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SWMP Program Plan

1. Introduction

The Ohio Department of Transportation (ODOT) has been identified as a Non-Traditional Small Municipal Separate Storm Sewer System (MS4) owner/operator by the Ohio Environmental Protection Agency (Ohio EPA). The permitted facilities under ODOT’s jurisdiction include: Interstate, regulated U.S. and State Highways as well as ODOT facilities within ODOT’s MS4 Urbanized Area Boundaries.

The Stormwater Management Plan (SWMP) continues to serve as the cornerstone for ODOT's stormwater management and water quality program and is designed to reduce the discharge of pollutants, protect water quality and satisfy the water quality requirements of Ohio Revised Code 6111. The SWMP assists ODOT in complying with water quality mandates from the U.S. EPA, such as the National Pollutant Discharge Elimination System (NPDES) regulations and Total Maximum Daily Load (TMDL) programs. The NPDES regulations have caused a fundamental shift in the focus of highway stormwater engineering and management from the basic principle of simply conveying runoff to managing the rates of discharge and the quality of the water being discharged from owner/operated storm sewer systems.

1.1 Permit History

ODOT was granted coverage by the Ohio EPA on March 19, 2003 under NPDES Permit No. OHQ000001 - Authorization for Small Municipal Separate Storm Sewer Systems (MS4) to Discharge Storm Water under the National Pollutant Discharge Elimination System (NPDES), henceforth known as ‘the permit’. The permit renews every five years. See Appendix A for a copy of the permit. Table 1-1 shows the timeline of permit renewal dates for ODOT’s storm water management program:

Table 1-1: ODOT's Permit Cycle

NPDES Permit Number

5-year permit cycle


2002 - 2007 (Enforced until 2009)


2009 - 2014


2014 - 2021


  2021 - 2026

The SWMP is intended to provide Stormwater Management Program implementation guidance and is the mechanism that combines the necessary regulatory elements together into one document that meets the permit requirements. In addition, the SWMP addresses the compliance requirements of Ohio EPA’s MS4 permit and allows ODOT to continue to discharge stormwater runoff into waters of the state from their storm sewer system that includes a combination of ditches/swales, catch basins, storm sewer pipes and culverts. The plan was significantly revised in 2018 to present ODOT’s agreed upon program revisions to formalize ODOT’s responses to a regulatory audit, which are incorporated into Best Management Practices Factsheets discussed in Section Using this SWMP

ODOT is to maintain a current SWMP demonstrating compliance with the permit and providing guidance to users of the SWMP; therefore the SWMP will be reviewed annually and updated as needed. User feedback is highly encouraged to increase efficiencies, usability, implementation and documentation of performance.

2. ODOT’S Stormwater Management Program Information

2.1 Program Goals

The goals of ODOT’s Stormwater Management Program include:

  1. Addressing permit requirements that include implementation, reporting and enforcement of ODOT’s SWMP practices and activities.
  2. Continuing outreach to ODOT audiences using ODOT policies, manuals and specifications and internal/external training activities.
  3. Assessing and evaluating ODOT’s stormwater BMPs and plan revisions as necessary.
  4. Continuing evaluation of existing or new ODOT policies, programs or operations for options to improve the SWMP reporting, implementation or best practices.

2.2 Minimum Control Measures

The permit requires ODOT address the following six Minimum Control Measures (MCMs):

  • MCM 1 - Public Participation and Outreach
  • MCM 2 - Public Involvement/Participation
  • MCM 3 - Illicit Discharge Detection and Elimination
  • MCM 4 - Construction Site Stormwater Runoff Control
  • MCM 5 - Post-Construction Stormwater Management in New Development and Redevelopment
  • MCM 6 - Pollution Prevention and Good Housekeeping for Municipal Operations

Each MCM requires incorporation of the following three elements – decision process, performance standards and annual reporting requirements. The TMDL pollutant of concern for ODOT is TSS. The performance standards and reporting requirements for TSS are included for each MCM. These are unique for each MCM and associated practices and have been incorporated strategically as part of each MCM.

To guide Stormwater Management Program implementation and reporting, this SWMP contains factsheets in Section 5, organized by MCM, that identify activities, roles and responsibilities and reporting requirements needed to address the regulatory requirements included in each MCM. Each MCM has a summary page which details the common items for the BMPs in the MCMs by the categories shown in Figure 2-1.

Figure 2-1

Figure 2-1: MCM Summary Page Contents

For each BMP, the factsheets include information on the practice, the office or division that supports implementation/reporting responsibilities and activities needed to implement the practice. At a minimum, each factsheet contains information identified in Figure 2-2 for each BMP that provides program information that also supports annual report development.

Figure 2-2

Figure 2-2: BMP Factsheet Contents

The BMP Factsheets are designed to be easily updated and portable for use in the field, including reporting forms. The BMPs will be reviewed annually for their effectiveness at meeting the measurable goals and, as necessary, the factsheets will be updated.

