Tag: stormwater

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.

Ten Eco-Friendly Fall Yard Tips

Save water, energy, time — and money — with these ten eco-friendly fall yard tips

The average American’s environmental footprint has increased exponentially over the past 100 years, with America currently having the highest per capita water consumption in the world. The average African uses about 5 gallons of water per day, an average European uses 50 gallons per day, and the average American uses over 100. In addition, chemicals, personal care products, pharmaceuticals, and other toxins have been detected in some of our water supply resources. There are many simple, cost-effective methods of reducing our ecological footprint and of improving the environment in which we all live — and it starts right in our own backyard.

1 Direct downspouts onto lawn or garden

downspout gardenStormwater has become a major environmental concern, as it carries pollution, chemicals, and bacterial contamination into our waterways. One of the easiest ways to prevent stormwater from entering storm drains is to direct downspouts onto grassy areas or gardens. Downspouts should never drain onto impervious surfaces such as driveways or walkways where stormwater flows unfiltered into storm drains or waterways. Plants and soil act as a filter for stormwater so that it is cleaner when it enters our water supply.

2 Install a rain barrel

Rain barrels capture rainwater from gutters and downspouts for reuse in gardens and lawns, preventing unfiltered pollutants from entering our waterways. Installed easily, rain barrels come in an assortment of shapes and sizes, can be inexpensively built from readily obtained materials, and can even be decorative. A rain barrel is also a fun project for kids, and introduces them to the concepts of conservation and reuse. Note: rain barrels should not be allowed to freeze, as they could suffer damage or even break. Empty them and put them into storage when winter arrives.

3 Clean gutters

clogged gutterOne of the easiest ways to prevent stormwater runoff AND save your roof and siding is to clean the gutters on your home. Utilizing a ladder or a service, remove all dead leaves and debris from gutters and ensure that water flows freely from gutters to downspouts. If your gutters clog frequently or if your home is in a heavily wooded area, consider installing gutter guards.

4 Sweep driveways and walkways

Never use a hose to wash down driveways, walkways, and sidewalks! Hosing down these surfaces wastes water and also pushes pollution into storm drains and waterways. Instead, sweep away dirt and debris and dispose of it properly so that pollution doesn’t enter drains or our water supply.

5 Aerate your lawn

aeration lawn
Photo courtesy of Akron Lawn Care Services

Over time, lawns become compacted from use, preventing water and nutrients from reaching roots. Aerating removes small plugs of soil from the lawn, loosening the soil and allowing oxyten, nutrients, and water to more easily permeate the lawn. Aeration improves the health of soil and allows grass roots to grow more deeply, resulting in a more vibrant lawn. Consider sharing the cost of aerator rental from your local hardware store with a neighbor.

6 Apply natural fertilizer

Contrary to what most lawn maintenance companies profess, lawns only need to be fertilized once per year, ideally in the fall. Avoid using chemical or synthetic fertilizers as they contain water-soluble nitrogen, which dissolves during rain or lawn watering and can run into our water supply. Instead, opt for natural fertilizers, which typically contain insoluble nitrogen that is released slowly over time onto the lawn. Natural fertilizer stays in the lawn for a longer time period, providing better feeding, and prevents over-fertilizing and subsequent burning. Even better, the easiest, most affordable natural fertilizer can be found right in your own backyard…

7 Start composting

compost-bins_green_wasteRather than being bagged and hauled off to already overflowing landfills, grass clippings, dead leaves, and other organic yard waste can be turned into organic fertilizer rich in nutrients. Simply shred the waste using clippers or a mulcher, and then add it to a compost bin. Compost bins can be quickly constructed with a few items from the hardware store or can be bought pre-assembled. Green waste, such as grass clippings, is rich in nitrogen, whereas brown waste provides carbon energy for the organisms responsible for doing the decomposing. Be sure to add relatively equal amounts of both for the best possible results. Add water to the pile until it is just moist enough to wring a few drops of water from the waste, and then let it do its work! Add kitchen vegetable scraps and yard waste to the pile, keep it moist, and turn it once a month. By spring, you will have all natural, nutrient rich fertilizer — for free. Note: meat, ashes, pet waste, and pressure treated wood should never be composted.

8 Overseed

Fall is the best time to add grass seed to your lawn. Overseeding inhibits weed growth, improves lawn appearance, and increases drought tolerance. When overseeding, use native grass and groundcover seeds that require less maintenance and water and provide higher stress tolerance than traditional grass seed. Utilize a seed spreader to ensure uniform seeding.

