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Wet Weather Benchmarking Report

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In the fall of 2008, the Michigan Department of Environmental Quality (MI DEQ) Water Bureau Director established a wet weather program designed to improve the understanding of rules, policies and regulations related to the monitoring, control and permitting of wet weather events and wet weather discharges.  The program created five Water Bureau staff work groups, tasked with identifying and benchmarking more appropriate ways and means to control and reduce adverse surface water quality impacts of wet weather discharge flows.

The five groups and their individual focus areas are as follows:

  1. Wastes to Land - including programs dealing with septage, biosolids, and animal feeding operations of all sizes.
  2. Earth Change - including programs dealing with soil erosion and sedimentation, forestry, construction, storm water, and farming other than animal feeding operations.
  3. Urban Living - including programs dealing with municipal and industrial storm water, and combined and sanitary sewer overflows.
  4. Wet Weather Monitoring - including ambient and discharge monitoring practices of state agencies, permit holders, and external organizations.
  5. Water Quality Based Effluent Limits (WQBEL) and Water Quality Standards Applicability.

This proactive approach recognized that the major surface water quality problems currently faced in the State of Michigan are derived from wet weather discharges.  The work groups provide a coordinated approach within the Water Bureau that draws on the expertise of Bureau staff to meet the goals of the newly created wet weather program.  Each work group was provided with specific research tasks that would yield information on the character of wet weather discharges arising from the various types of activities being considered in individual work groups.  For instance, each work group prepared specific questions to be asked of other states and the U.S. EPA for the purpose of benchmarking wet weather policies.  The responses to these questions from the states and U.S. EPA would contribute to a comprehensive understanding of wet weather regulatory policies and programs as practiced in this country.

The work on the questions for the states and U.S. EPA evolved to a final form of 16 pages from December 2008 through to mid May 2009.   The set of final overall questions are shown in the attached Appendix A.  Each work group listed questions in priority order.

To complement the detailed work of the five specified work groups and to gather information to respond to the prepared questions, a research team from the University of Michigan submitted a proposed work plan designed to solicit information from the Internet to document the states’ and U.S. EPA’s current wet weather practices.  In addition to internet based research, the proposal included the design and implementation of appropriate survey instruments serving to obtain information not readily available from the Internet on current wet weather practice from states and the U.S. EPA.  The Water Bureau approved this proposal and the research team commenced working in early May 2009.

The approved research plan called for the research team to complete its work and submit a final report by September 30, 2009.  As a consequence of the magnitude of the undertaking, a no-cost extension to the research contract extended the due date of the final report to November 30, 2009.


The initial effort of this research team involved searching the Internet resources of the states and the U.S. EPA to find answers to as many of the questions from the five working groups as possible.  While Internet research yielded useful results, many questions required further research.  The remaining questions were compiled into a questionnaire for distribution to each state agency, U.S. EPA Regions, and the U.S. EPA Headquarters.  In lieu of a more burdensome and costly paper format, Internet based survey instrument was used, which facilitated the final assembly of responses into a comprehensive report.  After review of several different web based survey instruments (including Zoomerang, UM Lessons, SurveyMonkey), we identified SurveyMonkey as the most suitable tool for our purpose.

In order to ensure efficient and sensitive design of these questionnaires, all researchers obtained certification from the University of Michigan (UM) Program for Education and Evaluation in Responsible Research and Scholarship (PEERRS).  Although the Institute for Social Research (ISR) informed us that the factual nature of our questionnaires does not require review by UM’s Institutional Review Board, we did receive valuable information from ISR.

Because of the quantity and diverse nature of questions unaddressed on the Internet, the remaining questions were divided into twelve separate questionnaires, according to the following wet weather issues:

  • Combined Sewer Overflows (CSOs)
  • Sanitary Sewer Overflows (SSOs)
  • Industrial Stormwater Permit Requirements
  • Municipal Stormwater Permit Requirements
  • Wet Weather Monitoring
  • Industrial Stormwater WQBEL Requirements
  • Municipal Stormwater WQBEL Requirements
  • Construction Stormwater WQBEL Requirements
  • Construction Nonpoint Source Pollution
  • Construction Stormwater
  • Land Application of Biosolids & Septage
  • Land Application of Manure

Each questionnaire was distributed to the appropriate contact person who was identified as being knowledgeable about a given wet weather issue.  In some cases, a contact person may have received more than one questionnaire, as some of the subject areas contain overlapping information.  In most cases, the contact person for municipal stormwater received both the Urban Living Work Group’s questions relating to municipal stormwater and the Water Quality Based Effluent Limitations (WQBEL) Work Group’s questions relating to municipal stormwater.

The results received from the respondents as well as the Internet research are grouped and presented in Chapters 1-8. Overall, U.S. EPA Headquarters, 45 states, and nine EPA Regions responded to one or more of the survey instruments.  In addition, two states opted out of survey participation for budgetary and standard policy reasons.

Research Areas
Urban Systems and Built Environment
Water Resources
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Digital Object Identifier
Full Citation

Bulkley, Jonathan, Danielle LeFevre, Hilton Clark, Amy Samples and Ria Berns. 2009. Wet Weather Benchmarking Report. University of Michigan: Ann Arbor: 1-383.