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.
Financing 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.
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.
Stormwater runoff is a concern year-round, but even more so in the spring when snow is melting and rain is abundant, particularly in humid continental climates. Stormwater starts as precipitation such as snow, sleet, and rain, which lands on natural ground cover such as forests, grass, or gardens. In a natural environment, stormwater soaks into the ground and is filtered by layers of dirt and rock, then finds its way to our groundwater and drinking water supply. Due to urbanization, stormwater in developed areas does not land on natural ground cover but instead washes off roads, driveways, parking lots, rooftops, and other impervious surfaces, becoming stormwater runoff. Stormwater runoff picks up road salt, chemicals, oil, bacteria, sewage, sediment, and garbage, then washes these pollutants into ditches and storm drains, contaminating our streams, rivers, ponds, and lakes. To make matters worse, climate change exacerbates stormwater runoff and contributes greatly to the impairment of surface water supplies.
How Climate Change Exacerbates Stormwater Runoff
A study by scientists from the National Center for Atmospheric Research in Boulder, Colorado published in December 2016 indicates that climate change will likely bring more intense, frequent, damaging storms to all areas of the country, particularly to the Northeast and the Gulf Coast. In fact, studies show that storms in these areas could become up to five times as frequent and bring 70% more rain if greenhouse gas emissions are not reduced. Storms of this magnitude will likely cause flash floods, landslides, and an overabundance of stormwater runoff – far more than current municipal stormwater systems are designed to handle.
The study also indicated that regions such as the Pacific Northwest and central United States will likely become drier, but with more intense, extreme rainfall. We have already seen this in northern California, where the Oroville Dam suffered serious damage after drenching rains in February. Prior to these rains, the state had been plagued by severe drought. Rising temperatures increase atmospheric humidity, causing extreme precipitation and an increased risk of flash flooding. And while it may seem counterintuitive, drought only intensifies the problem. Drought leads to less vegetation and more firmly packed soil, both of which inhibit infiltration. When heavy rains follow drought, soil tends to erode, washing remaining plants away as well. Regular, gentle rain is the key to restoring soil, and without it, soil degradation will only intensify.
Managing Increased Stormwater Runoff
Unfortunately, the above-mentioned factors will likely lead to an increase in stormwater runoff and its accompanying problems. Municipal stormwater systems, already faced with increased nutrient regulations, will likely become overwhelmed, resulting in backups, localized flooding, and increased runoff of contaminants such as bacteria and nutrients into waterways. Also, combined stormwater and wastewater systems overwhelmed by extreme precipitation will release more combined sewer overflows (CSOs) into our rivers, lakes, and streams, degrading water quality and affecting aquatic life. At the same time, drought exacerbates the problem by lowering water levels, leading to more concentrated levels of pollutants in our waterways. These combined factors cause water quality deterioration and create major problems for water treatment plants. Already facing dwindling budgets, municipalities will have difficulty meeting water quality standards if stormwater runoff continues to increase unabated.
Fortunately, successfully managing stormwater runoff is a realistic goal with proper planning and incorporation of best management practices (BMPs). Systems that proactively develop strategies to address stormwater runoff will find themselves far better prepared to manage both increased stormwater and more stringent regulations. Stormwater management strategies include the following:
Increase the use of Low Impact Development. Low Impact Development (LID), also known as green infrastructure, is a stormwater management approach that maintains natural hydrology during site development. LID minimizes impervious surfaces and utilizes existing natural site features along with conservational controls to manage stormwater. Examples of LID design include bioretention basins, grassed swales, and rain gardens.
Minimize impervious surfaces. Impervious surfaces such as roads, parking lots, and rooftops prevent infiltration. Install pervious pavements on driveways and walkways, stormwater bumpouts on streets, and tree boxes on sidewalks. Also, disconnect impervious surfaces by installing grass or gravel buffer zones. Lastly, plant green roofs and roof gardens to greatly reduce stormwater runoff while enhancing the environment.
Protect and create wetlands. Wetlands are of great value due to their ability to retain water and recharge groundwater. Constructed wetlands provide the same benefit as natural wetlands and help to mitigate water pollution.
Landscape with native flora. Native trees and plants provide habitat for and attract birds, butterflies, and other beneficial local wildlife, and are acclimated to local rainfall amounts and climate. Unlike turf grass, native plants require very little maintenance because they are naturally resistant to local pests and disease. Because they do not need fertilizers, pesticides, or supplemental watering, they are easy and inexpensive to maintain and are environmentally friendly.
Plant trees. Trees help to manage stormwater by reducing erosion and runoff along streams and waterways. They also help to cool urban areas and improve the air quality.
