 8.2 Active/Passive SWMP Sec. 3.4
SECTION 3.0 - PUBLIC EDUCATION PROGRAM 4
3.4 Ongoing Initiatives
The MS4 completes initiatives to engage, educate, and promote sustainable behavior of its key target
audiences. Ongoing initiatives include:
Adopt-a-Drain: A program that actively engages watershed champions and supplies them with a
tool to make a measurable difference in their neighborhoods by periodically cleaning debris from
adopted storm sewer inlets. The program also passively engages residents by creating an
environment where stormwater-related issues can be discussed and acted upon at a
neighborhood level, rather than the City acting as the sole information provider.
Key Audience: Residents
Strategy: Active and Passive Engagement
Treatment Area: Citywide
Distribution Channels: Recruitment, training, troubleshooting, and engagement
Performance Measure: Total weight of debris collected annually
Table 3.4.1: Adopt a Storm Drain Program Summary
Year Task Task
Outcome Goal Goal
Outcome Notes
2019 Implement pilot
program Complete Collect
250 lbs.
Met
773 lbs.
Time intensive but effective program,
11 Residents cared for 21 inlets.
2020
Implement program,
retain majority of the
recruited residents,
explore expansion
Complete Collect
500 lbs.
Met
1,362 lbs.
Covid-19 affected ability to engage
residents, many participants started
strong but tapered in their efforts mid-
year, 14 residents cared for 30 inlets.
2021
Implement program,
retain majority of the
recruited residents,
develop expansion plan
- Collect
750 lbs. - -
Educational Stormwater Video: Seven-minute video that describes the MS4’s Program, the
context for why stormwater is important, and ways residents/property owners can make a
difference. Residents view the video on the City’s website.
Key Audience: Residents
Strategy: Passive Engagement
Treatment Area: Citywide
Distribution Channels: MS4 website and email signature attachment
Performance Measure: Total views, watch time, and average view duration tracked annually
Table 3.4.2: Educational Stormwater Video Summary
Year Task Task
Outcome Goal Goal
Outcome Notes
2017 Maintain video Complete n/a n/a
179 Views
12 hours watch time, 4:02 average
duration
2018 Maintain video Complete Repeat 2017
Views
Met
502 Views
31 hours watch time, 3:42 average
view duration
2019 Maintain video, add
to City Channel
Not
Complete
Repeat 2018
Views
Not Met
214 Views
14.1 hours watch time, 3:57 average
view duration
SECTION 3.0 - PUBLIC EDUCATION PROGRAM 5
2020
Maintain video, add
to City Channel,
promote using
Facebook
Not
Complete
Repeat 2019
Views
Not Met
167 Views
Moved video to different viewing
service in September, shifted training
platform that no longer uses YouTube
and results in views
2021 Maintain video, add
to City Channel - Repeat 2020
Views - -
Dog-Waste Campaign: Campaign devoted to educating residents about the importance of dog
waste collection and disposal. The campaign includes the deployment and maintenance of
educational signage and dog waste stations in numerous parks and trail corridors.
Key Audience: Residents
Strategy: Passive and Active Engagement
Treatment Area: Citywide
Distribution Channels: Strategic signage and waste stations placed in high use areas.
Performance Measure: Tonnage tracked annually by calculating the total amount of dog
waste collected at all waste stations. The MS4 derives the total by multiplying the total waste
station bags collected by 10 lbs., which is the assumed weight of each bag.
Table 3.4.3: Dog Waste Campaign Summary
Year Task Task
Outcome Goal Goal
Outcome Notes
2017 Maintain stations Complete n/a n/a
19.5 Tons n/a
2018 Maintain stations Complete Repeat 2017
Total
Met
20.6 Tons n/a
2019
Maintain stations,
add urban specific
signs in 4 locations
Not
Complete
Repeat 2018
Total
Not Met
18.2 Tons
27% drop in visits from 2018, meaning
bags likely filled up more and replaced
less often due to staffing shortages
2020 Maintain stations Complete Repeat 2019
Total
Not Met
17.6 Tons
Increased cleanout visitation by Park’s
Staff; however, COVID-19 impacts.
2021 Maintain stations - Repeat 2020
Total - -
Vehicle Decal Wraps: Educational signage installed on the MS4’s Vactor truck and street sweeper
that visually displays the connection between urban areas and waterways.
Key Audience: Residents
Targeted Pollutant(s): E.coli, nutrients, oil, grease, floatables, and sediment
Strategy: Passive Engagement
Treatment Area: Citywide
Distribution Channel: Vehicle use
Performance Measure: Stormwater operator hours
Table 3.4.4: Vehicle Decal Wrap Summary
Year Task Task
Outcome Goal Goal
Outcome Notes
2017 Maintain decals Complete n/a n/a
4,300 Hours n/a
2018 Maintain decals Complete Repeat 2017
Hours
Met
5,400 Hours n/a
SECTION 3.0 - PUBLIC EDUCATION PROGRAM 6
2019 Maintain decals Complete Repeat 2018
Hours
Not Met
4,100 Hours
Staffing shortages prevalent
through 2019.
2020 Maintain decals Complete Repeat 2019
Hours
Not Met
3,400 Hours
Staffing shortages prevalent
through 2020.
2021 Maintain decals - Repeat 2020
Hours - -
Website: Website that includes a variety of information, spanning from what stormwater is, how
to report a pollution event, construction stormwater permits, rate model information, post-
construction design standards, and more. Address: www.bozeman.net/government/stormwater.
Key Audience: Residents, Home Owner Associations, and Contractors
Strategy: Passive Engagement
Treatment Area: Citywide
Distribution Channels: Available to the public via the internet
Performance Measure: Total unique page views tracked by Google Analytics.
Table 3.4.5: Website Summary
Year Task Task
Outcome Goal Goal
Outcome Notes
2017 Maintain website Complete n/a n/a
677 Views
2018 Maintain website Complete Repeat 2017
Views
Met
1,225 Views
2019 Maintain website Complete Repeat 2018
Views
Met
2,408 Views
Most Visitations: Homepage,
Construction, and Contact Us
2020 Maintain website,
update periodically Complete Repeat 2019
Views
Met
4,700 Views
Most Visitations: Homepage,
Construction, and Contact Us
2021 Maintain website,
update periodically - Repeat 2020
Views - -
General Outreach: Information developed by the MS4 and applied in various settings focused on
providing general stormwater information and soliciting public participation.
Key Audience: Residents
Strategy: Active Engagement
Treatment Area: Citywide
Distribution Channels: Presentations, conferences, community events, and advertisements
Performance Measure: Total events
o 2017: 10 (Green Drinks Event, MSU Class Presentations, GLWQD Board Presentation,
(2) MSAWWA Conference Presentation, SWMBIA Home Show Booth, Environment
Summit Community Event, Water Works Art Initiative, Gallatin Watershed
Sourcebook, Breaking Ground Advertisement)
o 2018: 15 (Montana DNRC Water Summit Presentation, MDEQ Stormwater
Conference Presentation, MDEQ Stormwater Conference Tour, Parade of Homes
Garden Tour, Gallatin College Presentation, MSU Landscape School Presentation,
Stream Team Training, City Commission Emergency Ordinance Presentation, City
Commission Capital and Budget Presentation, Gallatin Watershed Sourcebook
Creation and Distribution, Water and Society Class Presentation, Horticulture 201
SECTION 3.0 - PUBLIC EDUCATION PROGRAM 7
Stormwater Design Project, (2) Student-Led Campus Cleanup Events: Loose Litter and
Cigarettes, Campus Cleanup Event)
o 2019: 17 (City of Bozeman Planning Board Presentation, Lives and Landscapes Article,
Raccoon Facebook Post, Arbor Day Event, Mountain Outlaw Article, S. Church Traffic
Calming, MSU Teacher Tour, Water School Presentation, MSU EENG 341 Class
Presentation, Active Aging Week Presentation, Eagle Scout Stenciling Project,
Montana Stormwater Committee Webinar, Water and Society Class Presentation,
Water Hydrology Class Presentation, Hort. 201 Stormwater Design Project, Health
Advancement Butt Clean Up-Day, and Campus Clean Up Event)
o 2020: 12 (CATs Project #2, CATs Project #3, Grass Clippings Mailer, City of Bozeman
Climate Action Plan, MSU HORT 440 Class Project Review, Commission Budget
Presentation, City Clerk Training, Water and Society Class Presentation, Water
Hydrology Class Presentation, Hort 201 Stormwater Design Project, Campus Clean-Up
Event, Arbor Day Plantings along Mandeville Creek)
Construction Training: Trainings that educate contractors on proper selection and use of best
management practices (BMPs) and permit preperation. The MS4 holds training tailored to various
education levels, construction activities, and inspection procedures. Further, the MS4 maintains
a Construction Program that includes permits and materials for this group (SWMP Section 5.0).
Key Audience: Contractors and Engineers
Strategy: Active and Passive Engagement
Treatment Area: Citywide
Distribution Channels: BMP Manual, annual training, and lunch and learns
Performance Measure: Annual construction-site audit earned score (see SWMP Section 5.4)
Table 3.4.6: Website Summary
Year Task Task Outcome Goal Goal Outcome Notes
2018 Hold trainings Complete n/a n/a, 33%
2019 Hold trainings Complete Improve the
2018 Score Not Met, 28% Most Visitations: Homepage,
Construction, and Contact Us
2020 Hold trainings Not Complete Improve the
2019 Score Met, 34% Scheduled classes cancelled due
to Covid-19 meeting regulations.
2021 Hold trainings - Improve the
2020 Score - -
Project WET Curriculum: Class exercises taught by 4th, 5th, and 6th-grade teachers in Bozeman
School District (BSD) classrooms, educating students on stormwater-related issues, utilizing
customized, and location-specific lesson plans and activities. The City’s Park’s Division also uses
the lesson plans for their summer camps.
Key Audience: Residents
Strategy: Active Engagement
Treatment Area: Entire MS4
Distribution Channel: Trainings for teachers who then present lessons to students
Performance Measure: Total student participants
Table 3.4.7: Project WET Curriculum Summary
Year Task Task
Outcome Goal Goal
Outcome Notes
SECTION 3.0 - PUBLIC EDUCATION PROGRAM 8
2017 Coordinate Classroom
Use Complete n/a n/a
492 Students -
2018 Coordinate Classroom
Use Complete Repeat 2017
Student Count
Met
526 Students -
2019 Coordinate Classroom
and Camp Use
Not
Complete
Repeat 2018
Student Count
Not Met
100 Students
Spent year incorporating into
the BSD curriculum.
2020 Coordinate Classroom
and Camp Use
Not
Complete
Repeat 2019
Student Count
Not Met
Students
Program discontinued until
Covid-19 regulations lift.
Post-Construction Stormwater Program: Tailored outreach that educates HOA Boards and
management representatives on the proper function and maintenance of stormwater basins. The
MS4 maintains a Post-Construction Program that includes processes and materials tailored to this
group further described in SWMP Section 6.0.
Key Audience: Home Owner Associations and Property Management Companies
Strategy: Active and Passive Engagement
Treatment Area: Citywide
Distribution Channels: Participation in facility tours, board meetings, annual assemblies, and
development of educational information
Performance Measure: Annual post-construction audit earned score (see SWMP Section 6.4)
Table 3.4.8: Post-Construction Stormwater Program Summary
Year Task Task
Outcome Goal Goal
Outcome Notes
2018 Inspect Facilities and
Educate Owners Complete n/a n/a
25% -
2019 Inspect Facilities and
Educate Owners Complete Improve the
2018 Score
Met
32%
Limited capacity to complete
due to other priorities.
2020 Inspect Facilities and
Educate Owners Complete Improve the
2019 Score
Met
56%
Hired Project Manager to assist
with program.
2021 Inspect Facilities and
Educate Owners - Improve the
2020 Score - -
Carpet Cleaning Targeted Outreach: Educate local carpet cleaning and restoration companies on
proper disposal methods and potential enforcement penalties for illicit discharges to the storm
sewer system.
Key Audience: Carpet Cleaning and Restoration Companies
Strategy: Active Engagement
Treatment Area: Entire MS4
Distribution Channels: Written and verbal correspondence
Performance Measure: Illicit discharge reports related to targeted activities
Table 3.4.9: Carpet Cleaning Targeted Outreach Summary
Year Task Task
Outcome Goal Goal
Outcome Notes
2018 n/a n/a No Related
Illicit Discharges
Not Met
1 -
2019 Distribute a letter to
owners Complete No Related
Illicit Discharges
Met
0
Increased engagement yielded
a good result.
SECTION 3.0 - PUBLIC EDUCATION PROGRAM 9
2020 Inspect Facilities and
Educate Owners Complete No Related
Illicit Discharges
Met
0 -
2021 Inspect Facilities and
Educate Owners - No Related
Illicit Discharges - -
Lawn Care Targeted Outreach: Educate residents on best practices related to lawn mowing.
Key Audience: Residents
Strategy: Passive Engagement
Treatment Area: Entire MS4
Distribution Channels: Mailer sent with a monthly utility bill.
Performance Measure: Residential sites’ TSS median concentration (SWMP Section 8.4)
Table 3.4.10: Lawn Care Targeted Outreach Summary
Year Task Task
Outcome Goal Goal
Outcome Notes
2020 Distribute a mailer to
residents Complete One mailer in
2020
Met, sent
Fall 2020 First year tracking this metric.
2021 Distribute a Mailer - One mailer in
2021 - -
3.5 Future and Deferred Initiatives
The following items represent future initiatives for the MS4:
Education Video Series: Development of a multi-faceted video library that would bring to life
many of the concepts presented in the MS4’s static educational materials.
Adopt a Rain Garden: A program that would actively engage businesses to periodically clean and
dispose debris from adopted rain gardens.
CATs Program: Collaborative program where MSU students complete projects in support of the
City’s goals. Projects typically span a semester and include a variety of activities.
SECTION 3.0 - PUBLIC EDUCATION PROGRAM 10
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Section 4.0
Illicit Discharge Detection and Elimination Program
Graphic 4.0.2: Illicit connection confirmation Graphic 4.0.1: Bentonite slurry spill
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 2
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SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 3
4.1 Introduction
The MS4 strives to improve waterway health, protect public safety, and comply with its MS4 Permit
through the identification and elimination of pollutant sources by:
Completing dry weather screening of outfalls;
Inspecting the storm sewer for illegal connections;
Responding to and resolving pollution events; and
Enforcing municipal ordinances preventing illegal dumping.
SWMP Section 4.0 details the following components necessary to administer the MS4’s Illicit Discharge
Detection and Elimination Program, including:
Regulatory Framework (4.2)
Illicit Discharge Detection and Corrective Action Plan (4.3)
Enforcement Response Plan (4.4)
Event Tracking (4.5)
Non-Stormwater Discharge Evaluation (4.6)
Outfall Reconnaissance Inventory (4.7)
Storm Sewer Infrastructure Totals (4.8)
4.2 Regulatory Framework
Pursuant to §40.04.200 Bozeman Municipal Code (BMC), it shall be unlawful to discharge or cause to be
discharged into the MS4 any materials, including, but not limited to, pollutants or waters containing any
pollutants that cause or contribute to a violation of applicable water quality standards or that could cause
the city to be in violation of its MPDES. It shall be unlawful to store, handle, or apply any pollutant in a
manner that will cause exposure to rainfall or runoff and discharge to the MS4 and to state waters or
waters of the United States.
4.3 Illicit Discharge Detection and Corrective Action Plan
The MS4 uses the following Corrective Action Plan (CAP) to determine event priority, formulate a
response, and, if necessary, pursue enforcement:
Assign an Event Coordinator (EC).
Investigate to determine pollutant type and severity (site visit and correspondence). Methods for
investigation include:
Field observation (in person, CCTV, ORI).
Sampling and analysis (grab sample, turbidimeter, multi-parameter probe (pH and
temperature), and ammonia test strips).
Infrastructure analysis (GIS, plats, and record drawings).
Dye testing.
Correspondence with property owners.
Determine an event tier and response based on the following thresholds:
Tier 1 Event: Minimal impact to public safety, infrastructure, and environment. Spills with a
major dimension less than six feet and non-continuous. Outfalls and illicit connections
deemed potential sources of pollution. Response includes:
o Team: MS4 Staff and Code Compliance Officer
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 4
o Timeline: Initiate response within five days
o Resolution: MS4 Operations and/or contracted restoration firm.
o Pollutant Disposal: Public, Sediment/Pollutant Disposal Facility. Private, Contracted
Hauler.
o Report: Internal
o Examples: Leaking vehicles and dripping dumpsters.
Tier 2 Event: Moderate impact to public safety, infrastructure, and environment. Spills with a
major dimension greater than six feet and non-continuous, or spills with a major dimension
greater than six feet, continuous, and contained. Outfalls and illicit connections deemed
suspect and obvious sources of pollution. Response includes:
o Team: MS4 Staff and Code Compliance Officer
o Timeline: Initiate response within 24-hours
o Resolution: MS4 Operations and/or contracted restoration firm.
o Pollutant Disposal: Public, Sediment/Pollutant Disposal Facility. Private, Contracted
Hauler.
o Report: Internal
o Examples: Carpet cleaning process water discharge, sanitary overflow, camper waste
disposal, homeless camp cleanup, floor drain, illicit sanitary connections, and non-
hazardous chemical spills.
Tier 3 Event: Immediate threat to human health, infrastructure, and environment. Spills with
a major dimension greater than 6’, continuous, and not contained.
o Team: MS4 Staff, Code Compliance Office, and Emergency Services
o Timeline: Immediate
o Resolution: Fire, MS4 Operations, and/or contracted restoration firm.
o Pollutant Disposal: Public, Sediment/Pollutant Disposal Facility. Private, Contracted
Hauler.
o Reporting: Internal and MDEQ Notification
o Example: Hazardous spills
Eliminate discharge through various mitigation measures depending on event severity. Options
include:
Absorbent
Vaccum and disposal
Pipe plugs or seals
Decontamination
Enforcement
Infrastructure retro-fit
If applicable, notify appropriate state and federal agencies.
Complete an event report that includes:
Event Coordinator
Date
Event Location
Pollutant(s) of Concern
Event Tier Level
Response Staff
Response Time
Discharge Location
Description
Event Timeline
Conclusion/Resolution
Images
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 5
4.4 Enforcement Response Plan
Pursuant to §40.04.860 and §40.04.890 BMC, the MS4 has the authority to implement the following
Enforcement Response Plan (ERP) and use the following enforcement protocols for violators of BMC,
including:
Informal Response: Warning issued via email notification or verbal notice used for cases when the
responsible party unknowingly commits a violation of BMC. If not dealt with in an agreed upon
timeframe, or an agreement does not occur, the MS4 escalates to a Formal Response. The MS4
handles most Tier 1 events under this category.
Formal Response: Notice of Violation and Cease and Desist Order using a set compliance timeline
and monetary penalties based on staff time accrued and remediation costs. The MS4 uses this
approach in cases when the responsible party knowingly violates BMC or has a record of non-
compliance. The MS4 handles most Tier 2 and 3 events under this category.
Judicial Response: Civil penalties, injunctive relief, or criminal penalties using the Bozeman Police
Department, City Attorney, and Municipal Court. The MS4 uses this approach in cases where the
responsible party repeatedly and knowingly commits violations of BMC and fails to remedy issues
under a Formal Response.
Additional ERP Information:
Staff with Enforcement Authority: Stormwater Program Technician, Stormwater Program
Specialist, Stormwater Program Project Manager, Stormwater Program Coordinator have the
authority to investigate events as an EC; however, the the Stormwater Coordinator is the
authorized Enforcement Agent and makes determinations regarding penalties.
