water quality. The National Pretreatment Program, EPA’s successful treatment program for municipal and industrial wastewater sources, could serve as a model for integration.

To improve the industrial, construction, and MS4 permitting programs in their current configuration, EPA should (1) issue guidance for MS4, industrial, and construction permittees on what constitutes a design storm for water quality purposes; (2) issue guidance for MS4 permittees on methods to identify high-risk industrial facilities for program prioritization such as inspections; (3) support the compilation and collection of quality industrial stormwater effluent data and SCM effluent quality data in a national database; and (4) develop numerical expressions of the MS4 standard of “maximum extent practicable.” Each of these issues is discussed in greater detail in Chapter 6.


Watershed-based permitting will require additional resources and regulatory program support. Such an approach shifts more attention to ambient outcomes as well as expanded permitting coverage. Additional resources for program implementation could come from shifting existing programmatic resources. For example, some state permitting resources may be shifted away from existing point source programs toward stormwater permitting. Strategic planning and prioritization could shift the distribution of federal and state grant and loan programs to encourage and support more watershed-based stormwater permitting programs. However, securing new levels of public funds will likely be required. All levels of government must recognize that additional resources may be required from citizens and businesses (in the form of taxes, fees, etc.) in order to operate a more comprehensive and effective stormwater permitting program.

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