MS4 For Dummies, Autodesk and DLT Solutions Special Edition

Steve Kaelble

• Exactly what MS4 is

• What you need to know to be in compliance with federal and state regulations

• How to get the public involved in your efforts

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• Ways to deal with construction contaminants

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MS4 For Dummies, Autodesk and DLT Solutions Special Edition is all about Municipal Separate Storm Sewer Systems and the government agencies that oversee them. It’s about the problem of pollution, and the remedies and regulations that are designed to fight that pollution. It’s about running an MS4 that’s in compliance.

• Understand the problem — you need to know why stormwater can be a problem and why it’s your municipality’s responsibility to oversee it

• Figure out where you fall — a variety of different entities fall under MS4 rules; figure out if you’re included

• Reach out — getting the community involved and figuring out how to measure what’s going on can be very helpful

• Communicate — the rules are your responsibility and you need to enforce them and let everyone know what they are

Everything you need to know about MS4s!

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to federal, state, and municipal governments.

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MS4FOR

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AUTODESK AND DLT SOLUTIONS

SPECIAL EDITION

by Steve Kaelble

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Introduction

The concept is certainly simple enough — collect storm-water from places where it might cause trouble and move

it into waterways that will guide it onward toward the sea. That’s the task of an MS4. Not to be confused with MI5, the British spy agency, or the cable music channel VH1, or the PS3 gaming platform — MS4 is short for Municipal Separate Storm Sewer System, and it sounds cooler than MSSSS.

An MS4 typically has a lot of different components. There is, of course, the traditional storm sewer, with drains along the street that lead to pipes underground that lead to those dark and dramatic passageways where Hollywood likes to film fugitive chase scenes. But an MS4 also might include ditches, curbs, and gutters, because those, too, exist to move the stormwater from one place to another.

What else does it take to define an MS4? Two more words. First, municipal. According to the federal definition of an MS4, that means a system owned or operated by a public agency, such as a city, town, county, flood control district, state, or federal agency. And the other word is at least as important: separate. That means this particular storm sewer system does not connect to the sanitary sewer system and does not lead to a wastewater treatment plant.

That’s where things start to get a little tricky. If there’s no treatment plant, there’s nothing that’ll keep pollutants in the stormwater from reaching the waterway that is its ultimate destination. And that’s a problem.

Back in the 1970s, the Clean Water Act set America on a path toward improved waterways. That work is far from finished, because there are still plenty of bodies of water that are any-thing but clean. About two of every five waterways are still considered to be impaired by pollution, and a lot of that pol-lution comes from urban or suburban stormwater runoff. No surprise, then, that government officials are on the case.

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MS4 For Dummies, Autodesk and DLT Solutions Special Edition 2

About this BookMS4 For Dummies, Autodesk and DLT Solutions Special Edition is all about Municipal Separate Storm Sewer Systems and the government agencies that oversee them. It’s about the problem of pollution, and the remedies and regulations that are designed to fight that pollution. It’s about running an MS4 that’s in compliance.

Why a For Dummies book on this topic? Well, take a look on the Internet and you’ll find volumes and volumes of informa-tion about MS4s and the regulations that govern them. It’s rather dizzying, really. If an MS4 is your business, there’s a lot you need to know, and this book is here to help demystify that business.

Icons Used in This BookTo guide you through the book, we’ve employed some icons. Here’s what they mean:

This one will point out an interesting fact, a piece of informa-tion that will help you better understand some MS4 or regula-tory concept.

Pore over every word if you like, but please pay extra atten-tion to the sections marked by this icon. They’re there to point out the book’s biggest and most important points.

We’re talking toxic chemicals government regulations, which can be pretty scary. Check the paragraph by this icon for a detail you really shouldn’t avoid.

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Chapter 1

Down the DrainIn This Chapter▶ Washing pollutants down the drain

▶ Figuring out who’s responsible

▶ Watching from Washington

▶ Keeping tabs from the Statehouse

Back in the early days of television, those black-and-white times, commercials promoted White Rain shampoo as

being “soft as rainwater.” And they boasted of the rainwater results: clean, beautiful hair. Those certainly were the days!