4.5 Event Tracking
2017 Events: 5
Tier 1 Event: Ellis Apartments - Leaking vehicle
o Event ID: 201701
o Pollutant: Oil
o Local Control: Bozeman Municipal Code (report available upon request)
o Resolved: Yes, owner cleaned up oil.
o Significant: No, less than 5-gallons, no confirmed discharge to the storm sewer
Tier 1 Event: Crystal Bar - Illicit roof drain
o Event ID: 201702
o Pollutant: Wash water
o Local Control: Bozeman Municipal Code (report available upon request)
o Resolved: Yes, owner disconnected sink from the roof drain
o Significant: Yes, over 5-gallons, confirmed discharge to the storm sewer
Tier 2 Event: Lindley Park - Homeless camp clean up
o Event ID: 201703
o Pollutant: Trash, human waste, and drug paraphernalia
o Local Control: Bozeman Municipal Code (report available upon request)
o Resolved: Yes, restoration firm cleaned up debris
o Significant: No, less than 5-gallons, no confirmed discharge to the storm sewer
Tier 1 Event: NAC Construction Site Fueling Spill
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 6
o Event ID: 201704
o Pollutant: Diesel Fuel
o Local Control: MSU Safety and Risk Management
o Resolved: Yes, MSU Facility Services clean up
o Significant: Yes, over 5-gallons
Tier 1 Event: Stadium Tractor Hydraulic Oil Spill
o Event ID: 201705
o Pollutant: Hydraulic Oil (<25 gallons)
o Local Control: MSU Safety and Risk Management
o Resolved: Yes, MSU Facility Services clean up
o Significant: Yes, over 5-gallons, no confirmed discharge to the storm sewer
2018 Events: 7
Tier 1 Event: 15th & Patrick Oil Dumping
o Event ID: 201801
o Location: See map 4.2.1
o Pollutant: Used motor oil
o Local Control: BMC Section 40.04.200 and system cleaning
o Significant: No, less than 5-gallons, confirmed discharge to the storm sewer
Tier 1 Event: Solid Waste Hydraulic Hose
o Event ID: 201802
o Location: See map 4.2.1
o Pollutant: Hydraulic fluid
o Local Control: Solid Waste and Streets spill response
o Significant: No, over 5-gallons, no confirmed discharge to the storm sewer
Tier 1 Event: Prue Clean Technologies Carpet Cleaners
o Event ID: 201803
o Location: See map 4.2.1
o Pollutant: Soaps and cleaning chemicals
o Local Control: BMC Section 40.04.200
o Significant: Yes, over 5-gallons, confirmed discharge to the storm sewer
Tier 1 Event: Northwestern Energy Frac-Out
o Event ID: 201804
o Location: See map 4.2.1
o Pollutant: Bentonite slurry
o Local Control: BMC Section 40.04.200
o Significant: No, over 5-gallons, no confirmed discharge to the storm sewer
Tier 2 Event: Sanitary Sewer Overflow
o Event ID: 201805
o Location: See map 4.2.1
o Pollutant: Sediment and pathogens
o Local Control: Sewer Department sanitary sewer overflow response and system
cleanout
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 7
o Significant: Yes, over 5-gallons, confirmed discharge to the storm sewer
Tier 1 Event: John Deer Contractor Hydraulic Hose Failure
o Event ID: 201806
o Location: See map 4.2.1
o Pollutant: Hydraulic Fluid
o Local Control: MSU Safety and Risk Spill Response (sorbent material, 55-gallon drum,
disposal)
o Significant: No, under 5-gallons, no confirmed discharge to the storm sewer
Tier 1 Event: Barnard Holder Snow Machine Hydraulic Hose Failure
o Event ID: 201807
o Location: See map 4.2.1
o Pollutant: Hydraulic Fluid
o Local Control: MSU Safety and Risk Spill Response (sorbent material, 5-gallon buckets,
disposal)
o Significant: No, under 5-gallons, no confirmed discharge to the storm sewer
2019 Events: 4
Tier 2 Event: Sobo Lofts Fire
o Event ID: 201901
o Location: See map 4.2.1
o Pollutant: Ash, construction debris/chemicals, traction sand, and chlorinated water
o Local Control: Emergency fire operation and system cleaning
o Significant: Yes, 1.5 million gallons of water sprayed on the fire. The majority did not
discharge to Mandeville Creek due to a degraded historical irrigation conveyance that
ponded the flows until infiltration occurred.
Tier 1 Event: Durston Oil Spill
o Event ID: 201902
o Location: See map 4.2.1
o Pollutant: Motor oil
o Local Control: BMC Section 40.04.200
o Significant: No, immediate response and mitigation by MS4 Staff.
Tier 2 Event: Bogert Pool Filter Backflush
o Event ID: 201903
o Location: See map 4.2.1
o Pollutant: Chlorinated water, Celatom Diatomite Filter Media, and filter debris
o Local Control: BMC Section 40.04.200
o Significant: No, immediate response and implementation of operational controls,
plugged connection soon after eliminating the chance of future discharges.
Tier 1 Event: Karst Stage Oil Spill
o Event ID: 201904
o Location: See map 4.2.1
o Pollutant: Motor oil
o Local Control: BMC Section 40.04.200
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 8
o Significant: No, immediate response and mitigation by Karst stage staff.
2020 Events: 3
Tier 1 Event: Bogert Pavilion
o Event ID: 202001
o Location: See map 4.2.1
o Pollutant: Chlorinated wash-water
o Significant: No, implementation of operational controls and plugged the connection
eliminating the chance of future discharges.
Tier 1 Event: Vehicle Oil Leak
o Event ID: 202002
o Location: See map 4.2.1
o Pollutant: Diesel Fuel
o Significant: No, vehicle towed and spill cleaned.
Tier 1 Event: Willson Ave. Paint Spill
o Event ID: 202003
o Location: See map 4.2.1
o Pollutant: Paint
o Significant: No, immediate response by the Bozeman Fire Department and Streets
Division.
Table 4.5.1: Illicit Discharge Events
Event Tier 2017 2018 2019 2020 2021
Tier 1 4 6 2 3 -
Tier 2 1 1 2 0 -
Tier 3 0 0 0 0 -
Total: 5 7 4 3 -
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 9
4.6 Non-Stormwater Discharge Evaluation
The MS4 evaluates the following non-stormwater discharges to identify if they pose a waterway threat:
1. Water Line Flushing
Description: Chlorinated water resulting from Bac-T testing and cleaning of new water lines
Associated Pollutant(s): Chlorine
Local Control(s): Construction specifications requiring contractors to contain flush water
Risk: Medium, managed as Tier 2 illicit discharge
Illicit Discharges Reported: 0
Graphic 4.5.2: Event Locations
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 10
2. Landscape Irrigation, Irrigation, Lawn Watering, and Potable Water
Description: Intermittent over-watering or faulty sprinklers
Associated Pollutant(s): Varied depending on the source (well or potable supply)
Local Control(s): Water Conservation landscaping audits and outreach initiatives
Risk: Low, not managed as an illicit discharge
Illicit Discharges Reported: 0
3. Rising Groundwater, Springs, and Flows from Riparian Habitats
Description: Flows that enters the storm sewer system when ground and surface water levels
rise above the bottom elevation of the storm drain
Associated Pollutant(s): None
Local Control(s): Prohibition of sump drains that discharge to a street or other public right-of-
way, a sanitary sewer line, or onto neighboring properties
Risk: Low, not managed as an illicit discharge
Illicit Discharges Reported: 0
4. Uncontaminated Groundwater Infiltration
Description: Water other than wastewater that enters a storm sewer system from the ground
through such means as defective pipes, pipe joints, connections, or utility holes
Associated Pollutant(s): None
Local Control(s): Inspection of storm sewer pipe annually, and defective pipe repair
Risk: Low, not managed as an illicit discharge
Illicit Discharges Reported: 0
5. Uncontaminated Pumped Groundwater
Description: Groundwater pumped into the storm sewer system for lowering subsurface
levels, particularly for construction
Associated Pollutant(s): None
Local Control(s): Discharge must originate from a well located in an undisturbed area, initial
turbid first flush contained on site
Risk: Low, not managed as an illicit discharge
Illicit Discharges Reported: 0
6. Foundation Drains, Crawl Space Pumps, and Footing Drains
Description: Groundwater pumped or diverted from building foundations to the MS4.
Associated Pollutant(s): None
Local Control(s): Prohibition of sump drains that discharge to a street or other public right-of-
way, a sanitary sewer line, or onto neighboring properties
Risk: Low, not managed as an illicit discharge
Illicit Discharges Reported: 0
7. Air Conditioning Condensation
Description: HVAC and refrigeration condensation discharged to the MS4
Associated Pollutant(s): None
Local Control(s): Allowed
Risk: Low, not managed as an illicit discharge
Illicit Discharges Reported: 0
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 11
8. Swimming Pool and Hot Tub Drain Water
Description: Dumping of swimming pool and hot tub drain water into the MS4
Associated Pollutant(s): Chlorine
Local Control(s): Infiltration or discharge to sanitary sewer
Risk: Medium, managed as Tier 2 illicit discharge
Illicit Discharges Reported: 0
9. Fire Hydrant Flushing
Description: Discharges resulting from regular fire hydrant flushing by MS4 operators
Associated Pollutant(s): Chlorine
Local Control(s): Water and Sewer Division fire hydrant flushing process
Risk: Low, not managed as an illicit discharge
Illicit Discharges Reported: 0
10. Non-Commercial, Individual Residential, and Charity Carwashes
Description: Wash-waters resulting from vehicle washing
Associated Pollutant(s): Soaps, oils, greases, metals, and sediment
Local Control(s): The City requires a public assembly permit for non-commercial and charity
car washes on public property. If deemed appropriate, the MS4 can utilize this process to
require specific controls.
Risk: Low, not managed as an illicit discharge
Illicit Discharges Reported: 0
11. Street Wash Waters
Description: Water used to wash sidewalks, streets, parking lots, and buildings
Associated Pollutant(s): Sediment, oils, greases, and metals
Local Control(s): Allowed
Risk: Low, not managed as an illicit discharge
Illicit Discharges Reported: 0
4.7 Outfall Reconnaissance Inventory (ORI)
The MS4 has hundreds of storm sewer outfalls that discharge into numerous waterways and irrigation
ditches within its boundary. Staff uses the Draft 2016 Integrated Report available at the MDEQ’s Clean
Water Act Information Center, TMDL, and City GIS databases (250’ buffer with “outfall” terminus type) to
compile the following information:
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 12
Table 4.7.1: Receiving Waterways
# Waterway
Name
2018
Outfalls
2019
Outfalls
2020
Outfalls
2021
Outfalls TMDL Impairments
MS4
Waste
Load
Allocation
1 Baxter Creek 14 18 17 - No None None
2 Bozeman
Creek 60 63 20 - Yes
E. Coli, Nitrogen,
Sediment, Chlorophyll-
a, alteration in
streamside cover
Sediment:
81
tons/year
3 Bridger Creek 1 1 0 - Yes
Chlorophyll-a and
Nitrate/Nitrite (Nitrite
+ Nitrate as N)
None
4 Catron Creek 82 83 72 - No None None
5 Cattail Creek 42 44 43 - No None None
6 East Gallatin
River 13 22 10 - Yes Total Nitrogen, Total
Phosphorous None
7 Farmers Canal 46 51 40 - No None None
8 Figgins Creek 23 22 22 - No None None
9 Flat Creek 11 11 5 - No None None
10 Mandeville
Creek 48 53 50 - Yes Total Nitrogen, Total
Phosphorous None
11 Matthew Bird
Creek 29 31 19 - No None None
12 Maynard-
Border Ditch 16 13 14 - No None None
13 Middle Creek
Ditch 26 25 35 - No None None
14 Mill Ditch 0 0 0 - No None None
15 Nash Spring
Creek 0 1 2 - No None None
16 Rocky Creek 1 3 0 - Yes
Alteration in
Streamside Cover,
Anthropogenic
Substrate Alterations,
Physical Substrate
Alterations, Sediment
None
17 Story Ditch 10 10 12 - No None None
18 W. Gallatin
Canal 31 30 32 - No None None
19 Unnamed 167 153 70 - No None None
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 13
Graphic 4.7.2: Stormwater outfall map
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 14
The MS4 prioritizes and inspect outfalls once during each MS4 Permit term using the Center for Watershed
Protection protocol, including:
Outfall Inventory: Field and GIS analysis to update existing and add new outfalls to the MS4’s
databases. Coordination occurs between the Stormwater and Strategic Services Divisions.
Field Preparation: Staff utilizes waders, high visibility vest, measuring tape, multi-parameter
sensor (temp and pH), ammonia test strips, turbidimeter, sample bottles, field forms, clipboard,
camera, flashlight, legal pad, marker, pen, outfall maps, and nitrile gloves.
Develop Inspection Plan: The MS4 has five maintenance districts that contain approximately 20%
of the MS4’s outfalls. Staff inspects one maintenance district per year, or all within a five-year
permit cycle. Planning includes using GIS software to identify clusters of outfalls, property
ownership, safety concerns, and accessibility to plan inspection routes.
ORI Inspection: The MS4 visits individual outfalls and completes the following workflow:
Graphic 4.7.3: ORI Inspection Plan
If applicable, implement Corrective Action Plan: The MS4 initiates a response as defined in SWMP
Section 4.3 for any outfall classified as potential, suspect, or obvious pollution source.
The MS4 inspects outfalls deemed a high-priority annually. The MS4 considers an outfall to be high-
priority if it meets the following criteria:
18” or more in diameter.
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 15
Drains an urban watershed area of 25 acres or more.
Dumps stormwater directly into an impaired receiving water (i.e., no stormwater basin).
Obvious or suspect outfalls classified through previous years’ ORI.
High-priority outfalls include:
Outfall ID: OF.G08.00035
Discharge Location: Overbrook Dr. and Langhor Ave.
Receiving Waterway: Figgins Creek
Size and Material: 30” RCP
Table 4.7.4: OF.G08.00035
Inspection Year Date Flow Characterization
2019 February 1, 2019 Yes, Trickle Unlikely, No Indicators
2020 October 7, 2020 Yes, Trickle Unlikely, No Indicators
2021 - - -
Outfall ID: OF.F06.00090
Discharge Location: S. Bozeman Ave. and E. Cleveland St.
Receiving Waterway: Matthew Bird Creek
Size and Material: 20” Steel
Table 4.7.5: OF.F06.00090
Inspection Year Date Flow Characterization
2019 July 19, 2019 No Unlikely, No Indicators
2020 July 7, 2020 No Unlikely, No Indicators
2021 - - -
Outfall ID: OF.F06.00089
Discharge Location: S. Black Ave. and W. Cleveland St.
Receiving Waterway: Matthew Bird Creek
Size and Material: 19” RCP
Table 4.7.6: OF.F06.00089
Inspection Year Date Flow Characterization
2019 July 19, 2019 No Unlikely, No Indicators
2020 July 7, 2020 No Unlikely, No Indicators
2021 - - -
Outfall ID: OF.H05.00370
Discharge Location: N. 11th Ave. and W. College St.
Receiving Waterway: Mandeville Creek
Size and Material: 18” RCP
Table 4.7.7: OF.H05.00370
Inspection Year Date Flow Characterization
2019 July 19, 2019 Yes, Moderate Unlikely, No Indicators
2020 July 7, 2020 No Unlikely, No Indicators
2021 - - -
Outfall ID: OF.H05.00384
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 16
Discharge Location: N. 11th Ave. and W. Koch St.
Receiving Waterway: Mandeville Creek
Size and Material: 12” RCP
Table 4.7.8: OF.H05.00384
Inspection Year Date Flow Characterization
2019 January 31, 2019 No Unlikely, No Indicators
2020 July 8, 2020 No Unlikely, No Indicators
2021 - - -
Outfall ID: OF.F04.00441
Discharge Location: N. Rouse Ave. and E. Villard St.
Receiving Waterway: Bozeman Creek
Size and Material: 42” RCP (42” CMP replaced during Rouse Reconstruction in 2020)
Table 4.7.9: OF.F04.00441
Inspection Year Date Flow Characterization
2019 August 8, 2019 No Unlikely, No Indicators
2020 July 7, 2020 No Unlikely, No Indicators
2021 - - -
Outfall ID: OF.G04.00398
Discharge Location: N. 9th Ave. and W. Villard St.
Receiving Waterway: Tributary SWWW_00053
Size and Material: 24” RCP
Table 4.7.10: OF.G04.00398
Inspection Year Date Flow Characterization
2019 January 19, 2019 No Unlikely, No Indicators
2020 July 8, 2020 No Unlikely, One Indicator
2021 - - -
Outfall ID: OF.F03.00446
Discharge Location: N. Rouse Ave. and E. Peach St.
Receiving Waterway: Bozeman Creek
Size and Material: 43” RCP (Pipe upgraded from 27” RCP during Rouse Reconstruction)
Table 4.7.11: OF.F03.00446
Inspection Year Date Flow Characterization
2019 January 31, 2019 No Unlikely, No Indicators
2020 July 7, 2020 No Unlikely, No Indicators
2021 - - -
Outfall ID: OF.G03.00399
Discharge Location: N. 4th Ave. and W. Peach St.
Receiving Waterway: Tributary SWWW_00034
Size and Material: 30” RCP
Note: Outfall removed in 2020 because of BMX Bike Park project. New outfall location is the
jurisdictional boundary of SWWW_00034 (Manley Ditch) and the Cherry Creek Fishing Access.
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 17
Table 4.7.12: OF.G03.00399
Inspection Year Date Flow Characterization
2019 January 31, 2019 No Potential, Two+ Indicators
2020 - - -
2021 - - -
Outfall ID: OF.E03.00450
Discharge Location: N. Rouse Ave. and E. Tamarack St.
Receiving Waterway: Bozeman Creek
Size and Material: 36” RCP
Table 4.7.13: OF.G03.00450
Inspection Year Date Flow Characterization
2019 January 31, 2019 No Unlikely, No Indicators
2020 July 7, 2020 No Unlikely, One Indicator
2021 - - -
Outfall ID: OF.E03.00454
Discharge Location: N. Rouse Ave. and E. Tamarack St.
Receiving Waterway: Bozeman Creek
Size and Material: 30” RCP
Table 4.7.14: OF.E03.00454
Inspection Year Date Flow Characterization
2019 January 31, 2019 No Unlikely, No Indicators
2020 July 7, 2020 No Unlikely, No Indicators
2021 - - -
The MS4 completed the following outfall inspections:
Table 4.7.15: Outfall Inspection Totals
ORI
Year Outfalls Outfalls Inspected High-Priority
Outfalls
High-Priority Outfalls
Inspected
2019 634
108
Flow: 99 No, 1 Trickle, 6 Moderate, 2
Unknown
Pollution Charecterization: 104 Unlikely,
1 Potential, 1 Suspect, 2 Unknown
11
11
Flow: 9 No, 1 Trickle, 1
Moderate
Pollution Charecterization: 10
Unlikley, 1 Potential
2020 463
113
Flow: 104 No, 6 Trickle, 3 Moderate
Pollution Charecterization: 113 Unlikely
10
10
Flow: 8 No, 2 Trickle
Pollution Charecterization: 10
Unlikley
2021 - - - -
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 18
Graphic 4.7.16: High-Priority Stormwater Outfalls Map
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 19
4.8 Storm Sewer Infrastructure Totals
The MS4 collects and updates storm sewer data annually from the City’s GIS. The public can view the
MS4’s storm sewer system at: https://gisweb.bozeman.net/Html5Viewer/?viewer=infrastructure.
Table 4.8.1: Manholes
Owner 2017 2018 2019 2020 2021
City of Bozeman - 999 1,162 1,146 -
Montana State University - 155 155 155 -
Montana Department of Transportation - 68 67 76 -
Private or Null - 352 398 440 -
Total: 1,484 1,574 1,782 1,817 -
Table 4.8.2: Inlets
Owner 2017 2018 2019 2020 2021
City of Bozeman - 2,524 2,800 2,779 -
Montana State University - 207 207 204 -
Montana Department of Transportation - 187 187 187 -
Private or Null - 661 734 840 -
Total: 3,457 3,579 3,928 4,010 -
Table 4.8.3: Storm Sewer
Owner 2017 2018 2019 2020 2021
City of Bozeman - 67 Miles 73 Miles 74 Miles -
Montana State University - 8 Miles 8 Miles 8 Miles -
Montana Department of Transportation - 4 Miles 4 Miles 4 Miles -
Private, Other, and Null - 30 Miles 31 Miles 31 Miles -
Total: 89 Miles 109 Miles 116 Miles 117 Miles -
Table 4.8.4: Stormwater Facilities
Owner 2017 2018 2019 2020 2021
Total: 435 497 591 769 -
Table 4.8.5: Outfalls
Owner 2017 2018 2019 2020 2021
Total: 594 622 634 463 -
Table 4.8.6: Public Stormwater Treatment Units
Owner 2017 2018 2019 2020 2021
City of Bozeman - 9 12 17 -
Montana State University - 1 2 2 -
Montana Department of Transportation - 2 2 8 -
Total: 7 12 16 27 -
SECTION 4.0 – ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM 20
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Section 5.0
Construction Site Management Program
Graphic 5.0.2: Inlet sump clogged with construction debris Graphic 5.0.1: Compliant single-family residential property
SECTION 5.0 - CONSTRUCTION SITE MANAGEMENT PROGRAM 2
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SECTION 5.0 - CONSTRUCTION SITE MANAGEMENT PROGRAM 3
5.1 Introduction
The MS4 strives to improve waterway health, protect public safety, and comply with its MS4 Permit
through the regulation of construction sites by:
Providing educational opportunities;
Administering a permitting program;
Conducting site inspections; and
Enforcing municipal and state regulations.
SWMP Section 5.0 details the following components necessary to administer the MS4’s Construction Site
Management Program, including:
Regulatory Framework (5.2)
Construction Site Permitting Program (5.3)
Construction Site Enforcement Response Plan (5.4)
Construction Site Inventory (5.5)
Performance Tracking (5.6)
Future Opportunities (5.7)
Program Documents (5.8)
5.2 Regulatory Framework
Pursuant to §40.04.350 Bozeman Municipal Code (BMC), the MS4 requires owners/operators of
construction sites to comply with the following regulations:
Article 4 Chapter 40 Bozeman Municipal Code (BMC);
75-5-101 Montana Code Annotated (MCA); and
17.30.1101, 17.30.1301 et seq., and 17.30.601 et seq Administratve Rules of Montana (ARM).
5.3 Construction Site Permitting Program
Pursuant to §40.04.350 BMC, the MS4 requires owners/operators of construction sites to submit
Stormwater Pollution Prevention Plans (SWPPPs) before receiving a Building Permit or Infrastructure
Project Notice to Proceed. Three permit application types exist, including:
MDEQ General Permit for Stormwater Discharges Associated with Construction Activity
(Construction General Permit): The MS4 requires owners/operators to submit for construction
sites that meet the Eligibility Requirments of the most current Construction General Permit. The
MS4 completes one permit review for compliance with the most current Construction General
Permit’s Technology-Based Effluent Limitations and Stormwater Pollution Prevention Plan
(SWPPP) requirements. The MS4 provides the owner/operator a Permit Review Checklist and
Confirmation Letter. The MS4 does not confirm the owner/operator has corrected deficiencies
through consecutive reviews. Instead, the MS4 reviews changes onsite during Stormwater
Compliance Evaluation Inspections (CEI).
