Pennsylvania Department of Environmental Protection is planning to make several fundamental changes to its next general permit for municipal separate storm sewer systems, or MS4s, under the National Pollution Discharge Elimination System (NPDES). The changes are slated to take effect March 2018 and DEP is looking for “pre-draft” feedback on these proposed changes from those who are responsible for compliance with MS4 requirements. This is an opportunity for municipal engineers to be instrumental in these changes and explain how they may negatively affect municipal budgets.
DEP has published an unofficial draft of its next PAG-13 NPDES General Permit for Discharges from Small MS4s, which is available online at http:// tinyurl.com/nrmr8gr. Notice of the availability of the official draft PAG-13 general permit will soon be published in the Pennsylvania Bulletin, with a 30-day public comment period to follow.
Given the short comment period for the official draft revisions, it is recommended that all municipalities and storm water authorities become familiar with the unofficial draft as a starting point for preparing comments for the official document.
The most significant change for municipalities is most MS4 municipalities will not be able to use the general permit. DEP plans to expand the list of discharges that are not eligible to use the general permit. Municipalities will have to apply for an individual permit if their storm sewer system discharges to one or more impaired waterways.
Please familiarize yourself and communicate with your engineer regarding the draft and the proposed changes, take advantage of comment period to voice concerns for yet another unfunded mandate.
Please visit Pennsylvania’s DEP website at http://www.depweb.state.pa.us for additional important information or contact Peters Consultants, http;//www.petersconsultants.com Inc. for any technical assistance you may require.