pollutant of concern.

  • Phase II MS4s should be encouraged to make incremental financial contributions to a state or regional stormwater monitoring research collaborative to conduct basic research on SCM performance and longevity. Although the committee knows of no examples where this has been accomplished, this pooling of financial resources by multiple MS4s should produce more useful scientific data to support municipal programs than could be produced by individual MS4s alone. Phase II communities that do not participate in the research collaborative would be required to perform their own outfall and/or SCM performance monitoring, at the discretion of the state or federal permitting authority.

  • All MS4s should be required to indicate in their annual reports and permit renewal applications how they incorporated research findings into their existing stormwater programs, ordinances, and design manuals.


The watershed-based permitting program outlined in the first part of this chapter is ultimately essential if the nation is to be successful in arresting aquatic resource depletion stemming from sources dispersed across the landscape. Smaller-scale changes to the EPA stormwater program are also possible. These include integration of industrial and construction permittees into municipal permits (“integration”), as well as a number of individual changes to the current industrial, construction, and municipal programs.

Improvements to the stormwater permitting program can be made in a tiered manner. Thus, individual recommendations specific to advancing one part of the municipal, industrial, or construction stormwater programs could be implemented immediately and with limited additional funds. “Integration” will need additional funding to provide incentives and to establish partnerships between municipal permittees and their associated industries. Finally, the watershed-based permitting approach will likely take up to ten years to implement. The following conclusions and recommendations about these options are made:

The greatest improvement to the EPA’s Stormwater Program would be to convert the current piecemeal system into a watershed-based permitting system. The proposed system would encompass coordinated regulation and management of all discharges (wastewater, stormwater, and other diffuse sources), existing and anticipated from future growth, having the potential to modify the hydrology and water quality of the watershed’s receiving waters.

The committee proposes centralizing responsibility and authority for implementation of watershed-based permits with a municipal lead permittee working in partnership with other municipalities in the watershed as co-permittees,

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