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Draft MS4 permit and EPA information request raise compliance concerns for municipalities
Summary
Regional staff warned members the Connecticut DEEP released a draft MS4 permit with significant changes and that EPA has requested information from at least one municipality; the region will prepare joint comments and asked municipalities to review the draft and report red flags.
Regional staff notified committee members that the Connecticut Department of Energy and Environmental Protection (DEEP) released a draft Municipal Separate Storm Sewer System (MS4) permit that contains substantial changes and will be open for comment.
Staff asked municipalities to review the draft permit and to provide any compliance concerns or red flags for incorporation into regional comments; DEEP's deadline for comments was noted as in the weeks following the meeting. Staff said the DEEP draft appeared detailed and user-oriented, which staff interpreted as a sign the state may intend more stringent enforcement.
Staff also reported that the U.S. Environmental Protection Agency had sent a request for information to at least one municipality in the region related to MS4 compliance; that municipality (identified in the meeting as Beacon Falls) did not receive a fine but underwent a year-and-a-half process to reach compliance. Staff warned that enforcement attention is increasing and that noncompliant or incomplete annual reports could draw state or federal scrutiny.
Regional staff said they will compile municipal input and submit regional comments on the draft DEEP MS4 permit. They encouraged municipal stormwater and public works staff to review the draft and provide specific compliance challenges, especially those that would be difficult to implement under the proposed new permit language.