Construction Stormwater Permit: Sites Less than One (1) Acre: The MS4 requires
owners/operators to submit for construction sites with land disturbance less than one acre and
greater than 10,000 square feet. The MS4 completes numerous content and adequacy reviews of
the owner/operator’s submitted application and map, and provides a Construction Stormwater
Permit once deemed compliant with BMC.
Construction Stormwater Permit: Single-Family Residential Projects: The MS4 requires for
individual single-family and duplex home construction sites. The MS4 completes numerous
SECTION 5.0 - CONSTRUCTION SITE MANAGEMENT PROGRAM 4
content and adequacy reviews of the owner/operator’s submitted application and provides a
Construction Stormwater Permit once deemed compliant with BMC.
5.4 Enforcement Response Plan
The MS4 implements the following Construction Site Enforcement Response Plan (ERP) to ensure
compliant construction sites within its jurisdiction:
Image 5.4.1: ERP workflow
Inspection Type: Pursuant to §40.04.850.D BMC, the MS4 has the authority to complete CEIs at
construction sites to ensure compliance with BMC and the Construction General
Permit. Inspections may include: (1) Document review, including the site's NOI, SWPPP, BMP
specifications, site maps, self-inspection records, and administrator certification, and (2) Site tour
identifying pollutant sources, inspection of implemented BMPs, and compliance determinations
with the BMC and Construction General Permit. Inspection types include:
Unannounced: CEI resulting from a complaint or field observation. See SWMP Section 5.4.2.
Announced: CEI resulting from reoccurring inspection efforts, which the MS4 prioritizes based
on site prioritization and complaints. See SWMP Section 5.4.2.
Compliance Determination: Pursuant to §40.04.860 BMC, the MS4 has the authority to make BMC
and Construction General Permit non-compliance determinations, including:
SECTION 5.0 - CONSTRUCTION SITE MANAGEMENT PROGRAM 5
Permit and/or Site is Complaint: No permit nor site non-compliance determinations issued.
Inspection closed.
Permit and/or Site is Not Complaint: Permit and/or site non-compliance determinations
issued. See SWMP Section 5.4.3.
Enforcement Response: The MS4’s enforcement response options, including:
Verbal Warning: An informal response used when the MS4 determines the BMC and
Construction General Permit non-compliance determinations are low-risk, and there are
reasonable grounds that the owner/operator will correct the issues. Verbal warnings take the
form of phone calls, emails, or in-person meetings. Inspection closed.
Site Inspection Form: An informal response by the MS4 to document BMC and Construction
General Permit non-compliance determinations. The MS4 emails or delivers the Site
Inspection Form to the site owner/operator. See SWMP Section 5.4.4.
Enforcement Action: Pursuant to §40.04.860 and §40.04.890 BMC, the MS4 has the authority to
require the owner/operator to comply with BMC and/or the Construction General Permit using
the following actions:
Follow-Up CEI: An informal action completed to ensure the site owner/operator corrects the
non-compliance determinations issued in the Site Inspection Form. A Follow-Up CEI can take
the form of a site visit, a conversation, or a review of submitted information. If so, inspection
closed. If not, See SWMP Section 5.4.4 – Notice of Violations.
Notice of Violations (NOV): A formal enforcement action taken when the site owner/operator
does not resolve the non-compliance determinations. An NOV includes written violations of
the BMC and the Construction General Permit, a Cease and Desist Order, and Stop Work
Order. Both Orders apply to the site activities resulting in the issued violations and associated
non-compliance determinations. NOVs require the site owner/operator to submit a written
response within a set timeframe, documenting that they have resolved the violations and
associated non-compliance determinations. Upon the MS4’s review and approval of the
written response, the inspection is closed. If existing non-compliance determinations remain
or additional areas of non-complaince are identified, see SWMP Section 5.4.4 - Enforcement.
In severe cases, the MS4 bypasses the Follow-Up CEI and immediately issues an NOV.
Enforcement: A variety of formal enforcement penalties used by the MS4 when the site
owner/operator does not comply with the NOV’s requirements, including:
o Building Permit Stop Work Order: Pursuant to §10.02.010.D, BMC, a Building Official
may issue an order requiring any site owner/operator to immediately stop all work of
any kind related to site’s Building Permit. Any person who continues work after having
been served with a Stop Work Order, except such work as that person is directed by
the City to perform to remove a violation or unsafe condition, shall be subject to the
misdemeanor penalty provision of §10.02.100 BMC. The issuance of a Stop Work
Order cancels any pending inspections.
o Withholding Issuance of a Certificate of Occupancy: Pursuant to §10.02.010.C, BMC,
a Building Official of the City may withhold the issuance of a certificate of occupancy
when the available evidence shows the structure and associated development does
not conform with the standards of Chapter 40 BMC, a permit issued pursuant to
Chapter 40 BMC, or has failed to pay costs of the abatement of stormwater violations
as may be ordered by the City.
o Misdemeanor Criminal Charge and Prosecution (Judicial): Pursuant to §40.04.910
BMC, any person, firm or corporation, their agents or servants who violate any
SECTION 5.0 - CONSTRUCTION SITE MANAGEMENT PROGRAM 6
provision or requirement of Chapter 40 BMC or of a permit issued shall be guilty of a
misdemeanor and, upon conviction thereof, shall be punished by a fine not
exceeding $500.00 and in addition shall pay all costs and expenses of the case. A
separate offense shall be deemed committed upon each day during or on which a
violation occurs or continues.
Additional ERP Information:
Elimination and Abatement of Illegal Construction Discharges: The MS4 uses the ERP to
identify and resolve violations of BMC and/or the Construction General Permit.
Staff with Enforcement Authority: Stormwater Program Technician, Stormwater Program
Specialist, Stormwater Program Project Manager, Stormwater Program Coordinator have the
authority to issue non-compliance determinations. The Stormwater Coordinator is the
authorized Enforcement Agent and makes determinations regarding enforcement penalties.
Enforcement Action Available, Escalation Process, and Schedule: The MS4’s ERP is flexible and
includes escalation protocols based on a owner/operator’s response, while also providing
options for immediate action when the Enforcement Agent identifies severe violations of BMC
and/or the Construction General Permit. The MS4's ERP schedule is based on the Enforcement
Agent's determination of risk (weather, capacity, waterway proximity, site size, pollutant
source scale and severity, owner/operator compliance history, etc.). ERP implementation
ranges from immediate action to a timeframe extending a week or more. A typical Follow-Up
CEI occurs within five days. An NOV standard response timeframe is 10 days.
Abate Damages and Prevent Reoccourences: Upon the conclusion of the NOV via the Closure
Letter issuance, the MS4 maintains the authority to enact immediate enforcement action, as
detailed in SWMP Section 5.4.4 - Enforcement upon the identification of any repeat violations.
Site Prioritization and Inspection Frequency Protocol:
The MS4 uses the following Construction Site Scoring Matrix to determine a site’s priority level.
Table 5.4.2: Construction Site Scoring Matrix
Criteria 3-Points 2-Points 1-Point
Site Size (Acres) > 10-Acres 5 - 10 Acres < 5-Acre
Proximity to Waterbody < 1,000 ft > 1,000 or < 2,000 ft > 2,000 ft
Site Steepness per SWPPP Yes - No
Bozeman Creek Watershed Yes - No
Permit Review Checklist Score > 50 25 - 50 < 25
Once priority is determined, the MS4 completes inspections per the frequencies outlined below.
High-Priority Construction Sites (Over 10 Points):
o Once at construction commencment.
o After every .25” rain event. The MS4 interprets this standard to mean any rain event
that occurs within a six-hour timeframe and uses the Bozeman International Airport
NOAA Rain Gage.
o After every snow melt event resulting in visible erosion.
o Once at the conclusion of the project.
Medium-Priority Construction Sites (5 - 10 Points):
o As need basis per complaints and field observations.
Low-Priority Construction Sites (Below 5 Points):
SECTION 5.0 - CONSTRUCTION SITE MANAGEMENT PROGRAM 7
o As need basis per complaints and field observations.
o Less than One Acre Construction Sites
o Single-Family Residential Construction Sites
5.5 Construction Site Inventory
The following tables contain an inventory of construction site permits and inspection:
Table 5.5.1: Permit Type Inventory
Permit Type 2018 2019 2020 2021
City Single- Family Residential Total - 292 272 -
City Less than One Acre Total - 63 34 -
City Greater than One Acre Total 24 29 36 -
MSU Greater than One Acre Total 2 1 1 -
Table 5.5.2: Inpsection Type Inventory * Totals represent new permits/year and do not include return visits or final occupancy inspections. High-priority inspections count as one inspection.
Inspection Type 2018 2019 2020 2021
City Single-Family Residential Total 32 19 1 -
City Single-Family Residential Percentage (%) 17% 7% .4% -
City Less than One Acre Total 17 16 5 -
City Less than One Acre Percentage (%) 32% 25% 14% -
City Greater than One Acre Total 10 6 15 -
City Greater than One Acre Percentage (%) 42% 21% 42% -
MSU Greater than One Acre Total 2 3 2 -
MSU Greater than One Acre Percentage (%) 100% >100% >100% -
High-Priority Construction Sites:
OAC18-0014 South Tracy Reconstruction: Four acre site within the Bozeman Creek watershed.
The site includes the reconstruction of an existing road and underlying utilities.
Permit Confirmation: May 29, 2018
Initial Inspection: June 1, 2018
Precipitation Triggered Inspections:
o Inspection 1: June 19, 2018
o Inspection 2: June 22, 2018
o Inspection 3: July 2, 2018
o Inspection 4: August 28, 2018
Final Inspection: n/a
OAC18-0020 East Tamarack Reconstruction: Three acre site within the Bozeman Creek watershed.
The site includes the reconstruction of an existing road and underlying utilities.
Permit Confirmation: August 7, 2018
Initial Inspection: n/a
Precipitation Triggered Inspections:
o Inspection 1: August 28, 2018
o Inspection 2: September 17, 2018
o Inspection 3: October 5, 2018
SECTION 5.0 - CONSTRUCTION SITE MANAGEMENT PROGRAM 8
Final Inspection: n/a
OAC19-0001 16 Willson Residential Development: One acre site within the Bozeman Creek
watershed. The site includes the demolition of exisitng structures and construction of numerous
row houses.
Permit Confirmation: January 8, 2019
Initial Inspection: n/a
Precipitation Triggered Inspections:
o Inspection 1: May 28, 2019
o Inspection 2: June 10, 2019
o Inspection 3: June 21, 2019
o Inspection 4: July 9, 2019
o Inspection 5: July 16, 2019
o Inspection 6: September 9, 2019
o Inspection 7: September 23, 2019
o Inspection 8: June 8, 2020
o Inspection 9: June 16-17, 2020
o Inspection 10: July 23, 2020
o Inspection 11: September 7, 2020
Final Inspection: TBD
OAC19-0026 Bozeman Public Safety Center: Eight acre site within the Bozeman Creek watershed.
The site includes the demolition of existing structures and construction of commercial building.
Permit Confirmation: August 27, 2019
Initial Inspection: n/a
Precipitation Triggered Inspections:
o Inspection 1: August 27, 2019
o Inspection 2: September 23, 2019
o Inspection 3: January 8, 2020
o Inspection 4: June 8, 2020
o Inspection 5: June 16-17, 2020
o Inspection 6: July 23, 2020
o Inspection 7: September 7, 2020
Final Inspection: TBD
OAC20-0017 Front Street Interceptor Project: Three acre site within the Bozeman Creek
watershed. The site includes the installation of a trunk sewer line.
Permit Confirmation: August 12, 2020
Initial Inspection: August 18, 2020
Precipitation Triggered Inspections:
o Inspection 1: September 7, 2020
Final Inspection: TBD
OAC20-0043 Allision Subdivision: Fory-eight acre site within the Bozeman Creek watershed. The
site includes the installation of a subdivision, including utilities, roads, and structures.
Points: 12
SECTION 5.0 - CONSTRUCTION SITE MANAGEMENT PROGRAM 9
Permit Confirmation: December 17, 2020
Initial Inspection: January 12, 2021
Precipitation Triggered Inspections:
o Inspection 1: TBD
Final Inspection: TBD
5.6 Performance Tracking
The MS4 completes a Construction Site Compliance Audit in the fall, evaluating 50 random construction
sites to determine their compliance with the BMC and Construction General Permit. The MS4 evaluates
each construction site using the following criteria:
Implementation: BMPs present or absent.
Adequacy: Appropriate type and scale of BMPs for site conditions.
Installation: Adequate BMP installation per industry standard specifications.
Maintenance: Sufficient maintenance so that BMPs are in good working order.
After evaluation, the MS4 grades each construction site using one of the following categories:
0-Points: Not compliant with permit, high risk to infrastructure, public, and environment
1-Point: Partially compliant with permit, moderate risk to infrastructure, public, and environment
2-Points: Compliant with permit, low risk to infrastructure, public, and environment
The MS4 compiles the collected data and updates the following:
Table 5.6.1: Construction Site Compliance Audit Scores
Audit
Year Audit Dates Compliance
Trend
Total
Points
Earned
Score
OAC
Average
UAC
Average
SFR
Average
2018 October 24 - 26 n/a 33/100 33% 33% 37% 31%
2019 October 14 - 16 Decreasing 28/100 28% 28% 29% 28%
2020 November 6 - 13 Increasing 34/100 34% 67% 21% 27%
2021 - - - - - - -
2018 Discussion:
Increased BMP use but many not adequately maintained.
Noncompliance was mostly contained within private sites.
Increased inspection frequency is effective at increasing compliance rates.
2019 Discussion:
Compliance degrades back to pre-inspection levels after inspections.
Permit applicant does not always communicate the requirements to onsite workers.
64% of commercial and infrastructure sites yielded a score with moderate or low risk.
44% of residential sites yielded a score with moderate or low risk.
Only three sites fully complied with regulations.
Increase inspection frequency to ensure compliance throughout project life.
Inspect sites proportional to ratios (i.e. residential/commercial/infrastructure).
Apply more emphasis on installation, maintenance, and records during inspections.
2020 Discussion:
Multiple SWPPP reviews for a respective project do not result in elevated onsite compliance.
Inspection time and constant presence equates to improved compliance onsite.
SECTION 5.0 - CONSTRUCTION SITE MANAGEMENT PROGRAM 10
The City’s consulting engineer should create SWPPPs for public projects, not the contractor.
More emphasis required on installation, maintenance, and records during inspections.
5.7 Future Opportunities
Inspection Optimization Software: Develop a web-based inspection platform that will expedite
documentation and communication with construction site owner/operators.
5.8 Program Documents
Single-Family Residential Sites:
Construction Stormwater Permit: Single-Family Residential Projects
SFR Permit Review Checklist
Construction Stormwater Permit Confirmation
SFR and UAC Site Inspection Form
Less than One Acre Sites:
Construction Stormwater Permit: Sites Less than One Acre
UAC Permit Review Checklist
Construction Stormwater Permit Confirmation
SFR and UAC Site Inspection Form
Greater than One Acre Sites:
MDEQ Construction General Permit
MDEQ Construction General Permit Notice of Intent (NOI)
Graphic 5.6.2: Construction Compliance Audit Scores
SECTION 5.0 - CONSTRUCTION SITE MANAGEMENT PROGRAM 11
MDEQ Construction Stormwater Pollution Prevention Plan (SWPPP)
MDEQ Construction Stormwater Permit Notice of Termination
MDEQ Construction Stormwater Permit Transfer Notification
OAC Permit Review Checklist
OAC Site Inspection Form
SECTION 5.0 - CONSTRUCTION SITE MANAGEMENT PROGRAM 12
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Section 6.0
Post-Construction Program
Graphic 6.0.2: Dredged stormwater basinGraphic 6.0.1: Overgrown stormwater basin
SECTION 6.0 - POST-CONSTRUCTION PROGRAM 2
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SECTION 6.0 - POST-CONSTRUCTION PROGRAM 3
6.1 Introduction
The MS4 strives to improve waterway health, protect public safety, and comply with its MS4 Permit
through the regulation and oversight of existing and new structural BMPs in the following ways:
Enforcing water quality and flood control standards on new and redevelopment projects; and
Completing inspections of structural BMPs.
SWMP Section 6.0 details the components necessary to administer the MS4’s Post-Construction
Management Program, including:
Regulatory Framework and Applicable Documents (6.2)
Development Review (6.3)
Structural BMP Inventory (6.4)
Inspection Program (6.5)
High-Priority Structural BMPs (6.6)
Enforcement Response Plan (6.7)
Performance Tracking (6.8)
Ongoing and Future Initiatives (6.9)
6.2 Regulatory Framework and Applicable Documents
The MS4 requires developers with projects over one-acre to infiltrate, evapo-transpire, or capture for
reuse the first half-inch of rainfall to address stormwater runoff quality from new and redevelopment
from a 24-hour storm preceded by 48-hours of no measurable precipitation using structural best
management practices (BMPs). The runoff generated from the first half-inch of rainfall contains the
majority of pollutants deposited on impervious area during dry periods. Structural BMPs can mitigate the
loads by capturing the first flush, preventing pollutants from entering waterways.
Developers use surface and subsurface structural BMPs, which typically take the form of permeable
pavers, infiltration basins, and bio-retention areas. Additionally, in Bozeman, structural BMPs must also
be designed to limit runoff to the predevelopment level during a 10-year, 2-hour storm. This reduces peak
runoff and helps protect waterways and property.
The MS4 also requires developers to implement non-structural BMPs that promote waterway health,
including zoning and land planning, wetland regulations, waterway setbacks, and open space standards.
Various governing documents contain standards, policies, and regulations related to structural and non-
structural BMPs for new and redevelopment, including:
City of Bozeman Design Standards and Specification Policy - 2020
City of Bozeman Modifications to Montana Public Works Standard Specifications - 6th Edition
Montana Public Works Standard Specifications - 6th Edition
Bozeman Municipal Code
Montana Post-Construction Storm Water BMP Design Guidance Manual - 2017
City of Bozeman Stormwater Facilities Plan - 2008
6.3 Development Review
The MS4 completes development review tasks related to structural BMPs as Developers submit new and
redevelopment project proposals. Projects triggering the regulatory threshold covered in SWMP Section
SECTION 6.0 - POST-CONSTRUCTION PROGRAM 4
6.2 include commercial, multi-family, and subdivision developments. In most cases, Developers utilize
structural BMPs through an onsite management approach, which the MS4 defines as either on the
developing parcel or at the overarching subdivision scale. The onsite management approach's primary
benefits are the decentralized siting of structural BMPs, promoting green space and better integrating
structural BMPs into the landscape. The disadvantage of this approach includes increased structural BMP
totals throughout the MS4 and costly long-term maintenance.
An alternative to the onsite management approach is the use of an offsite management approach. This
approach results in structural BMPs located at the bottom of watersheds that contain numerous
subdivisions. This approach's primary benefit is that it reduces the number of structural BMPs, focusing
on a select few that the MS4 can more effectively inspect and maintain. The disadvantages of this
approach are that it requires significant planning, upfront MS4 investment, and an extensive payback
financing mechanism. The MS4 does not utilize an offsite management approach; however, is exploring
future opportunities. Graphic 6.3.1 provides a conceptual view of the varying management approaches.
The following information and Chart 6.3.2 describes the MS4’s typical structural BMP review process:
The Developer completes a seasonal high-groundwater analysis and soil study to establish a
baseline for the project’s pre-construction site conditions.
The Developer selects a structural BMP based on site conditions, completes a design, and
submits documents for review, including a drawings, drainage report, and maintenance plan.
The Engineering Division reviews the documents, ensures compliance with standards and
policies, and provides comments to the Developer via a review letter. This step can repeat until
the proposed design fully complies. The Stormwater Division offers review support, primarily
focusing on the maintenance-related aspects of the structural BMP.
SECTION 6.0 - POST-CONSTRUCTION PROGRAM 5
The Developer constructs the project and associated structural BMP after receiving approval. In
some cases, modifications may occur at this stage in response to unforeseen site conditions.
Once complete, the Engineering Division completes an inspection to verify the Developer
installed the BMP as approved. The Stormwater Division provides a secondary inspection focused
on stabilization. Results from the Stormwater Division’s inspection are stored in the Site
Inspection Form and shared with the Developer. This step can repeat numerous times until the
constructed BMP fully complies with the approved documents and Bozeman Municipal Code.
The Stormwater Division confirms that the GIS database contains the structural BMP.
The BMP goes into service and is managed by the owner indefinitely.
6.4 Structural BMP Inventory
The MS4 maintains an inventory of structural BMPs as construction occurs. The process typically includes
a combination of GIS digitization and field verification to ensure adequate data capture. The tables below
show the breakdown of structural stormwater BMPs based on four ownership categories, including:
Public: Contains structural BMPs located on public land, including the City, MSU, and MDT.
Private: Contains structural BMPs located on private property.