9 Update outdoor lighting

solar lights
Solar lighting is an attractive, energy-efficient option for a walkway

Shorter days are upon us, which means longer nights — and outdoor lighting that stays on for an extended period of time. Replace outdated incandescent bulbs with LED or fluorscent bulbs to save energy and money. Also, install automatic shut-offs or timers on outdoor lights to avoid running lights when they aren’t needed. Enthusiastic environmentalists can consider purchasing and installing solar lights. Solar lights are energy efficient and eco-friendly, wire-free, automatically turn on at dusk and off at dawn, produce a warm and inviting glow, and are a snap to install. Solar lights are available in every shape and size and can be used for walkways, entry areas, driveways, sheds, pools, patios, and even holiday decorating.

10 Perform an exterior house check

To save water and energy this winter, be sure to perform an exterior house check this fall. Examine all windows and doors for gaps and cracks, and repair any areas that allow heat to escape. Also, remove all hoses from outdoor spigots and be sure the water is turned off. If you have a pool, winterize it properly to prevent any damage, and be sure to install a quality pool cover to minimize water evaporation. Since the average pool holds about 25,000 gallons of water, avoiding the need to refill the pool in the spring is an important step in household water conservation.

Tata & Howard Raises Funds for Camp Sunshine

Tata & Howard Raises Funds for Camp Sunshine

flip flop day camp sunshine
Collin Stuart, Heidi White, Brooke Cotta, Marie Rivers, Molly Coughlin, Amanda Cavaliere, Karen Gracey, Brittany Colcord, Jenna Rzasa, and Matt St. Pierre pose with their flip flops

New England-based engineering firm participates in National Flip Flop Day to support Maine camp

Employee-owners from Tata & Howard, Inc., a leading innovator in water, wastewater, stormwater, and environmental services engineering solutions, participated in National Flip Flop Day on June 19th. The holiday, which falls on the third Friday in June each year, was started nine years ago by Tropical Smoothie Café in order to raise funds to benefit Camp Sunshine, a retreat in Maine for children with life-threatening illnesses and their families.

Tata & Howard team members participated in their own version of National Flip Flop Day in which employee-owners were able to wear flip flops to work in exchange for a donation to Camp Sunshine. 100% of donations were matched by Tata & Howard’s Philanthropy Committee.

“With offices throughout New England, Tata & Howard is committed to finding ways to give back to the community in which we live and work,” said Jenna Rzasa, P.E., Vice President of Tata & Howard. “Maine’s Camp Sunshine provides both solace and joy to severely ill children and their families, and we are deeply honored to support their efforts.”

Located in beautiful Casco, Maine, Camp Sunshine is the only organization in the nation that focuses on not only addressing the effects of a life-threatening illness on the child who is ill, but also the entire family. Surrounded by professional staff within the breathtaking grounds of Camp Sunshine, families receive a reprieve from the stress of having a child with an illness and spend a week just having fun together.

To date, National Flip Flop Day has raised over $2 million for Camp Sunshine.

EPA Issues 2015 MSGP for Industrial Stormwater Discharge

 

Photo by Roger Winstead
Photo by Roger Winstead

On June 4, 2015, the United States Environmental Protection Agency (EPA) issued a revised NPDES Multi-Sector General Permit (MSGP) for industrial stormwater discharges. The 2015 MSGP replaces the 2008 MSGP.

While the 2015 MSGP provisions are largely similar to the 2008 MSGP, EPA has made some changes to streamline the permit, enhance environmental protections, and improve clarity. The most significant changes are as follows:

  • Revised threatened and endangered species eligibility procedures.
  • Additional specificity for several of the technology-based effluent limits (i.e., control measures) for clarity.
  • A requirement that facilities discharging to a small number of federal Superfund sites notify their EPA regional office prior to filing their Notice of Intent (NOI).
  • Streamlining of Stormwater Pollution Prevention Plan (SWPPP) documentation (i.e., facilities do not have to expound on their compliance with certain effluent limits).
  • Public accessibility to SWPPP information, either by posting on the internet or by incorporating salient information into the NOI.
  • Electronic submission for the NOI, Notice of Termination, annual report, and monitoring.
  • Reduced requirements for inspections (i.e., facilities no longer have to conduct a separate comprehensive site inspection).
  • Specific deadlines for taking corrective actions.
  • Inclusion of saltwater benchmark values for metals.
  • Inclusion of the Airport Deicing Effluent Limitation Guideline for the air transportation sector.