Whether or not rainwater is clean and soft when it falls from the sky, by the time the rainwater reaches that lovely stream, you might not want your hair anywhere near it.

It’s Just Rainwater, Right?The Environmental Protection Agency warns of what happens when rainwater makes its way from the spot where it landed to the storm sewer that’s collecting it and directing it into a nearby waterway. For example, the rain might fall on a con-struction site, and by the time the rainwater hits the sewer it has picked up a wide variety of chemicals, solvents, asphalts, acids, debris, and sediment.

Or consider industrial facilities. Obviously, if someone spills or dumps toxic chemicals, bad things will result, but even more likely (and not as widely recognized) is inadvertent contamination of the rainwater that falls on the yard where chemical barrels are stacked.

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MS4 For Dummies, Autodesk and DLT Solutions Special Edition 4Take a look in your front yard. You may be part of the prob-lem, too, if you fertilize your lawn. Chemicals from lawns can end up in stormwater runoff. Things like phosphorus and nitrogen can find their way to lakes and streams. Just as they encourage your grass to grow, they can fuel the growth of undesirable and even harmful algae in waterways.

Even roads can be problems, because they can collect heavy metals from tires, road salt, and hydrocarbons from spilled brake fluid. Again, that pristine, soft rainwater of yesteryear will then come along and wash those pollutants down the drain and into a nearby waterway.

Whatever the source, the rainwater and chemicals and sedi-ment and other pollutants end up making their way through the MS4, which will eventually lead to a local river, lake, or coast. Watch out, fish! This kind of polluted runoff can cause major fish kills, and sediment can ruin aquatic habitats. It isn’t just fish that feel the pain, either — problems caused by stormwater pollutants can make waterways unsafe for swim-ming and not-so-great sources of drinking water.

No wonder the government wants to keep tabs on rainwater and melting snow and the bad stuff that can get mixed in.

Owning the ProblemWhen polluted stormwater makes it into streams and lakes and oceans, fish and other critters that rely on clean water are the biggest losers. But it’s not like they can do anything about it — so whose problem is it, anyway?

For starters, whoever owns and operates the MS4 is on the hook. Most often that means the local or state governmental entities running the storm sewer system.

Of course, it’s also the responsibility of whoever created the pollution in the first place. That’s not always possible to determine. After all, waste that runs off highways could have come from just about anyone. Same with the lawn fertilizer that causes big algae blooms in lakes. On the other hand, it’s not hard to imagine that construction or industrial sites are possible sources, so it’s reasonable to hold them accountable.



Chapter 1: Down the Drain 5 With that in mind, the people tasked with keeping this kind

of pollution under control have their eyes on a variety of players. That’s why MS4s themselves are permitted and moni-tored, and also why potential sources such as construction sites and industrial operations face regulatory scrutiny.

The Feds Want ActionWhat does the federal government want when it comes to stormwater carried by MS4s? It’s actually pretty simple. The Feds want what flows through storm sewers to be actual stormwater — not pollutants.

Put another way: An illicit discharge is any discharge to an MS4 that is not composed entirely of stormwater. Couldn’t be much more straightforward than that. Of course, something that simple is much easier said than done — you already knew that.

The idea of putting the words “simple” and “federal regulation” in the same sentence may seem laughable, but regulators are trying. In fact, the EPA has written what it calls “readable regu-lations” pertaining to the operators of small MS4s, regulations written in what the agency calls “plain language.”

The first round of federal regulations related to stormwater took aim at medium to large MS4s — generally those serving populations of 100,000 or more. Also covered by what the Feds call Phase I were construction projects of at least 5 acres along with ten types of industrial activity. Phase II brought smaller MS4s into the picture, along with smaller construction projects. Now, all these affected entities must file for National Pollutant Discharge Elimination System permits — NPDES for short — to prove to the government that they are complying with stormwater regulations.

The States Do, Too Federal regulators aren’t the only ones keeping their eyes

on stormwater pollutants and MS4s. State governments typi-cally have their own regulatory systems as well, which should come as little surprise because state leaders have to drink the water, too.