Open Space/Parkland: Contains structural BMPs located on HOA open space or parkland. Unknown: Contains structural BMPs without known ownership.
The MS4 also categorizes and tracks the type of structural BMPs:
Surface Detention Facility: Regulated discharge to receiving waterway via an outlet structure.
Underground Detention Facility: Regulated discharge to waterway via an outlet structure.
Surface Retention Facility: No discharge to a waterway.
Underground Retention Facility: No discharge to a waterway.
The MS4 updates the inventory annually, with variations occurring as ownership determinations arise.
SECTION 6.0 - POST-CONSTRUCTION PROGRAM 6
Table 6.4.1: Public Structural BMPs
Type 2017 2018 2019 2020 2021
Surface Detention Facility - - - 26 -
Underground Detention Facility - - - 2 -
Surface Retention Facility - - - 12 -
Underground Retention Facility - - - 1 -
Total: - - - 41 -
Table 6.4.2: Private Structural BMPs
Type 2017 2018 2019 2020 2021
Surface Detention Facility - - - 133 -
Underground Detention Facility - - - 12 -
Surface Retention Facility - - - 137 -
Underground Retention Facility - - - 40 -
Total: - - - 322 -
Table 6.4.3: Open Space/Parkland Structural BMPs Type 2017 2018 2019 2020 2021
Surface Detention Facility - - - 247 -
Underground Detention Facility - - - 32 -
Surface Retention Facility - - - 88 -
Underground Retention Facility - - - 7 -
Total: - - - 374 -
Table 6.4.4: Unknown Owner Structural BMPs Type 2017 2018 2019 2020 2021
Surface Detention Facility - - - 18 -
Underground Detention Facility - - - - -
Surface Retention Facility - - - 14 -
Underground Retention Facility - - - - -
Total: - - - 32 -
Table 6.4.5: Summary
Land Classification 2017 2018 2019 2020 2021
Public - - - 41 -
Private - - - 322 -
Open Space/Parkland - - - 374 -
Unknown - - - 32 -
Total: 439 497 589 769 -
The MS4 also completes an analysis annually to identify high-priority structural BMPs. To complete the
analysis, the MS4 completes a risk assessment in GIS using the following criteria:
Size: Structural BMPs larger than 1,076 square feet. Analyzed using geometry data in GIS.
Proximity: Within 500 feet of an impaired waterbody. Analyzed using a 500’ buffer in GIS.
Type: Surface detention or underground detention facility. Analyzed using GIS data.
The MS4 deems structural BMPs that meet all criteria as high-priority and manages them per the criteria
detailed in SWMP Section 6.5. Table 6.4.6 includes analysis totals, and Table 6.6.1 includes specific
structural BMP information.
SECTION 6.0 - POST-CONSTRUCTION PROGRAM 7
Table 6.4.6: High-Priority Structural BMP Ownership
Land Classification 2017 2018 2019 2020 2021
Public - - 12 13 -
Private - - 3 3 -
Open Space/Parkland - - 3 3 -
Unknown - - 1 1 -
Total: - - 19 20 -
6.5 Inspection Program
The MS4 completes inspections of typical and high-priority structural BMPs using qualitative and
quantitative data collection practices. Inspection frequencies for the two types include:
Typical: Complaint based, field observation, or as needed. No reoccurring return interval
established at this time.
High-Priority: Annual inspection per the requirements detailed in the MS4 Permit.
The MS4 receives permission from the underlying property owner to access the structural BMP. Once
granted, a typical inspection involves the review of the physical characteristics, flow path, maintenance
needs, and geometry of the structural BMP. The MS4 documents all notes and findings in a standard
inspection form. Post-inspection, the MS4 assigns each structural BMP a maintenance priority level:
Low: Structural BMP appears to be functioning as designed.
Medium: Structural BMP requires minor to moderate sediment and vegetation maintenance to
mitigate the risk of flooding, waterway pollution, and infrastructure failure.
High: Structural BMP requires significant sediment dredging, vegetation removal, and/or
infrastructure repairs to restore function.
The MS4 typically sends the owner a letter, inspection form, map, and maintenance guide, and requests
they submit a plan to complete necessary maintenance and resolve the identified issues.
The MS4 has completed the following inspections of structural BMPs (including high-priority):
Table 6.5.1: Post-Construction Facility Inspections
Land
Type
2017 2018 2019 2020 2021
#
Inspected
% of
Total
#
Inspected
% of
Total
#
Inspected
% of
Total
#
Inspected
% of
Total
#
Inspected
% of
Total
Public - - - - - - 13 - -
Private - - - - - - 4 - -
OS/Parkland - - - - - - 30 - -
Unknown - - - - - - 1 - -
Total: 8 1.8% 15 3.0% 72 12% 48 6% - -
The MS4 has completed the following occupancy inspections:
Table 6.5.2: Post-Construction Certificate of Occupancy Inspections
Project Type 2017 2018 2019 2020 2021
Under 1 Acre - - - - -
Over 1 Acre - - - - -
Total: - - - - -
SECTION 6.0 - POST-CONSTRUCTION PROGRAM 8
Image 6.5.3: Post-Construction Program Map
SECTION 6.0 - POST-CONSTRUCTION PROGRAM 9
6.6 High-Priority Structural BMPs
The MS4 manages the following structural BMPs as high-priority:
Table 6.6.1: High-Priority Structural BMPs
# Facility ID Owner Area
(ft2)
Receiving
Waterbody
2019
Rating
2020
Rating
2021
Rating
1 DP.H06.00026 MSU Facility 1 3,185 Mandeville Creek Low Low -
2 DP.H06.00400 MSU Facility 2 7,591 Mandeville Creek Low Low -
3 DP.H06.00024 MSU Facility 3 11,829 Mandeville Creek Low Low -
4 DP.H06.00023 MSU Facility 4 4,667 Mandeville Creek Low Medium -
5 DP.H06.00028 MSU Facility 5 1,294 Mandeville Creek Low Low -
6 DP.H06.00025 MSU Facility 6 7,231 Mandeville Creek - Low -
7 DP.I51.00073 City WRF 1 10,744 East Gallatin River Low Low -
8 DP.I51.00075 City WRF 2 1,355 East Gallatin River Low Low -
9 DP.I51.00074 City WRF 3 10,314 East Gallatin River Low Low -
10 DP.E02.00006 City Vehicle Maintenance 5,577 East Gallatin River Medium Medium -
11 DP.H04.00006 Bozeman School District 1 7,188 Mandeville Creek Low Low -
12 TBD Bozeman School District 2 7,000 Mandeville Creek - Low -
13 DP.E01.00007 Bridger Creek HOA 22,765 East Gallatin River High - -
14 DP.G02.00017 Tange's Addition 2,245 Mandeville Creek - Medium -
15 DP.G02.00048 Best Western GranTree 3,464 Mandeville Creek - Medium -
16 DP.H02.00001 Kenyon Noble 5,450 Mandeville Creek - High -
17 DP.F01.00026 SID 674 7,354 East Gallatin River - High -
18 DP.H07.00022 South University District 1 14,775 Mandeville Creek - Low -
19 DP.H07.00023 South University District 2 26,987 Mandeville Creek - Low -
20 DP.B05.00001 West Paw 3,967 Rocky Creek - Low -
A summary of work related to each high-priority structural BMP includes:
MSU Facilities 1-6
2019: All inspected and reports submitted to the MSU Facilities Director other than MSU
Facility 6, which was under construction.
2020: All inspected and reports submitted to MSU Facilities Director other than MSU Facility
6, which was under construction.
City WRF 1-3
2019: All inspected and reports submitted to the WRF Superintendent.
2020: All inspected and reports submitted to the WRF Superintendent.
City Vehicle Maintenance
2019: Inspected and report submitted to Public Works.
2020: Inspected and report submitted to the Streets Superintendent.
Bozeman School District 1-2
SECTION 6.0 - POST-CONSTRUCTION PROGRAM 10
2019: Bozeman School District 1 inspected and report submitted to the BSD Facilities Director.
Bozeman School District 2 not mapped or identified.
2020: Bozeman School District 1 and 2 inspected and reports submitted to the BSD Facilities
Director.
Bridger Creek HOA
2019: Inspected and report submitted to the Bridger Creek Subdivision Community
Association, Inc.
2020: Not inspected due to pending legal and policy issues.
Tanges Addition
2019: Not inspected.
2020: Inspected and report compiled; however, not sent to owner due to legal/policy issues.
Best Western GranTree
2019: Not inspected.
2020: Inspected and report submitted to the General Manager.
Kenyon Noble
2019: Not inspected.
2020: Inspected and report compiled; however, not sent to owner due to legal/policy issues.
SID 674
2019: Not inspected.
2020: Inspected and report compiled; however, not sent to owner due to legal/policy issues.
South University District 1-2
2019: Not inspected.
2020: Inspected and report compiled; however, not sent to owner due to legal/policy issues.
West Paw
2019: Not inspected.
2020: Inspected and report submitted to the General Manager.
6.7 Enforcement Response Plan
This section outlines the MS4’s Enforcement Response Plan, which provides strategies and authority to
ensure owners install, operate, and maintain structural BMPs.
Design: SWMP Section 6.2 references numerous documents containing regulations and
requirements regarding structural BMP design. If a developer does not fully comply with
regulations, the MS4 denies the site plan, making it impossible to acquire a building permit and
construct their project. If a developer were to move forward with construction without a building
permit, the Community Development’s Code Compliance offer would issue a Stop Work Order
per BMC Sec. 38.200.040.
Installation: SWMP Section 6.3 details the MS4’s structurtal BMP review process. During this
stage, the MS4 uses the following enforcement protocols:
Informal, Formal, and Judicial: The MS4 submits a written notification to the owner when an
erosion, sediment, and pollutant control issue is identified using the protocol in SWMP
SECTION 6.0 - POST-CONSTRUCTION PROGRAM 11
Section 5.3. The Construction Enforcement Response Plan is the authority until the site
reaches final stabilization. Requirements and permission to enter property are found in
Bozeman Municipal Code Section 40.04.350.
Formal: If an engineering-related issue, such as groundwater, geometry, location, or depth,
or a site plan deviation, such as a utility conflict, occurs the owner is required to coordinate
with the Engineering Division to find a solution. The MS4 withholds occupancy on the project
or does not accept infrastructure until the owner resolves the identified issues.
Operation and Maintenance: SWMP Section 6.5 outlines the MS4s structural BMP inspection
program. Upon sending the documents, the MS4 uses the following enforcement protocol:
Informal: The MS4 communicates with the owner and offers to review the results of the MS4’s
inspection. A six-month timeline is set, which requires the owner to submit a maintenance
plan to the MS4 describing how the identified issues will be resolved.
Formal and Judicial: The MS4 does not have formal policy or process at this time. Two projects
are ongoing as of late 2020 to determine this portion of the MS4’s ERP. The projects include
the Engineering Standards Update and the 2021 Stormwater Facilities Plan Update. The MS4
plans to present policy recommendations from these efforts to the Commission for decision-
making as soon as they are complete.
6.8 Performance Tracking
The MS4 completes a Structural BMP Compliance Audit annually, evaluating 50 random structural BMPs
to determine their condition based on the following criteria:
Vegetation Management: Evidence of reoccurring cattail, grass, and woody shrub removal.
Flow path: As designed, blocked by vegetation and/or sediment, and channelization.
Sediment accumulation, stagnant water or accumulation of vegetation which is reducing volume.
After evaluation, the MS4 grades each structural BMP using one of the following categories:
0-Points: Structural BMP requires sediment dredging, vegetation removal, or infrastructure
repairs to restore function.
1-Point: Structural BMP requires minor to moderate sediment and vegetation maintenance to
maintain function. 2-Points: Structural BMP appears to be well-maintained and functioning as designed.
The MS4 compiles the collected data and updates Table 6.8.1:
Table 6.8.1: Stormwater Structural BMP Audit Scores
Audit Year Audit Dates Trend Total Points Earned Score
2018 October 17 - 26 - 25/100 25%
2019 November 14 - 15 Increasing 32/100 32%
2020 November 2 - 6 Increasing 56/100 56%
2018 Summary:
Wal-Mart, Safeway, and other private entities maintain their structural BMPs more
frequently, yielding an average score six times greater than HOAs.
Structural BMPs integrated into landscapes are in better condition than those hidden.
The overwhelming majority of HOAs are unaware of their responsibilities and do not complete
maintenance regardless of previous engagement by the City.
Current design standards allow for the construction of inadequate systems.
SECTION 6.0 - POST-CONSTRUCTION PROGRAM 12
2019 Summary:
Structural BMPs integrated into landscapes are in better condition than those hidden.
The overwhelming majority of HOAs are ignorant of their maintenance responsibilities.
Current design standards allow for the construction of inadequate systems.
Legal private property access is an issue that requires consideration and resolution
Average Scores: Private = 1.0 and HOA = .3
2020 Summary:
New structural BMPs rate high and were a disproportionate majority, elevating the score.
HOA scores are improving mainly resulting from the addition of new structural BMPs.
Older private structural BMPs declined in performance.
Many structural BMPs are located on parkland property and may be the responsibility of the
MS4 due to the recently approved Parks and Trails District.
Private property access is an issue that requires consideration.
Average Scores: Private = 1.0 and HOA = 1.2
6.9 Ongoing and Future Initiatives
The following initiatives are planned or ongoing to facilitate improved plans, policies, and ordinances
related to the MS4’s Post-Construction Program:
2021 Engineering Design Standards Update (Standards Update): A project that includes
reviewing and updating the MS4’s Engineering Standards. Improvements will consist of better
incorporating the MS4 Permit’s water quality requirements, integrating the Montana Post-
Construction BMP Guidance Manual, and standardizing forms, such as drainage reports and
maintenance agreements.
2021 Stormwater Facility Plan Update (Facility Plan Update): The MS4’s Facilities Plan has not
received an update since 2008. The project will include reviewing and developing policy
recommendations related to deficient or previously unexplored programmatic components.
25%
32%
56%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2018 2019 2020 2021% Compliance/Earned ScoreCalendar Year
Post-Construction Compliance Audit Scores
Average Score/Trend
HOA
Private
SECTION 6.0 - POST-CONSTRUCTION PROGRAM 13
Center for Watershed Protection Code and Ordinance Worksheet: In 2020, the MS4 met with the
Parks, Planning, and Engineering Divisions and completed the worksheet to determine barriers
to implementing stormwater and land-use structural and non-structural BMPs.
The worksheet was helpful for barrier identification and internal discussion. The MS4 found that
some of the recommendations were not applicable or practicable due to various local conditions.
Further, the MS4 confirmed it already has aggressive and protective environmental regulations
in place, such as watercourse setbacks, open space requirements, a suite of structural BMP
options, strategic land use planning, and impervious area maximums. In summary, the MS4
identified the following items for having improvement potential:
Recommendation: Allow for alternative sidewalk and driveway materials.
o Current Status: The MS4 has seen a variety of permeable concrete paver surfaces
installed in the last few years. Current design standards do not explicitly cover.
o Future Opportunity: Consider modifying codes as a part of the Standards Update.
Recommendation: Secure permanent funding arrangements for the long-term management
and maintenance of open space.
o Current Status: The City requires the establishment of HOA’s at the time of
subdivision development; however, it does not require financial guarantees regarding
the maintenance of open space, which often includes stormwater facilities and
natural resource areas. This issue spans numerous policies and mainly centers on the
lack of assurance that HOAs exist and stay funded into perpetuity. Often HOAs
dissolve due to a lack of volunteers, representation, or ability to raise money.
o Future Opportunity: Review policy options as a part of the Facility Plan Update.
Recommendation: Long-term management plans that conserve natural systems required for
all open space areas.
o Current Status: Maintenace plans and open space agreements are typically not
specific and fail to address all needs adequately.
o Future Opportunity: Consider reviewing policies during the Park’s PROST Plan update.
Recomendation: Require limits of disturbance to be shown on construction plans and
physically marked at the site.
o Current Status: The Montana Construction General Permit does not require.
o Future Opportunity: Coordinate with MDEQ during the next permit issuance.
Recommendation: Require special treatment criteria for discharges to impaired or sensitive
waters, such as natural wetlands, lakes, trout streams, nutrient-sensitive estuaries, drinking
water supplies, etc.
o Current Status: The MS4 does not designate or select high-priority drainage areas.
o Future Opportunity: Consider modifying codes as a part of the Standards Update
and/or review policy options as a part of the Facility Plan Update.
Recomendation: Implement a local wetland protection ordinance.
o Current Status: Wetland mitigation is covered under USACE policy and requirements.
o Future Opportuinity: Review project options as a part of the Facility Plan Update.
Recommendation: Provide a reference to clear, understandable, and local or regionally based
design guidance or stormwater manual.
SECTION 6.0 - POST-CONSTRUCTION PROGRAM 14
o Current Status: The Montana Post-Construction BMP Design Guidance Manual exists;
however, it is not referenced nor codified in the MS4’s Engineering Standards.
o Future Opportuinity: Consider modifying codes as a part of the Standards Update.
Recomendation: Mandate performance bonds and periodic inspections to ensure proper
installation of stormwater practices based on the approved plans.
o Current Status: No requirements exist.
o Future Opportuinity: Review policy options as a part of the Facility Plan Update.
Recomendation: Include provisions for runoff reduction practice easements, inspector right-
of-entry, maintenance agreements, and post-construction inspections.
o Current Status: The listed items either do not exist or require improvement.
o Future Opportuinity: Consider modifying codes as a part of the Standards Update.
Recomendation: Require some percentage of treatment on-site if off-site stormwater
compliance is authorized.
o Current Status: The MS4 does not allow offsite stormwater management at this time.
o Future Opportuinity: Review policy options as a part of the Facility Plan Update.
Section 7.0
Good Housekeeping Program
Graphic 7.0.2: Sediment management facilityGraphic 7.0.1: Street sweeping debris pile
SECTION 7.0 - GOOD HOUSEKEEPING PROGRAM 2
Blank Page
SECTION 7.0 - GOOD HOUSEKEEPING PROGRAM 3
7.1 Introduction
The MS4 strives to improve waterway health, protect public safety, and comply with its MS4 Permit
through the responsible management of its storm sewer system, facilities, and daily work activities by:
Inspecting, maintaining, and repairing public assets;
Mitigating stormwater pollutants through the development and implementation of Facility and
Activity Stormwater Pollution Prevention Plans; and
Maintaining an environmentally conscious workforce through training.
SWMP Section 7.0 details the following components necessary to administer the MS4’s Good
Housekeeping Program, including:
Infrastructure Operations (7.2)
Facility Stormwater Pollution Prevention Program (7.3)
Activity Stormwater Pollution Prevention Program (7.4)
Training (7.5)
7.2 Infrastructure Operation
The City inspects, maintains, and repairs its storm sewer system on an annual basis. MSU maintains
infrastructure within its boundary. The following Divisions are responsible for conducting infrastructure
operations:
Table 7.2.1: Infrastructure Operations
Operation Goal Season Operational Area
Stormwater Division Operations
Storm Sewer Inspection (CCTV) 20% per year Year-round Citywide
Storm Sewer Cleaning 20% per year Year-round Citywide
Storm Sewer Repair As Required Spring, Summer, Fall Citywide
Treatment Unit Maintenance Annually Fall Individual Locations
Infiltration Facility Maintenance Annually Fall Individual Locations
Debris Hauling Annually Varies Sediment Facility
Streets Division Operations
Spring Cleanup Annually Spring Citywide
Fall Cleanup Annually Fall Citywide
Street Sweeping Annually Year-round Citywide
Sweepings Hauling Annually Varies East Gallatin Area
The MS4 uses the following metrics to track performance. The performance data comes from the MS4’s
Operation’s Dashboard, and infrastructure totals from SWMP Section 4.8. The metrics include:
Inlets and Manholes Cleaned: Storm sewer inlets and manholes serve two purposes: (1) mitigate
flood risk by collecting runoff from streets, parking lots, alleyways, and other hard surfaces, and
(2) treat stormwater by capturing sediment, trash, and other pollutants in their sumps.
Performance Measure: Clean 20% of public inlets and manholes annually
Calculation Type: Total assets (includes duplicate effort)
SECTION 7.0 - GOOD HOUSEKEEPING PROGRAM 4
Table 7.2.2: Inlet and Manholes Totals
Year City/MDT
Maintained
City/MDT
Total % Complete MSU
Maintained
MSU
Total
%
Complete
2018 742 3,778 20% 256 362 71%
2019 809 4,216 19% 263 362 73%
2020 909 4,188 22% 207 365 57%
2021 - - - - - -
Storm Sewer Cleaned: Storm sewers serve two purposes: (1) convey stormwater collected by
inlets to their point of discharge, and (2) capture sediment, trash, and other pollutants that fall
out of suspension, requiring reoccurring maintenance to remain functional.
Performance Measure: Clean 20% of pipes annually
Calculation Type: Total assets (mains and laterals, includes duplicate effort)
Table 7.2.3: Storm Sewer Totals
Year City/MDT
Maintained
City/MDT
Total % Complete MSU
Maintained
MSU
Total
%
Complete
2018 17 Miles 71 Miles 24% .1 Miles 8 Miles 1%
2019 14 Miles 77 Miles 18% .1 Miles 8 Miles 1%
2020 17 Miles 78 Miles 22% .1 Miles 8 Miles 1%
2021 - - - - - -
Infrastructure Repairs: Infrastructure repairs or “spot repairs” serve two purposes: (1) fix known
pipe failures and restrictions to ensure the adequate flow of stormwater, and (2) repair open
sections of pipe where scouring of subgrade soils occur, mitigating the chance of a road failure
and sediment load contribution.