2.3 ODOT’s SWMP - Public

ODOT is identified as a non-traditional MS4, as stated in the permit, which is defined as having storm sewer systems similar to municipal separate storm sewer systems. ODOT’s public is presented in Figure 2-3.

ODOT’s public is identified for each MCM on the MCM summary of the BMP Factsheets and as necessary for each BMP.

Figure 2-3

Figure 2-3: ODOT's Public

2.4 ODOT’s SWMP - Themes

The permit requires ODOT to develop mechanisms that target a minimum of five different stormwater themes or messages throughout the five-year permit term that reach at least 50% of ODOT’s public over the five-year term. ODOT’s TMDL pollutant, TSS, is included in the identified themes. The stormwater themes will be assessed annually and revised as necessary to continue to provide meaningful stormwater information to ODOT’s public. The themes will also be incorporated into ODOT’s six MCMs and associated BMPs as appropriate.

ODOT’s current stormwater program themes include:

  • Pollution Prevention – Prevention is the best way to reduce pollution in stormwater, including TSS. Pollution prevention is being incorporated into multiple aspects of ODOT’s operations.
  • General Stormwater Awareness – This theme provides general information on stormwater management and water pollution, ODOT’s stormwater program, and where to obtain more information on the program.
  • Water Quality – This theme shares information associated with stormwater quality and TSS reduction associated with ODOT assets (i.e. roadways, bridges, garages etc.). It identifies stormwater research needs to improve stormwater runoff water quality. Completed water quality/quantity research is associated with this theme.
  • Stormwater Control Practices – This theme provides information on multiple aspects of stormwater program controls. Stormwater controls include both structural or non- structural (e.g. procedures, operations and maintenance activities or policies). Included in this theme are implementation of pollution prevention controls, which indicate where and how to utilize these controls. These controls reduce the overall TSS in storm water runoff.
  • Illicit Discharge – An illicit discharge is a release to the storm sewer system of any item that is not composed entirely of stormwater. This theme will include information on the types of illicit discharges, as well as solutions for prevention, identification and removal. ODOT will address these discharges as they are encountered through scheduled roadway operations and maintenance activities.

2.5 ODOT’s SWMP - Pollutants

The Federal Highway Administration (FHWA) in partnership with the National Academies of Science and the Transportation Research Board (TRB) have invested into documenting pollutants identified in highway/roadway runoff. ODOT has incorporated information from these research studies and conducted their own research that includes evaluating soil types, average daily traffic, rainfall/ precipitation values and identified the following as the targeted pollutants for the Stormwater Management Program:

  • Sediment
  • Total Suspended Solids
  • Chlorides
  • Oil/Grease
  • Herbicides
  • Trash
  • Nutrients
  • Bacteria
  • Metals

Each BMP identifies the targeted pollutants for that practice that it is intended to reduce/mitigate. The Annual Report, discussed in Section 4, will provide information on targeted pollutants that may be numeric or narrative in nature and document meaningful management activities, reduction or mitigation of these pollutants.


The permit requires ODOT to establish pollutions controls to target TMDLs. Due to the linear nature, right-of-way (ROW) restrictions and common pollutant generating work activities, TSS was selected as ODOT’s TMDL pollutant of concern. TMDL Performance Standard for TSS are included in the MCMs.

2.7 MCM Success Evaluation, Selection of BMPs and Associated Measurable Goals

ODOT’s Stormwater Management Program continues to evolve over the duration of the program. BMPs have been added, revised, and combined. ODOT’s process for continued program improvement through evaluating the success and benefits associated with the current BMPs, MCMs and the SWMP overall. The process is shown in Figure 2-4 describes how ODOT develops or identifies BMPs and measurable goals to evaluate the success of the program BMPs.

Figure 2-4

Figure 2-4: ODOT's BMP measurable goal and MCM evaluation process

2.8 ODOT’s MS4 Regulated Area

In 2015, ODOT updated the MS4 Urbanized Area Boundary based on the 2010 U.S. Census Bureau Urbanized Areas. All ODOT-owned facilities and ODOT-maintained roadway segments that are within ODOT’s MS4 Urbanized Area Boundary are subject to the permit requirements. The entire facility parcel and roadway right of way is assumed to be impervious for the purpose of fee calculation. Table 2-1 shows information provided on ODOT’s regulated facility and roadway acreage and square mileage.

Table 2-1: Summary of ODOT’s MS4 Urbanized Area Regulated Fee Information



Square Miles










Appendix A includes maps of ODOT’s MS4 Urbanized Area Boundary, statewide and by district. Each map includes information on ODOT facility acreage within the district and roadway acreage that is necessary to support calculation of ODOT’s annual Stormwater Management Program fee.

2.9 ODOT’s Program Outfalls

ODOT has an Outfall Inventory Manual for the purposes of identifying outfalls within ODOT’s regulated roadway system and facilities. The manual defines an outfall as the point at which any discernible, confined, and discrete conveyance of ODOT’s storm sewer system discharges to surface waters of the State.

