June 11th is Your MS4 Deadline! Are You Ready to Submit?
What is an MS4?
An MS4, or “municipal separate storm sewer systems,” is part of the Texas Pollutant Discharge Elimination System (TPDES) general permit. The goal of an MS4 is to reduce potential pollutants conveyed to our local waters.
The MS4 lists several Minimum Control Measures, or MCMs, that a City must address:
- Public Education, Outreach and Involvement
- Illicit Discharge Detection and Elimination (IDDE)
- Construction Site Stormwater Runoff Control
- Post Construction Stormwater Management in New Development and Redevelopment
- Pollution Prevention and Good Housekeeping for Municipal Operations
- Industrial Stormwater Sources (MS4s with population over 100,000)
- Authorization for Construction Activities where the Small MS4 is the Site Operator (Optional)
I thought I wasn’t subject to the MS4 Permit
The MS4 applicability is based on urbanized area (UA) that is defined by the latest census. If any portion of your jurisdiction is located in an urbanized area, then it is subject to the MS4 requirements.
The updated MS4 Permit was renewed on Dec. 13, 2013 and is based on the 2010 Census. Look at the map of the 2000 and 2010 UA above to see if your community is now subject to MS4 requirements. Click here to view a larger map. UA maps from other areas in the country can be found on the U.S. Environmental Protection Agency’s website.
What do I have to do?
The main requirement of an MS4 is to prepare and to submit a Stormwater Management Plan, or SWMP. This will be a guide of best management practices or BMPs that your City will enact and document to address the MCMs. An annual report will have to be submitted to TCEQ every year for the next five years to update them on your progress.
Freese and Nichols has helped several cities meet their MS4 requirements by determining what BMPs a city is already performing, what new BMPs can be enacted, preparing and submitting their SWMP, and preparing the annual reports to make sure they stay in compliance. If you would like more information on how Freese and Nichols can help you please contact: Trey Shanks, CFM, Trey.Shanks@freese.com; 214-217-2221.