MS4 For Dummies, Autodesk and DLT Solutions Special Edition 6Take New York as an example. Just as there is an NPDES, so is there an SPDES — New York’s State Pollutant Discharge Elimination System. In all, there are three types of permits that pertain to stormwater runoff in New York, and they’re a mix of state and federal regulation. MS4s are covered, as are others that may be responsible for discharges. The New York State Department of Environmental Conservation keeps track of a lot of things, including annual reports of industry-specific monitoring.

States often take the lead in administering the federal regula-tions. That’s the case in Washington state, for example, where the Department of Ecology administers the federal NPDES pro-gram. The state has written its own stormwater management manuals and keeps tabs on the federal regulations as well as such state oversight as the Washington State Water Pollution Control Act.

And California is well known for implementing stricter than average environmental laws. Among the entities watching over California stormwater are the Department of Water Resources and the recently created Storm Water Advisory Task Force.



Chapter 2

The ABCs of NPDES Permitting

In This Chapter▶ Knowing if you’re covered

▶ Filing the papers

▶ Following the rules

▶ Asking for help

From the EPA’s point of view, stormwater discharges from MS4s can in most cases be considered point sources of

pollution. What that means is that they come from a pretty easily definable point: the storm sewer system (as opposed to things like agricultural runoff, which the EPA sees as a non-point discharge).

All point sources of pollution are required under the Clean Water Act to be covered by federally enforceable National Pollutant Discharge Elimination System permits — everybody calls them NPDES permits for short. Like all permits, these NPDES permits give permission to do something: in this case, discharge stormwater into a waterway. And like a lot of per-mits, they require something in return from the permit-holder. To comply with the NPDES permit, MS4s must come up with a stormwater management program.

Taking AimIf you’re an operator of an MS4, odds are that you’re cov-ered by the requirement to file for an NPDES permit. Initially, during what the EPA called Phase I, the requirements were



MS4 For Dummies, Autodesk and DLT Solutions Special Edition 8that medium and large MS4s had to file. But Phase II brought in regulated small MS4s, too.

A large MS4 is defined as a system that serves an incorpo-rated area with 250,000 or more residents. A medium MS4 is one serving a population between 100,000 and 249,999 residents. That leaves small MS4s: those serving up to 99,999 people. By the way, a small MS4 isn’t necessarily just a smaller municipality — it also might be a military base, for example.

The rules apply to regulated small MS4s. Your small MS4 might be regulated or it might not be, in which case no NPDES permit would be needed. The EPA explains that these small MS4s fit the bill for being regulated:

✓ Those MS4s that are in the boundaries of what the Census Bureau has defined as an “urbanized area.”

✓ Those MS4s that are outside an “urbanized area” but have discharges that the NPDES permitting authority believes are causing an adverse impact on water quality — or those that have the potential to cause an adverse impact.

✓ Those MS4s that don’t meet either of the first two crite-ria, but happen to have systems that are interconnected with other MS4s that are regulated.

But wait — there’s more! The requirements apply not only to MS4s but also to those involved in certain kinds of construc-tion or industrial activity. Phase I established 11 categories of activities to be covered by the requirements. One of those cat-egories is construction activity — specifically, those projects that “disturb” (as the Feds call it) at least 5 acres of land, as well as smaller projects that are part of a bigger scheme cov-ering at least 5 acres. The rules apply to whoever is in charge, which could be an owner, a developer, or a contractor.

As with MS4s, Phase II expanded the construction-related coverage downward, to projects between 1 and 5 acres, as well as smaller projects if they’re part of a bigger plan, or if the permitting agency believes they have a potential to muddy the waters.

For larger projects, there are no exceptions to the rules — everyone must comply.



Chapter 2: The ABCs of NPDES Permitting 9

Putting It on PaperOkay, so you’ve determined that your MS4 will need to obtain a permit. Time to sharpen your pencils, clear off the confer-ence room table and dive into a mess of paperwork, right? Maybe, maybe not.

