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Addressing the MS4 Permit: Where do You Start?

The Environmental Protection Agency’s (EPA’s) new 2016 Massachusetts Small MS4 General Permit has more stringent regulatory requirements than the 2003 permit. If you are wondering how – and when – to start working towards compliance, read on!

The new MS4 permit, effective on July 1, 2017, requires MS4 communities and institutions to develop, implement, and enforce a Stormwater Management Program that controls stormwater pollutants to the greatest extent practicable. The process begins by filing a Notice of Intent (NOI) by September 29, 2017 that addresses the six Minimum Control Measures (MCMs):

  1. Public Education and Outreach
  2. Public Involvement and Participation
  3. Illicit Discharge Detection and Elimination (IDDE)
  4. Construction Site Stormwater Runoff Control
  5. Stormwater Management in New Development and Redevelopment
  6. Good Housekeeping and Pollution Prevention

The NOI will essentially serve as a roadmap for compliance with the permit requirements and the six MCMs. It must describe specific action items under each MCM, as well as set target dates for compliance. For example, the new MS4 permit requires the development of a storm sewer outfall and catchment area map by July 2019, which must be further expanded to include pipes, manholes, catch basins, and contributing areas by July 2027.

Following the development and filing of the NOI, the public will have an opportunity to review and comment. EPA will then grant authorization following the public hearing, and their review and acceptance of the NOI. Once authorized, your community will need to prepare the studies, analysis, and documentation outlined in your NOI.

Stay tuned for more information on each of the six MCMs!