MS4 Permit

The MS4 permit requires regulated municipal MS4s (See Maps) to develop and fully implement a stormwater management program by 2008. Stormwater management programs must contain appropriate management practices in each of the six minimum control measures outlined below.

NOI and Annual Reports
As a first step toward obtaining SPDES permit coverage regulated MS4s were required to submit a Notice of Intent (NOI) form to DEC by March 10, 2003. The NOI required MS4s to provide an initial outline of planned management practices and to submit subsequent Annual Reports to assess progress toward the full implementation of an appropriate stormwater management plan. Please note that there is a different format for the Years 3-5 Annual Report. Click here to see a list of the forms.

Six Minimum Control Measures

The following sections detail the requirements of each minimum control measure and outline some activities and/or practices that can be used to fulfill these requirements. MS4s should check the final permit for full program responsibilities and requirements. To see the original EPA document, and for the purposes of printing and/or distribution, click on the name of the control measure.

Public Education and Outreach
Public Participation and Involvement
Illicit Discharge Detection and Elimination
Construction Site Runoff Control
Post-Construction Runoff Control
Pollution Prevention and Good Housekeeping

2.3 Public Education and Outreach

For supporting materials to assist with this measure please see the Educational section of this website.

Requirements:
To satisfy this minimum control measure, the operator of a regulated small MS4 needs to:

Implement a public education program to distribute educational materials to the community, or conduct equivalent outreach activities about the impacts of storm water discharges on local waterbodies and the steps that can be taken to reduce storm water pollution; and
Determine the appropriate best management practices (BMPs) and measurable goals for this minimum control measure. Some program implementation approaches, BMPs (i.e., the program actions/activities), and measurable goals are suggested below.

What Are Some Guidelines for Developing and Implementing This Measure?
Three main action areas are important for successful implementation of a public education and outreach program:

1. Forming Partnerships
Operators of regulated small MS4s are encouraged to enter into partnerships with other governmental entities to fulfill this minimum control measure's requirements. It is generally more cost-effective to use an existing program, or to develop a new regional or state-wide education program, than to have numerous operators developing their own local programs. Operators also are encouraged to seek assistance from nongovernmental organizations (e.g., environmental, civic, and industrial organizations), since many already have educational materials and perform outreach activities.

2. Using Educational Materials and Strategies
Operators of regulated small MS4s may use storm water educational information provided by the U.S. EPA or the NYS DEC instead of developing their own materials. Operators should strive to make their materials and activities relevant to local situations and issues, and incorporate a variety of strategies to ensure maximum coverage. Some examples include:

Brochures or fact sheets for general public and specific audiences;
Recreational guides to educate groups such as golfers, hikers, paddlers, climbers, fishermen, and campers;
Alternative information sources, such as web sites, bumper stickers, refrigerator magnets, posters for bus and subway stops, and restaurant placemats;
A library of educational materials for community and school groups;
Volunteer citizen educators to staff a public education task force;
Event participation with educational displays at home shows and community festivals;
Educational programs for school-age children;
Storm drain stenciling of storm drains with messages such as "Do Not Dump - Drains Directly to Lake;"
Storm water hotlines for information and for citizen reporting of polluters;
Economic incentives to citizens and businesses (e.g., rebates to homeowners purchasing mulching lawnmowers or biodegradable lawn products);and
Tributary signage to increase public awareness of local water resources.


3. Reaching Diverse Audiences
The public education program should use a mix of appropriate local strategies to address the viewpoints and concerns of a variety of audiences and communities, including minority and disadvantaged communities, as well as children. Printing posters and brochures in more than one language or posting large warning signs (e.g., cautioning against fishing or swimming) near storm sewer outfalls are methods that can be used to reach audiences less likely to read standard materials. Directing materials or outreach programs toward specific groups of commercial, industrial, and institutional entities likely to have significant storm water impacts is also recommended. For example, information could be provided to restaurants on the effects of grease clogging storm drains and to auto garages on the effects of dumping used oil into storm drains.