Performance Measure: Pipe integrity indicator
Calculation Type: Total repairs
Table 7.2.4: Infrastructure Repair Totals
Year City Total MSU Total
2018 16 Repairs 2 Repairs
2019 10 Repairs 0 Repairs
2020 3 Repairs 1 Repair
2021 - -
Storm Sewer Inspection: Storm sewer inspections serve two purposes: (1) identification and
prioritization of structural and maintenance needs for underground infrastructure and (2)
identifies illicit discharges, cross-connections, or illegal pipe connections.
Performance Measure: Inspect 20% of storm sewer mains annually
Calculation Type: Total assets (mains and laterals, includes duplicate effort)
Table 7.2.5: Storm Sewer Totals
Year City/MDT
Maintained
City/MDT
Total % Complete MSU
Maintained
MSU
Total
%
Complete
2018 14 Miles 71 Miles 20% .4 Miles 8 Miles 5%
2019 11 Miles 77 Miles 14% .02 Miles 8 Miles .2%
2020 9 Miles 78 Miles 12% .5 Miles 8 Miles 6%
2021 - - - - - -
SECTION 7.0 - GOOD HOUSEKEEPING PROGRAM 5
7.3 Facility Stormwater Pollution Prevention Program
The purpose of the MS4’s Facility Stormwater Pollution Prevention Program (FSWPPP) is to mitigate
stormwater pollutants generated on municipal facilities. To complete, the MS4 works to ensure all
municipal facilities meet or exceed the following Facility Minimum Standards (FMS):
Connect wash bays and interior floor drains to the sanitary sewer.
Store chemicals under cover and within secondary containment.
Prevent tracking at entries, exits, and within parking areas.
Stock spill kits with instructions, disposable bags, PPE, and absorbent products.
Perform preventative maintenance on vehicles and equipment.
Wash vehicles and equipment in designated locations.
Contain fuel tanks with secondary containment.
Implement BMPs for identified pollutants.
Maintain stormwater facilities per the following frequencies: (1) Stormwater basins, annual
vegetation and debris clearing, 10-15 year dredging; (2) Mechanical separators, annual
vacuuming; (3) Infiltration facilities, annual flushing; (4) Parking and drive surfaces, as required;
and (5) Inlets, manholes, and pipes, five-year flushing, vacuuming, and inspection cycle.
Stabilize disturbed areas within 14-days.
The MS4 uses the following FSWPPP inspection protocol:
If applicable, collect stormwater runoff sample to characterize facility pollutant concentrations.
Inspect facility and establish baseline compliance with FMSs.
Review existing documents, such as existing Standard Operating Guides (SOGs), safety data
sheets, spill documentation, and stormwater facility record drawings.
Coordinate with applicable leadership and develop FSWPPP that includes:
Overview
Stormwater Team
Site Description
Impaired Waterbodies
Sampling
Pollution Identification
Site Assessment
Spill Response Plan
Training
Inspections
Infrastructure Improvements
Record Keeping and Reporting
Site Map
Implement FSWPPP.
Train applicable staff annually.
Re-inspect and update the FSWPPP annually.
The following facilities are subject to the FSWPPP protocol:
Table 7.3.1: City Facilities Facility ID Facility Name Facility Classification Initial Inspection FSWPPP Development FSWPPP Update 1.1 City Shops Complex Operations and Storage Area 2019 2019 2020, 2021
1.2 Vehicle Maintenance Facility Operations and Storage Area 2019 2019 2020, 2021
SECTION 7.0 - GOOD HOUSEKEEPING PROGRAM 6
1.3 Laurel Glen Operations Facility Operations and Storage Area 2020 2020 2021
2.1 Water Treatment Plant Treatment Works 2020 2020 2021
2.2 Water Reclamation Facility Treatment Works 2019 2019 2020, 2021
3.1 East Gallatin Storage Area Material Storage Area 2020 2020 2021
3.2 Closed Landfill Material Storage Area 2019 2019 2020, 2021
3.3 Snow Storage Area Material Storage Area 2019 2019 2020 2021
4.1 Public Parking Garage Parking Facilities 2021 2021 2022
4.2 Public Parking Lots (4) Parking Facilities 2021 2021 2022
5.1 Bozeman Public Safety Facility Public Safety Facility 2019 2019 2020 2021
5.2 Fire Stations #1-3 Public Safety Facility 2021 2021 2022
Table 7.3.2: MSU Facilities Facility ID Facility Name Facility Classification Initial Inspection FSWPPP Development FSWPPP Update 1.4 University Shops Facility Operations and Storage Area 2019 2021 2022
3.4 MSU Material Storage Area Material Storage Area 2020 2021 2022
4.3 MSU Parking Garage Parking Facilities 2021 2021 2022
4.4 MSU Parking Lots (17) Parking Facilities 2021 2021 2022
Graphic 7.3.3: MS4 facilities
SECTION 7.0 - GOOD HOUSEKEEPING PROGRAM 7
7.4 Activity Stormwater Pollution Prevention Program
The purpose of the MS4’s Activity Stormwater Pollution Prevention Program (ASWPPP) is to mitigate
stormwater pollutants generated from municipal operations. To complete, the MS4 works to ensure all
operations meet or exceed the following Activity Minimum Standards (AMS):
Protect street surfaces and inlets by deploying controls that capture, contain, and allow the
collection and disposal of generated pollutants.
Cover or contain material stockpiles, and control run-on.
Stabilize disturbed areas within 14-days of activities.
Prevent tracking and the off-site migration of debris.
Capture and dispose concrete waste.
Manage dewatering flows to remove sediment to the maximum extent practicable before
entering the storm sewer system or waterways.
The MS4 uses the following ASWPPP inspection protocol:
Review activity and establish baseline compliance with AMSs.
Coordinate with applicable leadership and develop ASWPPP that includes:
Overview
Stormwater Team
Activity Description
Pollutant Identification
Standards Assessment and SOGs
Training
Record Keeping
Implement ASWPPP.
Train applicable crews annually.
The following activities are subject to the ASWPPP protocol:
Table 7.4.1: MS4 Activities Activity ID Activity Name Division Responsible Entity Location Inspection Year ASWPPP Development 1.1 Emergency Water Main Breaks Water/Sewer City Citywide 2019 2019
1.2 Sanitary Sewer Overflows Water/Sewer City, MSU Citywide 2019 2019
1.3 Trenching and Excavation Water and Sewer City Citywide 2020 2020
2.1 Sidewalk and Curb Construction Water/Sewer, Streets City Citywide 2021 2021
2.2 Concrete Cutting Water/Sewer, Streets City Citywide 2021 2021
3.1 Roadway Traction Sand Application Streets City, MSU Citywide 2020 2020
4.1 Solid Waste Collection Solid Waste City, MSU Citywide 2020 2020
5.1 Arena Construction MSU MSU Campus 2021 2021
6.1 Parks Mowing Parks City, MSU Citywide 2021 2021
6.2 Tree Planting, Pruning, Removal Parks City, MSU Citywide 2021 2021
SECTION 7.0 - GOOD HOUSEKEEPING PROGRAM 8
7.5 Training
The MS4 participates in local, state, and national trainings. The following lists completed efforts:
Comprehensive Stormwater Training
Stormwater Program Coordinator (Kayla Mehrens)
o 2017: Montana Water Environment Association Conference, Bellevue StormCon
Conference
o 2018: Montana Stormwater Conference, Denver StormCon Conference
o 2019: n/a
o 2020: Virtual Designing Successful Stormwater Facilities with Maintenance and
Enforcement in Mind, Virtual National Stormwater Symposium Stormwater Digital
Conference, Virtual Stormwater Rate Study with FCS Group, Virtual StormCon
Conference, Virtual Stormwater Pond Problems Webcast
Stormwater Program Specialist (Frank Greenhill)
o 2017: Montana Water Environment Association Conference
o 2018: International Erosion Control Association Conference, Montana Stormwater
Conference
o 2019: BMP 101 Introduction to Stormwater Management, BMP 201 Certified SWPPP
Administrator/Preparer, WQM 130 Stormwater Management for Industrial
Operations
o 2020: Virtual StormCon Conference
Stormwater Project Manager (Adam Oliver)
o 2020: Virtual Designing Successful Stormwater Facilities with Maintenance and
Enforcement in Mind, Virtual ADS/Baysaver BMP Design and Maintenance Workshop,
Virtual StormCon Conference
Stormwater Program Technician (Cody Flammond, Jon Silva)
o 2018:International Erosion Control Association Conference, Montana Stormwater
Conference, Phase 1 Leadership Training, Hazardous Waste Training
o 2019: Weekly meeting, bimonthly meeting, Weftech Chicago, WQM 130 Stormwater
Management for Industrial Operations
o 2020: Virtual StormCon Conference
Stormwater Operations Foreman (Mike Dilbeck)
o 2018: Montana Stormwater Conference
o 2019: Weftech Chicago
o 2020: n/a
MSU Director, Facilities Services (EJ Hook)
o 2018: Montana Stormwater Conference
o 2019: n/a
o 2020: n/a
Stormwater Operations Training:
SECTION 7.0 - GOOD HOUSEKEEPING PROGRAM 9
Awareness: Training for employees to increase awareness and reduce stormwater pollutants
generated from internal operations. Employees receive training every three years. Employees
at the Water Reclamation Facility and in the Solid Waste Division receive training annually.
MSU employees receive annual FSWPPP and ASWPPP training applicable to their MSU
department and assigned tasks. Training is typically combined with seasonal Safety and Risk
Management training.
Table 7.5.1: Awareness Training Content
Division Stormwater In Bozeman Video Rain Check Chapter 1: Intro Rain Check Chapter 2: Housekeeping Rain Check Chapter 3: Spill control Rain Check Chapter 4: Fueling Rain Check Chapter 5: Vehicle Maintenance Rain Check Chapter 6: Vehicle Washing Rain Check Chapter 7: Materials Management Rain Check Chapter 8: Waste Management Rain Check Chapter 9: Facility Maintenance Rain Check Chapter 12: Landscaping Water and Sewer X X X X X X X X X - X
Code Compliance X X - X - - - - - - -
Facilities X X X X X - X X X X
Forestry X X X X X X X X X - X
Parks and Cemetery X X X X X X X X X - X
Fire Operations X X X X X X X X X X -
Streets X X X X X X X X X - X
Solid Waste X X X X X X X X X X -
Water Treatment Plant X X X X X X X X X X X
Water Rec. Facility X X X X X X X X X X -
ASWPPP and FSWPPP: Training for applicable employees to increase awareness and reduce
stormwater pollutants generated from specific operations and facilities. Employees receive
training annually. Training content includes:
Table 7.5.2: ASWPPP Training Content
Division Water Main Breaks Sanitary Sewer Overflows Trenching and Excavation Sidewalk and Curb Construction Curb Cutting Traction Sand Application Solid Waste Collection Arena Construction Parks Mowing Tree Planting Water and Sewer X X X X X - - - - -
Facilities - - - - - - - - - -
Forestry - - - - - - - - - X
Parks and Cemetery - - - - - - - - - X
Streets - - - X X X - - - -
Solid Waste - - - - - - X - - -
MSU Operations - X - - - X X X X X
SECTION 7.0 - GOOD HOUSEKEEPING PROGRAM 10
Table 7.5.3: FSWPPP Training Content
Division MSU Shops Facility City Shops Complex Vehicle Maintenance Facility Laurel Glen Operations Facility East Gallatin Storage Area Closed Landfill Snow Storage Area MSU Material Storage Area Water Treatment Plant Water Reclamation Facility Public Parking Garage and Lots MSU Parking Garage and Lots Bozeman Public Safety Facility Fire Stations #1-3 Parks and Recreation Water and Sewer - X X X - - - - - - - - - - -
Facilities - X - - - - - - - - X - X X -
Forestry - - X - X - - - - - - - - - X
Parks and Cemetery - X - - X - - - - - - - - - X
Fire Operations - - - - - - - - - - - - X X -
Streets - X X - X - X - - - - - - - -
Solid Waste - - - - - X - - - - - - - - -
Water Treatment Plant - - - - - - - - X - - - - - -
Water Rec. Facility - - - - - - - - - X - - - - -
MSU Operations X - - - - - - X - - - X - - -
Table 7.5.4: Training Program Summary
Division
2017 2018 2019 2020 2021 Awareness Training FSWPPP and ASWPPP Training Awareness Training FSWPPP and ASWPPP Training Awareness Training FSWPPP and ASWPPP Training Awareness Training FSWPPP and ASWPPP Training Awareness Training FSWPPP and ASWPPP Training Water and Sewer 18 - 7 - 2 - 21 21 - -
Code Compliance 0 - 0 - 0 - 0 0 - -
Facilities 0 - 0 - 0 - 0 0 - -
Forestry 0 - 0 - 0 - 5 5 - -
Parks and Cemetery 0 - 0 - 14 - 17 17 - -
Fire Operations 0 - 0 - 0 - 0 0 - -
Streets 0 - 19 - 9 - 24 24 - -
Solid Waste* 14 - 17 - 16 - 19 19 - -
Water Treatment Plant 0 - 10 - 1 - 0 0 - -
Water Rec. Facility* 13 - 15 - 14 - 14 14 - -
MSU Operations 0 - 1 - 2 - 23 23 - -
SECTION 7.0 - GOOD HOUSEKEEPING PROGRAM 11
Construction Site Management Program Training
Stormwater Program Coordinator (Kayla Mehrens)
o 2020: Virtual BMP 301 Conducting Stormwater Compliance Evaluation Inspections
Stormwater Program Specialist (Frank Greenhill)
o 2017: BMP 101 Introduction to Stormwater Management Training, BMP 201 SWPPP
Administrator Training, BMP 202 SWPPP Preparer Training, BMP 101 Introduction to
Stormwater Management Training, BMP 102 Field Academy, BMP 201 SWPPP
Administrator Training, BMP 202 SWPPP Preparer Training, BMP 301 Compliance
Evaluation Inspection Training
o 2018: International Erosion Control Association Conference, BMP 101 Introduction to
Stormwater Management Training, 201/202 SWPPP Administrator and Preparer
Training, BMP 100 Construction Dewatering Training, 102 BMP Field Academy
o 2019: BMP 101 Introduction to Stormwater Management, BMP 201 Certified SWPPP
Administrator/Preparer
o 2020: Virtual BMP 301 Conducting Stormwater Compliance Evaluation Inspections
Stormwater Project Manager (Adam Oliver)
o 2020: Virtual BMP 301 Conducting Stormwater Compliance Evaluation Inspections
Stormwater Program Technician (Cody Flammond, Jon Silva)
o 2018: International Erosion Control Association Conference, 101 Introduction to
Stormwater Management Training, 201/202 SWPPP Administrator and Preparer
Training, 100 Construction Dewatering Training, 102 BMP Field Academy
o 2019: n/a
o 2020: Virtual CI241 Qualified Compliance Inspector of Stormwater – Montana, Virtual
BMP 301 Conducting Stormwater Compliance Evaluation Inspections
MSU Director of Facilities Services (EJ Hook)
o 2017: BMP 301 Compliance Evaluation Inspection Training
o 2018: n/a
o 2019: n/a
o 2020: n/a
Post-Construction Program Training
Stormwater Program Coordinator (Kayla Mehrens):
o 2017: Montana Water Environment Association Conference, Bellevue StormCon
Conference
o 2018: Montana Stormwater Conference (May 1-3), Denver StormCon Conference
o 2019: n/a
o 2020: Virtual The Benefits of Third Party Performance Verification: A Better
Understanding of NJDEP and WADOE TAPE Webinar, Virtual StormCon Conference,
Virtual Stormwater Pond Problems Webcast
Stormwater Project Manager (Adam Oliver)
SECTION 7.0 - GOOD HOUSEKEEPING PROGRAM 12
o 2020: Virtual Designing Successful Stormwater Facilities with Maintenance and
Enforcement in Mind, Virtual ADS/Baysaver BMP Design and Maintenance Workshop,
Virtual StormCon Conference
Development Review Engineer (Anna Russell P.E., Karl Johnson):
o 2020: Virtual The Benefits of Third Party Performance Verification: A Better
Understanding of NJDEP and WADOE TAPE Webinar
Development Review Engineer (Griffin Nielsen P.E., Cody Flammond P.E.):
o 2020: Virtual The Benefits of Third Party Performance Verification: A Better
Understanding of NJDEP and WADOE TAPE Webinar
Development Review Manager (Lance Lehigh P.E.):
o 2020: Virtual The Benefits of Third Party Performance Verification: A Better
Understanding of NJDEP and WADOE TAPE Webinar
Section 8.0
Sampling and Evaluation Program
Graphic 8.0.2: Stormwater runoff nutrient analysisGraphic: 8.0.1: In-stream sampling equipment
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 2
Blank Page
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 3
8.1 Introduction
The MS4 strives to improve waterway health, protect public safety, and comply with its MS4 Permit
through the collection of stormwater and waterway data points that:
Monitor stormwater and surface water quality over time;
Evaluate the effectiveness of infrastructure and administrative program investments;
Generate data that advises policy, capital, and operational decisions; and
Provide a data-driven performance metric easily communicated to the public.
SWMP Section 8.0 details the following components necessary to administer the MS4’s Sampling and
Evaluation Program, including:
Targeted Waterways (8.2)
Regulatory Requirements (8.3)
Urban Runoff Monitoring (8.4)
In-stream Wet Weather Monitoring (8.5)
Sediment Reduction Monitoring (8.6)
Long-term Trend Monitoring (8.7)
Evaluation (8.8)
Discussion (8.9)
8.2 Targeted Waterways
Bozeman Creek, a.k.a. Sourdough Creek, originates in the Gallatin Mountains south of the MS4. Flowing
north, Bozeman Creek enters the MS4 at E. Kagy Boulevard and continues until its confluence with the E.
Gallatin River at E. Griffin Dr. The Montana DEQ determined that Bozeman Creek contained impairments
from natural and anthropogenic sources when preparing the 2013 Lower Gallatin Planning Area TMDL.
Table 8.2.1: Bozeman Creek Impairment Information
Probable Cause Probable Sources Associated Uses TMDL
Alteration in stream-side or
littoral vegetative cover Agricultural grazing, crop production Aquatic Life No
Chlorophyll-a Agricultural grazing and crop production, residential
districts, municipal area
Primary Contact
and Recreation No
E.coli Septic tanks, urban runoff, storm sewers, pet waste,
livestock
Primary Contact
and Recreation Yes
Nitrogen (Total) Agricultural grazing and crop production, residential
districts, municipal area
Aquatic Life,
Primary Contact,
and Recreation
Yes
Sediment Natural sources, unpaved roads/trails, urban runoff,
storm sewers, municipal area Aquatic Life Yes
Mandeville Creek, a small spring feed watercourse, originates south of Bozeman. Flowing north,
Mandeville Creek enters the MS4 at Alder Creek Dr. and continues until its confluence with the E. Gallatin
River. The Montana DEQ determined Mandeville Creek contained impairments from anthropogenic
sources when preparing the 2013 Lower Gallatin Planning Area TMDL.
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 4
Table 8.2.2: Mandeville Creek Impairment Information
Probable Cause Probable Sources Associated Uses TMDL
Nitrogen (Total) Municipal point source discharges, residential
districts, municipal area
Aquatic Life,
Primary Contact,
and Recreation
Yes
Phosphorous (Total) Municipal point source discharges, residential
districts, municipal area
Aquatic Life,
Primary Contact,
and Recreation
Yes
8.3 Regulatory Requirements
The MS4 General Permit requires that the MS4 perform sampling, testing, and reporting of stormwater
discharges annually, including:
Monitor stormwater discharges based on residential and industrial land-use types
See SWMP Section 8.4 Urban Runoff Monitoring
Assess in-stream water quality impacts of stormwater discharges to Bozeman and Mandeville
Creeks (Self-Monitoring Requirements: Monitoring Option 2)
See SWMP Section 8.5 In-Stream Wet-Weather Monitoring and SWMP Section 8.7 Long-Term
Trend Monitoring.
Conduct TMDL-related monitoring to evaluate the effectiveness of best management practices
(BMPs) implemented to reduce pollutant loading from the MS4 to impaired waters (TMDL Related
Monitoring: Monitoring Option 2)
See SWMP Section 8.6 Sediment Reduction Monitoring
Self-evaluate results relative to long-term medians
See SWMP Section 8.8 Evaluation
For each of the monitoring requirements above, the MS4 conducts sampling, testing, and reporting of the
following parameters:
Total Suspended Solids (TSS), mg/L
Chemical Oxygen Demand (COD), mg/L
Total Nitrogen (TN), mg/L
Total Phosphorus (TP), mg/L
Copper (Cu), mg/L
Lead (Pb), mg/L
Zinc (Zn), mg/L
Oils and Greases, mg/L
pH, standard units
Estimated Flow
8.4 Urban Runoff Monitoring
Introduction: The MS4 collects urban runoff samples from representative watersheds to characterize
pollutant loading occurring from various land-use types before system treatment, such as stormwater
basins, sumps, infiltration galleries, and mechanical separation. In general, urban runoff pollutant
concentrations are variable and dependent on numerous environmental conditions, such as precipitation
cycles, wind, tree cover, and human activities.