EPA’s MSGP applies in areas of the country where EPA remains the NPDES permitting authority and has made the permit available for coverage, which includes the following:

  • Four states: Idaho, Massachusetts, New Hampshire and New Mexico;
  • The District of Columbia;
  • All U.S. territories except for the Virgin Islands;
  • Federally operated facilities in Colorado, Delaware, Vermont and Washington;
  • Most Indian Country lands; and
  • Various other designated activities in specific states.

For additional information on the 2015 MSGP, visit EPA’s website here.

For additional questions, or if you need assistance with the 2015 MSGP, please contact us.

Managing Stormwater in New England with Low Impact Development

10 Best Low Impact Development Stormwater Practices

Stormwater runoff is the number one source of water pollution in the country, and a major threat to clean water in many New England communities. Over the years, we have paved, constructed, and developed the land to the point that the natural landscape is decimated. Where snow, sleet, and rain would normally land on forests and grass and be filtered by layers of dirt and rock, it now washes off parking lots, roads, driveways, rooftops, and other hard surfaces, known as impervious cover, and picks up pollutants such as oil, trash, sediment, bacteria, fertilizer, oil, and road salt along the way. This heavily polluted, untreated water then makes its way into streets and storm drains and subsequently into rivers and lakes that supply our drinking water.

In Texas and Oklahoma this week, we’ve seen the devastating and deadly effects of stormwater runoff. Because the absorbent grasses and dirt have been mostly covered over by pavement and buildings, heavy rains now run off streets, roofs, and driveways, overwhelming drainage systems and, in extreme weather, flooding homes. And in New England, stormwater runoff has not only contributed to water pollution and flash flooding, but also to beach closures, algae blooms, and soil erosion.

What is 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. In LID, stormwater is viewed as a resource rather than a waste product, and the site is developed with this key concept in mind. Often, LID replaces traditional stormwater management practices that focus on moving stormwater off-site with curbs, pipes, and ditches.

LID is useful for creating functional, attractive, and environmentally friendly residential, commercial, and industrial sites, and is both sustainable and cost-effective. Some of the benefits include improved water and air quality, reduced stormwater runoff volume, increased natural habitat and recreational space, increased property values, improved groundwater recharge, and community beautification. Below we have compiled a list of ten LID stormwater practices that are most effective in managing stormwater in New England.

rain_garden_stormwater

1. Rain Gardens

A rain garden is typically situated close to the source of runoff and utilizes plants that are able to withstand extremes of moisture as well as excessive nutrients such as nitrogen and phosphorus. By slowing stormwater as it travels downhill, rain gardens provide opportunity for stormwater to infiltrate and also inhibit erosion. While rain gardens provide habitat for wildlife and are an attractive landscaping addition, it’s what’s beneath them that makes them an LID rain garden. Plants and soils are specifically chosen and engineered to clean stormwater by reducing nutrients and overall sediment loads. Multiple rain gardens are often spread over an area, cumulatively controlling the volume and improving the quality of stormwater runoff.

green_roof_fenway_park

2. Green Roofs 

A green roof, also knows as a rooftop garden, is exactly what its name suggests: a roof with vegetation on it. Through evapotranspiration, green roofs remove heat from the surface of the roof and in turn the surrounding air. A green roof is easily installed on any type of building, residential or commercial, and can be as simple as a single layer of groundcover or as intricate as Fenway Park’s extensive vegetable garden. In addition to providing excellent stormwater management and improving water quality, green roofs also provide such benefits as reduced energy use and air pollution, and improved comfort and quality of life.

permeable_pavement_stormwater

3. Permeable Pavement

The link between high levels of impervious surfaces and degraded water quality is indisputable, and most impervious surfaces are paved roadways. Reducing impervious surfaces is one of the key steps in improving any community’s water quality. Permeable, or pervious, pavement is designed to allow water to pass through it into the ground below where it is naturally filtered. Pervious pavement has a myriad of benefits including not only reduced stormwater runoff and replenished groundwater, but also reduction of flooding, pollutants, temperature, roadway ice buildup, and traffic hydroplaning accidents. In New England, special care needs to be taken when utilizing permeable pavement, as there is potential to compromise its effectiveness through plowing and sanding.

