Asset Management Grant Program Available in MA

Calling All Water Utilities!

The Massachusetts Department of Environmental Protection (MassDEP) and the Massachusetts Clean Water Trust (the Trust) are currently promoting Asset Management Programs (AMPs) by offering subsidized State Revolving Fund (SRF) financing for communities looking to improve one or more of their water-related utilities.

With the help of Asset Management Programs, water, wastewater, and stormwater utilities are poised to make beneficial financial decisions for the future. The goal of AMPs is to achieve long-term sustainability and deliver the required level of service in a cost-efficient manner. Financial decisions surrounding asset repairs, replacements, or rehabilitations, as well as the development and implementation of a long-term funding strategy can only help a utility.

Through the Asset Management Grant Program, MassDEP and the Trust are encouraging water utilities to focus on AMP development, maintenance, or improvements. This program is also aimed at helping communities and their utilities meet the Engineering Plan and Financial Sustainability Plan requirements for SRF construction loans. With that, the program will award grants with a maximum award of $150,000 or 60% of the total eligible project cost (whatever is less).

If awarded a grant, the recipient will be required to supply documentation of a full appropriation of funding mechanisms for the entire cost of the project to qualify. There are no requirements on the size or scope of the project. MassDEP will favor proposals that include a clear description of the applicant’s current asset management status and goals, and those that demonstrate a strong commitment to participate in their AMP.

Apply Today!

Tata & Howard encourages all MA utilities to apply for this special grant funding. Proposals and Project Evaluation Forms are due on August 23, 2019 by 12 pm.

For more detailed information concerning requirements and deadlines, please view the Guidelines for Proposal Submittal and Project Selection provided by MassDEP.

Asset Management

As one of MassDEP’s pre-qualified consulting engineering firms, Tata & Howard provides industry expertise in both Asset Management and funding assistance. For more information on Asset Management or how Tata & Howard can assist with your grant application, visit our website or contact us directly. We are happy to assist.

Falmouth Holds Dedication Ceremony for New Long Pond Water Filtration Facility

Falmouth Holds Dedication Ceremony for New Long Pond Water Filtration Facility

Tata & Howard Staff Joined Falmouth Selectmen, Public Works Staff, Methuen Construction Staff, and Residents for a Dedication Ceremony and Facility Tours

On October 16, 2018, the Falmouth Board of Selectmen held a public Dedication Ceremony for the town’s recently completed water filtration facility on Gifford Street.

Attendees included Phil MacClellan, Paul Howard, Karen Gracey, and Ryan Neyland.

Several Tata & Howard company representatives attended the event, including Project Technical Reviewer Paul B. Howard, P.E., Project Principal Patrick O’Neale, P.E., Project Manager Ryan Neyland, P.E., Project Engineer Phil MacClellan, P.E., and Company Co-President Karen Gracey, P.E.

 

T&H Project Principal Patrick O’Neale, P.E., joined Falmouth Public Works Director Raymond Jack in addressing attendees at the Dedication Ceremony.

Project Principal Patrick O’Neale, P.E. joined other key project personnel including Director of Public Works Raymond Jack and Water Superintendent Stephen Rafferty, in summarizing the history of the water supply and key aspects of the facility, as well as Tata & Howard’s role in the pilot study, design, and construction administration of the facility. The facility utilizes coagulation, mixing, flocculation, dissolved air flotation (DAF), ozone, dual-media filtration, and chemical feed systems to provide the community with water that meets current EPA and MassDEP regulations.

Local residents toured the award-winning facility.

Tata & Howard was the lead engineering firm for the design and construction administration of the new facility; Methuen Construction was the general contractor. The new Long Pond Water Filtration Facility is a state-of-the-art water purification facility that received widespread community support. Due to the advanced nature of the facility design processes, this facility became the first Class IV fully automated facility to be permitted in New England.

Tata & Howard was awarded a 2018 Engineering Excellence Silver Award from the American Council of Engineering Companies of Massachusetts (ACEC/MA) for “outstanding professional design excellence” for the Falmouth Long Pond Water Filtration Facility. ACEC/MA’s annual Engineering Excellence Awards recognize engineering firms for projects that demonstrate a high degree of achievement, value, and ingenuity.  The project also was recently featured in the November-December 2018 issue of World Water Magazine:  Falmouth_WorldWaterMag_Nov-Dec2018

Methuen Construction received several awards for the construction of the new 8.4-million gallon per day (mgd) facility. The firm was most recently awarded the prestigious 2018 National Excellence in Construction Eagle Award, the highest level awarded by the Associated Builders and Contractors (ABC). In 2017, Methuen won two Engineering News-Record (ENR) 2017 Best Projects New England awards in Water / Environmental and Safety categories for construction of the facility.

