It’s here! The OHC000006 General Permit can be found on Ohio EPA’s website: https://epa.ohio.gov/divisions-and-offices/surface-water/permitting/storm-water-discharges-from-small-and-large-construction-activities--general-permit
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RENEWAL PROCESS
If your site is currently covered under the previous iteration of the Construction General Permit (OHC000005), that coverage will be terminated 180 days after the effective date of the new permit (April 23, 2023) if you do not submit a renewal application. You can submit the renewal application through the Ohio EPA eBusiness Center here: https://ebiz.epa.ohio.gov/  
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Once you open your active permit(s) in STREAMS, you will click “Renewal” in the action drop down list as shown in the screen shot below to bring up the renewal application form. 

​If your project is complete and will not require renewed permit coverage, you need to submit a Notice of Termination (NOT) application form through Ohio EPA’s eBusiness Center by selecting “Terminate” in the dropdown list rather than “renewal”.

PERMIT UPDATES
One of the first (and obviously most important) changes to note in the OHC000006 permit is updating “stormwater” to one word instead of two. The Table of Contents was also updated and is now hyperlinked. Additional numbering has also been provided in longer sections to make navigation easier. 

POST CONSTRUCTION RERQUIREMENTS
Extended Detention Requirements: An additional volume equal to 20% of the WQv must be incorporated into the BMP for sediment storage.

Infiltration Practices Requirements: The design infiltration rate values must be derived from site-specific measurements obtained through field tests of the in-situ soil for practices designed to infiltrate the WQv (table 4a and 4b).

Pedestrian Trails: Pedestrian trails may implement post-construction BMPs in compliance with the current version of the ODOT Location and Design Manual, Volume Two Drainage Design (Ohio EPA accepted alternative to conditions of the permit).

Redevelopment Projects (Encourages the redevelopment of areas that were not previously subjected to WQv). Must meet one or both criteria:

• A 20% net reduction of site’s volumetric runoff coefficient with soil restoration or the use of a green roof
• A portion of the site treated using a practice meeting Table 4a/4b criteria for which the WQv (see Equation 1) Alternative Post-Construction BMP

This section does not apply to previous development that was obligated to obtain CGP coverage and provide management of the WQv under previous generations of this general permit (i.e., after April 21, 2003). This is in place to prevent a reduced level of treatment.

Alternative Post-Construction BMPs:

• All alternative post-construction BMPs require EPA approval and must fall within certain technical criteria outlined in the section:
• Practice must be capable of providing sustained, long-term stormwater treatment.
• The stormwater treatment efficiency must be equivalent to that in table 4a and 4b (includes laboratory, field testing).
• The discharge rate from the practice shall be reduced to prevent erosion and protect physical and biological stream integrity.
• New permit allows both pretreatment and primary practices to properly reference the BMP testing criteria and address changes to Washington TAPE and STEPP. 

SEDIMENT BARRIERS
Language to clarify “tubular barriers” (i.e. filter sock, silt sock) are allowable practice and referenced in the Rainwater and Land Development Manual.

STREAM SETBACKS
Ohio EPA strongly recommends 50ft buffers to be maintained around surface water (including wetlands).

ELECTRONIC RECORD KEEPING

• Electronic records cannot be modified without digital audit trail.
• Modifications and people responsible for making modifications must be documented.  
• Systems need to have clear instructions for users to ensure proper use.
• Electronic records (NOI, SWP3, coverage letter, and inspection reports) must be made readily available on-site (must be able to furnish immediately for authorized representatives).

NOTICE OF TERMINATION REQUIREMENTS
Permit remains in effect until a signed Notice of Termination (NOT) form is submitted and permit coverage is terminated by the Ohio EPA.

BIG DARBY CREEK PERMIT (Does not Apply to Warren County)

• New permit prioritizes infiltration practices to address WQv.
• An alternative discharge performance standard of 50 NTUs is provided for sediment ponds.  
• Only jurisdictional ephemeral streams are subject to riparian setback requirements.

OLENTANGY RIVER PERMIT (Does not Apply to Warren County)
Only jurisdictional ephemeral streams are subject to riparian setback requirements.
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As defined by the Federal Environmental Protection Agency, Low Impact Development (LID) refers to a variety of practices designed to mimic natural drainage to manage stormwater flow. The overarching goal is to minimize the impact of development on the natural landscape and environment. In contrast to high impact development with mostly impervious surface and grey infrastructure, these practices encourage stormwater percolation into the soil. In addition to managing stormwater volume, this helps to filter out pollutants that may be picked up by stormwater as it makes its way to natural waterways.
 
