Mass DEP: Cost Analysis of the 2014 MS4 Permit
Eric Correia, a junior majoring in Mechanical Engineering at Worcester Polytechnic Institute (WPI). Over the past summer, Eric has worked as a machine operator at Prattville Machine and Tool Co. in Peabody, MA.
Cameron Peterson, a junior majoring in Robotics and Mechanical Engineering. Cameron recently completed a course where he managed a team of fifteen people. He also is a second year Residential Advisor on WPI’s Campus.
Michael Giroux, a junior majoring in Biochemistry with a minor in Bioinformatics. During this summer, Michael has worked at WPI’s Bioengineering center at Gateway Park, developing new components in the field of Biotechnology.
The Department of Environmental Protection is the Massachusetts state agency responsible for ensuring clean air and water, the safe management of toxics and hazards, the recycling of solid and hazardous wastes, the timely cleanup of hazardous waste sites and spills, and the preservation of wetlands and coastal resources. Within this organization we will be working closely with Fredrick Civian, statewide Stormwater coordinator and Andrea Briggs, deputy regional director of the Mass DEP
Goal and Objectives
In collaboration with the Massachusetts Department of Environmental Protection and the Central Massachusetts Regional Stormwater Coalition, we sought to provide the towns of Millbury, Holden, and Southbridge, Massachusetts with a comprehensive analysis of their cost of compliance with the new 2014 MS4 permit. In order to achieve this goal, we:
1) Became educated on the details of the 2003 MS4 Permit and 2014 MS4 Permit
2) Assessed what Holden, Millbury, and Southbridge, Massachusetts have done to meet the requirements of the 2003 MS4 Permit
3) Identified Holden, Millbury, and Southbridge’s total current expenditures for stormwater management
4) Identified what changes each of our subject towns will have to make in order to comply with the requirements of the 2014 MS4 Permit
5) Provided a detailed analysis of the complete costs for each town to comply with the requirements of the 2014 MS4 Permit
6) Created an informational video to explain the costs of implementing the 2014 MS4 Permit
Water Pollution affects an enormous number of water bodies in the United States. “In 2006, there were over 15,000 beach closings or swimming advisories issued due to bacterial levels exceeding health and safety standards” (Council, 2008). Much of this pollution is due to stormwater runoff. Stormwater runoff occurs when water becomes displaced by weather and flows over impervious surfaces, such as roads and roofs. When stormwater flows over these surfaces, it often collects pollutants such as oils, nutrients, ammonia, sediments, and heavy metals (EPA, 2012). These pollutants can have environmental, aesthetic, and economic ramifications on surface bodies of water. In order to combat stormwater runoff, the United States Environmental Protection Agency (USEPA) has created a system to move stormwater runoff into nearby bodies of water through what is known as Municipal Separate Storm Sewer Systems (MS4). Unfortunately, while these systems are useful for draining stormwater runoff, they are also very effective at directing pollutants into water bodies.
Before 1972, stormwater runoff and sewage drained through the same pipe, which led to frequent overflows (Robert B. Stegmaier, 1942). These overflows led to the pollution of topsoil, and the need for a better solution became apparent. This situation led to the creation of the Clean Water Act (CWA) in 1972 (Andreen, 2003a). In 1990, the USEPA first released the MS4 permit as part of the CWA. The MS4 permit allows municipalities to regulate the discharge of pollutants into stormwater drains. The MS4 permit defines six minimum control measures to reduce pollution caused by stormwater runoff. These control measures are:
1) Public Education
2) Public Involvement and Participation
3) Illicit Discharge Detection and Elimination (IDDE)
4) Construction Site Runoff Control
5) Post-Construction Runoff Control
6) Pollution Prevention and Good Housekeeping
Municipalities fulfill these control measures with Best Management Practices (BMPs). These BMPs can include street sweeping, waste collection, and outfall sampling. The implementation of these BMPs cost municipalities money. Massachusetts has been regulated under the same MS4 permit since 2003. Even though this permit expired in 2008, the USEPA continued to administer it indefinitely until they were able to release a new permit. On September 30, 2014, the USEPA released the 2014 draft MS4 permit. This new draft permit is much more detailed than the 2003 permit and has much more stringent regulations. Due to this increased level of regulation, the 2014 draft MS4 permit will cost much more to implement than the 2003 MS4 permit.
