Municipal Stormwater Permitting

1
Municipal Stormwater Permitting

• Nancy Stoner
• Clean Water Project Director
• Natural Resources Defense Council
• 1200 New York Ave., NW
• Washington, DC 20005
• [phone]
• nstoner_at_nrdc.org

2
Stormwater Program Goals

• A strong stormwater program achieves water
  quality goals, including protection of all
  designated uses, for receiving waters.

3
Legal Standards

• Reducing discharges to the maximum extent
  practicable (MEP)
• Not causing or contributing to violations of
  water quality standards.

4
Implementation MEP Standard

• MS4 system must choose the technology that
  provides the greatest pollutant reduction unless
  it is determined to be infeasible.
• Should be applied directly to new and
  redevelopment proposals, including transportation
  projects.

5
Implementation Water Quality Standards

• Focus attention on areas of greatest/most
  significant loadings first-TMDL should be
  designed to facilitate that.
• Continually upgrade BMPs until WQS are achieved.

6
Procedural Requirements

• Where general permits are used, Notice of Intent
  (NOI) outlining MS4 plan for implementing the
  permit must be approved by permitting authority
  after opportunity for public comment and a public
  hearing, if requested.

7
Implementation of the Chesapeake Bay Agreement on
Stormwater

• MS4 permits should track these commitments

8
Other DC MS4 Issues

• WASA as a Co-Permittee in the DC MS4 permit.
• DC Stormwater Management Program

9
Funding

• Stormwater fees must be sufficient to fund the
  program and include incentives for stormwater
  minimization.

10
Conclusion

• We have to address stormwater pollution if we are
  going to make progress in urban areas in meeting
  water quality standards.
• Stormwater programs must be robust, targeted and
  continually approved.