What are the Benefits of LID? 
Economic

• cut costs associated with traditional infrastructure materials (such as curb, pavement, basin outlet/inlet structures, pipe conveyance systems, culverts, etc.)
• reduce clearing/grading costs (less disturbance = less of this work)
• increase value of residential lots (larger lots with more green space/natural vegetation)
• reduce landscaping costs (working around the natural areas that are already available on-site)
• reduce pollutant loading to ground water and drinking source water (reduces water treatment process costs)
• reduce long-term life cycle costs   
  
  

Environmental

• provide habitat for local pollinators
• effective stormwater volume management to reduce stream channel erosion
• reduce downstream pollutant loading
• reduce urban heat island effect  
  
  

Aesthetic

• vegetation and flowers add aesthetic value to built landscapes
• education and recreational opportunities
• provide ecosystems that deter mosquito breeding and other pests
  
  

Can LID Techniques be Used in Warren County?
Yes! In 2020, Warren County updated its stormwater regulations and technical design guide to allow for green infrastructure practices for water quality best management such as wetlands, permeable pavements, infiltration practices, and bioretention. Not only is low impact development permissible in the county, but with the numerous benefits, it is strongly encouraged! 

Other examples of Green Infrastructure that can be used as part of a Low Impact Development plan can be found here: https://www.epa.gov/green-infrastructure/what-green-infrastructure

Additional Resources
​www.warrenswcd.com/rain-gardens.html
https://www.epa.gov/nps/urban-runoff-low-impact-development
http://www.wceo.us/

One of the requirements for stormwater pollution prevention plans (SWPPPs) is to include an implementation schedule for major construction operations. This includes things like clearing, grubbing, excavating, grading, utility installation, and other similar activities.
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The Ohio EPA Rainwater and Land Development manual includes a table of what this general sequence should look like: https://epa.ohio.gov/static/Portals/35/storm/technical_assistance/6-24-09RLDCh8.pdf (pg 13)
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There are steps that should be taken as early in the construction process as possible to avoid problems with sediment and erosion control later in the project. 

Let’s breakdown those crucial early steps:

• Protect your natural areas. As construction activity is commencing, everyone working on the site should be aware of protected forested areas, streams, and wetlands that should not be disturbed. These should be marked off with easily identifiable fencing. If areas that were meant to be left alone get impacted, it can cause harm to sensitive natural areas and may also be in violation of other state and federal permits.
• Construct an area where equipment and vehicles have a clean exit from the site. A proper construction entrance/exit should consist of ODOT #1/#2's aggregate over a geotextile base. The proper aggregate size helps to ensure there will be enough vibration under the tires to kick mud off equipment and vehicles before leaving the construction site. It is best to have this installed as soon equipment and trucks are moving on and off the site to prevent off-site tracking.
• Install perimeter controls around all areas planned for disturbance. Clearing trees (root ball and all), grubbing, and grading work results in exposed soils. That sediment must be contained on the construction site. Perimeter controls need to be up around the entire perimeter of disturbance to help intercept sediment-laden discharges from moving off-site during rain events.
• Construct temporary basins. Basin construction should be part of the initial phase of construction. Basins must be installed and functional before any upslope development. As soon as the basin is dug, apply temporary seeding treatment to ensure embankments are stabilized throughout construction. Doing this early in the process helps to prevent erosion in the basin and sediment storage problems. The basin outlet structure should also have a skimmer device installed as soon as possible for de-watering off the surface of the basin rather than lower depths of water where more sediment is present.
• Follow construction timeline for remaining controls. Other sediment and erosion controls should also be installed as soon as possible. For example, when streets are installed, a sweeping schedule should be established. As new catch basins or street inlets are installed, get inlet protection on them right away. As lot development begins, make sure individual lot controls are in place. When concrete pouring is in full swing, there should be a designated washout area with controls.
• Communicate with your SWPPP inspector! Keep your inspector in the loop when new phases of the project begin in between inspection periods. If there are changes to the timeline or problems with getting certain controls established, let your inspector know so that they can help provide guidance that can help to keep things on track.  

Monarch Homes and Diggit Excavating met with Warren Co SWCD at a pre-construction meeting with the City of Lebanon where the requirements and sequence of sediment and erosion controls measures were discussed. Since that meeting, the team has been in constant contact with Warren Co SWCD, proving updates on initial groundbreaking and the control installation timelineas well as any changes to controls being used on the construction site.