The Massachusetts Department of Environmental Protection (MassDEP), in collaboration with Worcester Polytechnic Institute (WPI), developed this project in order to assess the cost of implementing the 2014 draft MS4 permit in three Massachusetts towns: Southbridge, Holden, and Millbury. Our subject towns are part of the Central Massachusetts Regional Stormwater Coalition (CMRSWC). As of the 2014 fiscal year, The CMRSWC consists of communities that share resources for stormwater management, such as water sampling kits and GPS mapping equipment. Our goal for this project was to provide a comprehensive analysis of the cost of implementing the 2014 draft MS4 permit in Southbridge, Holden, and Millbury Massachusetts.
In order to achieve our goal of providing a comprehensive analysis of the cost of implementing the 2014 draft MS4 permit in Southbridge, Holden, and Millbury Massachusetts, we utilized the following methodology.
1) Became educated on the details of the 2003 MS4 permit and 2014 MS4 permit
2) Assessed what Holden, Millbury, and Southbridge, Massachusetts have done to meet the requirements of the 2003 MS4 permit
3) Identified Holden, Millbury, and Southbridge’s total current expenditures for stormwater management
4) Identified what changes each of our subject towns will have to make in order to comply with the requirements of the 2014 MS4 permit
5) Provided a detailed analysis of the complete costs for each town to comply with the requirements of the 2014 MS4 permit
6) Created an informational video to explain the costs of implementing the 2014 MS4 permit
Throughout our project, we used various research methods such as document analysis, field work, and interviews in order to learn about the cost of compliance with the MS4 permit. By analyzing various background documents about stormwater management, including the 2003 MS4 permit and 2014 draft MS4 permit, we were able to learn about the need for stormwater management as well as the BMPs typically used to manage stormwater.
We conducted interviews with various municipal officials, including public works directors, fire chiefs, town engineers, and members of town conservation commissions. These interviews allowed us to learn about our subject towns’ stormwater programs and the costs associated with these programs. We also conducted an interview with the Department of Conservation and Recreation (DCR), which allowed us to estimate costs of BMPs, which town officials could not provide to us.
During our project, we also performed field work, which included outfall sampling using the CMRSWC kits, using dry and wet weather screening forms, and using the geographical information system (GIS) maps of our subject towns. This fieldwork allowed us to gain a more accurate understanding of the amount of labor involved with screening outfalls, which ultimately assisted us in completing our cost analysis.
After we completed our goals and objectives, we were able to provide findings and recommendations to our subject towns.
Findings and Recommendations
Finding 1: The 2014 draft MS4 permit may cost too much for the towns to effectively implement
The costs associated with stormwater management are very high, yet many towns have a limited budget for stormwater. The MS4 permit may cost too much for towns to individually implement. For implementation of the 2014 draft MS4 permit, Holden should expect to spend $258,790 annually, Millbury should expect to spend $753,173 annually, and Southbridge should expect to spend $343,008 annually.
Recommendation 1: Effective regionalization will allow towns to better implement their stormwater management programs
Due to the high cost of implementing the 2014 draft MS4 permit, we recommend that the towns regionalize. Regional organization, such as through the CMRSWC, can reduce the cost of many materials related to stormwater management.
Finding 2: Using innovative funding techniques can help the towns spend less from their general funds on stormwater management
The CMRSWC has received funding from the Community Innovation Challenge (CIC) grant. The first year of the Coalition’s existence was fully funded by the CIC grant program and the subsequent two years of grant funding supplemented the Coalitions expenditures. In FY2014, member towns paid 4,000 dollars to continue as members of the Coalition. Millbury has begun applying for other grants to support implementation of BMPs, which may save them money over time.
Recommendation 2: The towns should seek alternative sources of funding such as additional grants beyond the CIC
Due to the reduction of CMRSWC funding from the CIC, we recommend that the towns apply for other grants. These grants can include the 604(b) grant from the MassDEP. The Towns should apply to these grants as quickly as possible, and the Coalition should lobby for additional future funding from the USEPA and MassDEP.
Finding 3: Using innovative stormwater management techniques can help the towns save money and thus implement the permit more effectively
Millbury uses innovative stormwater BMPs, such as a school art contest, to fulfill the public participation control measure. These BMPs allow Millbury to implement the MS4 permit effectively and at a low cost.
Recommendation 3: The towns should strive to utilize innovative stormwater management techniques
Millbury’s use of creative BMPs has saved them money in implementing the MS4 permit. We encourage other towns to do the same, as they may be able to come up with BMPs, which are more efficient and cost-effective than their current BMPs.