What Are Appropriate Measurable Goals?
Measurable goals, which are required for each minimum control measure, are intended to gauge permit compliance and program effectiveness. The measurable goals, as well as the BMPs, should reflect the needs and characteristics of the operator and the area served by its small MS4. Furthermore, they should be chosen using an integrated approach that fully addresses the requirements and intent of the minimum control measure. An integrated approach for this minimum measure could include the following measurable goals:

Target DateActivity
1 year:Brochures developed (bilingual, if appropriate) and distributed in water utility bills; a storm water hotline in place; volunteer educators trained.
2 years:A web site created; school curricula developed; storm drains stenciled.
3 years:A certain percentage of restaurants no longer dumping grease and other pollutants down storm sewer drains.
4 years:A certain percentage reduction in litter or animal waste detected in discharges.
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2.4 Public Participation and Involvement

Requirements:
To satisfy this minimum control measure, the operator of a regulated small MS4 must:

Comply with applicable State and local public notice requirements; and
Determine the appropriate best management practices (BMPs) and measurable goals for this minimum control measure. Possible implementation approaches, BMPs (i.e., the program actions and activities), and measurable goals are described below.

What Are Some Guidelines for Developing and Implementing This Measure?
Operators of regulated small MS4s should include the public in developing, implementing, and reviewing their storm water management programs. The public participation process should make every effort to reach out and engage all economic and ethnic groups. EPA recognizes that there are challenges associated with public involvement. Nevertheless, EPA strongly believes that these challenges can be addressed through an aggressive and inclusive program. Challenges and example practices that can help ensure successful participation are discussed below.

Implementation Challenges
The best way to handle common notification and recruitment challenges is to know the audience and think creatively about how to gain its attention and interest. Traditional methods of soliciting public input are not always successful in generating interest, and subsequent involvement, in all sectors of the community. For example, municipalities often rely solely on advertising in local newspapers to announce public meetings and other opportunities for public involvement. Since there may be large sectors of the population who do not read the local press, the audience reached may be limited. Therefore, alternative advertising methods should be used whenever possible, including radio or television spots, postings at bus or subway stops, announcements in neighborhood newsletters, announcements at civic organization meetings, distribution of flyers, mass mailings, door-to-door visits, telephone notifications, and multilingual announcements. These efforts, of course, are tied closely to the efforts for the public education and outreach minimum control measure (see Fact Sheet 2.3).

In addition, advertising and soliciting for help should be targeted at specific population sectors, including ethnic, minority, and low-income communities; academia and educational institutions; neighborhood and community groups; outdoor recreation groups; and business and industry. The goal is to involve a diverse cross-section of people who can offer a multitude of concerns, ideas, and connections during the program development process.

Possible Practices (BMPs)
There are a variety of practices that could be incorporated into a public participation and involvement program, such as:

Public meetings/citizen panels allow citizens to discuss various viewpoints and provide input concerning appropriate storm water management policies and BMPs;
Volunteer water quality monitoring gives citizens firsthand knowledge of the quality of local water bodies and provides a cost-effective means of collecting water quality data;
Volunteer educators/speakers who can conduct workshops, encourage public participation, and staff special events;
Storm drain stenciling is an important and simple activity that concerned citizens, especially students, can do;
Community clean-ups along local waterways, beaches, and around storm drains;
Citizen watch groups can aid local enforcement authorities in the identification of polluters; and
"Adopt A Storm Drain" programs encourage individuals or groups to keep storm drains free of debris and to monitor what is entering local waterways through storm drains.


What Are Appropriate Measurable Goals?
Measurable goals, which are required for each minimum control measure, are intended to gauge permit compliance and program effectiveness. The measurable goals, as well as the BMPs, greatly depend on the needs and characteristics of the operator and the area served by the small MS4. Furthermore, they should be chosen using an integrated approach that fully addresses the requirements and intent of the minimum control measure. An integrated approach for this minimum measure could include the following measurable goals:

Target DateActivity
1 year:Notice of a public meeting in several different print media and bilingual flyers; citizen panel established; volunteers organized to locate outfalls/illicit discharges and stencil drains.
2 years:Final recommendations of the citizen panel; radio spots promoting program and participation.
3 years:A certain percentage of the community participating in community clean-ups.
4 years:Citizen watch groups established in a certain percentage of neighborhoods; outreach to every different population sector completed.
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2.5 Illicit Discharge Detection and Elimination

