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MS4 Stormwater Services in Massachusetts: Supporting Communities Through Sustainable Solutions

The Importance of Stormwater Management

Stormwater management is a vital part of maintaining healthy communities and ecosystems, particularly in urban areas where development often disrupts the natural flow of water. In Massachusetts, the MS4 (Municipal Separate Storm Sewer System) program plays a pivotal role in managing stormwater runoff and protecting our state’s valuable water resources. At Tata & Howard (T&H), we’re proud to help our local municipalities navigate these important regulations, providing expert stormwater solutions that not only ensure compliance but also support long-term sustainability and environmental well-being.

A Brief History of the MS4 Program

The MS4 program was first introduced by the U.S. Environmental Protection Agency (EPA) in 2003 as a way to reduce pollutants in stormwater runoff, which we know can seriously harm water quality and aquatic life. Initially, the program focused on larger urbanized areas, but over time, it has expanded to include smaller communities, recognizing that stormwater management is crucial no matter the size of the municipality. Over the years, the program has evolved to address new and ongoing environmental challenges.

The most significant update came in 2016 with the release of the EPA’s revised MS4 General Permit for Massachusetts. This new permit introduced even more stringent requirements aimed at reducing pollutants and improving stormwater management practices, while also taking into consideration emerging issues like climate change and increased storm events. These new requirements included, but were not limited to, an increased emphasis on green infrastructure; a stronger emphasis on public education and outreach; and enhanced pollutant reduction goals. As the program evolves, the focus on sustainability, innovation, and community engagement continues to grow stronger and stronger—and we’re thrilled to be part of this monumental work.

Key Requirements of the MS4 Program

The core goal of the MS4 program is to reduce the pollutants that stormwater runoff carries into water bodies, including harmful substances like sediment, heavy metals, and excess nutrients. To meet this goal, municipalities are required to develop and implement stormwater management programs that address these pollutants through Best Management Practices (BMPs). This can include constructed solutions like infiltration trenches, bioswales, rain gardens, green roofs, permeable pavement, and non-structural BMPs like ordinance development, street sweeping, proper disposal of hazardous waste, and using environmentally-friendly lawn care products.

The updated 2016 MS4 General Permit also placed a stronger emphasis on documentation, reporting, and tracking progress toward pollutant reduction goals. Municipalities are expected to engage with their communities on stormwater issues and educate residents on ways to reduce runoff at the local level. Furthermore, municipalities must also consider climate change impacts, ensuring that their stormwater systems can handle more frequent and severe storms. These requirements may seem challenging or tedious, but they serve as a real opportunity for communities to innovate and build more resilient infrastructure.

Recent Updates to the MS4 Regulations: Adapting to Evolving Challenges

The MS4 regulations continue to evolve to meet the growing environmental challenges posed by stormwater runoff. In recent years, there have been several key updates to the regulations that municipalities must be aware of to stay in compliance and effectively protect water quality. These updates not only address new environmental priorities but also reflect a growing recognition of the need for more comprehensive stormwater management strategies.

One significant update occurred in December 2020 when the EPA finalized modifications to the 2016 Massachusetts Small MS4 General Permit. These changes, which took effect on January 6, 2021, aimed to enhance stormwater management by addressing the emerging concerns surrounding pollution from commercial, industrial, and institutional (CII) properties. This new initiative would impact thousands of properties with impenetrable surfaces, making it part of a broader effort to address stormwater pollution from other various sources.

Additionally, the Massachusetts Department of Environmental Protection (MassDEP) has been working to align its Wetlands Protection Act (WPA) stormwater management standards with the MS4 General Permit Post-Construction Stormwater Rules. In October 2024, it was announced that this alignment would streamline the stormwater permitting process and ensure that state and federal regulations work together in harmony. By simplifying this process, municipalities are able to more efficiently meet the requirements of both the EPA’s MS4 program and MassDEP’s regulations. (After all, it is a group effort!)

