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Federal and State Requirements

Truckee Meadows Stormwater Quality Management Program

The Truckee Meadows Interlocal Stormwater Committee is legally bound to address stormwater pollution based on the requirements of two federal programs, the National Pollutant Discharge Elimination System (NPDES) Stormwater Permit Program and the Total Maximum Daily Load (TMDL) program. In Nevada, both of these programs are implemented by the state through the Nevada Division of Environmental Protection (NDEP). The NPDES permit requires the permittees to form a committee and to develop, administer, implement, and enforce a Stormwater Quality Management Program. The TMDL program applies to water bodies that are not meeting federal water quality standards, such as the Truckee River, and requires that the sources of pollution be assessed and that limits be set on the amount of pollution discharged to the water body.

The National Pollutant Discharge Elimination System Stormwater Permit Program

In 1987, Congress amended the Federal Water Pollution Control Act (also known as the Clean Water Act) in order to protect water bodies from the impacts of urban runoff. The Clean Water Act prohibits the discharge of any pollutant to waters of the United States from a point source, such as a factory or a sewage treatment plant, unless the discharge is authorized by a National Pollutant Discharge Elimination System (NPDES) permit. The NPDES program is a national permit program designed to regulate point source discharges. The 1987 amendments to the Clean Water Act defined stormwater discharges as point source discharges and established a framework for regulating municipal and industrial discharges under the NPDES program. In response to the 1987 amendments, the U.S. Environmental Protection Agency (EPA) promulgated the final regulations in 1990 that established the permit requirements for Phase I of the NPDES Stormwater Program.

The Phase I NPDES Stormwater Program addressed sources of stormwater runoff that had the greatest potential to negatively impact water quality nationwide. Under Phase I, EPA required NPDES permit coverage for stormwater discharges from medium and large municipal separate storm sewer systems (MS4s) located in incorporated places or counties with populations of 100,000 or more. In addition, Phase I required permit coverage for discharges from eleven categories of industrial activities, including construction activities that disturb five or more acres of land. In response to the Phase I NPDES permit requirements; the State of Nevada issued the City of Reno, the City of Sparks, Washoe County and the Nevada Department of Transportation their first permit on July 31, 1990.

In 1999, the EPA published the Phase II Final Rule for the NPDES Stormwater Program. Phase II requires permit coverage for stormwater discharges from certain regulated small municipal separate storm sewer systems (MS4s) and for construction activities disturbing between 1 and 5 acres of land. Under Phase II, operators of regulated small MS4s are required to design their programs to reduce the discharge of pollutants in stormwater to the "maximum extent practicable" (MEP), to protect water quality and to satisfy the appropriate requirements of the Clean Water Act. While Phase II rules do not supersede the Phase I requirements, Phase I communities such as the Truckee Meadows are encouraged by EPA and the State of Nevada to meet these minimum requirements. The Phase II Rule defines a small MS4 stormwater management program as a program comprised of six "minimum control measures" that, when implemented in concert, are expected to result in significant reductions of pollutants discharged into receiving water bodies. These "minimum control measures" consist of the following elements:

  • Public Education and Outreach
  • Public Participation/Involvement
  • Illicit Discharge Detection and Elimination
  • Construction Site Runoff Control
  • Post Construction Runoff Control
  • Pollution Prevention/Good Housekeeping

The Truckee Meadows Regional Stormwater Quality Management Program has been developed to meet these "minimum control measures."

Requirements of the Current Truckee Meadows National Pollutant Discharge Elimination System Permit

In accordance with the provisions of the Clean Water Act, the City of Reno, as lead agency for the Truckee Meadows Interlocal Stormwater Committee, applied for and was granted a National Pollutant Discharge Elimination System (NPDES) permit in January 2000. The Nevada Division of Environmental Protection (NDEP) issued the permit to the City of Reno, the City of Sparks, Washoe County and the Nevada Department of Transportation (the co-permittees). These jurisdictional entities own and operate the municipal storm drain system in the Truckee Meadows. The 5-year NPDES permit authorizes these co-permittees to discharge municipal stormwater runoff to the receiving waters of the Truckee River, Silver Lake Playa, Swan Lake Playa and Whites Lake Playa and their tributaries. The permit outlines a schedule of stormwater discharge monitoring and reporting requirements, the implementation of best management practices (BMPs), programs implemented to detect and eliminate illegal discharges, and public education and participation activities to promote the reduction of pollutants in stormwater discharges.

The Truckee Meadows Interlocal Stormwater Committee contracted with a professional engineering firm to assist in developing the Truckee Meadows Regional Stormwater Quality Management Program, a comprehensive program designed to meet the requirements of the NPDES permit.

The NPDES permit also requires the submittal of annual reports. Seven specific program areas must be addressed and summarized in an annual report to the NDEP. The annual reports shall include:

  • The current Stormwater Quality Management Program.
  • The proposed Stormwater Quality Management Program (i.e. revisions that will be made in response to lessons learned in implementing the program).
  • Data analysis and pollutant load estimates.
  • Drainage basin map updates.
  • Inspections and enforcements.
  • Public education activities.
  • Annual expenditures and budget for the coming year.

The Total Maximum Daily Load Program

The Clean Water Act also established a program to manage water pollution to water bodies that are not meeting federal water quality standards. Section 303(d) requires that states establish a list of water bodies that are impaired by water pollution, and to assess the sources of that pollution. For water bodies listed as impaired, states must assess the amount of pollution that a water body can receive without violating water quality standards. That amount of pollution is termed a "total maximum daily load" (TMDL). The TMDL is then allocated among the different sources, including point sources, runoff sources and natural sources, and best management practices (BMPs) are implemented to reduce the pollution.

A TMDL has been established for the Truckee River, addressing three pollutants: nitrogen, phosphorus and total dissolved solids. The nitrogen and phosphorus flowing into the river have historically caused excessive plant growth, which depletes oxygen when the plants die and decay. Oxygen depletion can result in harm to fish, wildlife, and their habitats. The Nevada Division of Environmental Protection (NDEP) has identified a number of programs and projects to address pollution in the Truckee River, including the NPDES stormwater permit program for the Cities of Reno and Sparks, Washoe County and the Nevada Department of Transportation. NDEP does not set specific requirements for TMDL implementation by the local governments' management of their stormwater. However, in order to protect the Truckee River, the local governments will conduct activities that will reduce nitrogen, phosphorus and total dissolved solids flowing to the River. The Truckee Meadows Regional Stormwater Quality Management Program has been developed to assess and manage these pollutants.

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