Municipal Stormwater Permitting

Nancy StonerClean Water Project Director

Natural Resources Defense Council1200 New York Ave., NW

Washington, DC 20005(202) 289-2394

nstoner@nrdc.org

Stormwater Program Goals

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

Legal Standards

Reducing discharges to the “maximum extent practicable” (MEP)

Not causing or contributing to violations of water quality standards.

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.

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.

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.

Implementation of the Chesapeake Bay Agreement on Stormwater

MS4 permits should track these commitments

Other DC MS4 Issues

WASA as a Co-Permittee in the DC MS4 permit.

DC Stormwater Management Program

Funding Stormwater fees must

be sufficient to fund the program and include incentives for stormwater minimization.

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.