One way or another, an MS4 or other entity affected by the law needs to get an NPDES permit. But if you think landing the permit is the whole point of this exercise, you’ll be sadly mis-taken. The important part is what the permit requires: that you develop and implement a stormwater management program.

Meeting the RequirementsThe devil is, indeed, in the details, and these details are key to compliance with federal law regarding stormwater discharges. The Feds aren’t just giving MS4s permission to send whatever they want into American waterways. MS4s and other NPDES permit holders are required in their permits to establish stormwater management programs — here’s another acronym for your alphabet soup: SWMP.

The whole idea is to get a better handle on stormwater dis-charges and do everything possible to make them be nothing but H2O. The EPA has decreed that an SWMP must set out six minimum control measures, with appropriate measurable goals. It’s up to you, the permit applicant, to establish the control measures and the goals, but it’s up to the NPDES per-mitting authority to decide whether they’re good enough to pass muster.

Bottom line: You’re required to come up with best manage-ment practices for each of the six minimum control measures (and yes, you’ll see these best management practices referred to as BMPs). The six minimum control measures are:

✓ Public education and outreach on stormwater impacts.

✓ Public participation/involvement.

✓ Illicit discharge detection and elimination.

✓ Construction site stormwater runoff control.



MS4 For Dummies, Autodesk and DLT Solutions Special Edition 10 ✓ Post-construction stormwater management in new

development/redevelopment.

✓ Pollution prevention/good housekeeping for municipal operations.

Did we say details? The EPA definitely wants details about these control measures and what they require — lots of really specific details. Nothing wishy-washy here. The EPA doesn’t want to know that you’re going to do something “as well as possible” or “as feasible.”

This means that for all of the requirements you spell out in your permit application, you need to specify what activity is required, who will carry it out, how much is required (this is the measurable standard), when it needs to happen, and where it’s supposed to be done.

Now unless you have a magic wand, you as an MS4 operator can’t just make pollutants vanish before they hit your system. You’re going to need to find ways to keep those pollutants out, and that means exerting some control over those who are creating the pollutants in the first place. For your SWMP to be effective, you need some legal authority.

Can Anyone Help Me?If you think this seems complicated, wait until you see the actual documentation and instructions from the EPA and the various state NPDES enforcement bodies. You’ll wish you were an accountant on April 15.

Rest easy, though. You’ll find experts willing to assist in all steps of the process, from creating the plan to interacting with the EPA to installing the technology necessary to make it happen. There are consulting firms that focus on stormwater issues. There are law firms that specialize in figuring out just what the EPA is talking about. There is the EPA itself, which has a wealth of information online, including state and federal contacts, publications, training opportunities and Webcasts. And there are resources that pull together a wide range of ser-vices helpful to governmental agencies, from MS4 expertise to IT solutions to engineering services to geospatial data.



Chapter 3

Getting the Word OutIn This Chapter▶ Educating the masses

▶ Involving the public

▶ Setting goals you can measure

So you thought about a career in sales, but decided that work in the public sector would be more fulfilling. Guess

what — like it or not, you’re in sales now! The first of the six minimum control measures that must be part of your MS4’s stormwater management plan is officially called public out-reach and education.

Okay, so maybe your new hat is that of a teacher. If that hat fits, go ahead and wear it. But know that what the EPA really expects from this education and outreach effort is a success-ful sale to the community — convincing the public and the business world of the importance of stormwater protection and getting everyone to buy into the plan.

Reaching Out to the PublicWhy must the community be informed and knowledgeable about your SWMP? The EPA offers two primary reasons:

✓ Increased support: If you can get the public to under-stand why this program is so important, you’re bound to win some allies. And that’s crucial if your success depends on winning some funding or attracting volun-teers to help out.

✓ Stronger compliance: A population that stands behind the concept is likely to follow the rules more faithfully.



MS4 For Dummies, Autodesk and DLT Solutions Special Edition 12 What’s required sounds simple enough: You’re supposed

to design and implement a public education program that distributes materials or conducts various outreach activi-ties. You want the public to really grasp how stormwater dis-charges impact your community’s waterways, what kinds of pollutants you’re talking about, and what the businesses and ordinary people can do to reduce this kind of pollution.