As soon as clearing and grading work was set to begin, there was a proper construction entrance in place and silt fence around the clearing boundaries that was supplemented with a mulch berm from the on-site clearing. The basin was dug as part of the first phase as well. The basin will be temporarily stabilized and have a skimmer installed on the outlet once installed. 

​We asked our friends at Diggit Excavating for their take on how communication has helped with the development process from their perspective:
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This is a great example of communication between our agency and developers and contractors on projects and how compliance can begin right out of the gate as a new project begins. This proactive approach helps to avoid many complications later in the construction process. ​

As it can sometimes be difficult to translate technical regulations into feasible solutions in the “real world” on-site, we decided to spotlight some practices with examples we've found while conducting our inspections.

This month we noticed some great Best Management Practices in Hamilton Township on the Valley View Subdivision site. Everyone that enters the site is greeted by a large-format blue sign at the main construction entrance outlining site safety and erosion control rules, so it's easy for everyone to reference at a moment's notice. There is also a great example of a SWPPP storage box containing the SWPPP and keeping it accessible while safe from the elements. Aaron Smith with DR Horton provided some insight into how the stormwater team approaches stormwater runoff on the construction site:

​If you work in land development and construction, you are likely familiar with silt fence. When installed and maintained properly, silt fence is an effective sediment control measure. It is also one of the most common perimeter control measures noted on Stormwater Pollution Prevention Plans in Warren County. However, there is another type of perimeter protection that is becoming increasingly popular and may be a great accessible supplement or even alternative to silt fence: mulch filter berms. Rather than capturing runoff to allow for sediment settling like silt fence, mulch berms filter out sediment as water passes through the berm. 
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Can I have filter berms listed on my SWPPP? 
Yes! Please do include them on your SWPPP if that is the plan. They are approved and encouraged by our office for use if a project plans to do extensive tree clearing work. Often silt fence is listed by default on the SWPPP and mulch berms are ultimately used during construction due to their benefits. Best practice is to have the perimeter control that is meant to be used written on the plan. However, if things do change as work commences, reach out to your designated SWPPP inspector to make sure the updates are documented on the plan moving forward. 
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What material can be used?
The Ohio Environmental Protection Agency’s Rainwater and Land Development Manual outlines the specifications for the materials that should be used for these filter berms. The guide specifically states compost used for filter berms shall be weed, pathogen, and insect free and derived from a well-decomposed source of organic matter. This material can include compost, mulch, or wood chippings. For projects that involve extensive tree clearing, we recommend considering mulch berms as a perimeter control practice. For the least amount of land disturbance, your site may even be able to avoid removing the entire root ball of the trees and mulch the stumps for filter berm material. If you have questions about using the material you have on-site for controls, contact the urban team at Warren County Soil and Water Conservation District.

How are filter berms installed?
​Filter berms are installed in the same location that silt fence would be installed: along the contour and away from the toe of a slope. Like silt fence, there are different specifications for spacing based on the percent slope as well. For silt fence, there are very specific installation steps that must be satisfied to ensure proper function. Mulch berms installation is a less labor-intensive process. Rather than trenching, placing, and stretching fencing to be completely taught, berms just need to be built up to achieve the specified measurements (minimum 1’ height and minimum 2’ wide or 2 times the height). 

What kind of maintenance do filter berms require?
The most common filter berm maintenance need is to rebuild the berm to meet the appropriate specifications as needed. Like silt fence, built up sediment should be removed from behind the berm if it reaches over 1/3 the height of the berm. If a berm is completely washed out by a large storm event, the berm material will need to be replaced as well. If wash out continues to occur, additional or alternative controls may be needed, such as a rock check dam, or the size of the berm may need to be modified.
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​Where can I find additional information?
The Ohio EPA Rainwater and Land Development Manual Chapter 6: Sediment Controls contains a section on filter berms. You can also reach out to Warren Co SWCD's Urban Team to discuss a plan for implementing mulch berms in your current or future projects. 

Rainwater and Land Development Manual:
https://epa.ohio.gov/divisions-and-offices/surface-water/guides-manuals/rainwater-and-land-development
Federal EPA:
https://www.epa.gov/system/files/documents/2021-11/bmp-compost-filter-berms.pdf
Warren County SWCD:
https://www.warrenswcd.com/
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Winter is upon us, and that means it’s time to ensure your project site is ready for the weather to come.

Refresher: In case you haven’t seen it, we have a blog post that goes over helpful general information for site winterization here.

