This document describes the scope and review methodology used throughout the project by the core team of SSC project reviewers: Michelle Chow (WEC), Alyssa Barton (PSK), and Charlie Holbein (WEC), as we researched and compiled lists of projects for the Nature’s Scorecard: Local Stormwater Pollution Controls project.

Project Scope

Phase I Municipal General Stormwater Permittees have had requirements to implement Structural Stormwater Controls (SSCs) since 1995. Reviewers focused the project on the years 2007–2021. We started with the first year the Washington State Department of Ecology (Ecology) articulated a full list of qualifying SSCs that was relatively similar to the 2019 list of qualifying SSC project types. 

Reviewers also opted to review a sub-section of the Puget Sound area Western Washington Permittees, rather than all Permittees. We selected five key Puget Sound Phase I’s (King County, Seattle, Tacoma, Pierce County, and Snohomish County), and the seven largest Phase II jurisdictions (Renton, Bellevue, Kent, Federal Way, Everett, Kitsap County, Thurston County), which include a mix of five cities and two counties with populations meeting or exceeding the original Phase I Permit population threshold (100,000). 

Project Methodology

💧 Throughout 2020, reviewers pulled and reviewed every annual report and relevant documents filed with Ecology by all 12 Phase I’s and II’s on PARIS, Ecology’s Clean Water Act Permit database. 

💧 Reviewers documented every reported SSC project for each Permittee in a “master” Excel spreadsheet list. For each project, reviewers documented details including but not limited to the year of the report, project start and completion dates, project name, description, receiving waterbody, GIS coordinates, project costs, project type provided by each Permittee, and project costs if available. 

💧 Phase II’s have no SSC requirements and thus did not report any SSCs to the Department of Ecology. Reviewers obtained this data by pulling all available budgets, capital facilities plans, and/or capital infrastructure plans where available from Phase II’s public website(s). Reviewers documented every project related to “water,” and added them to the master list. 

💧 Reviewers then combed the full master list and flagged all projects that didn’t appear to “qualify” as meeting SSC requirements described in the 2019 Phase I Permit. Reviewers met with Ecology staff to get feedback on what types of projects would “qualify,” based on general descriptions, and which would not. Reviewers then developed a “Decision Tool” describing the types of projects that likely do and do not “qualify” under the Phase I 2019 Municipal General Stormwater Permit, Appendix 12 list. Every project in the master List was assigned a project type based on the 2019 Permit, Appendix 12 (Type #1-11, or multiple where appropriate), or was flagged with a question, or flagged for removal if it did not qualify.  

💧 Reviewers then pulled the twelve Phase I and II Permittees’ project lists from the master list and shared them with staff from each respective Permittee. Reviewers requested to discuss project lists, including projects flagged with a question or flagged for removal. Reviewers also requested GIS coordinates for qualifying projects in order to map them. Reviewers ultimately removed all non-qualifying SSCs from the lists. 

💧 Reviewers received varying levels of assistance from different Permittees. Where Phase II staff offered up additional information to update the lists with additional projects, reviewers updated and corrected the lists. Reviewers did not add projects from Phase I’s if they were not reported to Ecology.

💧 Prior to project launch, reviewers offered to meet with Ecology and Permittees a final time to present findings and recommendations based on the data, and receive any final input on project lists.

💧 For purposes of conveying SSC information to the public, reviewers developed an “SSC Glossary of Terms” combining the eleven SSC project types as defined by the Permit into four “Function Types.” All projects on the final SSC list were assigned a Function Type and mapped in a GIS Storymap.  

As a result of the differences in Permit requirements over time; differences in Permit requirements for Phase I’s vs. a lack of requirements for Phase II’s; different data sources for Phase I’s and II’s; different reporting strategies across Phase I’s; differing levels of ability of municipal staff to coordinate and provide feedback on project lists; gaps in Permit reporting requirements (which we detail further in our Report); differences in how Phase I’s and II’s track their projects internally; and the scope of this project: we acknowledge that the dataset we have does not constitute a complete picture of the stormwater work being done within each jurisdiction.