There are really three main strategies for getting this job done, according to the Feds:

✓ Form partnerships: Reach out to other governmental entities as well as non-governmental groups that might share this interest. If you don’t have to reinvent any wheels here, by all means don’t. For example, an environ-mental group may already have some educational materi-als handy, and an industrial organization will have a way to reach its membership that you can tap into.

✓ Find or create educational materials and strategies: This includes brochures, refrigerator magnets, posters, utility bill inserts, Web sites, public speakers, booths at malls or local events, signage, even economic incentives. The partners that you found in the last bullet point may already have some of these things that you can borrow or adapt. Get creative!

✓ Seek out diverse audiences: You likely already guessed that you’ll have to sell to — or educate if you prefer — the big potential polluters, such as construction contrac-tors and industrial employers. But be sure you also hit all segments of the general public, and by “diverse” we also mean ethnically diverse. You might need signs in mul-tiple languages.

Go for things that’ll really get noticed by the right audience at the right time. For ideas about how to bring the public onboard your effort, flip over to Chapter 7.

Everyone Join in Now!The public education and outreach plan is minimum control measure Number 1. A logical Number 2 is public involvement and participation. After all, a public that is more involved is



Chapter 3: Getting the Word Out 13likely to be a public that will be more compliant. So what does this mean in practice?

✓ Follow the appropriate public notice requirements: This means placing ads in the newspaper or putting notices on your Web site — whatever local governmental bodies must do when they’re conducting public busi-ness. Specifically, you need to involve the public in the creation of your SWMP.

✓ Set up a citizen advisory group: This group will be gath-ering input, ideas, and opinions about the management plan. Be sure to include all types of affected parties, such as residents, business owners, and environmental organi-zations. Remember the concept of partnering and avoid-ing duplication of efforts; there may already be a group out there that can take on this task.

✓ Create ways to involve the masses: Invite the public to stream-cleaning events, get volunteers to stencil signs on storm drains, deputize a task force of locals to monitor compliance and turn in polluters. You’ll find lots of folks eager to help, including activists, retired people, Scouts, church groups, and kids who need to fulfill school ser-vice hour requirements.

Set Goals and Keep ScoreNot only are you required to implement a public education program and involve the public, you must prove that your efforts are doing the job. The other main component of all these minimum control measures is the measurement part. Don’t forget that you’re supposed to be establishing BMPs — best management practices — and how would you know if they’re the best if you don’t measure them?

On all these measures, the goals should reflect your commu-nity, including the kinds of pollution most prevalent and the waterways that you’re trying to keep those pollutants away from. Of course, keeping it local this way will help make your outreach more effective and your public participation more intense.



MS4 For Dummies, Autodesk and DLT Solutions Special Edition 14 So, for the public outreach part, you’ll need to set at least

three specific, high-priority goals, such as reducing nitrogen in discharges from the MS4. You’ll need to identify the target audience; in this case perhaps you decide you’re trying to reach people who fertilize their lawns. And then you’ll set your goal and a time frame — for example, you’ll deliver the message about the impact of lawn fertilizers to 25 percent of the target audience each year, so that by the end of the fourth year everyone will have gotten the message.

Other examples might include a campaign to reach dog owners and convince them of the need to scoop the poop when they’re out walking. Measure its effectiveness through surveying (you didn’t really want to follow dog-walkers around with a camera, did you?). Or maybe you launch a cam-paign to persuade driveway auto maintenance buffs to recycle their motor oil rather than dumping it down the storm sewer. For this one, measure the quantity of oil delivered to the recy-cling drop-off.

As for the second minimum control measure, the one having to do with public involvement, measurable goals aren’t terri-bly difficult to set. For example, when you’re establishing your advisory group, set targets for the number of members, the types of members, the start date, and the frequency of meet-ings. Or plan stream cleanup events and set targets for the time frame and the number of participants.



