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Key Challenges of Implementing Phase II MS4

Small cities, counties and other regulated entities are now in the third year of their first five-year permit to implement their Phase II MS4 program to protect water quality from pollutants in stormwater runoff. Year-to-year progress towards implementation must be demonstrated to the TCEQ until the full program is in place by August 2012. Some of the challenges and potential solutions faced by those implementing Phase II MS4 programs are discussed below.

Interdepartmental Support: Getting Adequate Action and Support from Other Department Personnel
Solution: Obtain Upper Level Management Support – This is critical to getting support across departments. It takes a cross-departmental team, with system-wide knowledge and skills, to develop approaches that effectively protect water quality.

Compliance Coordination: Add Staff in Tight Economic Times, Assign to Existing Staff, or Something Else?
Solution:  Outsource Compliance Coordination – Current budget limitations restrict many entities from hiring a compliance coordinator, and the same hiring limitations may be keeping existing staff’s plate full. Outsourcing to assist existing staff with compliance coordination is a cost-effective approach to consider.

Storm System Mapping, Inspections, and Maintenance: Figuring out who has the Time to Map Your Storm System, Much Less Inspect or Maintain it.
Solution: Multitask Field Work – Take advantage of required staff time in the field to: map the storm system, conduct illicit discharge inspections, and while you’re at it, assess the system for maintenance needs. Documenting your storm system in GIS provides a mechanism to track the location of infrastructure needs and illicit discharge problems.

Funding: Steady Implementation Means the Program Will Gradually Cost More Through 2012. How Will the Increased Activities be Funded?
Solution: Develop a New or Increase an Existing Stormwater Utility Fee – Utility fees provide a stable, long-term funding mechanism for Phase II MS4 permit compliance. Many entities have increased existing utility fees to address increasing storm system compliance and maintenance costs. Fee credits for low impact development provide the development community an incentive to help you meet post-construction runoff control requirements.

Post-construction Runoff Control Ordinance:  Revising Drainage Design Criteria to Include Water Quality Protection in Addition to Existing Flood Protection Requirements
Solution: Integrated Ordinance Development – Three ordinances are required for Phase II MS4 entities: construction site runoff control, illicit discharge detection and elimination, and post-construction runoff control. Be careful about adopting boilerplate ordinances as they are. The new ordinance requirements affect and may potentially conflict with existing codes. In particular, the post-construction runoff ordinance requirements likely will affect not only typical engineering services functions but also planning functions early in the development process. Click on the below links for good resources on example ordinances:

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TagsStormwater Utility, Phase II MS4, Ordinance, iSWM,

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