Executive Summary

1.0           Executive Summary

1.1            Introduction

Over the seven-week duration of this Interactive Qualifying Project (IQP), we, three undergraduate junior level Worcester Polytechnic Institute (WPI) students, worked to improve communication between the central Massachusetts Department of Environmental Protection (MassDEP) and 13 municipalities within the Central Massachusetts region as well as improve the overall understanding of the MS4 stormwater permit to promote municipality compliance.  These 13 municipalities, Auburn, Charlton, Dudley, Holden, Leicester, Millbury, Oxford, Paxton, Shrewsbury, Spencer, Sturbridge, Webster, and West Boylston applied jointly for and were awarded a Community Innovation Challenge (CIC) Grant.  Together, these municipalities make up the Central Massachusetts Regional Stormwater Coalition (CMRSC). The goal of this stormwater coalition is to develop communication within the 13 communities and work together to comply with both the current 2003 and the draft 2010 MS4 permit through education and training to yield a more cost effective and efficient means of stormwater management.  The EPA requires all of these municipalities to be regulated as Phase II communities.  This means that the populations of these towns are less than 100,000, and that their MS4 system is classified as ‘small’ (EPA, 2012).

In order to promote communication between the MassDEP and the 13 municipalities, a previous IQP selected an online database, which allows municipalities to directly input the relevant information from their annual reports regarding the six minimum control measures. The goal of our IQP was to improve this existing Zoho database and begin the MS4 system mapping process in order to allow the municipalities to make progress towards full compliance with the draft MS4 permit as well as create a better sense of communication between the municipalities and the MassDEP.

Ever since mankind has organized into towns and villages, access to clean water has been a primary objective for survival.  William Andreen, professor of law at the University Of Alabama School Of Law, notes in his paper concerning the effectiveness of the Clean Water Act that the early stages of the statute dealt with single discharges.  However, it was largely ineffective dealing with non-point source pollution (Andreen, 2004).  Thusly, in 1972, Congress reorganized and greatly expanded the Federal Water Pollution Control Act. The 1972 amendments, in addition to giving the statute more bite and enforcement mechanisms than its lesser predecessor, created a regulatory framework, the National Pollutant Discharge Elimination System (NPDES), for limiting pollutant discharges into America’s surface waters from point sources. The 1972 amendments also recognized the inherent problem with nonpoint source pollution (EPA, 2012).  In order for an individual, company or operator to legally discharge into a regulated body of water, they must apply to the Environmental Protection Agency (EPA) or state regulatory agency, for a NPDES permit.

Since its introduction in 1972, the EPA had begun to realize the ineffectiveness of the NPDES permit.  Consequently, in 2003 the EPA enacted a stormwater specific regulatory permit system. After seven years of the permit’s existence, the EPA began drafting a 2010 Municipal Separate Storm Sewer System (MS4) permit that would detail methods of stormwater management and control.  The draft 2010 MS4 permit details the minimum control measures that the EPA proposes to require of municipalities for dealing with stormwater pollution.  These six minimum control measures are:




(1) Public Education/Outreach

(2) Public Involvement/Participation

(3) Illicit Discharge Detection and Elimination

(4) Construction Site Runoff Control

(5) Post Construction Runoff Control

(6) Pollution Prevention/Good House-Keeping (EPA, 2010).


The EPA hopes these control measures will provide guidance to and appropriate regulation of the municipalities by detailing specific parameters for stormwater control.  Even so, many municipalities fear they will struggle with MS4 compliance.  Factors such as lack of manpower, monetary resources, GIS expertise, knowledge of the permit itself and how to properly document town activities all contribute to the large potential non-compliance with the permit once it is finalized.

1.2            Methodology

To efficiently accomplish the goals set out at the inception of our IQP, which included comparing the Leica and Garmin GPS (Global Positioning System) devices, expediting the implementation of the Zoho database, and gauge municipality understanding and compliance with the MS4 permit, we executed the following steps.  During the initial stages of our IQP, we took part in multiple training courses on the logistics of the MS4 permit, GIS training, Garmin GPS unit training, a Low Impact Development (LID) workshop, and Leica Tablet GPS training which prepared our group for fieldwork and interviews with the municipalities of the CMRSC. After these training sessions, we met with Carissa Lord, Bi-state Municipal Stormwater Coordinator, and Fred Civian, MassDEP’s Stormwater Coordinator, who gave us guidance on how to efficiently manage our time and expectations for assistance with the communities.

