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Storm Water Permitting

Contact

Robert Karesh
Statewide Stormwater Coordinator
312 Rosa L. Parks Avenue, 11th Floor
Nashville, Tennessee 37243
robert.karesh@tn.gov
615-253-5402

QLP

Introduction to the Tennessee Qualifying Local Program (QLP)

The Phase II stormwater regulations include provisions allowing for streamlining and coordination among programs at the state and local levels. This is true for the regulation of construction site runoff. The qualifying local program provision for the management and oversight of stormwater runoff from construction activities allows for this streamlining. Under this provision, the State of Tennessee, which has been delegated NPDES authority, can formally recognize a municipal program that meets or exceeds the provisions of its own construction general permit. When this occurs, a permitee, responsible for a project within the jurisdiction of a recognized municipality, would follow that municipality’s requirements for stormwater management.

Per CFR 122.44(s), the Division of Water Resources can formally recognize a regulated Municipal Separate Storm Sewer System (MS4) as a QLP that has been shown to meet or exceed the provisions of the General NPDES Permit for Discharges of Stormwater Associated with Construction Activities (CGP). If a construction site has submitted a program specific Notice of Intent (NOI) to a participating QLP, and has obtained a Notice of Coverage (NOC), the operator of the construction activity is authorized to discharge under the CGP without the submittal of an NOI, Stormwater Pollution Prevention Plan (SWPPP), or related permit fee to the division.

The Tennessee QLP program was developed through a grant-funded stakeholder driven process, with the intent of creating an effective program that incentivizes participation. Resultant incentives include streamlined QLP minimum requirements, a standardized interagency enforcement protocol, and recognition of QLP status as an alternative measurement of MS4 permit effectiveness. Obtaining QLP status is optional, but all regulated (MS4) are encouraged to consider participation.

Benefits of the QLP program include:

  • A more streamlined and efficient process for managing construction stormwater by eliminating permit and review duplication at the local and state levels;
  • Eliminating additional effort at the state level for construction site operators by providing only one set of requirements to follow; and
  • A more effective construction stormwater program resulting in greater water quality protection.

Current QLP Participants and Contact Information:

QLP

Stormwater Mgr.

Email Address

Bristol

Tim Beavers, P.E.

Tbeavers@bristoltn.org

Cookeville

Tracy Meggs, P.E.

tmeggs@cookeville-tn.org

Knox County

Chris Granju, P.E.

chris.granju@knoxcounty.org

Knoxville

David Hagerman, P.E.

dhagerman@cityofknoxville.org

Washington Co.

Mike Rutherford

mrutherford@wctndevelopmentservices.org

QLP Minimum Requirements

Regulated MS4s must implement and maintain a construction site stormwater runoff control program that addresses stormwater runoff from construction activities, as identified in sub-section 4.2.4 of the MS4 general permit. In addition, a QLP program must also include the following:

  1. Requirements for construction site operators to prepare and submit an NOI, and related comprehensive SWPPP, as identified in Section 3 (SWPPP Requirements) of the CGP,
  2. Specific procedures for SWPPP review, approval and NOC issuance,
  3. Requirements for construction site operators to perform inspections as identified in sub-section 3.5.8, and site assessments as identified in sub-section 3.1.2, of the CGP,
  4. A system for reporting to the division, information related to construction sites authorized by the QLP.

Application for QLP Status

An MS4 seeking QLP status may notify the division at any time, utilizing the application form below. In addition to administrative information, the applicant will be asked to provide copies of their construction stormwater ordinances, site plan review and approval procedures, project inventory and tracking procedures, and enforcement response plan.


QUALIFYING LOCAL PROGRAM APPLICATION DOWNLOAD
QLP Application (CN-1374) PDF

We would like to formally thank the following stakeholders for their participation and valuable contributions to the development of the Tennessee QLP program:

Knox County, Shelby County, City of Farragut, City of Franklin, City of Nashville, City of Knoxville, City of Chattanooga, City of Memphis, City of Bartlett, City of Jackson, City of Johnson City, Hamilton County, Bradley County, City of Elizabethton, City of Kingsport, City of Brentwood, City of Cleveland, Ft. Campbell, TN Department of Transportation, UT Municipal Technical Advisory Service, Associated General Contractors, Home Builders Association of TN, Road Builders Association, TN Society of Professional Engineers, TN Municipal League, American Public Works Association, TN Chamber of Commerce, UT-Water Resources Research Center, TVA, Harpeth River Watershed Association, Cumberland River Compact, and Jason Scott, with the Town of Farragut for designing the QLP program logo.