Aerial view of the new Long Pond Water Filtration Facility in Falmouth, MA.

The award-winning facility was built for the future and will provide a valuable health benefit to the residents of Falmouth for generations to come.Save

Michael F. Knox Joins Tata & Howard as Client Service Specialist

Michael F. Knox Joins Tata & Howard as Client Service Specialist

Water and Wastewater Professional Mike Knox to Run Emergency Response Training Programs

Tata & Howard, Inc., a leading innovator in water, wastewater, and stormwater engineering solutions, is pleased to announce that Michael F. Knox, has joined the firm as a Client Service Specialist. In this newly created role, Mr. Knox will concentrate on developing Emergency Response Training Programs to be offered starting this fall.

Prior to joining Tata & Howard, Mr. Knox worked as the Superintendent and Chief Operator for the Cherry Valley and Rochdale Water & Sewer District in Leicester, Massachusetts. He holds a 2C and 3T drinking water license and a 3M wastewater license, and he has a B.S. in Mechanical Engineering.

In addition, Mr. Knox served as a member of the Massachusetts Water and Wastewater Agency Responses Network (MAWARN) Steering Committee and was the MAWARN Chair from 2008 to 2011.  He is a member and Past President of the Massachusetts Water Works Association (MWWA).

“As a former Superintendent and Chief Operator of a Water & Sewer District, Mike brings a unique perspective to this position,” Paul B. Howard, P.E., T&H Senior Vice President stated. “Having worked with Mike in the past, we knew of his experience and expertise improving the safety and security of municipal assets and implementing emergency response programs.”

“We’re excited to have Mike on our team,” Karen L. Gracey, P.E., T&H Co-President said. “Mike’s knowledge and thorough understanding of critical emergency response methodologies and training skills will not only benefit municipal water operations but also help improve their service to the community water systems they manage.”

Emergency Response Plans (ERPs) are mandatory for all public water suppliers, and a minimum of 10 hours of Emergency Response Training is required.  ERP training is a process that helps water system managers and staff explore vulnerabilities, make improvements, and establish procedures to follow during an emergency. Preparing and practicing an ERP can save lives, prevent illness, enhance system security, minimize property damage, and lessen liability.

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State Revolving Fund Loan Program

Financial Assistance through the State Revolving Fund

The Massachusetts Department of Environmental Protection (MassDEP), is now accepting Project Evaluation Forms (PEFs) for new drinking water and wastewater projects seeking financial assistance in 2019 through the State Revolving Fund (SRF).  The SRF offers low interest loan options to Massachusetts cities and towns to help fund their drinking water and clean water projects. PEFs are due to the MassDEP Division of Municipal Services by August 24, 2018, 12:00 PM.

Water Main ReplacementFinancing for The Clean Water SRF Program helps municipalities with federal and state compliance water-quality requirements, focusing on stormwater and watershed management priorities, and green infrastructure. The Drinking Water SRF Program, provides low-interest loans to communities to improve their drinking water safety and water supply infrastructure.

This year, the MassDEP Division of Municipal Services (DMS) announced the following priorities for SRF proposals.

  • Water main rehabilitation projects which include full lead service replacement (to the meter) – this is a high priority for eligibly enhanced subsidy under the Drinking Water SRF.
  • Reducing Per- and polyfluoroalkyl (PFAS) contaminants in drinking water.
  • Asset Management Planning to subsidize Clean Water programs.
  • Stormwater Management Planning for MS4 permit compliance and implementation.

In addition, Housing Choice Communities will receive a discount on their SRF interest rate of not less than 1.5%.

Summaries of the Intended Use Plans (IUP), will be published in the fall, which will list the project name, proponents, and costs for the selected projects. After a 30-public hearing and comment period, Congress will decide which programs may receive funding from the finalized IUPs.

To Apply for SRF Financing

Tata & Howard is experienced with the SRF financing process and is available to help municipalities develop Project Evaluation Forms along with supporting documentation, for their local infrastructure needs.

Please contact us for more information.

The MassDEP Division of Municipal Services are accepting Project Evaluation Forms until August 24, 2018 by 12:00 PM.

 

We Can Help

For more information on the MassDEP State Revolving Fund and assistance preparing a PEF contact us.