Separate combined sewer overflows. By separating the collection of sewage and stormwater, overflow of sewer systems and treatment plants during rainy periods prevents the mixing of the surface runoff, which is lightly polluted, with municipal wastewater, which is highly polluted.
Climate change and stormwater runoff together create the perfect storm for water quality degradation. We are already seeing the effects of climate change on our nation’s infrastructure, and unless we address these complications now, we will likely find ourselves increasingly burdened by boil water orders and expensive water treatment projects. Fortunately, by proactively making some simple and largely inexpensive environmental improvements, we can protect our nation’s water bodies for future generations.
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
In 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..
Fortunately, 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.
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.
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.
On Wednesday, May 18, 2016, the Association to Preserve Cape Cod (APCC), the Barnstable Coastal Resources Committee, the Cape Cod Commission, and the Massachusetts Bays National Estuary Program hosted a free workshop entitled “2016 Small MS4 Stormwater Permit for Massachusetts and Stormwater Collaboratives.” The event, which was very well attended, was held at Cape Cod Community College and featured several presentations, including the keynote by Mr. Newton Tedder, MS4 Program, Region 1, US EPA, on “2016 Final Massachusetts Small MS4 General Permit for Stormwater.” Mr. Tedder, a key contributor to the revised permit, was available for questions. Also presenting at the workshop were Tata & Howard’s Stormwater Manager Jon Gregory, P.E., and Cherry Valley & Rochdale Water District Superintendent Michael Knox. Both Jon and Mike presented on the Central Massachusetts Regional Stormwater Coalition (CMRSWC), of which the Town of Leicester — which includes the Villages of Cherry Valley and Rochdale — is a member. The presentations included information which provided an overview of the CMRSWC as well as specific products and benefits. Congratulations to both Jon and Mike for their presentations, which provided clear and compelling data on the value of a regional stormwater collaborative.
On April 13, 2016, EPA issued a news release for the much-anticipated revised General Permit for Small Municipal Separate Storm Sewer Systems (MS4s) in Massachusetts, which was signed into effect April 4, 2016.
What you need to know:
Permit becomes effective July 1, 2018
A Notice of Intent (NOI) to apply for coverage under the permit will be due September 29, 2018
5-Year permit term
Covers 260 municipalities in Massachusetts plus state and federal facilities
Permit has the same six minimum control measures as the 2003 MA MS4 permit
The permit allows the following:
Permittee may prioritize catch basin inspection and cleaning based on their knowledge of the system
Credit for past work
Up to ten years to complete illicit discharge requirements
One year to update from 2003 Stormwater Management Plan
Other key facts:
Permit contains no end-of-pipe limits
No retrofits required during the permit term
Routine road maintenance and paving are exempt from post-construction requirements
Informational Public Meetings are being held throughout the state where requirements will be explained and questions can be asked:
Monday May 9, 2016 at 9:30am
Pioneer Valley Planning Commission
60 Congress Street, Springfield
Southeastern MA & Cape Cod:
Wednesday, May 18, 2016 at 12:30pm
Lecture Hall A, Science Building
Cape Cod Community College
2240 Route 132, West Barnstable
Thursday May 19, 2016 at 8:00am
Northern Essex Community College
100 Elliot Street, Haverhill
Tuesday, May 24, 2016 at 8:30am
200 Friberg Parkway, Westborough
Monday, June 6, 2016 at 9:00am
EPA Region 1
5 Post Office Square, Boston
Tata & Howard has extensive experience assisting municipalities in meeting MS4 permit requirements. Please contact our Stormwater Project Manager Jon Gregory, P.E. directly at 508-219-4016 or firstname.lastname@example.org for assistance or if you have additional questions.
What’s the big deal about stormwater? After all, it’s just rain, right? Not really. Rain or snow that lands on pervious, or porous, surfaces such as forests, gardens, or fields soaks into the ground and is naturally filtered and cleaned by layers of dirt and rocks, after which it finds its way to groundwater and drinking water supplies. Stormwater is precipitation that runs off impervious surfaces, such as rooftops, paved areas, lawns, and bare soil, directly into lakes and streams. Because it does not infiltrate and is therefore not filtered prior to entering ground or surface waters, stormwater is contaminated by everything it picks up along the way. These pollutants include but are not limited to pesticides, motor oil, gasoline, antifreeze, road salt, trash, fertilizers, sewage, bacteria, and pet waste, and they wreak havoc on drinking water supplies.