Requirements:
Recognizing the adverse effects illicit discharges can have on receiving waters, the final rule requires an operator of a regulated small MS4 to develop, implement and enforce an illicit discharge detection and elimination program. This program must include the following:

A storm sewer system map, showing the location of all outfalls and the names and location of all waters of the United States that receive discharges from those outfalls;
Through an ordinance, or other regulatory mechanism, a prohibition (to the extent allowable under State or local law) on non-storm water discharges into the MS4, and appropriate enforcement procedures and actions;
A plan to detect and address non-storm water discharges, including illegal dumping, into the MS4;
The education of public employees, businesses, and the general public about the hazards associated with illegal discharges and improper disposal of waste; and
The determination of appropriate best management practices (BMPs) and measurable goals for this minimum control measure. Some program implementation approaches, BMPs (i.e., the program actions/activities), and measurable goals are suggested below.

Does This Measure Need to Address All Illicit Discharges?
No. The illicit discharge detection and elimination program does not need to address the following categories of non-storm water discharges or flows unless the operator of the regulated small MS4 identifies them as significant contributors of pollutants to its MS4:


Water line flushing;
Landscape irrigation;
Diverted stream flows;
Rising ground waters;
Uncontaminated ground water infiltration;
Uncontaminated pumped ground water;
Discharges from potable water sources;
Foundation drains;
Air conditioning condensation;
Irrigation water;
Springs;
Water from crawl space pumps;
Footing drains;
Lawn watering;
Individual residential car washing;
Flows from riparian habitats and wetlands;
Dechlorinated swimming pool discharges; and
Street wash water.

What Are Some Guidelines for Developing and Implementing This Measure?
The objective of the illicit discharge detection and elimination minimum control measure is to have regulated small MS4 operators gain a thorough awareness of their systems. This awareness allows them to determine the types and sources of illicit discharges entering their system; and establish the legal, technical, and educational means needed to eliminate these discharges. Permittees could meet these objectives in a variety of ways depending on their individual needs and abilities, but some general guidance for each requirement is provided below.

The Map
The storm sewer system map is meant to demonstrate a basic awareness of the intake and discharge areas of the system. It is needed to help determine the extent of discharged dry weather flows, the possible sources of the dry weather flows, and the particular waterbodies these flows may be affecting. An existing map, such as a topographical map, on which the location of major pipes and outfalls can be clearly presented demonstrates such awareness. EPA recommends collecting all existing information on outfall locations (e.g., review city records, drainage maps, storm drain maps), and then conducting field surveys to verify locations. It probably will be necessary to walk (i.e., wade through small receiving waters or use a boat for larger waters) the streambanks and shorelines for visual observation. More than one trip may be needed to locate all outfalls.

Legal Prohibition and Enforcement
EPA recognizes that some permittees may have limited authority under State or local law to establish and enforce an ordinance or other regulatory mechanism prohibiting illicit discharges. In such a case, the permittee is encouraged to obtain the necessary authority, if possible.

The Plan
The plan to detect and address illicit discharges is the central component of this minimum control measure. The plan is dependant upon several factors, including the permittee's available resources, size of staff, and degree and character of its illicit discharges. As guidance only, the four steps of a recommended plan are outlined below:


1. Locate Problem Areas
EPA recommends that priority areas be identified for detailed screening of the system based on the likelihood of illicit connections (e.g., areas with older sanitary sewer lines). Methods that can locate problem areas include: public complaints; visual screening; water sampling from manholes and outfalls during dry weather; and use of infrared and thermal photography.
2. Find the Source
Once a problem area or discharge is found, additional efforts usually are necessary to determine the source of the problem. Methods that can find the source of the illicit discharge include: dye-testing buildings in problem areas; dye- or smoke-testing buildings at the time of sale; tracing the discharge upstream in the storm sewer; employing a certification program that shows that buildings have been checked for illicit connections; implementing an inspection program of existing septic systems; and using video to inspect the storm sewers.
3. Remove/Correct Illicit Connections
Once the source is identified, the offending discharger should be notified and directed to correct the problem. Education efforts and working with the discharger can be effective in resolving the problem before taking legal action.
4. Document Actions Taken
As a final step, all actions taken under the plan should be documented. This illustrates that progress is being made to eliminate illicit connections and discharges. Documented actions should be included in annual reports and include information such as: the number of outfalls screened; any complaints received and corrected; the number of discharges and quantities of flow eliminated; and the number of dye or smoke tests conducted.