Water Distribution Systems in New England

Introduction

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On July 1, 1847, Brattleboro postmaster Frederick Palmer had the idea of putting adhesive on the back of stamps, and so he produced and sold the first gummed postage stamp in America, now known as the 1847 Brattleboro Postmaster’s Provisional stamp.

New England is one of the oldest and most historically rich areas of the nation. Famous events such as the pilgrims founding Plimouth Plantation and Paul Revere’s midnight ride took place in Massachusetts. New Hampshire planted the first potato in America, Maine introduced the nation’s first sawmill, and Vermont produced the nation’s first gummed postage stamp. Connecticut has the most “firsts” of any state in the nation including the first newspaper, submarine, and hamburger, while tiny but mighty Rhode Island was the first colony in the nation to declare independence from Britain. New England also boasts another first: it is home to the nation’s first water distribution systems.

A Brief History

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Wooden pipe and fire plug from colonial Boston on display at the Waterworks Museum, Boston, MA.

Boston, Massachusetts became home to the nation’s first waterworks in 1652. Distribution pipes at that time were made of wood, constructed from bored-out logs from the area’s plentiful hemlock and elm trees and attached together with pitch, tar, or iron hoops. While this rudimentary distribution system did supply some of the area’s residents, it was mainly used for fire protection as homes during that time — constructed of wood and heated with fireplaces —were particularly prone to fire.

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It was over a century before other New England cities began installing wooden distribution pipes. Providence, Rhode Island, Portsmouth, New Hampshire, and Worcester, Massachusetts all laid wooden pipes during the late 1700s, and several other cities followed suit in the early 1800s. Contrary to some urban myths, wooden pipes are not still in use in any areas of New England today. The high pressure from modern water systems would instantly split any existing wooden pipes. Wooden pipes that are occasionally unearthed during some construction projects were disconnected years ago.

iron-pipes-new-engljand-chart

Wooden pipes were problematic for many reasons including warping and sagging, insect infestation, rotting, taste issues, and splitting. As iron became increasingly available during the early 1800s, cities began installing iron pipes. The first iron pipes in New England were installed in Portland, Maine in 1812, followed by Montpelier, Vermont in 1820, and in both instances the pipes were lead. Many other cities followed suit throughout the 19th century, utilizing wrought iron, cast iron, and lead pipe. In the 1950s, ductile iron piping was introduced and boasted the longevity of cast iron with the addition of increased strength, flexibility, and safety. It became widely used in the 1970s and it is still the material of choice throughout New England today.

Distribution Systems Today

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Destruction caused by a water main break. Photo copyright Erin Nekervis

New England can be considered a pioneer of our nation’s water infrastructure. After all, distribution systems have grown from a few wooden pipes in Boston to the intricate, complicated underground infrastructure that we enjoy today. However, because much of the area’s infrastructure was laid so long ago, it has reached the end of its useful life. Water main breaks occur daily and are not only inconvenient to customers, they can also be dangerous, as evidenced by the November 2016 water main break in Boston, Massachusetts that caused manhole fires and forced evacuation of the area. Maintaining and updating our distribution systems is critical to the health and safety of our nation, its people, and the economy. But with limited budgets and resources, where do we start?

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Tata & Howard provided design, bidding, and construction administration for a water main replacement in Milford, Massachusetts, identified in a Capital Efficiency Plan.

Strategically prioritizing improvements is imperative to today’s water systems, as the rehabilitation and replacement of our nation’s buried infrastructure is an ongoing task. Asset management provides a roadmap for utilities, allowing them to maximize their limited infrastructure dollars by planning for the replacement of critical infrastructure over time. Tata & Howard’s Capital Efficiency Plan™ (CEP) methodology takes it one step further by combining the concepts of asset management, hydraulic modeling, and system criticality into a single comprehensive report. The final report provides utilities with a database and Geographic Information System (GIS) representation for each pipe segment within their underground piping system, prioritizes water distribution system piping improvements, and provides estimated costs for water main replacement and rehabilitation.

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Tata & Howard provided water system distribution evaluation as well as design, bidding, and construction administration for a water tank replacement project in Paxton, MA. 

Since the firm’s inception in 1992, Tata & Howard has remained a niche firm with deep experience and expertise in the water environment, and has provided CEP and hydraulic modeling services for countless municipalities throughout New England. Tata & Howard has one of the largest pipe asset management databases of any consulting engineering firm in New England. In fact, we have data on over 5,000 miles of New England pipe, providing utilities with critical information about their systems such as condition and probability of failure of certain pipe cohorts.