Common problems associated with waters polluted by stormwater include bacterial and nitrogen overload, low-oxygen dead zones, toxic algae blooms, litter-strewn waterways, damage to coastal marshes, and beach closures. In addition, pollutants carried by stormwater can harm or kill fish and wildlife, destroy vegetation and wildlife habitats, and foul drinking water. And all of these problems come with a very high environmental and monetary price tag. The most cost-effective way to manage stormwater pollution is to prevent it in the first place, which requires the cooperation of the government, municipalities, and individuals.
How the Government Helps
The United States Environmental Protection Agency (EPA) has instituted stormwater regulations under its Clean Water Act, which aims to protect our nation’s water so that it is clean, drinkable, fishable, swimmable, and healthy. The National Pollutant Discharge Elimination System (NPDES) Permit Program controls water pollution by regulating point sources that discharge pollutants into waters of the United States. Three specific contaminants of concern are bacteria, phosphorus, and nitrogen, and many of our nation’s rivers, streams, and lakes are already widely contaminated by these pollutants.
NPDES Municipal Storm Water Permitting Program regulates stormwater discharges from municipal separate storm sewer systems (MS4s). MS4 refers to systems including roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, man-made channels, and storm drains that are owned or operated by a state, district, county, city, town, or other public body (created by or pursuant to state law).
Phase I of the NPDES stormwater program for MS4s requires operators of medium and large MS4s, or those that serve populations of 100,000 or greater, to implement a stormwater management program in order to control polluted discharges from these MS4s. Phase II extends coverage of the NPDES stormwater program to certain small MS4s, but utilizes a modified approach to how the stormwater management program is developed and implemented.
How Municipalities Help
Increasingly, municipalities are addressing the issue of stormwater through regional collaboratives, education, legislation, and taxation. Last January, the Portland, Maine City Council unanimously voted to charge property owners a stormwater fee, which is dependent on the size of their rooftops and driveways or parking lots. The fee goes into effect this coming January and will cost the average homeowner roughly $4.50 per month, but will have a much larger impact on businesses like L.L.Bean, which will incur a monthly fee of just under $10,000. Several other municipalities in New England have implemented similar fees, including Chicopee, Fall River, Northampton, Newton, and Reading, MA, and Burlington, VT. Across the nation, over 500 municipalities, including major cities such as Minneapolis, Baltimore, Charlotte, Des Moines, Philadelphia, Seattle, Salt Lake City, and Orlando, have also begun imposing stormwater fees. While many residents and businesses have complained about this alleged “rain tax,” the fees actually assist with the remediation and cleanup necessary due to stormwater pollution, which is exacerbated by impervious cover. It is possible for homeowners and businesses to reduce stormwater fees by reducing the square footage of their property’s impervious surfaces.
Regional collaboratives, aiming to comply with the NPDES Permit Program, are becoming increasingly common with MS4 permittees. These collaboratives, such as the Central Massachusetts Regional Stormwater Coalition (CMRSWC) in south-central Massachusetts, hold workshops together with stormwater engineering consultants in an effort to determine the most essential tasks for stormwater management as well as the critical content of each task. With this method, these municipalities are able to pool resources to identify and implement the most efficient, cost-effective methods of meeting MS4 Permit compliance within their communities.
How Individuals Can Help
Mitigating stormwater pollution requires a multi-faceted best practice approach that involves not only federal and local agencies and municipalities, but also homeowners and individuals. There are many ways for individuals to reduce stormwater pollution including cleaning up and properly disposing of pet waste in a timely fashion, maintaining healthy septic systems, reducing or eliminating the use of pesticides and fertilizers, and implementing cleaner automotive operations. In addition, homeowners may implement Low Impact Development (LID) practices on their property to manage stormwater and to save water. Some of the easiest and most cost-effective LID practices include installing rain barrels, rain gardens, green roofs, and permeable pavers. Comprehensive information on LID may be found here, and of course, public education is key. Some other important ways that individuals can mitigate stormwater pollution are as follows:
Unclog residential storm drainages that become blocked
Cover truck loads or piles of dirt, mulch, yard waste, and other debris
Dispose of chemicals, such as motor oil, paint, and grease, properly
Have septic systems professionally inspected and pumped at a minimum of once every three years
Wash vehicles on on the lawn or other unpaved, porous surface
Direct downspouts away from paved surfaces and clean roof gutters annually
Check vehicles for leaks
Avoid pesticides by utilizing Integrated Pest Management (IPM)
Cover bare spots in the yard with plants, rocks, or even a water garden
Sweep driveways and walkways instead of hosing them off
Make sure all trash containers are tightly covered so that trash doesn’t enter the environment
Because the monetary and environmental cost of damage caused by stormwater is so exorbitant, it is imperative that communities take action to proactively prevent stormwater runoff before it causes damage. The old adage about an ounce of prevention being worth a pound of cure is quite applicable in the case of stormwater, as methods for stormwater prevention are both inexpensive and simple to implement, whereas cleanup and treatment are costly. However, best stormwater management practices require cooperative involvement of governments, municipalities, businesses, and residents. In other words, it really does take a village to manage stormwater.
