Complying with MS4 permit standards can be difficult for municipalities to manage, especially smaller Phase II municipalities. Some of these communities may lack the proper funding necessary to comply with the permit within the given timeframe, and many worry that the USEPA and MassDEP would force them to exhaust their funds on complying with the MS4 permit. In reality, MassDEP wants to help municipalities manage stormwater more efficiently and economically. Even though MassDEP co-signed the MS4 permit and has enforcement power, their primary goals are to protect the environment and help municipalities across
Massachusetts to do so. Therefore, MassDEP helps to communicate MS4 permit requirements to municipalities in order to mitigate the effects of stormwater runoff. Municipalities also face challenges with sufficient manpower. Because of this, many municipalities reach out to third parties in order to assist with compliance with the MS4 permit. However, additional manpower
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could require additional funding as well. As a result, a group of Central Massachusetts
municipalities applied for federal grant funding for meeting the requirements of the MS4 permit.
2.3.1 The Community Innovation Challenge Grant
In 2012, Massachusetts Governor Deval Patrick’s administration developed the CIC grant program to incentivize municipal governments to improve local community services. In just two years, the program invested $6.25 million across 49 unique projects involving 197 municipalities in the Commonwealth of Massachusetts (Commonwealth of Massachusetts, 2013b).
Some of the projects funded by this grant have included local educational projects, data management health projects, and environmental projects which include the Regionalization of Municipal Stormwater and Policy Development Project (Regionalization Project)
(Commonwealth of Massachusetts, 2013a). The Regionalization Project encompasses 13 municipalities across Central Massachusetts that comprise the Central Massachusetts Regional Stormwater Coalition2 (CMRSWC). The CMRSWC is a group of municipalities striving to control stormwater runoff more cost effectively and efficiently through a collaborative effort (Central Massachusetts Regional Stormwater Coalition [CMRSWC], 2012b). So far, the project has received at least $310,000 since 2012, and the recipients have used the money to fund projects such as developing a training DVD/CD for town personnel and volunteers which
summarizes the MS4 permit, creating a stormwater Best Management Practices (BMP) Toolbox, and developing an online database for regional stormwater management (CMRSWC, 2012a). As of November 2012, 17 new municipalities joined the CMRSWC3, which adds to the
collaborative effort of the battle against stormwater runoff in Central Massachusetts.
Although the grant has benefitted the municipalities of the CMRSWC by providing funding to collaboratively meet the MS4 permit requirements, these municipalities still require more funding in order to meet the requirements of the greatly expanded, 2013 draft MS4 permit. In
2 The 13 municipalities consist of Auburn, Charlton, Dudley, Holden, Leicester, Millbury, Oxford, Paxton, Shrewsbury, Spencer, Sturbridge, Webster, and West Boylston.
3 These new municipalities consist of Boylston, Grafton, Hardwick, Hopkinton, Monson, Northbridge,
Northborough, North Brookfield, Palmer, Rutland, Southbridge, Sterling, Upton, Uxbridge, Ware, Westborough, and Wilbraham.
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2013, the CMRSWC applied for $200,000 from the CIC grant, but only received $115,000 for the 2013 fiscal year. Because the funding was less than the CMRSWC’s expectations, each of the municipalities participating in the CMRSWC had to provide an additional $2,833 to compensate for the funding not received by the grant (Tata & Howard, 2013c).
Since the grant money is limited, the municipalities will need to make sure that they are spending it on projects with the greatest potential to increase current MS4 permit compliance. Although MassDEP does not provide the funding for the grant or receive any of its funds, MassDEP employees often attend CMRSWC meetings.
2.3.2 MassDEP’s Role
MassDEP acts as an educational liaison for Massachusetts municipalities by providing
professional advice on meeting the requirements of the MS4 permit and stormwater management BMPs. As stated previously, MassDEP has educational materials online such as its stormwater BMP handbook. MassDEP employees are also helping municipalities prepare for the 2013 MS4 draft permit by communicating the new requirements to municipalities. In the past few years, MassDEP has worked with the CMRSWC in order to collaboratively manage stormwater runoff and assist municipalities with compliance with the MS4 permit requirements. Although
stormwater management information is available online, MassDEP still provides professional advice to municipalities in order to educate them on stormwater management programs, the MS4 permit requirements, stormwater BMPs, and other stormwater topics in order to prevent
stormwater pollution (Massachusetts Department of Environmental Protection, 2013d). Besides MassDEP, environmental consulting firms also provide professional advice to municipalities.
2.3.3 Stormwater Engineering Consulting Firms
Meeting the requirements of the MS4 permit not only requires sufficient time and funding, but also enough manpower. Some municipalities seek external assistance from groups that are knowledgeable about stormwater management and the MS4 permit. One of these groups is a consulting firm. Consulting firms are groups of experts in a certain field who provide
professional advice to clients for a fee (Darnay & Magee, 2007).
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One stormwater engineering consulting firm that deals with stormwater management specifically for the CMRSWC is Tata and Howard. Tata and Howard is a stormwater engineering consulting firm specializing in water, wastewater, stormwater, and hazardous wastes (Tata and Howard, 2013a). Tata and Howard have been collaboratively working with municipalities in the CMRSWC by providing professional advice and assistance on creating stormwater by-laws, innovative technologies for IDDE, development of stormwater programs, and the creation of annual reports since 2011 (Tata and Howard, 2013b). Another consulting firm working with the CMRSWC is Verdant Water, a Professional Limited Liability Company (PLLC) owned by Aubrey Strause, a Professional Engineer who formerly worked with Tata and Howard. Verdant Water not only aids the CMRSWC, but also aids other organizations related to water
management as well, such as the Seacoast (New Hampshire) Stormwater Coalition and the New England Water Environment Association (NEWEA) (Verdant Water, 2013). Collaboratively, these professional experts and municipal employees work towards compliance with the MS4 permit.
2.3.4 Volunteer Groups
Through the effort of volunteer groups, municipalities can not only fulfill the Public Involvement/Participation control measure of the MS4 permit, but also receive external assistance for compliance with the permit. Since the MS4 permit requires public involvement with the review and implementation of their Stormwater Management Program (SWMP), municipalities can utilize assistance from the general public and volunteer groups to achieve compliance with additional control measures. Such activities may include outfall mapping, stream cleaning, or public education campaigns. For instance, the towns of Leicester, Grafton, and Charlton all utilized the assistance of local residents and Boy Scout groups during a cleanup event on Earth Day, April of 2013 (Tata and Howard, 2013c; Szczurko, 2013; Girard, 2013).
While this satisfies the Public Involvement/Participation control measure of the MS4, it is also a demonstration of Pollution Prevention/Good Housekeeping. Some municipalities have reached out to volunteers to stencil catch basins, which notify the general public that dumping into the basins is illegal and introduces pollutants into the environment. The town of Oxford has let volunteers from the public stencil catch basins, and one boy scout in Westborough even organized a project to stencil 150 catch basins for his Eagle Scout project (Zeneski, 2013;