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Storm Water Management (MS4)
Municipal
Separate Storm Sewer Systems: MS4s: What Do School
Districts Need To Do?
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Determine
school needs to
determine if the school district is located
in a Designated
Urbanized Area. See the attached list of
the New York State Automatically Designated Urbanized
Areas. To verify if a specific address falls within a Designated
Urbanized Area, go to:
http://www.dec.ny.gov/docs/water_pdf/ms4_overview.pdf.
If your district does not fall within a Designated
Urbanized Area, then you are not required to comply
with the EPA/DEC MS4 regulation. However,
to protect resources and quality of life, New York State
encourages all localities, urban and rural, to manage
stormwater through existing land use approval processes.
The State of New York recommends that every community,
whether or not it is regulated under the state/federal
program, adopt a Stormwater Management Local Law.
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If
your district or some of the district property falls
within a Designated Urbanized Area, then use the
attached NYSDEC, Local School District Decision Tree
for MS4 Determination, to determine if the
district needs to file a Notice of Intent (NOI) with
NYSDEC to obtain a SPDES permit and/or needs to pursue
waiver eligibility with NYSDEC. IMPORTANT: EPA does not
require coverage for a stormwater system that serves a single
building.
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If
your district is in a Designated Urbanized Area, it is recommended that the district contact their local
municipality to see if they have or will cover your MS4s
under their permit or waiver. If they will not, then the
district must comply with the EPA/DEC MS4 requirements by
1/8/08.
(NYSDEC is
encouraging municipalities to provide permit coverage for
school districts through agreements. In some instances,
municipalities may own or operate the stormwater systems
that serve the school district).
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In
addition to obtaining the required permits, MS4’s must
also:
- Develop,
implement and enforce a stormwater management program (SWMP)
designed to reduce the discharge of pollutants from
small MS4’s to the maximum extent practicable (MEP) to
protect the water quality and to satisfy the appropriate
water quality requirements of the Environmental
Conservation Law and the CWA.
- SWMP’s
must include six minimum control measures:
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Public Education and Outreach
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Public Involvement/Participation
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Illicit Discharge Detection and Elimination
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Construction Site Runoff Control
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Post-Construction Storm Water Management in New and Redevelopment
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Pollution Prevention/Good Housekeeping for Municipal
Operations
- For
each of these six minimum measures, measurable goals are
to be selected, identified and management practices
implemented to achieve those measurable goals.
BACKGROUND::
In 2003, the Environmental Protection Agency (EPA), under
the terms of the 1987 amendments to the Federal Water
Pollution Control Act (FWPCA), also referred to as the
Clean Water Act (CWA), required that the New York State
Department of Environmental Conservation (NYSDEC) expand
its permitting program to include a new federally mandated
program to control stormwater runoff and protect
waterways. According to the federal law, commonly known as
Stormwater Phase II, permits will be required for
stormwater discharges from Municipal Separate Storm Sewer
Systems (MS4s) in urbanized areas and for
construction activities disturbing one or more acres. The
NYSDEC has developed two general permits, one for MS4s in
urbanized areas and one for construction activities. The
permits are part of the State Pollutant Discharge
Elimination System (SPDES). Operators of regulated MS4s
and operators of construction activities were required to
obtain permit coverage under either an individual SPDES
permit or one of the general permits no later than March
10th, 2003 or prior to commencement
of construction. EPA/DEC requires stormwater
management programs be fully functional by January
8, 2008.
FYI: If you are a New York State School, and are totally lost, the then
you may also want to look at your school's 2005 Building
Condition Survey, that was submitted to Facilities
Planning. See question #40 Site Storm Drainage for
some basic information. The engineer doing the survey may have made some observations
about your storm sewers.
Links:
State Education
Department Facilities Planning Newsletter about free software
for MS4
DEC
Summary of MS4 Permits
School
Decision Tree on MS4's
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