Educational Outreach
Outreach to public employees, businesses, property owners, the general community, and elected officials regarding ways to detect and eliminate illicit discharges is an integral part of this minimum measure that will help gain support for the permittee's storm water program. Suggested educational outreach efforts include:


• Developing informative brochures, and guidances for specific audiences (e.g., carpet cleaning businesses) and school curricula;
• Designing a program to publicize and facilitate public reporting of illicit discharges;
• Coordinating volunteers for locating, and visually inspecting, outfalls or to stencil storm drains; and
• Initiating recycling programs for commonly dumped wastes, such as motor oil, antifreeze, and pesticides.


What Are Appropriate Measurable Goals?
Measurable goals, which are required for each minimum control measure, are intended to gauge permit compliance and program effectiveness. The measurable goals, as well as the BMPs, should reflect the needs and characteristics of the operator and the area served by its small MS4. Furthermore, they should be chosen using an integrated approach that fully addresses the requirements and intent of the minimum control measure. An integrated approach for this minimum measure could include the following measurable goals:

Target DateActivity
1 year:Sewer system map completed; recycling program for household hazardous waste in place.
2 years:Ordinance in place; training for public employees completed; a certain percentage of sources of illicit discharges determined.
3 years:A certain percentage of illicit discharges detected; illicit discharges eliminated; and households participating in quarterly household hazardous waste special collection days.
4 years:Most illicit discharge sources detected and eliminated.

The educational outreach measurable goals for this minimum control measure could be combined with the measurable goals for the Public Education and Outreach minimum control measure (see Fact Sheet 2.3).


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2.6 Construction Site Runoff Control

For supporting materials to assist with this measure please see the

Requirements:
The Phase II Final Rule requires an operator of a regulated small MS4 to develop, implement, and enforce a program to reduce pollutants in storm water runoff to their MS4 from construction activities that result in a land disturbance of greater than or equal to one acre. The small MS4 operator is required to:

Have an ordinance or other regulatory mechanism requiring the implementation of proper erosion and sediment controls, and controls for other wastes, on applicable construction sites;
Have procedures for site plan review of construction plans that consider potential water quality impacts;
Have procedures for site inspection and enforcement of control measures;
Have sanctions to ensure compliance (established in the ordinance or other regulatory mechanism);
Establish procedures for the receipt and consideration of information submitted by the public; and
Determine the appropriate best management practices (BMPs) and measurable goals for this minimum control measure. Suggested BMPs (i.e., the program actions/activities) and measurable goals are presented below.

What Are Some Guidelines for Developing and Implementing This Measure?
Further explanation and guidance for each component of a regulated small MS4's construction program is provided below.

Regulatory Mechanism
Through the development of an ordinance or other regulatory mechanism, the small MS4 operator must establish a construction program that controls polluted runoff from construction sites with a land disturbance of greater than or equal to one acre. Because there may be limitations on regulatory legal authority, the small MS4 operator is required to satisfy this minimum control measure only to the maximum extent practicable and allowable under State, Tribal, or local law.

Site Plan Review
The small MS4 operator must include in its construction program requirements for the implementation of appropriate BMPs on construction sites to control erosion and sediment and other waste at the site. To determine if a construction site is in compliance with such provisions, the small MS4 operator should review the site plans submitted by the construction site operator before ground is broken.

