Stormwater CenterDesign · Data · Practice

Local Review Process

A structured, multi-stage plan review process is the administrative foundation of a successful local stormwater management program. It provides a predictable and transparent framework for ensuring that proposed land development projects comply with local ordinances and meet established performance standards for water quality and quantity control. A well-defined review process helps both municipal staff and design professionals navigate regulatory requirements efficiently, leading to the construction of effective, functional, and maintainable stormwater infrastructure.

The process translates the policies and technical standards of a stormwater manual into practice on a site-by-site basis. It begins with initial concepts and culminates in the final acceptance of constructed facilities, ensuring that the public interest in resource protection is upheld from project inception through its long-term operation.

Stages of the Review Process

The local stormwater plan review is typically a phased process that aligns with the overall land development approval timeline. Each stage has a distinct purpose, requiring specific submissions from the applicant and a corresponding focus for the municipal reviewer. This multi-step approach allows major design issues to be resolved early, preventing costly revisions during later stages.

Stage Typical Submittals Reviewer Focus
Pre-Application / Concept Plan Basic site map, project narrative, preliminary locations of buildings and impervious areas, proposed stormwater practice types and locations. High-level feasibility, opportunities for Better Site Design, appropriate practice selection for site constraints, identification of major resource protection issues (e.g., buffers, steep slopes).
Preliminary Plan Review Scaled site plan, preliminary grading and drainage area maps, initial sizing calculations, draft erosion and sediment control plan. Confirmation of drainage patterns, verification of initial sizing against sizing criteria, integration with other site elements, compliance with resource protection buffers and setbacks.
Final Design Review Full engineering plans and specifications, detailed hydrologic and hydraulic reports, final landscape plans, soils investigation reports, draft maintenance agreement and easement plats. Detailed verification of all calculations, compliance with all ordinance standards and construction specifications, adequacy of the long-term maintenance plan and associated legal instruments.
Construction Phase Inspection requests at key milestones, material certifications, field change requests. Adherence to the approved plans, proper installation techniques, material verification, effective implementation of erosion and sediment controls.
Final Approval / As-Built Certified as-built drawings, final inspection request, executed maintenance agreements, documentation of maintenance responsibility transfer. Verification that constructed facilities match approved plans (or acceptable deviations), confirmation of functionality, and completion of all legal and financial closeout requirements.

Review Checklists

Checklists are essential tools for ensuring a consistent, thorough, and objective review of stormwater management plans. They translate complex ordinance requirements and technical standards into a verifiable format, providing a clear record of compliance for both the reviewer and the applicant. By standardizing the review, checklists minimize subjectivity and help ensure that all projects are evaluated against the same criteria.

Effective checklists are tailored to each stage of the review process:

  • Plan Review Checklists: These are used during the preliminary and final design review stages. They typically cover administrative completeness (e.g., all forms submitted, fees paid), technical completeness (e.g., all required reports and calculations included), and substantive compliance with design criteria. A substantive review would verify items such as the correct application of runoff calculation methods, adherence to material specifications, and the inclusion of required design elements like pretreatment, underdrains, and observation wells.
  • Construction Inspection Checklists: These are field-based tools used by inspectors to verify that stormwater practices are built according to the approved plans and specifications. Checklists are often practice-specific, guiding the inspector through critical installation steps and hold points. For example, a bioretention construction checklist would include verification of excavation depth and dimensions, placement and composition of filter media, installation of the underdrain system, and final grading and planting.
  • Maintenance Inspection Checklists: While used after construction is complete, the maintenance plan and its associated checklists are a required component of the final design submission. The review of these documents ensures that a clear, actionable plan is in place for long-term upkeep. These checklists guide future inspectors in assessing the functional condition of a facility, noting issues like sediment accumulation, erosion, vegetation health, and structural integrity.

Construction Inspection and Enforcement Hooks

A thoroughly reviewed and approved plan has little value if it is not implemented correctly in the field. The construction phase is a critical control point in the stormwater management process, requiring active oversight by municipal inspectors or qualified third-party professionals. The goal of construction inspection is to ensure that the developer’s contractor builds all facilities in strict accordance with the approved plans and construction specifications.

A key element of a successful inspection program is the establishment of “hold points.” These are mandatory inspection milestones in the construction sequence that must be approved by the inspector before work can proceed. Examples include:

  • After excavation for an infiltration practice but before placement of stone or filter media.
  • After installation of outlet control structures but before backfilling.
  • After placement of all components of a filter media bed but before placement of topsoil or mulch.