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 5
Sites: The MS4 has a network of four monitoring locations: two within residential drainage basins and two
within commercial/industrial drainage basins, including:
Site: RES_01
Location: Near the intersection of S. Bozeman Ave. and E. Garfield St.
Land-use: Residential
Drainage Basin: Seven acres
Inlet ID: I.F06.00082
Latitude: 45.667143
Longitude: -111.034474
Inlet ID: I.F06.00083
Latitude: 45.667143
Longitude: -111.034724
Parameters: TSS, COD, TP, TN, pH, Copper, Lead, Zinc, Oils and Greases, and Flow
Frequency: Two samples per year
Site: IND_01
Location: Near Commercial Dr. cul-de-sac (west)
Land-use: Commercial and Industrial
Drainage Basin: 10 acres
Inlet ID: I.E01.00184
Latitude: 45.703061
Longitude: -111.030112
Inlet ID: I.E01.00185
Latitude: 45.703164
Longitude: -111.030428
Parameters: TSS, COD, TP, TN, pH, Copper, Lead, Zinc, Oils and Greases, and Flow
Frequency: Two samples per year
Site: RES_02
Location: MSU Campus near the intersection of S. 12th Ave. and W. Garfield St.
Land-use: Residential
Drainage Basin: Four acres
Inlet ID: I.H06.00329
Latitude: 45.666911
Longitude: -111.054301
Inlet ID: I.H06.00259
Latitude: 45.666970
Longitude: -111.054226
Parameters: TSS, COD, TP, TN, pH, Copper, Lead, Zinc, Oils and Greases, and Flow
Frequency: Two samples per year
Site: IND_02
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 6
Location: MSU Campus near the intersection of S. 6th Ave. and W Garfield St.
Land-use: Industrial
Drainage Basin: Two acres
Inlet ID: I.G06.00603
Latitude: 45.664409
Longitude: -111.044957
Inlet ID: I.G06.00630
Latitude: 45.664409
Longitude: -111.044942
Parameters: TSS, COD, TP, TN, pH, Copper, Lead, Zinc, Oils and Greases, and Flow
Frequency: Two samples per year
Methods: The MS4 collects urban runoff samples from storm sewer inlets at each site using Thermo-
Scientific Nalgene Samplers (Samplers). Before runoff events, Staff installs each Sampler at the selected
inlet grate and positions it to collect the first flush of urban runoff. Once full, the Sampler closes itself
prohibiting additional collection or dilution of the original sample.
Analysis: The MS4 collects, transfers, packages, and ships samples to a certified laboratory, which analyzes
the following parameters:
Total Suspended Solids (TSS), mg/L
Chemical Oxygen Demand (COD), mg/L
Total Nitrogen (TN), mg/L
Total Phosphorus (TP), mg/L
Copper (Cu), mg/L
Lead (Pb), mg/L
Zinc (Zn), mg/L
Oils and Greases, mg/L
pH, standard units
Estimated Flow
The MS4 estimates flow, in gallons per minute (gpm), using the Rational Formula where:
Q = CiA Equation 1
Q is peak runoff rate (cfs converted to gpm)
C is the runoff coefficient (C-Factor, Bozeman Engineering Standards)
i is rainfall intensity (in./hr., MSU Rain Gage)
A is the drainage area (acres)
Table 8.4.1: Sampling Location Runoff Coefficients (C-Factors)
Location Name Primary Land Use Runoff Coefficient (C-Factor)
RES_01 Low to Medium Density Residential 0.35
RES_02 Dense Residential 0.50
IND_01 Industrial 0.80
IND_02 Industrial 0.80
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 7
Table 8.4.2: Urban Runoff Monitoring Results * Reporting Limit (RL)
Site TSS
mg/L
Oil &
Grease
mg/L
Total
Nitro.
mg/L
Phosp.
mg/L
Zinc
mg/L
Lead
mg/L
Cop.
mg/L
COD
mg/L pH Flow
gpm
RES_01: 2017 (1) 203 2.00 6.20 0.908 0.1160 0.0052 0.0220 251.00 6.7 N/A
RES_01: 2017 (2) 368 5.10 RL 12.00 1.230 0.1790 0.0073 0.0300 175.00 7.0 N/A
RES_01: 2018 (1) 460 4.00 14.00 1.920 0.2720 0.0092 0.0290 708.00 6.4 55.0
RES_01: 2018 (2) 113 1.00 RL 2.30 0.544 0.1220 0.0033 0.0130 129.00 6.5 22.0
RES_01: 2019 (1) 5890 6.00 28.80 8.400 2.0200 0.1750 0.3380 3330.00 7.4 49.5
RES_01: 2019 (2) 206 1.00 RL 5.50 0.680 0.2100 0.0060 0.0240 258.00 6.9 14.3
RES_01: 2020 (1) 2300 3.00 21.50 4.400 0.6200 0.0530 0.0760 1340.00 6.7 110.0
RES_01: 2020 (2) 109 1.00 RL 3.40 0.6400 0.1400 0.0040 0.0200 363.00 6.3 49.5
RES_01: 2021 (1) - - - - - - - - - -
RES_01: 2021 (2) - - - - - - - - - -
RES_01 Median 287 2.50 9.10 1.069 0.1945 0.0067 0.0265 310.50 6.7 88.0
RES_02: 2017 (1) - - - - - - - - - -
RES_02: 2017 (2) - - - - - - - - - -
RES_02: 2018 (1) 1430 15.00 8.40 2.030 0.6520 0.0367 0.0840 605.00 7.0 18.0
RES_02: 2018 (2) 199 3.00 3.40 0.457 0.2610 0.0081 0.0220 234.00 6.8 18.0
RES_02: 2019 (1) 806 9.00 8.60 1.930 0.5000 0.0410 0.0820 579.00 7.5 40.39
RES_02: 2019 (2) 568 8.00 17.50 2.060 0.7500 0.0220 0.0810 1100.00 6.8 11.7
RES_02: 2020 (1) 1490 3.00 9.80 2.220 0.5100 0.0300 0.0490 487.00 6.8 89.76
RES_02: 2020 (2) 176 3.00 7.40 0.800 0.2900 0.0070 0.0260 382.00 6.4 40.4
RES_02: 2021 (1) - - - - - - - - - -
RES_02: 2021 (2) - - - - - - - - - -
RES_02 Median 687 5.50 8.50 1.980 0.5050 0.0260 0.0650 533.00 6.8 71.8
IND_01: 2017 (1) 149 4.00 17.30 1.380 0.5780 0.0160 0.0440 292.00 7.0 -
IND_01: 2017 (2) 1820 5.10 RL 11.68 1.320 33.3500 0.0371 0.0867 151.00 6.9 -
IND_01: 2018 (1) 602 15.00 8.50 1.890 4.7100 0.0371 0.0620 606.00 7.3 179.5
IND_01: 2018 (2) 293 4.00 3.40 0.588 0.1910 0.0081 0.0270 195.00 7.0 71.8
IND_01: 2019 (1) 1470 4.00 4.90 1.960 1.5600 0.1020 0.1620 647.00 7.6 161.6
IND_01: 2019 (2) 333 2.00 10.70 0.940 0.8800 0.0250 0.0700 651.00 7.2 46.7
IND_01: 2020 (1) 2880 2.00 17.10 6.800 2.7200 0.1070 0.2450 1240.00 6.7 359.1
IND_01: 2020 (2) 347 2.00 4.80 0.880 1.7600 0.0280 0.0540 347.00 7.2 161.6
IND_01: 2021 (1) - - - - - - - - - -
IND_01: 2021 (2) - - - - - - - - - -
IND_01 Median 474 4.00 9.60 1.350 1.6600 0.0326 0.0660 476.50 7.1 287.3
IND_02: 2017 (1) - - - - - - - - - -
IND_02: 2017 (2) - - - - - - - - - -
IND_02: 2018 (1) 899.0 4.00 8.80 1.600 0.5600 0.0158 0.0570 592.00 6.7 14.4
IND_02: 2018 (2) 380.0 5.00 4.40 0.737 0.2450 0.0099 0.0320 271.00 3.4 14.4
IND_02: 2019 (1) 2570 10.00 2.00 4.440 1.3500 0.0780 0.1760 1420.00 7.6 32.3
IND_02: 2019 (2) 301 3.00 10.20 1.440 0.8200 0.0260 0.1000 634.00 6.8 9.3
IND_02: 2020 (1) 1040 3.00 5.20 1.410 0.6200 0.0230 0.0590 730.00 7.0 71.8
IND_02: 2020 (2) 225 2.00 4.00 0.810 0.3000 0.0080 0.0300 248.00 6.2 32.3
IND_02: 2021 (1) - - - - - - - - - -
IND_02: 2021 (2) - - - - - - - - - -
IND_02 Median 639.5 3.50 4.80 1.425 0.5900 0.0194 0.0580 613.00 6.8 23.3
Evaluation: The MS4 enters monitoring results into a local spreadsheet, stores analysis reports for safe
record, and analyzes the data using the following Scoring Matrix (Matrix) and protocol to interpret,
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 8
evaluate, and communicate the results. The Matrix includes scores ranging from 0 to 4-points,
representing a set increase from EPA benchmarks provided in previous MS4 General Permits.
Table 8.4.3: Stormwater Reference Site from MDEQ and EPA
Site TSS
mg/L
Oil &
Grease
mg/L
Total
Nitro.
mg/L
Phosp.
mg/L
Zinc
mg/L
Lead
mg/L
Copper
mg/L
COD
mg/L pH
Reference 125 10 2 0.4100 0.2100 0.1650 0.0400 80 6 to 9
Example: The TSS Benchmark is 125 mg/L. As such, the 3-Point range is two times that amount (250), the
2-Point range is three times that amount (375), etc.
Table 8.4.4: Urban Runoff Monitoring: Scoring Matrix
Parameter 4-Points 3-Points 2-Points 1-Point 0-Points
TSS (mg/L) 0 – 125 126 - 250 251 - 375 376 - 500 > 500
Oil and Grease (mg/L) 0 - 10 11 - 20 21 - 30 31 - 40 > 41
Total Nitrogen (mg/L) 0 - 2.0 2.1 - 4.0 4.1 - 6.0 6.1 - 8.0 > 8.0
Phosphorus (mg/L) 0 - .41 .42 - .82 .83 - 1.23 1.24 - 1.65 > 1.65
Zinc (mg/L) 0 - .20 .21 - .40 .41 - .60 .61 - .80 > .80
Lead (mg/L) 0 - .10 .11 - .20 .21-.30 .31 - .40 > .40
Copper(mg/L) 0 - .04 .041 - .08 .081 - .12 .121 - .160 > .160
COD 0 - 80 81 - 160 161 - 240 241 – 320 > 320
PH (High End) 7.6 - 9.0 9.1 - 10.0 10.1 - 11.0 11.1 -12.0 12.1 - 14.0
PH (Low End) 6.0 - 7.5 5.0 - 5.9 4.0 - 4.9 3.0 - 3.9 1.0 - 3.0
The MS4 relates results to the Matrix and then populate the appropriate Urban Runoff Monitoring charts
with the corresponding point totals.
Example: A 2018 RES_01 sample contained 135 mg/L of TSS. The MS4 assigns and populates the Urban
Runoff Monitoring: RES_01 chart TSS box with 3-points. The same approach applies to all sites and
parameters.
Table 8.4.5: Urban Runoff Monitoring: RES_01
Parameter 2018 2019 2020 2021
(1) (2) (1) (2) (1) (2) (1) (2)
TSS 1 4 0 3 0 4 - -
Oil and Grease 4 4 4 4 4 4 - -
Total Nitrogen 0 3 0 2 0 3 - -
Phosphorus 0 3 0 3 0 3 - -
Zinc 3 4 0 3 1 4 - -
Lead 4 4 3 4 4 4 - -
Copper 4 4 0 4 3 4 - -
COD 0 3 0 1 0 0 - -
PH 4 4 4 4 4 4 - -
Event Points: 20 33 11 28 16 30 - -
Annual Points: 53 39 46 -
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 9
Table 8.4.6: Urban Runoff Monitoring: IND_01
Parameter 2018 2019 2020 2021
(1) (2) (1) (2) (1) (2) (1) (2)
TSS 0 2 0 2 0 2 - -
Oil and Grease 3 4 4 4 4 4 - -
Total Nitrogen 0 3 2 0 0 2 - -
Phosphorus 0 3 0 2 0 2 - -
Zinc 0 4 0 0 0 0 - -
Lead 4 4 4 4 3 4 - -
Copper 3 4 0 3 0 3 - -
COD 0 2 0 0 0 0 - -
PH 4 4 4 4 4 4 - -
Event Points: 14 30 14 19 11 21 - -
Annual Points: 44 33 32 -
Table 8.4.7: Urban Runoff Monitoring: RES_02
Parameter 2018 2019 2020 2021
(1) (2) (1) (2) (1) (2) (1) (2)
TSS 0 3 0 0 0 3 - -
Oil and Grease 3 4 4 4 4 4 - -
Total Nitrogen 0 3 0 0 0 1 - -
Phosphorus 0 3 0 0 0 3 - -
Zinc 1 3 2 1 2 3 - -
Lead 1 4 4 4 4 4 - -
Copper 2 4 2 2 3 4 - -
COD 0 2 0 0 0 0 - -
PH 4 4 4 4 4 4 - -
Event Points: 11 30 16 15 17 26 - -
Annual Points: 41 31 43 -
Table 8.4.8: Urban Runoff Monitoring: IND_02
Parameter 2018 2019 2020 2021
(1) (2) (1) (2) (1) (2) (1) (2)
TSS 0 1 0 2 0 3 - -
Oil and Grease 4 4 4 4 4 4 - -
Total Nitrogen 0 2 4 0 2 3 - -
Phosphorus 1 3 0 1 1 3 - -
Zinc 2 3 0 0 1 3 - -
Lead 4 4 4 4 4 4 - -
Copper 3 4 0 2 3 4 - -
COD 0 1 0 0 0 1 - -
PH 4 1 4 4 4 4 - -
Event Points: 18 23 16 17 19 29 - -
Annual Points: 41 33 48 -
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 10
The MS4 sums the individual scores to obtain an Event Point Total, sums both Event Scores to obtain an
Annual Point Total, and calculates a Final Score by transferring and summing the Annual Points in the
Urban Runoff Monitoring: Results chart. Finally, the MS4 divides the Total Points by the Possible Points to
calculate the Final Score and transfers the Final Score to SWMP Section 8.8.
Table 8.4.9: Urban Runoff Monitoring: Results
Sites 2018 2019 2020 2021
RES_01 Annual Points 53 39 46 -
IND_01 Annual Points 44 33 32 -
RES_02 Annual Points 41 31 43 -
IND_02 Annual Points 41 33 48 -
Total Points: 179 136 169 -
Possible Points: 288 288 288 288
Final Score (decimal): .62 .47 .59 -
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 11
Graphic 8.4.10: Urban Runoff Monitoring Map
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 12
8.5 In-Stream Wet-Weather Monitoring
Introduction: The MS4 conducts In-Stream Wet-Weather Monitoring to analyze the impacts of urban
runoff to Bozeman and Mandeville Creeks during wet weather. Combined, the Creeks receive urban runoff
from over 1,700 acres of dense development at over 100 individual discharge points or outfalls. Non-point
source pollution sources exist upstream of the MS4 as identified in the Lower Gallatin Planning Area
TMDL. This approach allows the MS4 to take sole responsibility for and mitigate the impacts stemming
from urban runoff.
Sites: The MS4 monitors two (2) locations on Bozeman Creek and two (2) locations on Mandeville Creek.
Each Creek has one (1) station upstream and one (1) downstream of the MS4 boundary. Sample sites
include:
Site: UPS_01
Location: Bozeman Creek upstream of MS4, near Kagy Blvd.
Latitude: 45.657248
Longitude: -111.028584
Parameters: TSS, COD, TP, TN, pH, Copper, Lead, Zinc, Oils and Greases, and Flow
Frequency: Two (2) samples per year
Site: DWS_01
Location: Bozeman Creek downstream of MS4, near Gold Ave.
Latitude: 45.699668
Longitude: -111.027347
Parameters: TSS, COD, TP, TN, pH, Copper, Lead, Zinc, Oils and Greases, and Flow
Frequency: Two (2) samples per year
Site: UPS_02
Location: Mandeville Creek upstream of MS4, near Campus Blvd.
Latitude: 45.656506
Longitude: -111.05803
Parameters: TSS, COD, TP, TN, pH, Copper, Lead, Zinc, Oils and Greases, and Flow
Frequency: Two (2) samples per year
Site: DWS_02
Location: Mandeville Creek downstream of MS4, near E. Baxter Ln.
Latitude: 45.697742
Longitude: -111.051959
Parameters: TSS, COD, TP, TN, pH, Copper, Lead, Zinc, Oils and Greases, and Flow
Frequency: Two (2) samples per year
Methods: The MS4 collects in-stream samples using Thermo-Scientific Nalgene Samplers (Sampler).
Before rain events, Staff mounts each Sampler to a metal post driven into the creek bed and positions it
to collect a sample as soon as the water levels rise one-half to three-quarters of an inch. The Sampler
closes itself and does not allow additional collection or dilution of the original sample once full.
Analysis: The MS4 collects, transfers, packages, and ships samples to a certified laboratory, which analyzes
the following parameters:
Total Suspended Solids, mg/L
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 13
Chemical Oxygen Demand, mg/L
Total Nitrogen, mg/L
Total Phosphorus, mg/L
Copper, mg/L
Lead, mg/L
Zinc, mg/L
Oils and Greases, mg/L
pH, standard units
The MS4 determines Bozeman Creek’s stream-flow using real-time data collected from the Bozeman
Creek gaging station. The MS4 estimates flow for Mandeville Creek using historical data collected by
Gallatin Local Water Quality District, since no permanent gauging station exists.
Table 8.5.1: In-Stream Wet-Weather Monitoring Results * Reporting Limit (RL)
Site TSS mg/L
Oil &
Grease
mg/L
Total
Nitro.
mg/L
Phosp. mg/L Zinc mg/L Lead mg/L Copper mg/L COD mg/L pH
UPS_01: 2017 (1) 7 5.80 RL 0.41 0.085 0.0054 0.0005 0.0036 11.6 8.2
UPS_01: 2017 (2) 14 1.00 RL 0.50 RL 0.022 0.0100 RL 0.0010 RL 0.0050 RL 15.0 8.1
UPS_01: 2018 (1) 14 1.00 RL 0.50 RL 0.052 0.0100 RL 0.0010 RL 0.0050 RL 10.0 8.1
UPS_01: 2018 (2) 10 RL 1.00 RL 0.60 0.028 0.0090 0.003 RL 0.0020 RL 5.0 8.3
UPS_01: 2019 (1) 30 7.60 RL 2.79 0.147 0.0505 0.0010 RL 0.0017 9.0 7.7
UPS_01: 2019 (2) 72 1.00 RL 1.60 0.160 0.0300 0.0010 RL 0.0050 RL 5.0 RL 8.2
UPS_01: 2020 (1) 74 1.00 RL 0.50 RL 0.260 0.0200 0.0010 RL 0.0050 RL 26.0 8.1
UPS_01: 2020 (2)* 14 1.00 0.50 0.085 0.0100 0.0010 0.0050 10.0 8.1
UPS_01: 2021 (1) - - - - - - - - -
UPS_01: 2021 (2) - - - - - - - - -
UPS_01 Median 14 1.00 0.50 0.085 0.0100 0.0010 0.0050 10.0 8.1
UPS_02: 2017 (1) - - - - - - - - -
UPS_02: 2017 (2) - - - - - - - - -
UPS_02: 2018 (1) 185 1.00 RL 3.10 0.430 0.0330 0.0027 0.0060 49.0 8.2
UPS_02: 2018 (2) 53 1.00 RL 0.50 RL 0.081 0.0180 0.0004 0.0020 16.0 8.1
UPS_02: 2019 (1) 10 6.8 RL 0.74 0.153 0.0422 0.0010 RL 0.0034 6.0 7.9
UPS_02: 2019 (2) 30 1.00 RL 0.80 0.144 0.0300 0.0010 RL 0.0050 RL 5.0 8.1
UPS_02: 2020 (1) 16 1.00 RL 0.80 0.080 0.0100 RL 0.0010 RL 0.0050 RL 11.0 8.3
UPS_02: 2020 (2) 10 RL 1.00 RL 0.60 0.066 0.0200 0.0010 RL 0.0050 RL 5.0 8.4
UPS_02: 2021 (1) - - - - - - - - -
UPS_02: 2021 (2) - - - - - - - - -
UPS_02: Median 23 1.00 0.77 0.113 0.0250 0.0010 0.0050 8.50 8.2
DWS_01: 2017 (1) 10 5.40 RL 0.55 0.088 0.0070 0.0006 0.0036 15.3 8.2
DWS_01: 2017 (2) 134 1.00 RL 1.80 0.264 0.0300 0.0060 0.0060 42.0 8.1
DWS_01: 2018 (1) 34 1.00 RL 0.50 RL 0.082 0.0100 RL 0.0010 RL 0.0005 RL 18.0 8.1
DWS_01: 2018 (2) 17 1.00 RL 0.70 0.057 0.0220 0.0007 0.0002 RL 14.0 8.3
DWS_01: 2019 (1) 100 7.00 3.00 0.238 0.1100 0.0021 0.0045 13.0 7.9
DWS_01: 2019 (2) 350 1.00 RL 3.40 0.645 0.1400 0.0140 0.0210 94.0 8.2
DWS_01: 2020 (1) 58 1.00 RL 0.50 RL 0.141 0.0300 0.0030 0.0050 28.0 8.2
DWS_01: 2020 (2)* 58 1.0 0.70 0.141 0.0300 0.0021 0.0050 18.00 8.2
DWS_01: 2021 (1) - - - - - - - - -
DWS_01: 2021 (2) - - - - - - - - -
DWS_01: Median 58 1.00 0.70 0.141 0.0300 0.0021 0.0050 18.00 8.2
DWS_02: 2017 (1) - - - - - - - - -
DWS_02: 2017 (2) - - - - - - - - -
DWS_02: 2018 (1) 297 1.00 RL 2.80 0.368 0.0700 0.0168 0.0150 53.0 8.2
DWS_02: 2018 (2) 43 1.00 RL 0.80 0.102 0.0280 0.0026 0.0030 18.0 8.2
DWS_02: 2019 (1) 1180 6.80 3.38 1.340 0.1240 0.0222 0.0173 123.0 8.0
DWS_02: 2019 (2) 84 1.00 RL 2.00 0.235 0.0500 0.0040 0.0050 RL 7.0 8.3
DWS_02: 2020 (1) 190 1.00 RL 2.40 0.365 0.0700 0.0100 0.0130 63.0 8.1
DWS_02: 2020 (2) 68 1 2.10 0.191 0.0400 0.0030 0.0080 63.0 8.1
DWS_02: 2021 (1) - - - - - - - - -
DWS_02: 2021 (2) - - - - - - - - -
DWS_02 Median 137 1.00 2.25 0.300 0.0600 0.0070 0.0105 37.00 8.2
* Unable to obtain sample during the 7/1/2020 - 12/31/2020 timeframe. Additional samples will be collected in 2021, as per MS4
Permit Part IV.6.b. Median concentrations used to calculate 2020 Report Card Grade.
