Presented at StormCon 2018, Beth Uhler, Program Manager takes us through the requirements for Pennsylvania.

1. Stormwater Pollution Reduction
Requirements in Pennsylvania
Beth Uhler
Program Manager

2. REGULATORY
PROCESS
PARTNERSHIPS
EDUCATION AND
OUTREACH
BANG FOR YOUR
BUCK
FUNDING
MECHANISMS
$$
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3. Background
National Pollutant Discharge Elimination System
(NPDES) Municipal Separate Storm Sewer System (MS4)
Program
– Phase I – Medium MS4s (100,000 – 249,999) and Large
MS4s (≥ 250,000).
– Phase II – Small MS4s
A regulated Small MS4 is any MS4 that is not already covered by
Phase I and is located within the Urbanized Area boundaries as
defined by the U.S. Census Bureau.
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4. Pennsylvania Phase II MS4s
4
Boroughs, Townships, Cities, and a Town
941 Small MS4s + 180 more
2 Large MS4s
0 Medium MS4s

5. New MS4 Permit Cycle
Pollutant Reduction
Planning required:
• Chesapeake Bay
• Surface waters considered
impaired for sediment or
nutrients, and/or
• Surface waters with a wasteload
allocation in an Environmental
Protection Agency (EPA)-
approved Total Maximum Daily
Load for sediment or nutrients.
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6. 6
1) Delineating storm sewersheds;
2) Determining existing pollutant loads;
3) Identifying proposed Best Management
Practices (BMPs);
1) Operations and maintenance of BMPs;
2) Funding mechanisms, and
3) Public participation.
Pollutant Reduction Planning
Methodology

7. Delineating Storm Sewersheds
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8. Determining Existing
Pollutant Loads
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Pollutant Chesapeake Bay
Impaired Surface
Waters
Surface Waters with a
TMDL
Sediment 10% 10%
10%- short-term
WLA- long-term
Phosphorous 5% 5%
5%- short-term
WLA- long-term
Nitrogen 3% n/a n/a

9. Identifying Proposed
Best Management Practices
• Identify potential project sites;
• Conduct a desktop review and field
investigations for site suitability;
• Propose candidate Best Management
Practices (BMPs); and
• Quantify pollutant reductions.
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10. Operations and Maintenance
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• Identify the responsible party
• Identify the required maintenance activities

11. Funding Mechanisms
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• Identify funding source for each BMP
• Identify project sponsors and partners

12. Public Participation
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• Make a copy of PRP available to the public for review
• Publish a public notice in a newspaper describing the plan
and where it may be viewed
• Accept comments for a minimum of 30 days
• Accept comments from any interested member of the public
at a public meeting or hearing.
• Record of consideration of each timely comment received
must be included in the PRP.

13. REGULATORY
PROCESS
PARTNERSHIPS
EDUCATION AND
OUTREACH
BANG FOR YOUR
BUCK
FUNDING
MECHANISMS
$$
13

14. Regulatory Process
14
September 2016 –
PA DEP guidance
workshops on the PRP
September 2017 –
PRPs and TMDL Plans
were due with the
Notice of Intent
(NOI)/application for
the 2018 permit
Municipalities did not
budget the
development of the
plans for 2017
Thus, had to
incorporate the
expense into the 2018
budget, which did not
allow work to
commence until
January 2017 at the
earliest
Allowed only ~6.5
months to prepare a
plan that utilizes
thousands/millions of
dollar in taxpayer
money
This time frame did not
allow for a
comprehensive
approach of planning,
coordination and
partnership
development for
implementation

15. 15
The local government structure in the state of Pennsylvania
contributes to the challenge of implementing quality pollutant
reduction projects:
• Municipalities are small
• Projects are not as economical as if implemented on a more
regional scale
• The PA DEP promotes partnerships across municipal boundaries
but do not suggest framework for their formation
• Municipalities are left to burden the expense of implementing
projects on their own
• Limited timeframe did not provide adequate time to develop
partnerships
Partnerships

16. Education and Outreach
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17. Bang for Your Buck
1717
BEST PROJECT TYPES USING DEP METHODOLOGY
Basin Retrofit:
• Also low cost per pounds of sediment
reduction
• Challenge: marrying projects that
have the greatest need for retrofit
with those that provide the greatest
reduction
o municipalities will prioritize cost
effective projects over water
quality benefits
Stream Restoration :
• Lowest cost per pounds of sediment
reduction
• Challenge: applicants may not
understand the level of technical
expertise needed to design and
construct these types of projects.
o projects proposed may not get
through the PA DEP permitting
process

18. Funding Mechanisms
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Grants
Low Interest
Loans
Stormwater Fees
Public-Private Partnerships

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Contact CEG for all of your stormwater management needs!
CEDARVILLE Engineering Group, LLC
159 E. High Street, Suite 500, Pottstown, PA 19464
610-705-4500
info@cedarvilleeng.com
©2018