requirements in the Phase II stormwater program makes it virtually impossible to measure or track actual pollutant load or runoff volume reductions achieved. It is recommended that both Phase I and II MS4s shift to a more collaborative monitoring paradigm to link management efforts to receiving water quality.


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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.

REFERENCES

April, S., and T. Greiner. 2000. Evaluation of the Massachusetts Environmental Results Program. Washington, DC: National Academy of Public Administration..

Atkins, J. R., C. Hollenkamp, and J. Sauber. 2007. Testing the watershed: North Carolina’s NPDES Discharge Coalition Program enables basinwide monitoring and analysis. Water Environment & Technology 19(6).

Bellucci, C. 2007. Stormwater and Aquatic Life: Making the Connection Between Impervious Cover and Aquatic Life Impairments for TMDL Development in Connecticut Streams. Pp. 1003-1018 In: TMDL 2007. Alexandria, VA: Water Environment Federation.

Bromberg, K. 2007. Comments to the NRC Committee on Stormwater Discharge Contributions to Water Pollution, January 22, 2007, Washington, DC.

Burton, G. A., and R. E. Pitt. 2002. Stormwater Effects Handbook. Boca Raton, FL: Lewis/CRC Press.

California EPA, State Water Board. 2006. Storm Water Panel Recommendations—The Feasibility of Numeric Effluent Limits Applicable to Discharges of Storm Water Associated with Municipal, Industrial, and Construction Activities. Available at http://www.cacoastkeeper.org/assets/pdf/StormWaterPanelReport_06.pdf.

Campbell, R. M. 2007. Achieving a Successful Storm Water Permit Program in Oregon. Natural Resources & Environment 21(4):39-44.



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