Training Opportunity: There is a free training webinar on site winterization available through StormwaterOne here.
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When ice and snow melts and warm weather in the spring brings heavy rain, bare soils on construction sites are subject to erosion. As a result, sediment-laden runoff can enter storm systems and natural waterways if proper precautions are not taken. One of the best lines of defense for keeping soils in place is stabilization through temporary or permanent seeding. Yes, you can (and should!) stabilize idle sites (not going to be worked for >14 days) and sites that reach final grade in winter. 

March 1st-August 15th: Oats, Tall Fescue, Annual Ryegrass, Perennial Ryegrass, Creeping Red Fescue, Kentucky Bluegrass*

August 16th-November 1st: Rye, Tall Fescue, Annual Ryegrass, Perennial Ryegrass, Creeping Red Fescue, Kentucky Bluegrass, Wheat*

Note: It is advised that seedings should not be made from October 1 through November 20. During this period, the seeds are likely to germinate but probably will not be able to survive the winter. For dormant seeding, it is advised to wait until temperatures consistently stay below 50 degrees F to prevent early germination. Temporary seeding/mulching techniques can be used until the dormant seeding window.

*Other approved species can be substituted

November 1st-February 29th: Mulching/temporary stabilization until temperatures consistently stay below 50 degrees F when dormant seeding can be implemented as a permanent solution.

This means if you are reading this article in November 2022, you have missed the normal growing season. Therefore, if your site has not been stabilized, you’re down to two options: mulching for temporary stabilization or dormant seeding for a permanent solution if areas have achieved final grade. 

WHAT EXACTLY IS DORMANT SEEDING?
With this practice, the seeds will freeze and remain dormant during winter weather conditions. Then as spring weather emerges, the seeds will thaw and begin to germinate. This cycle follows what happens to seeds naturally during this time of year. This practice works great for the bare, exposed soil conditions that are often present at project sites that have recently achieved final grade. 

HOW IS DORMANT SEEDING DONE?
​Step 1 – Pick Your Seed
The timeline above outlines seeding practices in the Rainwater and Land Development Manual specifically for stabilizing construction sites for commercial, industrial, and/or residential purposes and at different times of the year. The USDA Natural Resources Conservation Service also provides a seeding table that outlines the grasses and legumes suitable for different uses and provides formulas for calculating seeding rates. This table can be found in the Ohio Field Office Technical Guide (FOTG) located here.

Step 2 – Prep
When soil conditions allow, prepare the seedbed, apply required amounts of lime and fertilizer.

Step 3 – Seed
Within the appropriate timeframe outlined above, apply seed mixture with cyclone seeder, drill, cultipackers seeder, or hydro-seeder.
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Step 4 -- Mulch
Mulch and anchor immediately after seeding. Acceptable mulch materials include straw, hydroseed, or erosion control matting/blankets.

ADDITIONAL INFORMATION
If you aren’t sure what stabilization practices will work best for your site during winter months, our team at Warren County Soil and Water Conservation District is happy to help. Feel free to give us a call at (513)695-1337.

ADDITIONAL RESOURCES:
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Rainwater and Land Development Manual 

Ohio EPA NPDES General Construction Permit 

Natural Resources Conservation Service

​Our urban team at Warren Co SWCD conducts routine sediment and erosion control inspections on active construction sites in Warren County. During these inspections and through collaboration with other surrounding soil and water districts, we have developed a list of common compliance issues with the Ohio EPA Construction General Permit regulations that can be fixed with a couple of easy steps:

1) Copy of the Current SWPPP + Construction Activity Log On-Site
To make sure our inspectors are looking for the most up-to-date sediment and erosion control features on-site and to ensure that run-off from the current site conditions is accounted for, it is required that a copy of the most up-to-date Stormwater Pollution Prevention Plan is available on-site.

EASY FIX: Keep in touch with your local inspector to make sure that changes to the sediment and erosion plans are documented on the SWPPP. Keep a copy of this plan and construction activity logs in a construction trailer on-site or in a mailbox in residential developments. A great portable option is to anchor a mailbox in a concrete-filled bucket that can be moved with you to the next job site. Be sure to let inspectors know where these plans are going to be kept throughout the construction process. 

2) Dumpster Covers
Construction site dumpsters can contain a variety of waste materials. Some of these, such as paints, adhesives, plasters, etc. can be harmful to natural environments if they enter waterways through storm systems. While most sites have dumpsters on-site, one of the commonly missed sediment and erosion control measures is a dumpster lid.

EASY FIX: Covering dumpsters with a lid or tarp prevents rainwater from entering the waste bin and carrying out pollutants through openings in the bottom of the container.