grassed_swale_stormwater

4. Grassed Swales

A grassed swale is an open channel designed to manage a specific water quality volume, often along roadsides and parking lots. Stormwater runoff is slowed by vegetation as it flows in these channels, allowing the stormwater to infiltrate and be filtered by the underlying soil. Grassed swales are long and shallow in shape and have plants that are both flood and erosion resistant.

grassed_swale_stormwater

5. Disconnected Impervious Surface (DIS)

DIS is a low-cost, effective way of reducing the volume and flow of stormwater runoff by directing stormwater runoff from impervious areas to graded and vegetated pervious surfaces. DIS is effective for both roofs and paved areas utilizing slightly different designs and provides both infiltration and filtration.

bioretention_basin_stormwater

6. Bioretention Basins

Bioretention basins are landscaped depressions specifically designed to slow and treat on-site stormwater runoff. Typically utilized in parking lots and residential areas, these basins incorporate pollutant removal systems that naturally operate in forests. During a storm event, runoff pools above the mulch and is slowly filtered through the soil beneath before being collected by a perforated underdrain. The clean, filtered runoff is then returned to the storm drain system or local receiving waters.

green_streets_stormwater

7. Alternative Street Design

Alternative street design is mainly effective for new construction and takes into account all aspects of “green streets.” When building a new street, all existing hydrologic functions of the land need to be considered and incorporated in the best possible way into the design. This includes preserving wetlands, buffers, and highly permeable soils while minimizing impervious areas. Typically streets are more narrowly constructed with wide, pervious sidewalks and plenty of vegetated areas.

stormwater bumpout

8. Bioretention Curb Extensions (Stormwater Bumpout)

A stormwater bumpout is a curb extension that extends the existing curb. Typically located either mid-block or at an intersection and composed of a layer of stone that is topped with flood and nutrient tolerant plants and soil, these attractive bumpouts filter stormwater while providing an aesthetic benefit to communities. The bumpout is constructed with an inlet (or curb-cut) that directs stormwater runoff into the bumpout where it can be infiltrated and filtered. The vegetation in a stormwater bumpout is short enough so as not to impact driver sight-lines.

stormwater planters

9. Stormwater Planters and Tree Boxes

Stormwater planters and tree boxes are installed in sidewalks and are designed to manage stormwater runoff from streets and sidewalks. Planters are typically sunken into the sidewalk, rectangular in shape with concrete sides, and lined with a permeable fabric. They are then filled with stone or gravel and topped with soil, hardy plants, and trees. Because they are built down into the sidewalk, runoff is directed into these planters that provide storage, infiltration, and evapotranspiration.

rain cistern stormwater

10. Rain Barrel/Cistern

A rain barrel collects and stores stormwater runoff from rooftops, where it can later be used to water lawns and gardens. To be effective, they must be emptied between storms and utilized by a high percentage of a community’s population. While one rain barrel holds a relatively small amount of water, a large volume of rain barrels can be extremely effective in significantly reducing the amount of stormwater entering a community’s sewer system during storms.

lid-stormwater.net
lakesuperiorstreams.org
nrdc.org
epa.org
lowimpactdevelopment.org
msrc.org
phillywatersheds.org

EPA Announces 2015 MSGP Available Soon, Advises Preparation

Photo by Roger Winstead
Photo by Roger Winstead

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:

  1. 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.
  2. Determine if your facility qualifies for a conditional “no exposure” permit exclusion.
  3. 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.
  4. Discuss internally who will prepare and certify the documents submitted through the NeT and NetDMR tools for your facility.
  5. 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.

Tata & Howard, Inc. participates in Rally for the Jimmy Fund

Tata & Howard, Inc. participates in Rally for the Jimmy Fund

Charitable event celebrates over $4 million in donations to Dana-Farber Cancer Institute since its 2006 inception

Tata & Howard team members at the Marlborough, MA corporate office participated in the Rally for the Jimmy Fund on April 13, 2015
Tata & Howard team members at the Marlborough, MA corporate office participated in the Rally for the Jimmy Fund on April 13, 2015

MARLBOROUGH, MA, April 14, 2015 – Tata & Howard, Inc., a leading innovator in water, wastewater, stormwater, and hazardous waste engineering solutions, participated in the Rally for the Jimmy Fund yesterday. The Rally encourages people to wear Red Sox gear on Opening Day at Fenway Park, which fell on Monday, April 13 this year, in exchange for a donation to the Jimmy Fund. Tata & Howard team members were happy to donate to the Jimmy Fund while enjoying a casual Red Sox day at the office.