When inspections reveal deficiencies, the municipality must have clear enforcement mechanisms. These “enforcement hooks” are established in the local stormwater ordinance and provide the legal authority to compel compliance. Common enforcement tools include:

  • Notice of Violation: A formal written notice to the developer detailing the non-compliant work and specifying a timeframe for correction.
  • Stop-Work Order: An order that legally halts all construction activity on a site (or a portion of it) until deficiencies are corrected and re-inspected.
  • Withholding of Other Permits: A municipality may refuse to issue building permits for vertical construction or withhold the final Certificate of Occupancy until all stormwater infrastructure is installed correctly and is fully functional.
  • Forfeiture of Financial Securities: Most jurisdictions require developers to post performance bonds or other financial sureties. If a developer fails to correct deficiencies, the municipality can “call” the bond, using the funds to hire another contractor to complete or repair the work.

As-Built Verification and Project Closeout

The final stage of the review and approval process is project closeout. This administrative phase ensures that the completed project is properly documented and that provisions for long-term care are legally in place before the developer’s obligations are released.

The centerpiece of this stage is the as-built plan. An as-built plan is a revised set of the original engineering drawings that documents the final, in-place conditions of the constructed stormwater facilities. It must reflect all field changes and deviations from the original design and be certified for accuracy by a licensed professional engineer or land surveyor. As-builts are a critical record, providing the baseline information needed for all future maintenance, inspections, and any potential retrofits.

The closeout process typically involves the following steps:

  1. The developer submits certified as-built plans to the municipality.
  2. A municipal inspector conducts a final inspection, using the as-built plans to verify that all components are present, accessible, and functioning correctly.
  3. The developer submits the final, executed maintenance agreement and easement documents for recording with the local land records office.
  4. Upon successful final inspection and recording of all legal documents, the municipality formally accepts the facilities (if they are to be publicly maintained) and authorizes the release of the developer’s performance bond.
  5. The facility is entered into the municipality’s asset inventory and long-term maintenance tracking system.

Tips for Streamlining Review

Municipalities can take several steps to make their stormwater plan review process more efficient and effective for both staff and applicants:

  • Develop and publish clear, comprehensive submission checklists and application guides.
  • Require pre-application meetings for all major development proposals to identify key issues early.
  • Implement a digital submission and review platform to streamline document management and communication.
  • Provide applicants with a single, consolidated set of comments from all reviewing departments after each review cycle.
  • Establish a formal process for inter-departmental coordination between engineering, planning, and public works.
  • Ensure review staff receive regular training on local codes, new stormwater technologies, and best practices in plan review.
  • Consider authorizing a list of qualified third-party engineering firms to conduct reviews on behalf of the municipality to manage peak workloads.

Frequently Asked Questions

What is the difference between a concept plan and a final plan?

A concept plan is a preliminary submittal that focuses on the overall site layout and the proposed strategy for managing stormwater. It involves approximate sizing and locations for practices. A final plan contains detailed engineering calculations, construction-ready drawings, specifications, and legal documents required for a permit. The review process moves from high-level feasibility at the concept stage to detailed regulatory compliance at the final stage.

Who typically reviews stormwater plans?

Stormwater plans are generally reviewed by professional engineers or trained technicians within a municipality’s department of public works, engineering, or community development. Some jurisdictions also use qualified third-party engineering consultants to perform reviews on their behalf, particularly for complex projects or during periods of high development activity.

How many review cycles are typical for a project?

The number of review cycles can vary depending on the quality of the initial submission and the complexity of the project. A well-prepared plan might be approved after one or two reviews. It is common for a final engineering plan to go through two or three rounds of review and revision before it fully meets all ordinance requirements and is approved.

What happens if a project is built differently from the approved plan?

If construction deviates from the approved plans without authorization, the municipality can take enforcement action. This may include issuing a stop-work order until the issue is corrected, requiring the unapproved work to be removed and reconstructed, or withholding the certificate of occupancy. Minor field changes are sometimes acceptable but must be documented and approved by the reviewing engineer, and ultimately recorded on the final as-built plans.

Why are as-built plans required for project closeout?

As-built plans create a permanent, accurate record of the infrastructure as it was actually constructed. This is critical for several reasons: it verifies to the municipality that the facilities were built correctly, it provides the baseline for all future maintenance and inspection activities, and it serves as an essential reference for future site modifications or utility work. Without an accurate as-built, long-term asset management is extremely difficult.

Can a developer get a waiver from stormwater requirements?

Local ordinances define the conditions under which a waiver may be granted. Waivers are typically not granted from the core requirements to manage stormwater. However, some ordinances may include provisions for waivers from specific design constraints or allow for alternative compliance options, such as payment of a fee-in-lieu or off-site mitigation, particularly for redevelopment projects or sites with severe physical limitations.