Chapter 4

Enforcing the RulesIn This Chapter▶ Watching the detectives

▶ Catching the bad guys

In a perfect world, you could create your stormwater man-agement program, educate the public, and get the com-

munity onboard — and everyone would follow the plan, your stormwater discharges would be pure as spring, and all the fish would live happily ever after. Yeah, right.

In the real world, you’ll sell a lot of people on the impor-tance of cleaning up stormwater, but somebody’s going to find the process too much of a hassle, or too costly or time-consuming. Or, somebody just won’t get the message. One study found that almost half the water discharged from one California MS4 wasn’t water that had fallen from the sky — it was stuff that had been dumped into the system.

You need a way to enforce the rules. That’s why minimum control measure Number 3 is titled “Illicit Discharge Detection and Elimination.”

Stormwater Detectives If you’re going to be cracking down on illicit discharges, you

had better be clear about what is illicit. The EPA simply states that an illicit discharge is “any discharge to an MS4 that is not composed entirely of stormwater.” The main exceptions are those coming from industrial operations that already have their own NPDES permits, and water that firefighters have used to put out a fire — who knows what’s in that water, but it wouldn’t be fair to penalize them for doing their job.



MS4 For Dummies, Autodesk and DLT Solutions Special Edition 16Illicit discharges can come from a wide range of places, including sanitary sewers, septic systems, carwashes, oil changes, radiator flushes, accidental spills, and people improperly disposing of household chemicals. Your SWMP must include a number of things related to illicit discharges:

✓ A map of the storm sewer system: The map should show all places where stormwater is discharged and name the waterways where it’s going.

✓ A prohibition of non-stormwater discharges into the MS4: This would be a local ordinance along with the means for enforcing it.

✓ A plan to detect illicit discharges into the system: This means locating problem areas, figuring out where the illicit discharges are coming from, stopping the viola-tions, and documenting what has occurred.

✓ Educational outreach: You’re expected to be sure public employees, businesses, property owners, and the general public all know the dangers of illicit discharges.

✓ BMPs and measures: Here’s where you figure out your best management practices and measurable goals.

The EnforcerHow much enforcement authority your MS4 has depends on a lot of things. If you’re part of city government, odds are good that you can get appropriate ordinances passed prohibiting illicit discharges into the MS4. But plenty of other MS4s have only limited authority under state, tribal, or local law that would allow them to tell residents and businesses what they can or can’t do. To those MS4s, the EPA has incredibly helpful advice: “the permittee is encouraged to obtain the necessary authority, if possible.”

Assuming that you’re able to get the authority you need, your plan should include details about how you’ll enforce the rules. For example, if your detection program finds evidence of an illicit discharge, the next step is to find where it came from. You’ll require whoever is responsible to fix the prob-lem, follow up later to ensure that it has, indeed, been fixed, document the incident, and demand that the source of the discharge pay any recovery and remediation costs.



Chapter 5

Construction ConundrumIn This Chapter▶ Containing the contaminants

▶ Planning for the next stage

What sounds more harmful to the environment — pesticides, construction chemicals, nitrogen, phos-

phorous, grease, sediment, sanitary waste? Bet you didn’t pick sediment, but when it comes to things that can trickle off rainy construction sites, flow through storm sewers, and mess up waterways, sediment is one of the biggest concerns.

Keeping the Mess On-SiteYour MS4’s stormwater management program is required to deal specifically with runoff from construction sites. As with the other minimum control measures, you need a plan, best management practices, and ways to measure the results. Specifically, with regard to construction sites, your SWMP must include:

✓ Regulations requiring erosion and sediment control at construction sites, plus controls for other wastes.

✓ Site plan review procedures that are on the lookout for water-quality threats.

✓ A plan for site inspections and enforcement.

✓ Sanctions designed to encourage compliance.

✓ A way for the public to submit pertinent information.

✓ Best management practices and measurable goals.



MS4 For Dummies, Autodesk and DLT Solutions Special Edition 18 What kinds of measurable goals are appropriate? There are

lots of possibilities. You could, for example, set a goal of edu-cating a certain percentage of construction workers and con-tractors about the SWMP, what’s required of them, and why.