New England Stormwater Collaborative Announces 2014 Stormy Awards by Janice Moran, NEWEA
April 8, 2015, Worcester, MA—The 2014 Stormy Award winners were announced during New England Water Works Association’s (NEWWA) Annual Meeting on April 1, 2015 in Worcester, MA. Five (5) awards were given to those highlighted ideas or simple, effective ways to boost funding, staff capacity, or political support for stormwater programs.
2014 STORMY AWARD WINNERS:
Developing Municipal IDDE Partnerships —Lexington, MA (Department of Public Works – Engineering Division)
Unique Stormwater Program Funding for Proactive Operations —City of Bristol, CT
The New England Stormwater Collaborative was formed in the Fall of 2013 by the New England Water Works Association, New England Water Environment Association and the New England Chapter – American Public Works Association. The Collaborative was developed to engage the stormwater community, provide a forum for information and education exchange, and advocate sound stormwater management practices.
*Tata & Howard has provided engineering services to the Central Massachusetts Regional Stormwater Coalition since 2009, and the project has been funded by Community Innovation Challenge (CIC) Grants. Of more than 120 applications received in the initial round, this stormwater project was one of few that was fully funded, which demonstrates the importance of the work and the value to the region. This project, which is supported by MassDEP, DCR, Blackstone River Coalition, and many others, is highly regarded in the industry.
The long awaited 2014 Draft Massachusetts Small Municipal Separate Storm Sewer Systems (MS4) General Permit was released on September 30th, 2014. It is important to note that this permit is still in draft form and that the current 2003 MS4 Permit is still administratively effective. The public comment period is 90 days, ending on December 29, 2014. During the comment period, public meetings and hearings will be scheduled for Municipalities and the general public to ask questions and learn more about the permit. One public hearing has already been scheduled for November 19, 2014 at 1:00 p.m. at Leominster Public Library. Representatives from Tata & Howard will be at the Leominster hearing taking notes and asking necessary questions.
The draft permit and associated documents can be found here. Currently, US EPA estimates costs of compliance for the six minimum controls measures to be between $78,000 and $829,000 per year, averaged over the permit term. The application for coverage and reporting requirements are similar to the current procedures of the 2003 Massachusetts MS4 Permit, and the six minimum control measures are comparable to the most recent 2013 Draft New Hampshire MS4 Permit.
The most significant change in the new permit is for the Water Quality Based Effluent Limitations. The permit names specific MS4 Communities and requirements to address Total Maximum Daily Loads (TMDLs) and Water Quality Limited Waters. These requirements, listed in Appendix F and H of the new permit, are detailed and provide phased plans that extend up to 20 years past the permit’s start date. Some of these reductions for established TMDLs require specific numerical percentage reductions. All other approved TMDLs, including parameters for nutrients (nitrogen and phosphorus), bacteria, pathogen, and metals, require non-numeric reductions. Many MS4 Communities are on these lists. For more information on TMDL and Water Quality Limited Water requirements for a specific community, or for assistance with questions or comments on the draft permit, please contact Tata & Howard.
The agency also posted a Fact Sheet that includes responses to comments it received on the 2008 Draft New Hampshire MS4 Permit.
The public comment period for the 2013 Draft NH MS4 Permit is from February 12, 2013 to 11:59 pm April 15, 2013. Â A public hearing is set for Thursday, March 14 2-5 PM in Portsmouth.Â Tata & Howard will attend the public hearing, and will provide comments to USEPA. Â Please contact us at (207) 518-9500 with questions about this permit, or for assistance in determining the impact of this proposed permit on your community.
The CMRSWC project has been awarded an additional grant for the next phase of its stormwater compliance program. Tata & Howard has been working with 13 communities in south-central Massachusetts under a project funded by a Community Innovation Challenge (CIC) Grant, and an additional 17 communities have committed to participate in the next phase of work. This project, which is supported by MassDEP, DCR, Blackstone River Coalition, and many others, is highly regarded in the industry, and enables participating communities to fully comply with both 2003 and 2013 Massachusetts MS4 permit requirements.
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Tata & Howard is interested in motivated environmental professionals dedicated to providing great client service and high quality, efficient work. Please send your resume and cover letter to HR@tataandhoward.com.
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