In Conclusion

Water distribution systems have come a long way since the days of hollowed out logs providing fire protection to colonial Bostonians. The underground network of distribution pipes has grown astronomically and now incorporates safer, stronger, and more cost-effective materials. As distribution systems are updated and expanded, it is critical that accurate, up-to-date information is available to water systems so that they may invest their limited capital wisely.

UST Removals in Massachusetts

Photo courtesy of https://www.enviroequipment.com
Photo courtesy of https://www.enviroequipment.com

As of August 7, 2017, MassDEP’s closure requirement 310 CMR 80.15 mandates all single-walled steel underground storage tanks (USTs) to be closed-in-place or removed. Covered under this regulation are tanks and associated piping that have more than ten percent of their volume underground and hold petroleum products or hazardous substances listed in the U.S. Comprehensive Environmental Response Compensation Liability Act. With the deadline now less than one year away, it is important to fully understand single-walled USTs, their potentially harmful impact on the environment, and how to properly plan to remove them.

Single-Walled USTs Explained

USTs have been used for many years to store hazardous substances and petroleum products used by a wide variety of businesses. In addition to the tank itself, a “UST system” includes the underground piping that is used to fill the tank and draw product from it. Until the mid-1980s, most USTs were made of bare steel, which is likely to corrode and leak over time. These leaks can exist undetected for years and cause pollution of the surrounding soil and even groundwater. The piping in the system can also leak if not properly installed and maintained. In many cases, contaminant leaks do not get discovered until the owner or operator realizes that a significant amount of product in a tank goes missing or when the tank is removed and contaminants are found in the underlying soil. Another indication of a leaking UST is neighbors complaining of odors in their buildings or experiencing problems with their drinking water.

Leaking USTs, specifically single-walled steel USTs, have caused considerable environmental damage in Massachusetts, affecting public and private water supplies, wetlands, and soil. In some cases, vapors from contaminated soil and water have permeated homes and businesses. Many millions of dollars have already been spent on cleaning up these leaks, but fully protecting public health and the environment from UST leaks relies on removing or closing the storage tanks altogether.

Benefits of the MassDEP UST Removal Requirements

The site of a former gas station transformed into a pocket park in Hamilton, Ohio. Photo courtesy of https://www.journal-news.com
The site of a former gas station transformed into a pocket park in Hamilton, Ohio. Photo courtesy of https://www.journal-news.com

The removal or permanent closure of aging, single-walled USTs benefits many areas of a community. The new MassDEP regulations will benefit human health, ecosystem functions, and land productivity.

Human health benefits are among the top reasons why single-walled USTs are now required to be removed by August 7, 2017. Contaminated well water and vapor intrusion are the most critical threats to human health from failing USTs. Leaks from USTs can endanger residents for miles through contamination of groundwater, and increased cancer rates and blood disorders have been attributed to exposure to petroleum products, which are commonly found in USTs. The petroleum vapors which are emitted are highly flammable and are potentially dangerous when found in people’s homes. Vapors can travel through soil, sewer lines, storm drainage systems, and other pathways to enter homes and other buildings.

Many single-walled USTs are located in old gas stations, providing the opportunity to add aesthetic and ecological benefits to a community. If a UST leaks into soil, the site becomes contaminated and is considered a brownfield. Removing or closing USTs and making the site usable again decreases the need for development elsewhere and helps preserve greenfields, such as pastures or forests. Many old gas stations are situated in quite visible locations within towns or neighborhoods and can be reused for purposes such as gateways, town centers, or pocket parks. Such redevelopment opportunities improve a locality’s appeal and create recreational value.

Removing or closing-in-place single-walled USTs results in several ecological benefits. Preventing leakage of hazardous material can reduce surface water contamination – protecting fish and other wildlife. Below the ground, removing USTs ensures that leaking tanks will not compromise underground aquifers for future generations. In the long run, this will better protect our drinking water’s taste and purity. Removing USTs also greatly improves land use because former UST sites with a “clean bill of health” will be more likely to develop and prosper without environmental restrictions.

Are there any exceptions to the new regulations?