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 15
Evaluation: The MS4 enters data into a local spreadsheet and stores analysis reports for a safe record
upon receipt. Further, the MS4 analyzes the data using the following Scoring Matrix (Matrix) and protocol
to interpret, evaluate, and communicate the results. The Matrix includes points ranging from 0 to 4-points,
which relate to the percent change of pollutants between the upstream and downstream sites.
Example: A percent change of 0-20% equals 4-points, 21-40% equals 3-points, 41-60% equals 2-points, 61-
80% equals 1-point, and 81- >100% equals 0-points.
Percent change is determined using the following formula:
% = ((Y2 – Y1) / Y1) * 100 Equation 2
For example, TSS: ((200-150)/150) x 100 = 33.3%, resulting in a score of 3-points.
Table: 8.5.2: In-Stream Wet-Weather Monitoring: Scoring Matrix
Parameter 4-Points 3-Points 2-Points 1-Point 0-Points
TSS (% ) (<0) – (20) (21) – (40) (41) – (60) (61) – (80) (81) – (>100)
Oil/Grease (% ) (<0) – (20) (21) – (40) (41) – (60) (61) – (80) (81) – (>100)
Total Nitrogen (% ) (<0) – (20) (21) – (40) (41) – (60) (61) – (80) (81) – (>100)
Phosphorus (% ) (<0) – (20) (21) – (40) (41) – (60) (61) – (80) (81) – (>100)
Zinc (% ) (<0) – (20) (21) – (40) (41) – (60) (61) – (80) (81) – (>100)
Lead (% ) (<0) – (20) (21) – (40) (41) – (60) (61) – (80) (81) – (>100)
Copper (% ) (<0) – (20) (21) – (40) (41) – (60) (61) – (80) (81) – (>100)
COD (% ) (<0) – (20) (21) – (40) (41) – (60) (61) – (80) (81) – (>100)
PH (% ) (<0) – (20) (21) – (40) (41) – (60) (61) – (80) (81) – (>100)
The MS4 relates results to the Matrix and then populates the appropriate Urban Runoff Monitoring charts
with the corresponding scores.
Example: A 2018 Bozeman Creek UPS_01 and DWS_01 TSS percent change equaled 35%. The MS4 assigns
and populates the In-Stream Wet-Weather Monitoring: Bozeman Creek UPS_01 and DWS_01 chart TSS
box with 3-points. The same approach applies to all sites and parameters.
Table 8.5.3: In-Stream Wet-Weather Monitoring: Bozeman Creek UPS_01 and DWS_01
Parameter 2018 2019 2020 2022
Event 1 Event 2 Event 1 Event 2 Event 1 Event 2 Event 1 Event 2
TSS 0 1 0 0 4 0 - -
Oil and Grease 4 4 4 4 4 4 - -
Total Nitrogen 4 4 4 0 4 3 - -
Phosphorus 2 0 1 0 4 1 - -
Zinc 4 0 0 0 2 0 - -
Lead 4 0 0 0 0 0 - -
Copper 4 4 0 0 4 4 - -
COD 2 0 2 0 4 1 - -
PH 4 4 4 4 4 4 - -
Event Points: 28 17 15 8 30 17 - -
Annual Points: 45 23 47 -
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 16
Table 8.5.4: In-Stream Wet-Weather Monitoring: Mandeville Creek UPS_02 and DWS_02
Parameter 2018 2019 2020 2022
Event 1 Event 2 Event 1 Event 2 Event 1 Event 2 Event 1 Event 2
TSS 1 4 0 0 0 0 - -
Oil and Grease 4 4 4 4 4 4 - -
Total Nitrogen 4 2 0 0 0 0 - -
Phosphorus 4 3 0 1 0 0 - -
Zinc 0 2 0 1 0 0 - -
Lead 0 0 0 0 0 0 - -
Copper 0 2 0 0 0 2 - -
COD 4 4 0 3 0 0 - -
PH 4 4 4 4 4 4 - -
Event Points: 21 25 8 13 8 10 - -
Annual Points: 46 21 18 -
The MS4 sums the individual scores to obtain an Event Point Total, sums both Event Scores to obtain an
Annual Point Total, and calculates a Final Score by transferring and summing the Annual Points in the In-
Stream Wet-Weather Monitoring: Results chart. Finally, the MS4 divides the Total Points by the Possible
Points. The MS4 transfers the Final Score to SWMP Section 8.8.
Table 8.5.5: In-Stream Wet-Weather Monitoring: Results
Parameter 2018 2019 2021 2022
Bozeman Creek Annual Points 45 23 47 -
Mandeville Creek Annual Points 46 21 18 -
Total Points: 91 44 65 -
Possible Points: 144 144 144 144
Final Score (decimal): .63 .31 .45 -
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 17
Graphic 8.5.6: In-Stream Wet-Weather Monitoring Map
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 18
8.6 Sediment Reduction Monitoring
Introduction: The MS4 conducts Sediment Reduction Monitoring to comply with the Montana DEQ’s
sediment load reduction requirements detailed in the 2013 Lower Gallatin Planning Area TMDL. The MS4
tracks tons captured in BMPs detailed in SWMP Section 2.3 and SWMP Section 2.4.
Table: 8.6.1: Bozeman Creek Sediment Waste Load Reduction
Sediment Source Estimated Load Waste Load
Allocation
Required Load
Reduction Load Reduction
MS4 218 tons/year 137 tons/year 37% 81 tons/year **DEQ Imposed**
Table 8.6.2: Mandeville Creek Sediment Waste Load Reduction
Sediment Source Estimated Load Waste Load
Allocation
Required Load
Reduction Load Reduction
MS4 None None None 10 tons/year **Self Imposed**
Sites: Stormwater treatment units described in SWMP Section 2.5.
Methods: Measurement process described in SWMP Section 2.5.
Analysis: The MS4 analyzes the following parameter:
Total Sediment Captured (tons)
Evaluation: The MS4 enters data into a local spreadsheet for safe record upon receipt. Further, the MS4
incorporates the data into the following Scoring Matrix (Matrix) to interpret, evaluate, and communicate
the results. The Matrix includes scores ranging from 0 to 4-points, which relate to total annual sediment
capture. For example, a load reduction for Bozeman Creek of ≥ 81 tons equals 4-points, 60 – 80 tons equals
3-points, 40 – 59 tons equals 2-points, 20 – 39 tons equals 1-point, and 0 – 19 equals 0-points.
Table 8.6.3: Sediment Reduction Monitoring: Scoring Matrix (Bozeman Creek)
Parameter 4-Points 3-Points 2-Points 1-Point 0-Points
Sediment Captured (tons) ≥81 60 – 80 40 – 59 20 – 39 0 – 19
Table 8.6.4: Sediment Reduction Monitoring: Scoring Matrix (Mandeville Creek)
Parameter 4-Points 3-Points 2-Points 1-Point 0-Points
Sediment Captured (tons) ≥10 7.5 – 9.9 5.0 – 7.4 2.5 – 4.9 0 – 2.4
Results: The MS4 relates results to the Matrix and then populate the Sediment Reduction Monitoring:
Results chart with the corresponding scores. The MS4 weighs Bozeman Creek more heavily than
Mandeville Creek because of DEQ’s imposed reduction requirements.
2018 Totals:
Bozeman Creek: 45.7 tons
Mandeville Creek: 1.0 tons
2019 Totals:
Bozeman Creek: 44.8 tons
Mandeville Creek: 5.8 tons
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 19
2020 Totals:
Bozeman Creek: 41 tons
Mandeville Creek: 8 tons
The MS4 calculates a Final Score by summing the weighted Annual Points in the Sediment Reduction
Monitoring: Results chart and dividing by the Possible Points to calculate the Final Score. Finally, the MS4
transfers the Final Score to SWMP Section 8.8.
Table 8.6.5: Sediment Reduction Monitoring: Results
Waterway 2018 2019 2021 2022
Bozeman Creek Annual Points (2) x (1.5) = 3 (2) x (1.5) = 3 (2) x (1.5) = 3 -
Mandeville Creek Annual Points (0) x (.5) = 0 (2) x (.5) = 1 (3 )x (.5) = 1.5 -
Total Points: 3 4 4.5 -
Possible Points: 8 8 8 8
Final Score (decimal): 0.38 0.50 0.56 -
8.7 Long-Term Trend Monitoring
Introduction: Aquatic macroinvertebrate assemblages respond predictably to sedimentation by shifting
from sediment-intolerant to sediment-tolerant taxa. Changes in macroinvertebrate assemblages are
quantified using the Observed:Expected (O:E) ratio biological index model, which compares the observed
taxa at a site with the expected taxa that would be present at a site under a variety of environmental
conditions. Using the percent difference in O:E ratios between upstream and downstream sites the MS4
is able to assess stormwater discharge impacts to macroinvertebrate assemblages. A positive percent
difference in O:E ratios indicate that stormwater discharges are not negatively impacting
macroinvertebrate community assemblages. Conversely, negative percent differences in O:E ratios
indicate that stormwater discharges are negatively impacting macroinvertebrate community assemblies.
Sedimentation affects macroinvertebrates community assemblages by:
Filling interstitial voids in gravel substrate
Reducing gravel attachment sites
Altering stream morphology
Increasing stream temperature
Sites: The MS4 monitors benthic macroinvertebrates on Bozeman and Mandeville Creeks at the In-Stream
Wet-Weather Monitoring Sites (SWMP Section 8.5).
Methods: The MS4 derives macroinvertebrate biological index monitoring protocols from MDEQ Sample
Collection, Sorting, and Taxonomic Identification of Benthic Macroinvertebrate Communities Standard
Operating Procedures (one sample taken per location per year).
Analysis: The MS4 collects and preserves macroinvertebrate samples and then delivers to an accredited
lab, which completes the analysis of the following parameters:
Taxonomic Sorting and Identification
Species Abundance
Species Diversity
Observed / Expected Ratios
Percentage of Sediment Tolerant Species
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 20
Upon receiving macroinvertebrate analysis results, the MS4 enters the calculated O:E ratios in the table
below and then calculates the percent change between upstream and downstream sites.
Graphic 8.7.1: Monitoring Results: UPS_01 & DWS_01
Year O:E Ratio: UPS_01 O:E Ratio: DWS_01 O:E Ratio (% )
2018 0.20 0.37 +85%
2019 0.33 0.20 -39%
2020 0.29 0.33 +14%
2021 - - -
Table 8.7.2: Monitoring Results: UPS_02 & DWS_02
Year O:E Ratio: UPS_02 O:E Ratio: DWS_02 O:E Ratio (% )
2018 0.29 0.16 -45%
2019 0.29 0.25 -14%
2020 0.12 0.20 +67%
2021 - - -
Evaluation: The MS4 enters data into a local spreadsheet and stores analysis reports for a safe record
upon receipt. Further, the MS4 analyzes the data using the following Scoring Matrix and protocol to
interpret, evaluate, and communicate the results. The Scoring Matrix includes scores from 0 to 4-points,
which relate to percent change in O:E ratios between the upstream and downstream sites for each creek.
Example: An O:E ratio percent change of 0-(-20%) equals 4-points,- 21-(-40%) equals 3-points,- 41-(-60%)
equals 2- points, -61-(-80%) equals 1-point, and >-80% equals 0-points.
Percent change is determined using Equation 2 found in SWMP Section 8.3.
Example: An upstream Bozeman Creek sample has an O:E ratio of 1.1, and the downstream sample has an
O:E ratio of 0.8. The MS4 finds the difference and divides by the original to arrive at a percentage ((0.8 -
1.1)/1.1) x 100 = -30%, resulting in a score of 3-points.
Table 8.7.3: Long-Term Trend Monitoring: Scoring Matrix
O:E Ratio 4-Points 3-Points 2-Points 1-Point 0-Points
O:E Ratio (% ) >0 – (-20) -21 – (-40) -41 – (-60) -61 – (-80) -81 – (-100)
The MS4 relates results to the Matrix and then populates the Long-Term Trend Monitoring: Results chart
with the corresponding scores, and calculates a Final Score by summing the Event Points in the Long-Term
Trend Monitoring: Results chart and dividing by the Possible Points. Finally, the MS4 transfers the Final
Score to SWMP Section 8.8.
Table 8.7.4: Long-Term Trend Monitoring: Results
Waterway 2018 2019 2020 2021
Bozeman Creek Event Points 4 3 4 -
Mandeville Creek Event Points 2 4 4 -
Total Points: 6 7 8 -
Possible Points: 8 8 8 -
Final Score (decimal): .75 0.88 1.0 -
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 21
8.8 Evaluation
The MS4 calculates a Final Grade to determine the overall effectiveness of its programs and initiatives
detailed in SWMP Section 1.0 to 7.0 by transferring scores from each protocol (SWMP Sections 8.4 - 8.7)
to the Programmatic Evaluation: Final Points chart, and utilizes a weighted sum calculation to make the
four scores comparable.
Table 8.8.1: Programmatic Evaluation: Final Points (2018)
Evaluation Type Final Scores Weight Weighted
Total
Weighted
Total (%)
Urban Runoff Monitoring .62 .25 .155 15.5%
In-Stream Wet-Weather Monitoring .63 .25 .16 16.0%
Sediment Reduction Monitoring .38 .25 .10 10.0%
Stream Health Monitoring .75 .25 .19 19.0%
Final Weighted Total (%): 60.5%
Table 8.8.2: Programmatic Evaluation: Final Points (2019)
Evaluation Type Final Scores Weight Weighted
Total
Weighted
Total (%)
Urban Runoff Monitoring 0.47 .25 0.1175 11.75%
In-Stream Wet-Weather Monitoring 0.31 .25 0.0775 7.75%
Sediment Reduction Monitoring 0.50 .25 0.1250 12.50%
Stream Health Monitoring 0.88 .25 0.2200 22.00%
Final Weighted Total (%): 54.0%
Table 8.8.3: Programmatic Evaluation: Final Points (2020)
Evaluation Type Final Scores Weight Weighted
Total
Weighted
Total (%)
Urban Runoff Monitoring 0.59 .25 0.1475 14.75%
In-Stream Wet-Weather Monitoring *0.45 .25 *0.1125 11.25%
Sediment Reduction Monitoring 0.56 .25 0.1400 14.00%
Stream Health Monitoring 1.0 .25 0.25 25.00%
Final Weighted Total (%): 65.0%
Table 8.8.4: Programmatic Evaluation: Final Points (2021)
Evaluation Type Final Scores Weight Weighted
Total
Weighted
Total (%)
Urban Runoff Monitoring - .25 - -
In-Stream Wet-Weather Monitoring - .25 - -
Sediment Reduction Monitoring - .25 - -
Stream Health Monitoring - .25 - -
Final Weighted Total (%): -
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 22
The MS4 relates the Final Weighted Total (%) to the following equally distributed ranges (100-percent
scale) and their associated Final Grades, and populates the Stormwater Report Card with a Final Grade for
the corresponding year.
Table 8.8.5: Grading Matrix
Grade A B C D F
Score (%) 90 - 100% 80 - 89% 70 - 79% 60 - 69% 0 - 59%
Table 8.8.6: Stormwater Report Card
2018 Final Grade 2019 Final Grade 2020 Final Grade 2021 Final Grade
D
61%
F
54% D
65% -
The MS4 utilizes its empirical knowledge, performance measures, and data to continually evaluate and
optimize its programmatic workloads detailed in this SWMP. Also, the MS4 compares its Final Grades to
the criteria below and, as necessary, works to implement the following improvement strategies:
Grade = A: No stormwater impact on receiving waters, allowing for a continuation of
administrative programs and reduction of TMDL Action Plan investment to maintain grade.
Grade = B: Low stormwater impact to receiving waters, requiring continuation of administrative
programs and TMDL Action Plan investment to increase grade.
Grade = C: Moderate stormwater impact on receiving waters, requiring an expansion of
administrative programs and continuation of TMDL Action Plan investment to increase grade.
Grade = D: Significant stormwater impact on receiving waters, requiring an expansion of
administrative programs and TMDL Action Plan investment to increase grade.
Grade = F: Major stormwater impact on receiving waters, reassessment of administrative
programs and TMDL Action Plan investment strategy required.
8.9 Discussion
2017 Result: The MS4 did not document sampling efforts using the scoring matrices described
above because Staff had not developed the evaluation. Implementation begins with the first
sampling event of 2018.
Preliminary analysis of available 2017 data indicates that the developed evaluation methodology
is effective at tracking program performance, and likely would have resulted in an F. The MS4
expects a positive trend over the MS4 Permit Term as Staff implements the content of this SWMP.
2018 Results: The MS4 received a Stormater River Impact Report Card grade of D. The MS4 has
analyzed data, compiled point scores, and developed strategies to improve its grade for 2019,
including:
Residential Urban Runoff Monitoring
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 23
Problem Statement: Residential urban areas generally yield TSS, total nitrogen,
phosphorus, and COD levels that result in suboptimal point scores. Conversely, oil,
grease, zinc, lead, and copper concentrations generally result in satisfactory levels.
Hypothesis: Grass clippings are primarily responsible for elevated levels of TSS, total
nitrogen, phosphorus, and COD.
Rationale: Elevated pollutant levels coincide directly with the growing season,
providing justification for the MS4’s hypothesis. Fall samples traditionally yield
optimal point scores due to growing season subsidence. Organic matter in
stormwater runoff:
Increases TSS concentrations
Increases total nitrogen and phosphorus via decomposition
Increases COD via organic matter decomposition
Action Plan: Increase outreach and education program described in SWMP Section
3.0 and complete capital projects described in SWMP Section 2.3.
Industrial Urban Runoff Monitoring
Problem Statement: Industrial urban areas generally yield TSS, total nitrogen,
phosphorus, zinc, lead, copper, and COD levels that result in suboptimal point scores.
Conversely, oil and grease concentrations generally result in satisfactory levels.
Hypothesis: Gravel parking lots, outdoor equipment storage, and heavy commercial
traffic are primarily responsible for elevated levels of TSS, total nitrogen, phosphorus,
zinc, copper, lead, and COD.
Rationale: The MS4 documented these pollutant generating activities and site
conditions at both industrial monitoring areas, resulting in:
Increased offsite TSS migration (TSS adsorbs and transports pollutants)
Increased nutrient levels originating from erosive landscapes
Increased metal levels from corrosion, combustion, and brake-dust
Increase COD levels via organic and inorganic particle decomposition
Action Plan: Enforce development regulations described in SWMP Section 6.0,
construct capital projects described in SWMP Section 2.3, maintain good
housekeeping performance levels described in SWMP Section 7.0, and implement the
outreach and education program described in SWMP Section 3.0.
Instream Wet-Weather Monitoring
Problem Statement: Instream wet-weather samples generally yield TSS, total
nitrogen, phosphorus, zinc, lead, copper, and COD levels that result in suboptimal
point scores. Conversely, oil and grease concentrations generally result in satisfactory
levels.
Hypothesis: Stormwater discharges from urban areas with a direct connection to
aquatic systems negatively affect instream water quality.
Rationale: Documented increases in pollutant levels between all upstream and
downstream instream-monitoring locations, resulting from developments
constructed pre-1980 lacking on-site stormwater treatment.