Site plan review aids in compliance and enforcement efforts since it alerts the small MS4 operator early in the process to the planned use or non-use of proper BMPs and provides a way to track new construction activities. The tracking of sites is useful not only for the small MS4 operator's recordkeeping and reporting purposes, which are required under their NPDES storm water permit (see Fact Sheet 2.9), but also for members of the public interested in ensuring that the sites are in compliance.

Inspections and Penalties
Once construction commences, BMPs should be in place and the small MS4 operator's enforcement activities should begin. To ensure that the BMPs are properly installed, the small MS4 operator is required to develop procedures for site inspection and enforcement of control measures to deter infractions. Procedures could include steps to identify priority sites for inspection and enforcement based on the nature and extent of the construction activity, topography, and the characteristics of soils and receiving water quality. Inspections give the MS4 operator an opportunity to provide additional guidance and education, issue warnings, or assess penalties. To conserve staff resources, one possible option for small MS4 operators is to have these inspections performed by the same inspector that visits the sites to check compliance with health and safety building codes.

Information Submitted by the Public
A final requirement of the small MS4 program for construction activity is the development of procedures for the receipt and consideration of public inquiries, concerns, and information submitted regarding local construction activities. This provision is intended to further reinforce the public participation component of the regulated small MS4 storm water program (see Fact Sheet 2.4) and to recognize the crucial role that the public can play in identifying instances of noncompliance.

The small MS4 operator is required only to consider the information submitted, and may not need to follow-up and respond to every complaint or concern. Although some form of enforcement action or reply is not required, the small MS4 operator is required to demonstrate acknowledgment and consideration of the information submitted. A simple tracking process in which submitted public information, both written and verbal, is recorded and then given to the construction site inspector for possible follow-up will suffice.


What Are Appropriate Measurable Goals?
Measurable goals, which are required for each minimum control measure, are intended to gauge permit compliance and program effectiveness. The measurable goals, as well as the BMPs, should reflect the needs and characteristics of the operator and the area served by its small MS4. Furthermore, they should be chosen using an integrated approach that fully addresses the requirements and intent of the minimum control measure. An integrated approach for this minimum measure could include the following measurable goals:

Target DateActivity
1 year:Ordinance or other regulatory mechanism in place; procedures for information submitted by the public in place.
2 years:Procedures for site inspections implemented; a certain percentage rate of compliance achieved by construction operators.
3 years:Maximum compliance with ordinance; improved clarity and reduced sedimentation of local waterbodies.
4 years:Increased numbers of sensitive aquatic organisms in local waterbodies.

Are Construction Sites Already Covered Under the NPDES Storm Water Program?

Yes. EPA's Phase I NPDES storm water program requires operators of construction activities that disturb five or more acres to obtain a NPDES construction storm water permit. General permit requirements include the submission of a Notice of Intent and the development of a storm water pollution prevention plan (SWPPP). The SWPPP must include a site description and measures and controls to prevent or minimize pollutants in storm water discharges. The Phase II Final Rule similarly regulates discharges from smaller construction sites disturbing equal to or greater than one acre and less than five acres (see Fact Sheet 3.0 for information on the Phase II construction program).

Even though all construction sites that disturb more than one acre are covered nationally by an NPDES storm water permit, the construction site runoff control minimum measure for the small MS4 program is needed to induce more localized site regulation and enforcement efforts, and to enable operators of regulated small MS4s to more effectively control construction site discharges into their MS4s.

To aid operators of regulated construction sites in their efforts to comply with both local requirements and their NPDES permit, the Phase II Final Rule includes a provision that allows the NPDES permitting authority to reference a "qualifying State, Tribal or local program" in the NPDES general permit for construction. This means that if a construction site is located in an area covered by a qualifying local program, then the construction site operator's compliance with the local program constitutes compliance with their NPDES permit. A regulated small MS4's storm water program for construction could be a "qualifying program" if the MS4 operator requires a SWPPP, in addition to the requirements summarized in this fact sheet.

The ability to reference other programs in the NPDES permit is intended to reduce confusion between overlapping and similar requirements, while still providing for both local and national regulatory coverage of the construction site. The provision allowing NPDES permitting authorities to reference other programs has no impact on, or direct relation to, the small MS4 operator's responsibilities under the construction site runoff control minimum measure profiled here.