Soil contamination from a UST which leaked hundreds of gallons of oil. Photo courtesy of https://mde.maryland.gov
Soil contamination from a UST which leaked hundreds of gallons of oil. Photo courtesy of https://mde.maryland.gov

The MassDEP has included exceptions to the UST removal regulations. Tanks are not required to be removed or closed-in-place if they are consumptive use tanks – such as for heating oil in homes – and single-walled tanks that were relined prior to August 8, 2007 in accordance with API 1631. For these relined tanks to be exempt, the owner or operator must possess a permit and approval issued by the head of the local fire department, or a current legally valid warranty for relining. Other exceptions to the new regulations include single-walled steel tanks that have been wrapped with fiberglass, aramid, carbon fiber, or plastic compounds. It is important to note that single-walled steel tanks that are temporarily out-of-service are NOT exempt from the closure requirement, even if they are consumptive tanks for onsite usage. USTs that are not actively used or temporarily out of service are considered abandoned and must be removed or closed-in-place by August 7, 2017.

MassDEP’s UST closure regulation allows tanks to be permanently closed-in-place only if they cannot be removed from the ground without removing a building, or the removal would endanger the structural integrity of another UST, structure, underground piping, or underground utilities. When closing a tank in place, it is required to clean all contaminants out of the tank to prevent future leaks.

In Conclusion

Meeting MassDEP’s closure requirements means more than just being up to code. Removing hazardous USTs benefits everyone involved. It improves a property’s environmental footprint, removes high risk conditions, and reduces an owner’s environmental liability. Compared to the cost of cleaning up hazardous materials after a UST leak, removing a single-walled UST is well worth it. There is only one year left to comply with the MassDEP UST regulations, so it is imperative to start planning now to remove or close-in-place your single-walled USTs.

Please feel free to contact us for any questions on MassDEP’s requirement or for assistance with UST removals and closures.

 

A Roadmap to Massachusetts MS4 Stormwater Compliance

The long-anticipated 2016 Massachusetts Small MS4 General Permit, which replaces the 2003 Small MS4 General Permit, was finally signed on April 4, 2016 and jointly issued by the U.S. EPA and MassDEP on April 13, 2016, with an effective date of July 1, 2018. While this date may seem a long way off, it actually affords municipalities limited time to efficiently and effectively determine Massachusetts MS4 compliance needs.

The Time to Plan is Now

Marlborough-stormwater-pretty-300x225In addition to the six Minimum Control Measures included in the original 2003 Permit, the 2016 Massachusetts MS4 General Permit also specifically includes limits to Total Maximum Daily Loads (TMDLs). TMDLs set pollution limits for affected waterways. These pollution limits represent the maximum amount of pollutant a specific body of water can handle before marine life, wildlife, and/or recreational uses become adversely affected. Because stormwater has the potential to have a significantly negative impact on waterways, TMDLs are a necessary protection measure. Unfortunately, addressing stormwater contributions to TMDLs will require that many communities make some structural and treatment modifications to their stormwater systems, and these take both time and money.

A Notice of Intent (NOI) to apply for coverage under the Permit must be filed to the Massachusetts Department of Environmental Protection (MassDEP) by September 29, 2018. The Permit is expected to increase municipalities’ stormwater costs substantially for the duration of the permit term — an increase that simply may not seem affordable to some communities. And, non-compliance is not an option as it brings with it its own costs including the potential for regulatory action and fines.

The best course of action to establish compliance with the 2016 Massachusetts Small MS4 General Permit is a proactive, systematic approach. Municipalities should be evaluating current MS4 stormwater measures including stormwater system mapping, best management practices (BMPs), illicit discharge monitoring and elimination, etc., and assessing whether or not they are still in compliance with the new Permit. In addition, municipal stormwater systems should be carefully evaluated for cost-efficient and effective means of becoming fully compliant as well as provided with a proposed 5-year budget for compliance. In this way, small MS4 stormwater systems can approach local government officials with a clear and defendable stormwater budget so that nobody is caught unprepared..

Mid-CityScrap_condition1-225x300Fortunately, stormwater assessments that are conducted by licensed professional engineers, such as Tata & Howard’s MS4 Compliance Assessments, provide a significant return on investment. As part of the assessment, the entire system is meticulously evaluated for the most budget-conscious ways in which to fully meet compliance. Permit exclusions will also be assessed and all previous stormwater work will be documented to establish proper credit. The assessment also provides a well-planned course of action that is defendable when justifying projects and procuring funding.

Key Dates:

  • July 1, 2018: Revised MS4 Permit effective date
  • September 29, 2018: Notice of Intent (NOI) to apply for coverage under the permit due to EPA/MassDEP (90 days from effective permit date)
  • July 1, 2019: 5-year Stormwater Management Plan (SMP) must be posted publically (one year from the effective permit date)

While the 2016 Massachusetts Small MS4 General Permit has received critical attention and is likely to increase municipalities’ stormwater costs, it is also likely to significantly increase protection to the Commonwealth’s waterways. The fact also remains that the revised MS4 Permit has already been signed and issued. Therefore, finding a balance between compliance and budgetary constraints must be a priority for all MS4 communities.

