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Engineer warns of additional MS4 stormwater obligations; assistant manager calls them 'unfunded mandates'
Summary
Pennoni engineer briefed the board on MS4 permit status, PRP sediment-reduction targets and a future Volume Management Plan; Assistant Manager David Thompson said the requirements place a financial burden on the township.
The Douglass Township Board received an update June 16 on the status of the municipal separate storm sewer system (MS4) permit and upcoming requirements from Pennsylvania Department of Environmental Protection.
Greg Kerr of Pennoni & Associates told the board that the township's MS4 permit (effective March 16, 2018) is entering its seventh year and that DEP has administratively extended the general permit through March 15, 2026. Under the current permit the township must complete a Pollution Reduction Plan (PRP) to achieve a 10% reduction in sediment for Green Lane Reservoir and Swamp Creek; the township submitted alternate PRP projects to DEP for review.
Kerr also outlined a forthcoming Volume Management Plan (VMP) requirement tied to DEP's Maximum Extent Practicable (MEP) calculator. The VMP will have to be submitted for DEP review by Sept. 20, 2028 and completed by Sept. 30, 2031 unless DEP authorizes another schedule.
Assistant Manager David Thompson told the board the new obligations are a fiscal concern. He told the board the MS4 items are "unfunded mandates placing the financial burden on the Township," and cautioned that the township will need to plan inspections, BMP maintenance and potential capital work to meet inspection schedules and PRP obligations.
Pennoni will continue coordinating with township staff and PA DEP on alternate PRP project sites; township staff said stormwater information and BMP inspections schedules are available on the township website.
Ending: The board accepted the engineer's report and directed continued coordination with Pennoni and DEP as the township prepares to meet permit deadlines and planning obligations.