The MS4 permit provides the following definition for “surface waters of the State”:

All streams, lakes, reservoirs, ponds, marshes, wetlands, or other waterways which are situated wholly or partly within the boundaries of the State, except those private waters which do not combine or affect a junction with a surface water. Waters defined as sewerage systems, treatment works, or disposal systems in Section 6111.01 of the ORC are not included.

The outfalls within ODOT’s MS4 area were located, inventoried and mapped between 2006 and 2009. Two types of outfalls, ditches and pipe outfalls, were included in the inventory and added to ODOT’s web-based mapping portal known as Transportation Information Management System (TIMS). As part of the outfall inventory, each outfall was evaluated for presence of dry weather flows. The outfalls identified as having dry weather flows are evaluated for potential illicit discharges.

3. Office Involvement and Expectations

3.1 Central Office

The Office of Hydraulic Engineering (OHE) manages all aspects of the Stormwater Management Program for ODOT. OHE develops and maintains the SWMP, coordinates activities, evaluates BMPs, administers the Stormwater Management Program Consultant Task Order, and prepares and coordinates the Annual Report with the Ohio EPA. OHE is the primary contact with the other Central Office Divisions, ODOT Districts, and the Ohio EPA.

ODOT Central Office has several divisions that have roles/responsibilities associated with SWMP implementation and reporting. A simplified ODOT Central Office organizational structure as well as each department/office are presented in Figure 3-1. A Stormwater Management Program organizational chart with department and associated MCMs is included in Appendix B. Most activities associated with MCM 1 and MCM 2 are conducted by Central Office staff. The BMP Factsheets provide a summary of the Central Offices and ODOT District MS4 Liaison involvement with each BMP.

Figure 3-1

Figure 3-1: Simplified ODOT Central Office Organizational Structure

3.2 Districts

ODOT is organized into 12 districts, detailed in Appendix C. Each district has several offices or departments involved with the implementation of the SWMP as presented in Figure 3-2. Many of the activities within MCM 3, MCM 4, MCM 5, and MCM 6 are be performed by district personnel. These activities are coordinated by the district departments and performed by district staff. Each district utilizes existing staff to perform the activities and one staff member within the district will act as the MS4 Liaison.

Figure 3-2

Figure 3-2: Simplified District Office Organizational Structure

3.2.1 MS4 Liaison

The 12 ODOT districts have a staff member assigned to the role of MS4 Liaison. The MS4 Liaison aids and coordinates the implementation and reporting of MS4 district level activities. They are provided training to understand the Stormwater Management Program and how the district activities are impacted by the MS4 permit. The MS4 Liaisons report Stormwater Management Program implementation activities to OHE and work with district staff to collect information throughout the year.

3.2.2 District Staff

The district staff perform SWMP activities as part of their normal work activities, or through issued work orders needed to comply with the permit and report their activities to the MS4 Liaison. The district staff are responsible for reporting their activity to the MS4 Liaison. An organizational chart with department and associated MCM is available in Appendix B.

4. Annual Reporting

4.1 What is in the Annual Report

The permit requires a report to be submitted by April 1 for each year the permit is in effect. The annual report, herein called the “report”, covers the period from January to December of the previous year. The report is required to contain:

  • Table of Organization including the primary contact person
  • Status of compliance with permit conditions
  • Results of information collected and analyzed
  • An implementation schedule
  • Proposed changes to the SWMP including BMPs
  • Any variances granted to ODOT’s Stormwater Management Program

4.2 Who is Responsible for Collecting and Submitting Annual Report Information?

Figure 4-1OHE begins collecting information for the report in January of each calendar year. OHE is responsible for collecting SWMP information at the Central Office level. The Central Office departments are responsible for providing the required information to OHE. The MS4 Liaisons collect certain ODOT district level SWMP information to be included in the report to OHE. The district level departments are responsible for providing the required information to the MS4 Liaison or to OHE. Figure 4-1 shows the flow of information into the report. The BMP Factsheets contain the reporting needs and requirements for each BMP.

4.3 How is the Annual Report Submitted and Provided to the Public?

ODOT submits the annual report to Ohio EPA using the Surface Water Tracking, Reporting, and Electronic Application Management System (STREAMS) through Ohio EPA’s online eBusiness Center website. The reports must be submitted by ODOT. A consultant can complete the report for ODOT, but it cannot be submitted by the consultant.

The report is posted on ODOT’s stormwater website. All of ODOT’s public and the general public have access to the report  via ODOT’s stormwater web page.

5. Best Management Practices Fact Sheets

To view the fact sheets on ODOT's best management practices (BMPs) and minimum control measures (MCMs), please download the PDF version of this publication from the Attachment field.

To view current progress on these goals, visit the SWMP Annual Report.

Appendix A. District MS4 Urbanized Area Maps

To view the MS4 urbanized area maps, please download the PDF version of this publication from the Attachment field.

Appendix B. Stormwater Management Program Organization Chart

Appendix B

Appendix C. ODOT Districts

Appendix C