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13 I BACKGROUND This digest is intended to clarify and document responsibility for implementation, and liability for enforcement, in connection with maintaining and executing NPDES stormwater permit requirements, practices, and reporting at airports.
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14 ments between airport owners and tenant operators/service providers and collect and organize information on the BMPs currently being implemented at airports. 2.2 Background Legal Research Current arrangements between airport owners and tenant operators/service providers related to stormwater, management, permitting, and compliance tend to vary greatly from state to state based on geographic location, state water quality issues, weather conditions, seasonal weather variations, size of airport, ownership and management authority at airports, permitting authority, varying degrees of regulatory scrutiny, and variables that may include but are not limited to: • Compliance history associated with previous pollutant releases.
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15 In addition to reviewing EPA's regulations and MSGP, the research included identifying, reviewing, and summarizing any decisions of EPA's Environmental Appeals Board and federal case law interpreting EPA's stormwater regulations or general stormwater permits. At the state level, further research was conducted on the five states considered in Phase I to identify and describe any independent state legal authority for regulating stormwater discharges associated with industrial activity.
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