Is a Small MS4 Required to Regulate Construction Sites that the Permitting Authority has Waived from the NPDES Construction Program?

No. If the NPDES permitting authority waives requirements for storm water discharges associated with small construction activity, the small MS4 operator is not required to develop, implement, and/or enforce a program to reduce pollutant discharges from such construction sites.

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2.7 Post-Construction Runoff Control

For supporting materials to assist with this measure please see the

Requirements:
The Phase II Final Rule requires an operator of a regulated small MS4 to develop, implement, and enforce a program to reduce pollutants in post-construction runoff to their MS4 from new development and redevelopment projects that result in the land disturbance of greater than or equal to 1 acre. The small MS4 operator is required to:

Develop and implement strategies which include a combination of structural and/or nonstructural best management practices (BMPs);
Have an ordinance or other regulatory mechanism requiring the implementation of postconstruction runoff controls to the extent allowable under State or local law,
Ensure adequate long-term operation and maintenance of controls;
Determine the appropriate best management practices (BMPs) and measurable goals for this minimum control measure.

What Is Considered a "Redevelopment" Project?
The term "redevelopment" refers to alterations of a property that change the "footprint" of a site or building in such a way that there is a disturbance of equal to or greater than 1 acre of land. The term does not include such activities as exterior remodeling. Because redevelopment projects may have site constraints not found on new development sites, the rule provides flexibility for implementing post-construction controls on redevelopment sites that consider these constraints.


What Are Some Guidelines for Developing and Implementing This Measure?
This section includes some sample non-structural and structural BMPs that could be used to satisfy the requirements of the post-construction runoff control minimum measure. It is important to recognize that many BMPs are climate-specific, and not all BMPs are appropriate in every geographic area. Because the requirements of this measure are closely tied to the requirements of the construction site runoff control minimum measure (see Fact Sheet 2.6), EPA recommends that small MS4 operators develop and implement these two measures in tandem. Sample BMPs follow.

Non-Structural BMPs
Planning and Procedures.
Runoff problems can be addressed efficiently with sound planning procedures. Master Plans, Comprehensive Plans, and zoning ordinances can promote improved water quality by guiding the growth of a community away from sensitive areas and by restricting certain types of growth (industrial, for example) to areas that can support it without compromising water quality.
Site-Based Local Controls
These controls can include buffer strip and riparian zone preservation, minimization of disturbance and imperviousness, and maximization of open space.
Structural BMPs
Storage Practices
Storage or detention BMPs control storm water by gathering runoff in wet ponds, dry basins, or multichamber catch basins and slowly releasing it to receiving waters or drainage systems. These practices both control storm water volume and settle out particulates for pollutant removal.
Infiltration Practices
Infiltration BMPs are designed to facilitate the percolation of runoff through the soil to ground water, and, thereby, result in reduced storm water quantity and reduced mobilization of pollutants. Examples include infiltration basins/trenches, dry wells, and porous pavement.
Vegetative Practices
Vegetative BMPs are landscaping features that, with optimal design and good soil conditions, enhance pollutant removal, maintain/improve natural site hydrology, promote healthier habitats, and increase aesthetic appeal. Examples include grassy swales, filter strips, artificial wetlands, and rain gardens.


What Are Appropriate Measurable Goals?
Measurable goals, which are required for each minimum control measure, are intended to gauge permit compliance and program effectiveness. The measurable goals, as well as the BMPs, should reflect needs and characteristics of the operator and the area served by its small MS4. Furthermore, the measurable goals should be chosen using an integrated approach that fully addresses the requirements and intent of the minimum control measure. An integrated approach for this minimum measure could include the following goals:

Target DateActivity
1 year:Strategies developed that include structural and/or non-structural BMPs.
2 years:Strategies codified by use of ordinance or other regulatory mechanism.
3 years:Reduced percent of new impervious surfaces associated with new development projects.
4 years:Improved clarity and reduced sedimentation of local waterbodies.
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2.8 Pollution Prevention and Good Housekeeping

