Puget Sound Olympia

Municipal Stormwater

Municipal Stormwater Permits: Pilot Audit Program

Purpose of effort

The most populated areas of the state are regulated by a municipal stormwater permit, which is administered by the Department of Ecology’s Water Quality Program. Beginning in late 2015, we are planning to pilot a Municipal Stormwater Permit audit program to evaluate Phase II City and County Permittees’ compliance with the permit and to assess the overall clarity and effectiveness of our permit language and its requirements.

We will use the results of this effort to inform future permit development. If we find deficiencies, we will follow up as appropriate.


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Desired Outcomes

Under this effort, Ecology will take a focused look at certain aspects of the stormwater management programs being implemented, in order to:

  • Improve Ecology’s knowledge of local operations, priorities, constraints, and challenges
  • Clarify permit requirements and implementation expectations for Permittees
  • Assess compliance with the permit and determine if improvements are needed to more effectively implement permit requirements
  • Identify strengths and weaknesses of the permits to inform the 2018/2019 permit reissuance and future modifications
  • Document positive elements of programs that may benefit other Permittees

Ecology is responsible for conducting compliance assurance activities and enforcing permit conditions and requirements for the state’s municipal stormwater permit program.

  • We will conduct the Pilot Audit Program slowly so we can refine and enhance the program and process.
  • We will provide notice to the Permittees who will receive an audit.
    • Mutually agreeable date(s) for the audit will be selected, within a reasonable timeframe.
    • An audit plan will be provided ahead of time. For example, we will identify which program element(s) will be reviewed and what documentation must be provided.
  • Our permit managers will provide a follow-up report, including findings, to Permittees in a timely manner.
  • When non-compliance issues are found, we will work with the Permittee to establish a plan with timeframes and specific actions to bring the program into compliance.
    • We will follow established protocols to attain compliance, including enforcement actions, if necessary.

Audit plan strategies

Develop a standard, state-wide approach for SWMP audits (initially for Phase II 2013/14 permits)

  • Created standard audit questionnaire forms for each permit component. Questions may be tailored to Permittee based on review of Annual Report and program records.

Follow flexible approach, designed to achieve more contact with Permittees, using two levels of effort as described below.

  • Screening level – Annual Report review, and basic interview with main contact.
    • Screening audit may stand on its own, or may lead to a follow-up detailed on-site evaluation.
  • Detailed on-site evaluation – A closer look at one or two programs: intensive review of files/records, detailed interviews with those involved with permit requirements, field component (if appropriate).

Audits are expected to focus on the following permit sections:

  • 2015/2016: IDDE; Municipal O&M; Construction Activities; and Public Education and Outreach

Frequently asked questions

Q: What is an audit?
Q: Why is Ecology conducting the audit?
Q: Has an audit ever been conducted before and if so, what are some lessons learned?
Q: How are you choosing who you will audit?
Q: What will you do with the information you uncover?
Q: Will you penalize or fine Permittees if you find problems?
Q: Where can I find information about Ecology’s water quality enforcement actions?
Q: How will we find out if we’re being audited?
Q: Will everybody receive audit findings or just the audited jurisdiction?
Q: How much time will it take for the audit? What should I expect?
Q: How long will Permittees have to prepare documents?



Municipal Stormwater Permit Contacts