Environmental Health and Safety

Stormwater Management Program

Introduction

This document has been prepared in connection with Western Michigan University’s (WMU) 2025 National Pollutant Discharge Elimination System (NPDES) Permit Application for Discharge of Stormwater to Surface Waters of the State from a Municipal Separate Storm Sewer System (MS4). This Stormwater Management Program (SWMP) reflects WMU’s current approach to stormwater management and incorporates elements of prior program development efforts completed in coordination with external consultants.

The NPDES Program protects the surface waters of the state by assuring that discharges of wastewater comply with state and federal regulations. Anyone discharging or proposing to discharge wastewater to the surface waters of the state is required to make application for and obtain a valid NPDES permit prior to wastewater discharge.

NPDES permits are required under Section 402 of the Federal Clean Water Act (the “Federal Act”), as amended (33 U.S.C. 1251 et seq., P.L. 92-500, 95-217), and under Part 31, Water Resources Protection, of Michigan’s Natural Resources and Environmental Protection Act (NREPA), 1994 PA 451, as amended. Part 31 of the NREPA also provides authority for the State to issue NPDES permits. The Michigan Department of Environment, Great Lakes, and Energy (EGLE) administers the NPDES permit program for the State of Michigan.

 

Public Access to the SWMP

WMU makes its Stormwater Management Program (SWMP) available to the public through the WMU Environmental Health and Safety (EHS) website and in coordination with the Kalamazoo Stormwater Working Group (KSWG). The SWMP is promoted at least annually through campus events, public outreach efforts, and educational initiatives to encourage awareness and participation in stormwater management.

 

Regulated Area

A map identifying the urbanized area associated with the WMU jurisdictional boundary (as defined by the 2010 Census, or most current applicable Census designation used for MS4 permitting) is provided as Figure 1. The WMU MS4 system is located within the Kalamazoo urbanized area and discharges stormwater into surface waters of the state via outfalls to Arcadia Creek and/or through connections to the City of Kalamazoo MS4 drainage network.

 

Outfalls and Points of Discharge

The surface water receiving stormwater discharge from the WMU MS4 is Arcadia Creek. WMU stormwater outfalls and points of discharge are summarized in Table 1 (see Attachment G, “BMP Maintenance Plan,” for tables and figures).

WMU Facilities Management maintains the stormwater system inventory, including outfalls and points of discharge, within a GIS-based mapping system that is periodically updated. There are currently 10 stormwater outfalls that discharge directly to Arcadia Creek and 24 points of discharge to the City of Kalamazoo MS4, which ultimately discharge to Arcadia Creek.

 

Enforcement Response Procedure

WMU maintains control over its MS4 infrastructure within the campus footprint and is responsible for compliance with its NPDES permit. While third-party discharges may occur (e.g., contractors, vendors, or campus activities), WMU retains authority to enforce compliance through University policies, procedures, and contractual requirements.

WMU implements a proactive approach to stormwater management through the use of best management practices (BMPs) and enforcement mechanisms to prevent, reduce, and eliminate pollutant discharges to the maximum extent practicable.

 

Tracking Non-Compliance

WMU utilizes a tracking system to document instances of non-compliance. The following information is recorded:

  • Description of violation
  • Location of violation
  • Date violation occurred
  • Name of responsible person or department
  • Enforcement action taken
  • Date compliance was reestablished
  • Actions taken to reduce, eliminate, and prevent recurrence

Records may be maintained electronically and are available for regulatory review upon request. Supporting documentation, including correspondence, is retained in separate files as appropriate.

 

Stormwater Management Program

The WMU Stormwater Management Program (SWMP) is comprised of six minimum control measures required by the U.S. Environmental Protection Agency (EPA) and EGLE:

1. Public Education Program (PEP)

Provides education and outreach to students, staff, and the public to reduce the discharge of pollutants to stormwater and promote stewardship of water resources.

2. Public Participation/Involvement Program (PPP)

Encourages public involvement in the development, review, and implementation of the SWMP, including access to program information and opportunities for engagement.

3. Illicit Discharge Elimination Program (IDEP)

Detects and eliminates illicit discharges and improper connections to the MS4 through inspection, investigation, and corrective action.

4. Construction Stormwater Runoff Control Program

Addresses stormwater runoff from construction activities in accordance with Part 91 Soil Erosion and Sedimentation Control requirements and other applicable standards.

5. Post-Construction Runoff Control Program

Manages stormwater runoff from new development and redevelopment projects that disturb one acre or more (or are part of a larger common plan), ensuring long-term control of stormwater impacts.

6. Pollution Prevention and Good Housekeeping Program

Reduces pollutant runoff from municipal operations through proper maintenance practices, staff training, and operational controls.

WMU’s SWMP also includes implementation of applicable Total Maximum Daily Load (TMDL) requirements for E. coli in Arcadia Creek, including monitoring and best management practices to reduce pollutant loading. Monitoring efforts are implemented using a phased, data-driven approach that prioritizes in-stream evaluation and targeted outfall sampling where warranted.

 

References

Boyer, K. B., and Kieser, M.S. (2012) Urban Stormwater Management—An MS4 Success Story for Western Michigan University. Journal of Green Building (7):1, pp. 28–39.

Kieser & Associates, LLC (K&A). 2011. Western Michigan University TMDL Compliance Planning Project. Prepared for Western Michigan University (Project Code: 8635-0006).

Kieser & Associates, LLC (K&A). 2014. Western Michigan University Arcadia Creek Water Quality Monitoring Project. Prepared for Western Michigan University (Project Code: 2-12-0502).

Kieser & Associates, LLC (K&A). 2023. Western Michigan University Arcadia Creek E. coli Monitoring Project. Prepared for Western Michigan University.

Attachments

WMU SWMP '26 with no attachments

 

Published:  3/18/2026