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TCEQ rolls out comprehensive MS4 permit, moves reporting to NetMS4; electronic applications due Feb. 11, 2025
Summary
TCEQ issued a renewed Phase II MS4 general permit (effective Aug. 15, 2024) that adopts a comprehensive permit approach, requires electronic applications and annual reporting through NetMS4, and sets a Feb. 11, 2025 deadline for coverage where designated.
TCEQ staff detailed the 2024 renewal of the Phase II municipal separate storm sewer system (MS4) general permit, TXR-040000, and the agency's transition to electronic applications and annual reporting via EPA's NetMS4 system.
Rebecca Villalba, team leader for the stormwater team, said the renewed permit, effective Aug. 15, 2024, replaces the two-step approach with a comprehensive general permit that prescribes requirements and measurable goals for minimum control measures (MCMs). She said public education/outreach and public involvement/participation are now separated into two MCMs and that the permit removes the "urbanized area" term in favor of "urban areas with a population of at least 50,000 people."
Why it matters: The permit eliminates the requirement to submit a separate stormwater management program (SWMP) for approval, replaces it with prescriptive permit conditions, and requires electronic application submission using NetMS4. Automatic designations from the 2020 Census brought new MS4s into coverage.
Reporting and deadlines: Rebecca said existing and newly designated small MS4s must seek coverage under the general permit by Feb. 11, 2025 and submit applications electronically via NetMS4. Annual reporting will move to calendar-year reporting in the NetMS4 system; the first annual report under the 2024 general permit begins when electronic authorization is approved and is due by March 30, 2026, relative to each authorization date.
User permissions and fees: Rebecca warned that NetMS4 user permissions must meet signatory requirements in 30 Texas Administrative Code chapter 305.44(a) and that TCEQ has denied some user-permission requests that did not meet the rule's qualifications. On a fee question, staff confirmed the application fee listed in the permit is $400 and that ePay issues can result from incorrect selections.
PFAS and MSGP monitoring: Rebecca reiterated TCEQ is not proposing to add EPA's draft quarterly PFAS monitoring requirement at this time.
Discussion vs. decision: staff presented the renewal, answered multiple procedural questions and provided resources and training links; no formal votes were taken.
Ending: Rebecca said TCEQ anticipates providing training with EPA on NetMS4 annual reporting later in the year and urged MS4 operators to use available templates and contact the stormwater general permit mailbox for application-bucket moves.