Clean and Green for the Long Run

Construction projects can affect stormwater discharges in two ways. I’ve already talked about the first — the sediment and other yucky stuff that can flow off of a construction site while the work is going on.

But the threat isn’t over when construction is finished. That’s because the construction project gives way to a new develop-ment, and a new development brings new threats. For one thing, there’s a good chance a big parking lot exists where there wasn’t one before, and a big new building. Adding those impervious surfaces can increase the volume of stormwater running off the site. And who knows what that stormwater will contain — it depends on the use of the new development, but it could include nitrogen, phosphorous, oils, pesticides, and other chemicals.

MS4s are required to be proactive here. Through minimum control measure Number 5, they must create and enforce a plan for runoff after the construction project is done. This includes passing ordinances or regulations telling the prop-erty owner what must be done.

The plan must include best management practices that are both structural and nonstructural. Structural BMPs might cover stormwater retention ponds, requirements that encour-age water to sink into the site’s soil rather than add to the runoff, and landscaping requirements that reduce runoff and even remove pollution. Nonstructural BMPs can include, among other things, zoning ordinances and master planning.

Again, there are lots of things that can be measured here. For example, the plan might set a goal of reducing by 30 percent the road surface areas that drain directly into the MS4. Rather than curb and gutter designs that funnel the water right down the drain, developments could choose such alternatives as grassy swales.



Chapter 6

An Ounce of PreventionIn This Chapter▶ Doing everything you can

▶ Monitoring the results

“Do as I say, not as I do.” Who said that, anyway? You certainly don’t want it to be you, the administrator

of an MS4. The last of the EPA’s minimum control measures is there to ensure that MS4s aren’t guilt of hypocrisy.

The thing is, a fair amount of the pollutants that wind up coming out of storm sewer systems are the responsibility of the MS4 itself, not some industrial plant or construction contractor. There are pollutants that collect on streets and parking lots and vehicle maintenance areas. There are problems that stem from poor development practices, flood management schemes that aren’t well planned — even poor maintenance of MS4s themselves.

A Clean Water City MS4s and the governmental entities that often run them are

required to be part of the solution. They are tasked with cre-ating an operations and maintenance program to prevent or at least reduce pollutant runoff from municipal operations.

A big part of this is training. Employees need to know how to incorporate pollution prevention and good housekeep-ing techniques, whatever it is that they’re doing for the city. Maybe they work in the parks and open spaces. Maybe they’re in fleet or building maintenance. Maybe construction is their area of focus, or maybe they work with the MS4.



MS4 For Dummies, Autodesk and DLT Solutions Special Edition 20In all cases, municipal employees have a great potential to impact the pollution prevention effort, so they need to under-stand how to make that influence a positive one. Thus, regular training, often annual, is the best way to respond. The good thing is it’s easily measurable, which the Feds love.

It may seem surprising that the MS4 itself could be a source of the problem. But think about it, you’re dealing with a system that may be decades old. And you’re dealing with city budg-ets, which aren’t always healthy. You can see how an MS4 might not be getting the maintenance it needs.

So, the MS4 must map the system and create a maintenance schedule, giving the most frequent attention to areas that are most critical. You can base such priority decisions on a number of factors, such as the types of materials that typically accumulate in a particular area, their quantities, and where the places are that stormwater discharges into waterways.

Eyeing the ResultsAs hard as you’re going to work on this, you’re definitely going to want to know how it’s turning out. So the require-ments that your minimum control measures actually be measurable shouldn’t be too much of a drag. Most of that measurement, though, is of the SWMP — keeping tabs of the various activities required by the plan and whether everyone is doing what they’re supposed to be doing. Wouldn’t it be great to know if all this work is actually reducing the level of pollutants that you’re discharging into waterways?

As it happens, Phase I MS4s actually are required to do some monitoring of this nature. They must do discharge characteri-zation and field screening, and also develop a monitoring pro-gram and conduct an assessment of controls. Phase II MS4s don’t have such a stringent requirement, although they’re certainly allowed to do monitoring if they so choose.