In November 2024, the EPA provided Massachusetts MS4 Permittees with written notice that they intend to reissue the National Pollutant Discharge Elimination System (NPDES) Massachusetts MS4 General Permit for discharges to certain waters of the Commonwealth of Massachusetts. When finalized, the Draft Permit will replace the Final Massachusetts MS4 General Permit issued on April 4, 2016 and modified on December 7, 2020. The public comment period for the Draft Permit was recently extended for an additional 90 days from February 20, 2025 to May 21, 2025.

Though there have been several other key updates—all of which can be found on the EPA website—municipalities now have more focused guidance on how to reduce pollutants from a wider range of sources and ensure their stormwater systems are prepared for the future. These changes reflect a growing recognition that stormwater management must be comprehensive, addressing not only the volume of runoff but also the variety of pollutants that affect water quality.

Tata & Howard’s Role in MS4 Compliance

At T&H, we believe that MS4 compliance is about much more than just ticking boxes. It’s about helping municipalities achieve meaningful improvements in stormwater management that benefit both people and the environment, which is at the heart of what we aim to accomplish.

Our team works closely with municipalities to develop customized stormwater management plans that align with regulatory guidelines while also addressing the unique needs of each community. We understand first-hand that each municipality faces different challenges, and we take pride in our tailored approach to help them overcome these obstacles effectively.

Some examples of MS4 Compliance Services provided by T&H include the following:

Public Outreach Assistance
Stormwater Management Program Preparation
Stormwater Infrastructure Mapping
Annual Reporting to the EPA and MassDEP
Outfall Inspection and Inventory Services
Phosphorous Control Planning

Looking to the Future: A Sustainable, Resilient Tomorrow

The MS4 program is more than just a set of regulations; it’s a framework for creating a cleaner, healthier environment for Massachusetts communities. At Tata & Howard, we are proud to be part of the solution, helping municipalities comply with MS4 requirements while also driving innovation in stormwater management. Together, we can build a sustainable, resilient future where both communities and the environment thrive.

As we look ahead, we’re excited about the progress being made in stormwater management. With a focus on collaboration, sustainability, and community engagement, we can turn regulatory requirements into meaningful opportunities for positive change. By working together, we can ensure that Massachusetts continues to lead the way in responsible stormwater management and create a healthier, more sustainable environment for future generations.

It Takes a Village to Manage Stormwater

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

parking_lot_impervious — Stormwater fees are based on the amount of impervious surfaces on a property

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.

green_roof_stormwater — Green roofs help manage stormwater in urban settings

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:

ladybug_pest_management — Ladybugs are a natural predator to pests such as aphids

- - - 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

Rain gardens filter stormwater, provide habitat for wildlife, and beautify the area

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.

EPA Announces 2015 MSGP Available Soon, Advises Preparation

On May 27, 2015, the EPA announced that the new Multi-Sector General Permit (MSGP), originally proposed in 2013 and referred to as the 2015 MSGP, will be available soon for operators seeking permit coverage to discharge stormwater associated with industrial activity. Filing to renew coverage under the 2015 MSGP must be done electronically using EPA’s new NPDES eReporting Tool (NeT), and, once covered by the new permit, all monitoring data will be submitted electronically using NetDMR.

To prepare for the new 2015 MSGP, EPA recommends taking the following steps:

Visit EPA’s MSGP webpage (https://water.epa.gov/polwaste/npdes/stormwater/EPA-Multi-Sector-General-Permit-MSGP.cfm) to learn about the status of the 2015 MSGP, your eligibility, NeT and NetDMR training, and to obtain guidance on complying with the new permit.
Determine if your facility qualifies for a conditional “no exposure” permit exclusion.
Review your Notice of Intent (“NOI”) submitted for coverge under the 2008 MSGP for information that will help you file a new NOI for the 2015 MSGP.
Discuss internally who will prepare and certify the documents submitted through the NeT and NetDMR tools for your facility.
Review your existing Stormwater Pollution Prevention Plan (SWPPP) to identify the revisions necessary to make it current and consistent with the 2015 MSGP requirements. Your SWPPP must be prepared and ready to implement prior to filing an NOI for the 2015 MSGP.

If you need assistance with your 2015 MSGP, please contact us at contact@tataandhoward.com or 800-366-5760.

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