If it’s not on paper, it didn’t happen.

A few weeks ago I attended a conference where a panel of state and federal regulators provided updates on MS4 programs in a few states. The theme appeared to be a state-of-each-state, sharing current progress and current challenges of each state’s MS4 program. Paperwork, including forms, annual reports, permits, modification documentation (“many are changing their programs without permission”)[…]


TS4 – a term sometimes used to describe a municipal separate storm sewer permit addressing urban discharges from transportation facilities. Its not a term used officially by EPA or supported by law, but it does get thrown around a lot. State DOTs are in a unique position. They have typically been seen as co-permittees with the[…]

Municipal or Urban

Some friends and I have been discussing the differences between the terms urban and municipal as they relate to stormwater (ok, its nerdy, but you knew that when you signed up). The term, municipal, has a nice familiar ring to it. And when connected to stormwater, there is an unmistakable relationship between land use associated[…]

Successful or Effective?

  Generally, success can easily be specified, prescribed, and measured. Effectiveness is more difficult to quantify – like most other good things in life. As you read these comparisons, think about how you would you measure each.   successful – doing what you said you would do effective – doing more than you had to[…]

Is the Maximum Extent Practicable?

First of all, what exactly is MEP? Getting things done to the Maximum Extent Practicable has been in our regulatory vocabulary so long I can almost say the word practicable without much stutter (this is a fairly new development for me). Eliminating pollutants to the Maximum Extent Practicable; reducing impairments to the Maximum Extent Practicable; and my personal favorite;[…]

Clean Water In, Clean Water Out

It’s not our responsibility to clean up someone else’s water. It is our responsibility to preserve the quality of waters coming to us and through us as they move across our property or activity.  If it’s clean coming in, it should be clean going out.  If it’s dirty coming in, it should not be dirtier after our[…]