Required or not, effective monitoring is really the best way to know where your SWMP is working and where it could be better. As with most games, it’s a lot more fun if you’re keep-ing score.



Chapter 7

Ten Ways to Get the Public Educated and Involved

In This Chapter▶ Spreading the word

▶ Reaching out to businesses

▶ Gauging public opinion

You and your MS4 are never going to successfully tackle the problem of polluted stormwater on your own. You

need the public on your side. Here are some ideas.

✓ Put it on paper: People and organizations have been printing pamphlets and brochures to influence the public since before the days of Ben Franklin. Distribute brochures with water or sewer bills, or buy a page in the local weekly paper.

✓ Put it on the airwaves: The media can be great friends to your public outreach campaign. The best bet is to get on the news or in the paper, because a news story is free. If you have a news hook, such as the launch of a new initia-tive or an event, send out a news release or stage a news conference.

✓ Put it online: Of all the forums you can control yourself, the Web is the most inexpensive and flexible way to get your message before the public. And you’ll be surprised how easy it can be. Build your own site with online blog services that are cheap (or even free) and simple to use.

✓ A video is worth a million words: Professional videos are persuasive, and often expensive. The good news is that a professional isn’t always necessary. With your own digital video camera, easy-to-use (and often free) video software,



MS4 For Dummies, Autodesk and DLT Solutions Special Edition 22and a YouTube account, you can easily tell the story yourself. Use video to follow the path of nasty pollutants from the street or a yard, down the storm sewer, and into a pristine river. People don’t think about what’s on the other end of that drain, so you need video to make it real!

✓ Be businesslike: Reaching out to businesses should definitely be part of your public outreach. You’ll want to tailor your message to the kind of business. Slogans are great. If you’re focusing on automotive businesses, for example, create posters or flyers with the title “Is Water Quality Going Down the Drain in Your Garage?”

✓ Spread the wealth: Businesses crave attention for being good neighbors. So establish an award or recognition program for businesses that are doing the right thing with regard to stormwater. For example, Portland, Oregon, has an “Eco-Logical Business” program.

✓ Get ’em while they’re young: Who says public outreach has to focus just on adults and business owners? Some of the world’s most eager environmentalists are kids, and they command lots of influence over adults. In Daly City, California, the local utility showed eighth-graders photos of marine animals tangled in trash, and attracted its big-gest crowd ever for a beach cleanup.

✓ Attention, dog owners! Plenty of communities have found creative ways to get pet owners to clean up after Fido by helping them understand how rampant pet waste can foul the water. One community has posted bilingual signs in public spaces. For humans, the signs state, “Pick up after your dogs.” The message in the second language: “Grrrrr, bark, woof. Good dog!”

✓ Call out the volunteers: If local residents feel like they have a personal stake in these efforts, they’ll be more apt to par-ticipate willingly and spread positive word. Try an “Adopt-a-Stream” program through which interested businesses and individuals can survey and clean up the streambanks, moni-tor water quality and wildlife activity, and plant trees.

✓ Open your ears: A lot of outreach efforts involve you doing the talking. It also helps to do some listening. A survey is a great place to start — survey local residents, business owners, even schoolchildren, to learn what they know about stormwater pollution, what activities they’re involved in that might need to be addressed, what their attitudes might be if control measures are implemented.



About Autodesk and DLT SolutionsAs the Master Government Reseller, DLT Solutions has teamed

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Through its best-in-class information technology products and

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more, DLT provides trusted and innovative Autodesk solutions

to federal, state, and municipal governments.


Steve Kaelble

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MS4 For Dummies, Autodesk and DLT Solutions Special Edition is all about Municipal Separate Storm Sewer Systems and the government agencies that oversee them. It’s about the problem of pollution, and the remedies and regulations that are designed to fight that pollution. It’s about running an MS4 that’s in compliance.

• Understand the problem — you need to know why stormwater can be a problem and why it’s your municipality’s responsibility to oversee it

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