Texas Phase II MS4 General Permit Status Update

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Trey Shanks

Environmental Scientist

Requirements for Detailed Measureable Goals and Procedures, Public Notice Adjustments

The revised permit will include changes in requirements that affect all Small MS4s.
Key changes include:

  • Identification of clear, specific and measurable annual goals
  • Development of standard operating procedures
  • Public notice and public reporting

Remind Me, What is a Small MS4?

A “municipal” separate storm sewer system (MS4) is a storm system owned or operated by a public entity like a city, flood control district, county or public agency. It includes ditches, curbs, gutters, storm sewers and similar means of conveying runoff that do not connect with a wastewater collection system or treatment facility before discharging into water bodies.

A Small MS4 is an MS4 in an urbanized area of the State defined by the 2010 U.S. Census. MS4s located within the boundaries of the 2000 or 2010 Urbanized Areas are subject to the Small MS4 general permit conditions.

How Can Freese and Nichols Help?

Freese and Nichols has provided Phase II MS4 program consulting services for more than 15 years to help cities, counties and other public entities meet EPA stormwater quality protection mandates. Freese and Nichols has significant expertise in MS4 program management and can assist with all aspects of program requirements, including:

Permit Coordination Assistance

  • MS4 Permit reauthorization assistance
  • Stormwater Management Plan Development
  • EPA, TCEQ coordination for permit renewal, inspections, compliance support
  • MS4 annual reporting to TCEQ
  • Data management systems for documentation and recordkeeping compliance assurance, integration with asset management and/or work order systems

Specific MS4 Program Activities

  • Storm system mapping inventory, condition assessment
  • Illicit discharge inspections
  • Stormwater ordinances for MS4 requirements
  • Construction site stormwater inspections
  • Standard operating procedures, checklists development
  • Public education and outreach – web sites, fact sheets, in-person engagements
  • Facility inspections for good housekeeping practices

Upcoming Deadlines

  • January 24, 2919: TCEQ Small MS4 Permit Renewal 
    The TCEQ has approved and issued the next five-year general permit (TXR040000) for Small MS4s.
  • July 23, 2019: Deadline to Submit SWMP to TCEQ
    Regulated organizations (Small MS4s) have six months from the effective date of the renewed permit to develop and submit an updated Stormwater Management Program (SWMP) to TCEQ for review and approval. The SWMP details the specific actions the MS4 is conducting or will conduct to protect water quality in creeks, rivers, lakes and other waterbodies from polluted stormwater runoff.

Who Should I Contact at FNI to Learn More?

Contact your FNI Client Representative or any of our MS4 team leaders below:


See Also

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Trey Shanks, CFM, IAM, leads Freese and Nichols’ Asset Management services. He is a Principal in our Fort Worth office.