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Stormwater Management Program Plan
Some of my thoughts on the draft:
The philosophical approach in the SWMPP is to do as little as possible, meet the minimum or argue to do less. For example, “This SWMP Plan has been developed to generally describe the City of Hoover’s efforts to maintain compliance with the requirements of NPDES Permit ALS000027.” [page 15] This statement describes the approach as compliance and general; this suggests the city has no intention of a comprehensive stormwater management program and will do as little as possible. BMPs are not mentioned. Further, there is no acknowledgment in this description of new requirements under this permit.
· The permit is updated each cycle for clarification and includes very few “new” requirements. The Hoover SWMPP has few updates so aspects that were not met in 2018 and 2021 are still lacking. The majority of changes (as shown in the next section) of the SWMPP are designed to reduce the responsibility of the city rather than meet the permit requirements.
· Since 2010 the EPA has noted that the goals and objectives of the program are not measurable[1]. EPA provides guidance on long-and-short term goals (https://www3.epa.gov/npdes/pubs/measurablegoals.pdf ).
· November 7, 2024 ADEM wrote a letter to the mayor identifying three aspects of the MS4 Annual Report that were to be deleted in future reports (https://lf.adem.alabama.gov/WebLink/DocView.aspx?id=105539745&dbid=0&cr=1 ). The city did not delete those sections in the next report and has added those as new sections in the SWMPP [page 28]. This is a clear act of defiance.
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Documents you might find helpful
The Hoover 2025 Draft SWMPP is available here:
The NPDES Permit (2024) is available starting on page 50 here:
https://lf.adem.alabama.gov/WebLink/DocView.aspx?id=105521690&dbid=0&cr=1
All of my comments are available here:
https://docs.google.com/document/d/1FDbx4qdakrcS4IO7341y0U2GB6kIe9Cd4kDyqtHYL6k/edit?usp=sharing
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