PSATS submitted comments to DEP regarding the draft NPDES MS4 General Permit (PAG-13), expressing concerns over crediting of municipal success in reducing sediment and pollutants under the current permit, particularly those that individually or collaboratively exceeded their current permit goals. Under the proposed rules, DEP wants townships to focus on managing the amount of rainwater running off roads and parking lots, instead of reducing sediment and pollutants. Pollutant control measures under the current program would be eliminated. 

While collaboration is incentivized under the permit, it isn’t clear how permittees under the MS4 General Permit would be able to work with communities under the MS4 Individual Permit, which would remain on a sediment reduction objective. The draft stormwater management ordinance is twice as long as the current ordinance and delves into zoning issues and may conflict with existing Act 167 stormwater ordinances. 

Many townships and their consultants have submitted comments on the draft permit and PSATS urged DEP to take these concerns and suggestions into consideration. Comments may be submitted until 11:59 p.m. today through www.ahs.dep.pa.gov/eComment or via email at ecomment@pa.gov. Township officials are encouraged to share comments with Holly Fishel at hfishel@psats.org.   

To access the draft permit and related documents, click here. To access the Pennsylvania Bulletin notice, which provides a brief overview of the major changes, click here. PSATS provided a webinar last week and a recording is available to help townships and their consultants learn more about the DEP draft. Click here to view PSATS comments.