The Rally and the Jimmy Fund

The Red Sox organization has partnered with the Jimmy Fund since 1953, and the Rally for the Jimmy Fund is just one of many Red Sox/Jimmy Fund initiatives. Monies raised through the Rally help ease the patient experience and allow future discoveries to revolutionize cancer treatments around the world. Eighty-nine cents of every dollar raised by the Jimmy Fund and Dana-Farber goes directly to Dana-Farber Cancer Institute, which received the highest possible ranking of four stars by Charity Navigator, America’s largest independent evaluation of non-profit organizations. Since its inception in 2006, Rally for the Jimmy Fund has raised over $4 million.

“We are thrilled to be part of such a worthwhile charity,” stated Donald J. Tata, P.E., President of Tata & Howard.” Through participation in other local events such as the PanMass Challenge and the Mass Dash for the Jimmy Fund, Tata & Howard team members raise funds for the Jimmy Fund throughout the year. The Rally for the Jimmy Fund was yet another way for us to support Dana-Farber and cancer research.”

CMRSWC Wins Stormwater Award

CMRSWC Wins Stormwater Award

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.

Stormy Award logo2014 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. 

How Dangerous is Dumping Snow into the Ocean?

A “snow farm” located in Boston Harbor. When it all melts where will it go?

If you’re in New England this year, the only thing on people’s minds – apart from the Patriots’ Superbowl win – is the extreme snow fall we’ve faced.

Cities around the region are reaching record-breaking snow accumulation resulting in budget-breaking snow clean up for cities and towns.  What’s got most officials worried is that it’s only February.  Winter here in New England has a long way to go.

In Boston, a harbor city, with historically narrow and windy streets, crews are running out of places to put the snow.  Streets are becoming impassable, sidewalks are nearly non-existent.  Traffic is slowing to a halt, trains are freezing on the rails, creating difficult and dangerous traveling conditions for all.

When conditions go beyond salting and plowing, some municipalities use diesel-powered snow melters to dispose of the snow.  Massachusetts’ Governor, Charlie Baker announced that the state has bought two of these to help with condition across the state.  These machines are costly, but provide a slow, but guarantee of snow removal. But with the amount of snow the entire state has faced in recent weeks, snow melters will take a long time to whittle away at all the piles. Coastal cities, like Boston, are considering another dramatic option – plowing snow into the ocean. While this option is equally successful at getting rid of snow, it could potentially be more expensive in the long run.

While the act of dumping snow into the ocean has long been banned, there is the option for cities and towns to request a waiver from the state in situations where the accumulated snow poses a danger to the public.  However this has now become a very difficult debate for officials to maneuver – one of protecting public health no matter what side of the debate you are on.

It’s important to remember that dumping snow into the ocean is nothing like the snow that falls into the ocean during a snow storm.  Plowed snow is snow that has been dragged through the streets, always with large amounts of salt, oil, and any other debris left on the roads. That pollutes the ocean, and so can only be done if the snow constitutes a danger to public health — a point, some argue, Boston has approached.

But doesn’t that debris and pollution enter the ocean when the snow melts and drain through the storm drains?

The short answer is, “Yes”. Paul Levy, the first director of the Massachusetts Water Resource Authority, writes that he thinks it’s pretty silly to let Boston build up the snow in giant snow farms right near the water, but not let the city push the snow into the harbor – when it’s going to melt into the water anyway.  Forcing the city to create snow mountains only means wasting time that could be better spent getting rid of snow from increasingly clogged streets, he says in a blog post.

In a response to his original call for ocean dumping, Levy commented, “I’m not suggesting we make a habit out of it. I’m suggesting that when you have an emergency situation, with gridlock on the streets, extraordinary measures are called for. It’s just a matter of time before someone dies because an ambulance can’t get there; or a person slips off a snowbank in front of a car or truck, or isn’t seen walking on the street and gets flattened, or whatever. If doing the harbor disposal for a day or two could expedite the street cleaning, it’s worth a bit of environmental degradation. After all, we engage in environmental protection, at least in part, as a public health measure. If we are too pure about that, we can end up causing a different kind of public health problem.”

With more snow expected this week, the debate will continue whether to dump or not to dump.  Until it melts, we New Englanders, naturally a hardy group, will just continue to cry “Uncle” to Mother Nature.

Summary of 2014 Draft MA Small MS4 General Permit

MarlboroughMA_Stormwater10The 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.