3) Porta-Potties Located Away from Storm Drains
Access to restrooms on-site is essential, but if waste from the facility leaches from the containment and gets carried into the storm system it can end up in our creeks and lakes. This not only poses a public health threat, it also introduces excess nutrients and hazards to aquatic ecosystems.

EASY FIX: If possible, place porta potties away from direct storm drain entryways where leachate would be able to soak into the ground prior to getting washed into roadways, storm conveyance systems, or waterways. 

4) Proper Concrete Slurry Containment Concrete slurry containment is important to prevent clogging storm systems and preventing these materials from getting into waterways where they can harm wildlife.

EASY FIX: The Construction General Permit outlines the proper specifications for a concrete washout pit, which should be designed with 4 walls for complete containment and a liner to prevent these materials from leaching into the ground. If the site makes it difficult for trucks to wash into the bins at ground level, the ground can be dug out to provide a deeper bin. If it is not possible for pump trucks to fold up and properly wash out at these sites, there should be designated areas for this activity to take place on lots with liner on the ground, surrounding controls to prevent run off, and the waste should be dug out and taken off site. 

5) Stabilized Basins – Right out of the Gate Basin installation should be one of the first items in the construction sequence. Basins must be installed and functional before any upslope land disturbance takes place. This is an imperative step because basins are used to control both stormwater quantity and quality. Often after the basin is constructed, there is an idle period before seeding and strawing the basin. This can lead to increased erosion, the formation of rills and gullies on the basin embankments, and ultimately more sediment removal to achieve proper final storage capacity.

EASY FIX: Stabilizing the basin with seed and straw right after installation can help minimize the impacts of erosion, ensure the basin will operate as designed, and minimize sediment accumulation. A stabilized basin early on may save you time and money from having to remove sediment from the basin at project completion to restore proper storage volume. Don’t forget to install a skimmer structure right out of the gate, too!

The Ohio Rainwater and Land Development Manual serves as a great resource for additional details and specifications regarding construction site good housekeeping items. Warren Co SWCD’s expert Urban Team is also available to help – contact us at (513) 695-1337 or wcswcd@gmail.com.  

Did you find this information helpful? We have more to share! Sign up to receive future editions of Development Digest as well as regulatory updates and information from Warren Co SWCD.​

Each summer in partnership with the Warren County Engineer's Office, Warren Co SWCD runs a basin inspection program to help homeowners and property managers maintain stormwater basins throughout the county. 

As you may already know, basins are designed in accordance with the Ohio Environmental Protection Agency and local stormwater requirements. It is important to keep stormwater basins functioning because they collect and detain stormwater; help to settle out and hold sediment; protect local creeks, streams, and lakes; and help to reduce the potential for flooding. 

This week we are excited to welcome four interns who will spend their summer learning about the work Warren Co SWCD does to maintain soil health and water quality in our county while supporting the basin inspection program. You may see them out and about in the county in their vibrantly colored safety shirts! At the end of the summer, all of their stormwater basin inspections will be available online through our new stormwater basin inspection map found in the property owner assistance portion of our website.

​In order to effectively manage stormwater for an increasing population (and therefore impervious cover), engineers design sites with retention or detention basins for more storage. Before an area is disturbed or developed, the land is classified as an permeable surface meaning water can infiltrate into the subsurface. Roads, sidewalks, houses, and other structures prevent infiltration, and to accommodate for the quantity of water that is no longer able to infiltrate we build storm sewers that direct water to basins for storage.  In addition to accommodating runoff, basins provide many other benefits including treatment by allowing for settling time and regulating the amount of water being released preventing erosion down a watershed.

A detention pond does not contain a permanent pool of water and is designed to store water temporarily before leaving the outfall structure and releasing to a stream. Detention ponds are constructed for flood events and have shorter settling and retention times than retention basins. A retention basin stores water year-round, and the outfall structure contains an orifice at a higher elevation compared to a detention pond. In Ohio, we primarily see retention ponds surrounding developments due to the higher amounts of precipitation we receive compared to out west.
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Many variables are considered when determining size and location of these stormwater control measures. Properties include rainfall intensity in the geographic location, soil type(s), land cover, distance to creek, and total impervious area after development. To learn more about basin sizing & structure requirements you can read through the Ohio EPA Construction General Permit Parts III.G.2.d.ii. and III.G.2.e.

Questions? Contact our office at (513) 695-1337 for more information from your local basin experts! Is there a basin on your property in Warren County? You can view the latest inspection report on its functionality here.