Action Plan: Enforce development regulations described in SWMP Section 6.0,
construct capital projects described in SWMP Section 2.3 and implement
administrative programs described in SWMP Sections 3.0, 4.0, 5.0, 6.0, and 7.0.
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 24
Sediment Reduction Monitoring
Problem Statement: Remove 81 tons/year of sediment from stormwater discharges
to Bozeman Creek and 10 tons/year to Mandeville Creek.
Hypothesis: Achieve MDEQ and self-imposed sediment reduction requirements by
2023.
Rationale: Quantified sediment removal totals by treatment units as detailed in
SWMP Section 2.5 and calculated sediment-loading totals of 0.14 tons/acre.
Action Plan: Continue TMDL Action Plan described in SWMP Section 2.2, construct
capital projects described in SWMP Section 2.3, and maintain utility operations goals
described in SWMP Section 7.0.
Long-Term Trend Monitoring
Problem Statement: Macroinvertebrate O:E ratios decreased in Mandeville Creek,
resulting in suboptimal point scores. Conversely, macroinvertebrate O:E ratios
increased in Bozeman Creek, resulting in optimal point scores. Hypothesis: Physical habitat characteristics and stream origination points impact
macroinvertebrate O:E ratios in addition to stormwater discharges.
Rationale:
85% improvement in Bozeman Creek O:E ratios between upstream and
downstream sites.
45% reduction in Mandeville Creek O:E ratios between upstream and
downstream sites.
Action Plan: Continue TMDL Action Plan described in SWMP Section 2.2, construct
capital projects described in SWMP Section 2.3, maintain utility operation goals
described in SWMP Section 7.0, and implement administrative programs described in
SWMP Sections 3.0, 4.0, 5.0, 6.0, and 7.0.
2019 Results: The MS4 received a grade of F (54.0%), which is 6.5% lower than the 2018 grade.
Various factors influenced this score and are further described below:
Residential Urban Runoff Monitoring
Analysis:
Spring Samples: Collected on April 20, 2019. Record 2019 snowfall resulted in
increased traction sand application and delayed street sweeping cycles,
yielding pollutant concentrations above long-term medians for TSS, Oil and
Grease, Total Nitrogen, Total Phosphorous, Zinc, Lead, Copper, and COD.
Fall Samples: Collected on August 22, 2019. Reoccurring street sweeping and
implementation of SWMP programs resulted in a reduction in the number of
pollutants exceeding long-term medians. Total Nitrogen, Total Phosphorus,
Zinc, and COD concentrations were above the long-term medians, likely
resulting from organics, such as grass clippings.
Action Plan: Increase outreach and education programs described in SWMP Section
3.0, maintain good housekeeping performance levels described in SWMP Section 7.0,
and complete capital projects described in SWMP Section 2.3.
Industrial Urban Runoff Monitoring
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 25
Analysis:
Spring Samples: Collected on April 20, 2019. Record 2019 snowfall resulted in
increased traction sand application and delayed street sweeping cycles,
yielding pollutant concentrations above long-term medians for TSS, Oils and
Grease, Total Phosphorous, Zinc, Lead, Copper, and COD.
Fall Samples: Collected on August 22, 2019. Reoccurring street sweeping and
implementation of SWMP programs resulted in a reduction of the number of
pollutants exceeding long-term medians. Total Nitrogen, Zinc, Lead, Copper,
and COD concentrations were above the long-term medians, resulting from
heavy commercial traffic, equipment storage, and historical development
practices.
Action Plan: Enforce development regulations described in SWMP Section 6.0,
construct capital projects described in SWMP Section 2.3, maintain good
housekeeping performance levels described in SWMP Section 7.0, and implement the
outreach and education program described in SWMP Section 3.0.
Instream Wet-Weather Monitoring
Analysis:
Spring Samples: Collected on June 13, 2019 during a non-typical high intensity
and short duration storm (greater than 1” per hour) that resulted in
suboptimal percent change scores for TSS, Total Nitrogen, Total
Phosphorous, Zinc, Lead, Copper, and COD. Bozeman Creek flow at the time
of collection was 63 cfs (221 cfs max daily flow). Non-typical storms result in
increased erosion and mobilization of pollutants.
Fall Samples: Collected on September 6, 2019 during low base-flow
conditions that resulted in suboptimal percent change scores for TSS, Total
Nitrogen, Total Phosphorous, Zinc, Lead, Copper, and COD. Bozeman Creek
flow at the time of collection was 27 cfs (38 cfs max daily flow).
Action Plan: Enforce development regulations described in SWMP Section 6.0,
construct capital projects described in SWMP Section 2.3, and implement
administrative programs described in SWMP Sections 3.0, 4.0, 5.0, 6.0, and 7.0.
Sediment Reduction Monitoring
Analysis: Sediment loading within the various treated urban basins averaged .13
tons/acre, .01 tons/acre less than the previous year. Sediment collection totals
increased from 46.7 in 2018 to 50.6 tons in 2019. The MS4 installed five new
treatment structures in 2019, resulting in increased sediment collection totals.
Action Plan: Continue TMDL Action Plan described in SWMP Section 2.2, construct
capital projects described in SWMP Section 2.3, and maintain utility operations goals
described in SWMP Section 7.0.
Long-Term Trend Monitoring
Analysis: Data showed a 39% decrease in Bozeman Creek and a 14% decrease in
Mandeville Creek O:E ratios. Bozeman Creek’s macroinvertebrate community did not
show an improvement based on the prior year’s data. Mandeville Creek’s
macroinvertebrate community did improve based on the prior year’s data. More
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 26
sampling events are required to show a trend in this data set, as two data points for
each location are not adequate to assess stream health. O:E ratios for both Creek’s
upstream sample locations are well below the reference streams benchmark and
appear to be impacted by other pollution sources originating outside of MS4 limits.
Action Plan: Continue TMDL Action Plan described in SWMP Section 2.2, construct
capital projects described in SWMP Section 2.3, maintain utility operation goals
described in SWMP Section 7.0, and implement administrative programs described in
SWMP Sections 3.0, 4.0, 5.0, 6.0, and 7.0.
2020 Results: The MS4 received a grade of D (65%), which is 11% higher than the 2019 grade, 4%
higher than the 2018 grade, and the highest score recorded to date. The increase in the score may
suggest the various structural and administrative BMPs implementd in this SWMP are having a
positive impact, providing justification to contiue its planned efforts. Various factors influenced
this score and are further described below:
Residential Urban Runoff Monitoring
Analysis:
Spring Samples: Collected on June 24, 2020. A high intensity-short duration
storm event and an abundance of grass clippings in the RES_01 sample
yielded pollutant concentrations above long-term medians for TSS, Oils and
Greases, Total Nitrogen, Total Phosphorous, Zinc, Lead, Copper, and COD. TSS
concentration was 700% above it long-term median, likely a result of grass
clippings. The RES_02 sample yielded pollutant concentrations above long-
term medians for TSS, Total Nitrogen, Total Phosphorus, Zinc, and Lead. Oils
and Greases, Copper, and COD concentrations were below long-term
medians. High intensity - short duration storm events are known to have
increased pollutant concentrations in the first flush of runoff.
Fall Samples: Collected on October 13, 2020. Reoccurring street sweeping
and implementation of SWMP programs resulted in pollutant concentration
below the long-term median for all parameters, except for COD (RES_01),
which was 16.9% above the long-term median.
Action Plan: Increase outreach and education programs described in SWMP Section
3.0, maintain good housekeeping performance levels described in SWMP Section 7.0,
and complete capital projects described in SWMP Section 2.3.
Industrial Urban Runoff Monitoring
Analysis:
Spring Samples: Collected on June 24, 2020. Gravel parking lots, metal
buildings, lack of street sweeping, observed outdoor industrial operations
and storage, and a high intensity – short duration storm event yielded
pollutant concentrations above long-term medians for TSS, Total Nitrogen,
Total Phosphorous, Zinc, Lead, Copper, and COD at IND_01. Oils and Greases
concentration at IND_01 were below long-term median concentrations.
IND_02 results yield pollutant concentrations above long-term medians for
TSS, Total Nitrogen, Zinc, Lead, Copper, and COD, likely due to storm event
characteristics and the surrounding industrial land use. Oils and Greases and
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 27
Total Phosphorus concentrations were below their long-term medians at
IND_02.
Fall Samples: Collected on October 13, 2020. Zinc was the only pollutant to
exceed its long-term median at IND_01. Elevated levels of Zinc may be the
result from surrounding metal buildings, lack of street sweeping, and
observed outdoor industrial operations and storage. IND_01 TSS, Oils and
Greases, Total Nitrogen, Total Phosphorus, Lead, Copper, and COD
concentrations were all below long-term median concentrations, possibly
because of the low intensity nature of the storm event sampled. Pollutant
concentrations for all parameters at IND_02 were below long-term medians.
Action Plan: Enforce development regulations described in SWMP Section 6.0,
construct capital projects described in SWMP Section 2.3, maintain good
housekeeping performance levels described in SWMP Section 7.0, and implement the
outreach and education program described in SWMP Section 3.0.
Instream Wet-Weather Monitoring
Analysis:
Spring Samples: Collected on June 28, 2020 during a high intensity - short
duration storm that resulted in suboptimal percent change scores for only
Zinc and Lead. Bozeman Creek flow at the time of collection was 48 cfs (54
cfs max daily flow). Minimal impacts to Bozeman Creek resulting from
stormwater discharges. On Mandeville Creek, the sampling event led to
suboptimal point scores for all parameters except for Oils and Greases and
pH. Stormwater discharges had significant impacts to Mandeville Creek.
Fall Samples: The MS4 was unable to collect a fall sample from
UPS_01/DWS_01 due to sampling equipment malfunction at UPS_01. The
long-term medians for both UPS_01 and DWS_01 were used to calculate the
point score. A substitute sample will be collected as per General Permit Sec.
IV.6.b. Sampling results, point score, and Report Card grade will be updated
upon analysis of the substitute sample. On Mandeville Creek, the sampling
event led to suboptimal point scores for all parameters except for Oils and
Greases and pH. Stormwater discharges had significant impacts to Mandeville
Creek.
Action Plan: Collect UPS_01/DWS_01 substitute samples, enforce development
regulations described in SWMP Section 6.0, construct capital projects described in
SWMP Section 2.3, and implement administrative programs described in SWMP
Sections 3.0, 4.0, 5.0, 6.0, and 7.0.
Sediment Reduction Monitoring
Analysis: Sediment loading within the various treated urban basins averaged .09
tons/acre, .04 tons/acre less than the previous year. Sediment collection totals
increased from 50.6 in 2019 to 54.6 tons in 2020. The MS4 installed eight new
treatment structures in 2020, however the new structures’ sediment capture totals
are not included due to the timing of installation.
SECTION 8.0 - SAMPLING AND EVALUATION PROGRAM 28
Action Plan: Continue TMDL Action Plan described in SWMP Section 2.2, construct
capital projects described in SWMP Section 2.3, and maintain utility operations goals
described in SWMP Section 7.0.
Long-Term Trend Monitoring
Analysis: Data showed a 14% increase in Bozeman Creek and a 67% increase in
Mandeville Creek O:E ratios. Bozeman Creek’s macroinvertebrate community
showed a 53% improvement based on the prior year’s data. Mandeville Creek’s
macroinvertebrate community showed an 81% improvement based on the prior
year’s data. More sampling events are required to show a trend in this data set, as
three data points for each location are not adequate to assess stream health. O:E
ratios for both Creek’s upstream sample locations are well below the reference
streams benchmark and appear to be impacted by other pollution sources originating
outside of the MS4.
Action Plan: Continue TMDL Action Plan described in SWMP Section 2.2, construct
capital projects described in SWMP Section 2.3, maintain utility operation goals
described in SWMP Section 7.0, and implement administrative programs described in
SWMP Sections 3.0, 4.0, 5.0, 6.0, and 7.0.
Section 9.0
Stormwater Management Plan Updates
Graphic: 9.0.1: Permeable Paver WalkwayGraphic 9.0.2: Boulevard Infiltration Gallery
SECTION 9.0 – STORMWATER MANAGEMENT PLAN UPDATES 2
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SECTION 9.0 – STORMWATER MANAGEMENT PLAN UPDATES 3
9.1 Introduction
The MS4 updates the information in this SWMP annually, and tracks change specific to each section. This
SWMP requires changes to meet operation and policy adjustments that occur in local government.
9.2 Program Administration (SWMP Section 1.0)
January/February 2020:
Section 1.1: Updated and simplified MS4 objective language.
Section 1.2: Completed minor grammar updates.
Section 1.3: Removed ERU total of “$3.23” as the fee changes annually with rate increases.
Section 1.3: Updated the description of the utility rate model workflow to improve clarity.
Section 1.3: Updated the 2019 total impervious area and total site plan performance measure.
Section 1.3: Added the FY20 Approved Budget information.
Section 1.3: Added Graphic 1.3.1 to show budget and staffing changes over time.
Section 1.4: Updated project information and staff hours, added FY20 Budget information.
Section 1.5: Added new Stormwater Infrastructure Specialist, clarified organizational structure,
added SWMP Support Divisions, removed future positions, and changed meeting frequencies.
Section 1.5: Updated Graphic 1.5.1.
Section 1.5: Updated Graphic 1.5.2 to include 2019 numbers, recalculated totals.
Section 1.6: Added mechanical separation unit, added responsibilities related to the Post
Construction Program.
Section 1.7: Updated Gallatin Watershed Council’s name.
Section 1.10: Updated 2019 and 2020 SWMP advertisement dates, and added public comments.
January/February 2021:
Sections 1.1-1.10: Streamlined sections, removed excess language, reformatted duplicate
information into charts, and corrected grammatical errors.
Section 1.1: Added puctuation and removed language referencing “Master Plan”.
Section 1.2: Completed minor grammar updates and clarified language.
Section 1.2: Removed language regarding an MOU requirement between the City and MSU.
Section 1.3: Updated the 20 total impervious area and total site plan performance measure.
Section 1.3: Added the FY21 Approved Budget information.
Section 1.3: Updated Graphic 1.3.1 and 1.3.2.
Section 1.3: Added Graphics 1.3.3 -1.3.6.
Section 1.3: Removed excess language, clarified content, and reformatted.
Section 1.4: Added the FY21 Approved Budget information.
Section 1.4: Removed excess language, clarified content, and reformatted.
Section 1.5: Updated and clarified language for all positions.
Section 1.5: Updated Graphic 1.5.1 to include 2020 numbers, recalculated totals.
Section 1.6: Completed minor language edits.
Section 1.7: Updated section title and completed wording edits.
Section 1.8: Removed two permit references.
Section 1.10: Updated 2021 SWMP advertisement dates, and updated Graphic 1.10.1.
9.3 Capital Project Program (SWMP Section 2.0)
January/February 2020:
Section 2.1: Removed language related to specialized equipment, updated subprogram goals
SECTION 9.0 – STORMWATER MANAGEMENT PLAN UPDATES 4
Section 2.2: Added “over” before $650,000 and updated vitrified clay pipe total
Section 2.2: Completed numerous grammar updates
Section 2.3: Updated performance metrics, clarified some language, relocated completed projects
and added new projects
Section 2.4: Updated Ongoing and Completed projects, clarified some names and categories
Section 2.4.2 and 2.4.3: Updated graphics
Section 2.5: Updated pollutant reduction totals
Section 2.6: Updated performance measures
January/February 2021:
Sections 2.1-2.6: Streamlined sections, removed excess language, reformatted duplicate
information into charts, and corrected grammatical errors.
Section 2.2: Revised the Total Maximum Daily Load Action Plan.
Section 2.3: Updated performance metrics and projects.
Section 2.4: Updated projects and graphics, and clarified some names and categories.
Section 2.5: Updated pollutant reduction totals.
Section 2.6: Updated performance measures.
9.3 Public Education Program (SWMP Section 3.0)
January/February 2020:
Section 3.2: Clarified language under passive and active engagement sections
Section 3.3: Updated group to include MSU Students
Section 3.4: Clarified existing activities, added new activities, updated performance measures,
added tasks, goal, and notes for each item per year
Section 3.5: Removed Adopt A Rain Garden and moved it into the ongoing initiatives section
January/February 2021:
Sections 3.1-3.4: Streamlined sections, removed excess language, reformatted duplicate
information into charts, and corrected grammatical errors.
Section 3.3: Improved formatting.
Section 3.4: Updated intiative information.
9.4 Illicit Discharge Detection and Elimination Program (SWMP Section 4.0)
January/February 2020:
Section 4.4: Added 2019 events and updated Graphics 4.4.1 and 4.4.2
Section 4.6: Updated total outfall numbers per each waterway, updated high priority outfall
information and 2019 inspection results, and updated 2019 ORI inspection totals
Section 4.7: Added 2019 infrastructure totals and updated Graphic 4.7.1
January/February 2021:
Sections 4.1-4.8: Streamlined sections, removed excess language, reformatted duplicate
information into charts, and corrected grammatical errors.
Section 4.3: Changed Response Protocol to Corrective Action Plan. Expanded and added detail to
contained sections to provide additional detail regarding the MS4’s process.
Section 4.4: Improved language related to the MS4’s Enforcement Response Plan.
Section 4.5: Added 2020 events and updated Graphics
SECTION 9.0 – STORMWATER MANAGEMENT PLAN UPDATES 5
Section 4.6: Updated controls for hot tub and pool discharge and remove construction
dewatering, which is covered under SWMP Section 5.0.
Section 4.7: Updated graphics provided more information regarding the MS4’s ORI Inspection
Plan, and updated high-priority outfall inspection information.
Section 4.8: Updated storm sewer infrastructure totals.
9.5 Construction Site Management Program (SWMP Section 5.0)
January/February 2020:
Section 5.1: Updated #3 to include the mention of inspection
Section 5.3: Added final occupancy and infrastructure approval section
Section 5.3: Added 2019 totals and updated Graphic 5.3.1
Section 5.4: Added 2019 performance totals and audit results, updated Graphic 5.4.1
Section 5.5: Removed timeline for item #1
January/February 2021:
Sections 5.1-5.8: Streamlined sections, removed excess language, reformatted duplicate
information into charts, and corrected grammatical errors.
Section 5.3: Updated to be specific to the MS4’s permitting program and account for operational
changes made during 2020.
Section 5.4: Added section to better aling with the requirments of the MS4 Permit, including a
flow chart and description of the MS4’s enforcement process.
Section 5.5: Added section to include more detailed information regarding high-priority sites and
rain events, added 2020 totals, reformatted tables, and updated Graphic.
Section 5.6: Added 2020 performance totals and audit results and updated the chart.
Section 5.8: Updated document names.
9.6 Post-Construction Program (SWMP Section 6.0)
January/February 2020:
Section 6.3: Updated Graphic 6.3.1
Section 6.4: Added 2019 performance totals, updated Graphic 6.4.1, added 2019 audit results,
and updated Graphic 6.4.2
January/February 2021:
Sections 6.1-6.9: Streamlined sections, removed excess language, reformatted duplicate
information into charts, and corrected grammatical errors.
Sections 6.1-6.9: Revised the entire section to account for programmatic changes and improve
alignment with the MS4 Permit.
9.7 Good Housekeeping Program (SWMP Section 7.0)
January/February 2020:
Section 7.2: Clarified language and added 2019 performance totals
Section 7.3: Clarified Facility Minimum Standards, updated Facility Stormwater Pollution
Prevention Plan protocols, updated Graphic 7.3.1, updated completion performance metric, and
removed performance metric related to standard violations
SECTION 9.0 – STORMWATER MANAGEMENT PLAN UPDATES 6
Section 7.4: Clarified Activity Minimum Standards, updated Activity Stormwater Pollution
Prevention Plan protocols, updated completion performance metric, and removed performance
metric related to standard violations
Section 7.5: Updated 2019 training activities and totals
January/February 2021:
Sections 7.1-7.5: Streamlined section, removed excess language, reformatted duplicate
information into charts, and corrected grammatical errors.
Section 7.2: Adjusted infrastructure maintenance frequencies and updated performance totals.
Section 7.3: Modified Facility Minimum Standards, updated Facility Stormwater Pollution
Prevention Plan protocols, added tables and updated map, and removed performance metric.
Section 7.4: Modified Activity Minimum Standards, updated Activity Stormwater Pollution
Prevention Plan protocols, and removed completion performance metric.
Section 7.5: Developed training section to include tables and updated strategies, updated
participation numbers, and updated training events.
9.8 Sampling and Evaluation Program (SWMP Section 8.0)
January/February 2020:
Section 8.4: Added 2019 raw data and updated point scores
Section 8.5: Added 2019 raw data and updated point scores
Section 8.6: Added 2019 raw data and updated point scores
Section 8.7: Added 2019 raw data and updated point scores
Section 8.8: Calculated 2019 score and updated Graphic 8.8.5
Section 8.9: Added 2019 Results
January/February 2021:
Sections 8.1-8.9: Streamlined section, removed excess language, reformatted duplicate
information into charts, and corrected grammatical errors.
Section 8.4: Added 2020 raw data and updated point scores.
Section 8.5: Added 2020 raw data and updated point scores.
Section 8.6: Added 2020 raw data and updated point scores.
Section 8.7: Added 2020 raw data and updated point scores.
Section 8.8: Calculated 2020 score and updated Graphic 8.8.5.
Section 8.9: Added 2020 Results.