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Jon Gregory, P.E., Tata & Howard’s Stormwater Manager, has dedicated his career to water environment engineering consulting and has over 18 years of experience in the design, permitting, and construction of water related projects. He is currently working on numerous stormwater projects throughout Massachusetts including assisting communities with MS4 compliance. 

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MassDEP agrees to co-issuance of new MS4 stormwater permit with EPA

MassDEPDespite serious concerns over costs to municipalities and timing of implementation, MassDEP has agreed to co-issue the new MS4 stormwater permit with EPA. According to a March 31, 2016 letter from MassDEP Commissioner Martin Suuberg to US EPA Region 1 Administrator Curt Spalding, MassDEP agreed to co-issue the permit in spite of concerns in order to remain involved with cities and towns on permit implementation. The letter states, “MassDEP would have preferred some time for additional discussion of important issues. Nevertheless, MassDEP needs to be involved with EPA and cities and towns on how this permit is implemented. This is too important an issue for our environment, for our cities and towns and for the Commonwealth.”

The letter further stated that EPA had not addressed all comments previously submitted by MassDEP, and that the proposed permit would present significant hurdles to municipalities. The complete letter can be read here.

ON-DEMAND WEBINAR: MS4 Compliance

ON-DEMAND WEBINAR: MS4 Compliance

PROACTIVE PREPARATION: A Small Community’s Approach Toward MS4 Compliance

stormwater_street_drainJon Gregory, P.E., Project Manager, presented this webinar on MS4 compliance. The Town of Leicester is similar to many small towns in Massachusetts in terms of the search for funds and resources for compliance with the impending new MS4 Permit.  The Town is currently using a small yearly stormwater-dedicated budget and any free municipal worker time to start proactively working towards compliance rather than waiting for the final Permit to be administered. The webinar discusses tasks ongoing and completed working towards future Permit compliance, as well as available and used resources from a local stormwater coalition, Central Massachusetts Regional Stormwater Coalition, in which Leicester has been an active member for the last three years.  Topic include components of an IDDE Program, ordinances, good housekeeping in municipal operations, communication with municipal leaders, and collaboration with local stormwater groups. The webinar is approximately 30 minutes.

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EPA Anticipates MS4 Permit to be Released in January 2016

On December 2, EPA and MassDep held a briefing at the State House to update legislators on MS4 permits. EPA stated that they anticipate the permit will be released as early as mid-January 2016.

ms4_permitThe December 2 briefing held at the State House was co-hosted by legislators Carolyn Dykema, State Representative for the Massachusetts 8th Middlesex District and Jamie Eldridge, Massachusetts State Senator representing the Middlesex and Worcester Districts. Jennifer Pederson, Executive Director for Massachusetts Water Works Association, was also in attendance.

The draft permit received over 1,400 comments to which EPA is in the process of responding. Key points include the following:

  • Timing: EPA is looking at spreading out the time frames for compliance. The permit will not be effective on the date it is issued; rather, it will likely be effective six months from the date of issue while also giving permittees 90 days to submit as well as providing more time on the illicit discharge program;
  • Requirements: EPA is working to realign their requirements with state stormwater standards;
  • Training: EPA is working on tools and templates to help with communication and required training, and will be holding several workshops when the permit is released;
  • Cost: EPA is looking for ways to reduce costs to permittees and indicated there would likely be different cost estimates in the final permit compared to the draft permit;
  • Credit for Previous Tasks: EPA intends to give credit for tasks that were completed under the existing MS4 permit so that permittees will not have to repeat tasks.

The legislators in attendance expressed their concern over the costs to their communities to comply, particularly since their towns’ estimated costs for compliance were considerably higher than what EPA originally stated. While EPA said that costs could potentially be adjusted once the permit was released, they also affirmed that costs to communities with TMDLs or impaired waters would be significantly higher in order to sufficiently address water quality issues. However, EPA also stressed that the impending permit is strictly for planning purposes and will not require construction of Best Management Practices.

MassDEP noted that they are currently reviewing all changes that EPA proposes to make to the permit. DEP is particularly interested in seeing if comments that MassDEP Commissioner Marty Suuberg had previously submitted on the draft have been incorporated into the final permit.

Please feel free to contact us with any additional questions on the impending MS4 Permit.

To learn about our stormwater services, please click here.