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Summary
Pages 1-12

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From page 1...
... To comply with the CWA regulations, industrial and construction permittees must create and implement a stormwater pollution prevention plan, and MS4 permittees must implement a stormwater management plan. These plans document the stormwater control measures (SCMs)
From page 2...
... For example, a subset of industrial facilities must conduct "benchmark monitoring" and the results often exceed the values established by EPA or the states, but it is unclear whether these exceedances provide useful indicators of potential water quality problems. Finally, state and local stormwater programs are plagued by a lack of resources to review stormwater pollution prevention plans and conduct regular compliance inspections.
From page 3...
... Perhaps most problematic is that the requirements governing stormwater dischargers leave a great deal of discretion to the dischargers themselves in developing stormwater pollution prevention plans and self-monitoring to ensure compliance. These problems are exacerbated by the fact that the dual responsibilities of land-use planning and stormwater management within local governments are frequently decoupled.
From page 4...
... These analogs for the traditional focus on the "discharge" of "pollutants" have great potential as a federal stormwater management tool because they provide specific and measurable targets, while at the same time they focus regulators on water degradation resulting from the increased volume as well as increased pollutant loadings in stormwater runoff. Without these more easily measured parameters for evaluating the contribution of various stormwater sources, regulators will continue to struggle with enormously expensive and potentially technically impossible attempts to determine the pollutant loading from individual dischargers or will rely too heavily on unaudited and largely ineffective self-reporting, selfpolicing, and paperwork enforcement.
From page 5...
... Despite this assessment, there are a number of overarching truths that remain poorly integrated into stormwater management decision-making, although they have been robustly characterized for more than a decade and have a strong scientific basis that reaches even farther back through the history of published investigations. There is a direct relationship between land cover and the biological condition of downstream receiving waters.
From page 6...
... Focusing on only one of these factors is not an effective management strategy. For example, even without noticeably elevated pollutant concentrations in receiving waters, alterations in their hydrologic regimes are associated with impaired biological condition.
From page 7...
... Stormwater management would benefit most substantially from a well-balanced monitoring program that encompasses chemical, biological, and physical parameters from outfalls to receiving waters. Many processes connect sources of pollution to an effect observed in a downstream receiving water -- processes that can be represented in watershed models, which are the key to linking stormwater dischargers to impaired receiving waters.
From page 8...
... STORMWATER MANAGEMENT APPROACHES A fundamental component of EPA's stormwater program is the creation of stormwater pollution prevention plans that document the SCMs that will be used to prevent the permittee's stormwater discharges from degrading local waterbodies. Thus, a consideration of these measures -- their effectiveness in meeting different goals, their cost, and how they are coordinated with one another -- is central to any evaluation of the stormwater program.
From page 9...
... Individual controls on stormwater discharges are inadequate as the sole solution to stormwater in urban watersheds. SCM implementation needs to be designed as a system, integrating structural and nonstructural SCMs and incorporating watershed goals, site characteristics, development land use, construction erosion and sedimentation controls, aesthetics, monitoring, and maintenance.
From page 10...
... INNOVATIVE STORMWATER MANAGEMENT AND REGULATORY PERMITTING There are numerous innovative regulatory strategies that could be used to improve the EPA's stormwater program. The course of action most likely to check and reverse degradation of the nation's aquatic resources would be to base all stormwater and other wastewater discharge permits on watershed boundaries instead of political boundaries.
From page 11...
... Integration of the three permitting types is necessary, such that construction and industrial sites come under the jurisdiction of their associated municipalities. Federal and state NPDES permitting authorities do not presently have, and can never reasonably expect to have, sufficient personnel to inspect and enforce stormwater regulations on more than 100,000 discrete point source facilities discharging stormwater.
From page 12...
... issue guidance for MS4 permittees on methods to identify high-risk industrial facilities for program prioritization such as inspections; (3) support the compilation and collection of quality industrial stormwater effluent data and SCM effluent quality data in a national database; and (4)


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