Requirements:
Recognizing the benefits of pollution prevention practices, the rule requires an operator of a regulated small MS4 to:

Develop and implement an operation and maintenance program with the ultimate goal of preventing or reducing pollutant runoff from municipal operations into the storm sewer system;
Include employee training on how to incorporate pollution prevention/good housekeeping techniques into municipal operations such as park and open space maintenance, fleet and building maintenance, new construction and land disturbances, and storm water system maintenance. To minimize duplication of effort and conserve resources, the MS4 operator can use training materials that are available from the U.S. EPA or the NYS DEC;
Determine the appropriate best management practices (BMPs) and measurable goals for this minimum control measure. Some program implementation approaches, BMPs (i.e., the program actions/activities), and measurable goals are suggested below.

What Are Some Guidelines for Developing and Implementing This Measure?
The intent of this control measure is to ensure that existing municipal, State or Federal operations are performed in ways that will minimize contamination of storm water discharges. EPA encourages the small MS4 operator to consider the following components when developing their program for this measure:

Maintenance activities, maintenance schedules, and long-term inspection procedures for structural and non-structural controls to reduce floatables and other pollutants discharged from the separate storm sewers;
Controls for reducing or eliminating the discharge of pollutants from areas such as roads and parking lots, maintenance and storage yards (including salt/sand storage and snow disposal areas), and waste transfer stations. These controls could include programs that promote recycling (to reduce litter), minimize pesticide use, and ensure the proper disposal of animal waste;
Procedures for the proper disposal of waste removed from separate storm sewer systems and areas listed in the bullet above, including dredge spoil, accumulated sediments, floatables, and other debris; and
Ways to ensure that new flood management projects assess the impacts on water quality and examine existing projects for incorporation of additional water quality protection devices or practices. EPA encourages coordination with flood control managers for the purpose of identifying and addressing environmental impacts from such projects.

The effective performance of this control measure hinges on the proper maintenance of the BMPs used, particularly for the first two bullets above. For example, structural controls, such as grates on outfalls to capture floatables, typically need regular cleaning, while non-structural controls, such as training materials and recycling programs, need periodic updating.


What Are Appropriate Measurable Goals?
Measurable goals, which are required for each minimum control measure, are meant to gauge permit compliance and program effectiveness. The measurable goals, as well as the BMPs, should consider the needs and characteristics of the operator and the area served by its small MS4. The measurable goals should be chosen using an integrated approach that fully addresses the requirements and intent of the minimum control measure. An integrated approach for this minimum measure could include the following measurable goals:

Target DateActivity
1 year:Pollution prevention plan (the new BMPs and revised procedures) completed; employee training materials gathered or developed; procedures in place for catch basin cleaning after each storm and regular street sweeping.
2 years:Training for appropriate employees completed; recycling program fully implemented.
3 years:Some pollution prevention BMPs incorporated into master plan; a certain percentage reduction in pesticide and sand/salt use; maintenance schedule for BMPs established.
4 years:A certain percentage reduction in floatables discharged; a certain compliance rate with maintenance schedules for BMPs; controls in place for all areas of concern.

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MS4 Forms

Below are the links to the initial General Permit for Small Municipal Separate Storm Sewer Systems (MS4s) and Notice of Intent that were required to be submitted by March 10, 2003.

General Permit (GP-02-02)
Notice of Intent

In order to assess progress toward the full implementation of an appropriate stormwater management plan, MS4 communities are required to submit an Annual Report form with a Municipal Compliance Certification. Below are the instructions to the Annual Report, and the Annual Report form.

Years 3-5 Annual Report Instruction Packet
Adobe PDF Format

Years 3-5 Annual Report Form with Municipal Compliance Certification
Microsoft Word Format

Years 1 & 2 Annual Report Instructions
Microsoft Word Format
Corel Wordperfect Format
Adobe PDF Format

Years 1 & 2 Annual Report Form
Microsoft Word Format
Microsoft Excel Format
Corel Wordperfect Format
Adobe PDF Format

Years 1 & 2 Municipal Compliance Certification Form
Microsoft Word Format
Corel Wordperfect Format
Adobe PDF Format


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