Finding 4: Towns that communicate with other towns, even to a small extent, can more effectively manage and fund their stormwater management programs
A previous IQP group from WPI demonstrated that the CMRSWC towns spend less money on stormwater management than towns that work independently. This type of collaboration can also help generate more innovative BMPs, which will save the towns money.
Recommendation 4: Regionalization can help towns save money by sharing information and resources
We recommend that the towns regionalize and attempt to share information and resources. This practice will help them implement the 2014 draft MS4 permit more effectively.
Finding 5: In each of our subject towns, stormwater management information was divided amongst different departments
In many of our subject towns, there was not one person fully dedicated to stormwater management. Multiple departments in each town were responsible for implementing the stormwater management programs. As a result, we often had to request information from more than one department in each town.
Recommendation 5: Having a central source of stormwater management should allow for easier implementation of future MS4 permits and make continuous compliance easier for the towns
We recommend that the towns research the feasibility of either creating a position dedicated to managing stormwater information, or making this responsibility part of a single position. If smaller towns cannot afford to pay for this position, we recommend that multiple towns share a person dedicated to stormwater information. This practice will make it easier to implement the MS4 permit in the future.
Finding 6: The IDDE control measure will be a significant contributor to the increase in cost between the 2003 and 2014 draft MS4 permits
The 2014 draft MS4 permit has many more requirements than the 2003 MS4 permit, especially in the IDDE control measure. Much of the increase in cost between the two permits will be due to the increased stringency of the IDDE measure. The IDDE measure will also have more detailed requirements for practices such as outfall sampling with water testing kits.
Recommendation 6: The CMRSWC should have one person in charge of keeping track of and maintaining the sampling kits
When we performed sampling in the field, the sampling kits were often disorganized and had expired components, which slowed down our work. Having the kits intact will make it easier to sample, and will thus save money on sampling costs.
Finding 7: The current Asus tablet in use by the CMRSWC is slow and ineffective
When we used the tablet in the field, it was often slow to load. Town employees often complained about the delay. When we used a new smart phone, we did not see this delay. The delay caused by the old technology costs the towns in the CMRSWC money on labor costs.
Recommendation 7: The towns should use software, which can collect data offline and then upload it to an online database later, as well as a tablet, which is more up to date. This would allow the DPW workers to work more efficiently, thus saving the town labor costs
We recommend that the Coalition should purchase a new tablet, such as an Apple iPad. The labor costs that the tablet will save will pay for the cost of the tablet very quickly.
The Massachusetts Department of Environmental Protection should research the potential of providing standardized materials available to Massachusetts municipalities
Many of the control measures of the permit, such as public education and public involvement and participation, require municipalities to create similar documents. If the MassDEP could create standardized templates for these requirements, it could reduce the cost to towns, as well as give them more time to focus on eliminating pollutants.
The CMRSWC should streamline and update the digital forms. This practice would reduce the time needed to inspect outfalls, thus saving money
While we performed fieldwork in Holden, we found that the dry and wet weather forms had categories relating to pollutants, which are not regulated by the MS4 Permit. These extra categories made the forms time-consuming to fill out. Collecting this additional information causes the towns to spend increased labor costs. By updating the forms, the CMRSWC can reduce labor costs for the towns.
Recommendations for Future Research
We recommend that future project groups research the cost of implementing Total Maximum Daily Load (TMDL) requirements in towns. These requirements may generate a very large cost, which has not been researched well. We also recommend that future research groups attempt to eliminate some of the biases, which may have appeared in our research. These biases stemmed from our limited sources of budget data, and as a result, some of our cost figures may be inaccurate. We recommend other project groups eliminate this bias by finding multiple sources for town budget data.
The findings and methods that we present should help the towns understand and prepare for the financial implications of implementing the 2014 draft MS4 permit. The towns will have to work hard to comply with this new permit, but this effort will be worth protecting people and the environment from the negative effects of stormwater runoff. Among our most important recommendations, we emphasize the benefits of regionalization, the use of innovative stormwater management and funding techniques, and the centralization of stormwater management in each town. We also recommend that the towns reach out to the MassDEP for advice on implementing the 2014 draft MS4 permit. Although the task of effective stormwater management is daunting, the towns can plan to effectively manage stormwater, thus protecting human health and the environment.