Upon the conclusion of our trainings, we began outreaching to Shrewsbury, Dudley, Millbury and Charlton town employees to aid them in GPS mapping their outfalls and catch basins while simultaneously generating feedback on two different GPS units: the Garmin Oregon 450 and the Leica CS25 Tablet. This fieldwork gave us the opportunity to connect with the municipal employees, see firsthand the physical state of the municipality’s MS4 system and assess how well the systems complied with the draft MS4 permit.

In order to aid the municipalities in complying with the MS4 Permit and facilitating communication between the MassDEP and the 13 CIC municipalities, we interviewed and surveyed employees of the municipalities, who regularly deal with the MS4 system and permit regulation.  Our survey was intended to act as a precursor to our interview questions, though are response rate was abysmal, yielding a 15% return rate. Once we sat down with the municipalities, we broke up our interview into three distinct topics. The first topic was the municipalities’ opinion on the stringency or vagueness that the 2003 and 2010 MS4 permit draft regulations present. The conversation then shifted to how each municipality complied or did not comply with the six minimum control measures in both the 2003 and 2010 MS4 permit. Finally we discussed the Zoho database developed by MassDEP and the previous IQP team which aimed to give the municipalities a structured application and means of reporting their town’s compliance with the six MS4 permit control measures.  After we gathered the necessary information, we used it to improve the functionality of the Zoho database and provide the MassDEP with information to help them understand what compliance issues the 13 included municipalities faced.

1.3            Findings/Discussion

Over the course of this project, we came to several conclusions pertaining to the pros and cons of the Garmin and Leica GPS units, municipality opinion on the current and draft MS4 permits, and the potential feasibility of the Zoho database.

1.3.1       Garmin v. Leica

As we conducted GPS mapping with Shrewsbury, Dudley, Millbury, and Charlton, we were able to generate useful feedback on the two types of GPS mapping units, the Garmin Oregon 450 unit and the Leica CS25 Tablet unit. We found when using the Garmin unit that the triangulation to fix our location took roughly one minute with an error parameter of 2-5 meters. The mapped point had to be named manually which our group found to be tedious.  For future users attempting to locate the mapped outfalls, we concluded that finding them would be difficult without previous knowledge of the town’s roadways due to the non-uniformity of the reference labeling of the mapped points.  Another drawback of the Garmin unit is its lack of post processing capabilities.  Post processing refers to the steps taken, after waypoints are created, to superimpose them onto an orthographic map.  In order to superimpose the mapped points on to an orthographic map, we had to use Garmin’s Basecamp software.

Conversely, the Leica unit was more accurate, but more time consuming than the Garmin. In order to gather a fixed location, the tablet had to boot up, connect to AT&T wireless data internet and establish a Bluetooth connection to the Leica GG02 GPS antenna.  This entire process took roughly 20 minutes. It took about 10 more minutes to obtain an initial fixed location. With the unit fully operational, the catch basin and outfall forms were generated by PeopleGIS, a third party company that developed forms which are to be filled out and submitted at every mapped catch basin or outfall while in the field.  These forms contain information pertaining to the MS4 permit regarding catch basin and outfall inspection. We found the precision of the Leica unit to be within 2-4 centimeters of accuracy and that once submitted, the forms contained all of the necessary post processing information.  These onsite forms eliminated the need for additional post processing after field work was completed, unlike the Garmin where post processing was necessary.

1.3.2       MS4 Permit Compliance

Our interviews with the municipalities provided us with a great deal of information about potential compliance issues as well as what municipalities may need in order to be in full compliance when the final permit is issued. One of the areas that the municipality employees we sat down with focused on in the MS4 permit was Public Education. They believed that the EPA is asking too much of them in individually developing and implementing a Public Education program. They suggested that either the MassDEP or EPA develop a model Public Education program that the municipalities could just implement and distribute rather than allocating scarce municipal resources to developing an education program. Also, the municipality employees believed that the stormwater educational outreach program would draw more attention if it were developed by a respected source like the EPA rather than individual municipalities.

1.3.3       Post-Construction Stormwater Management

Another control measure the municipalities had a potential issue with was Post-Construction Stormwater Management.  The municipalities did not have much trouble in developing a regulatory bylaw, but they struggled with implementation and guidance from the EPA.  We noticed that certain municipalities found it very difficult to obtain any form of EPA follow up on stormwater management issues.  We also realized that most municipalities felt that post construction best management practices (BMP), methods of stormwater management that mitigate the adverse effects of construction development and redevelopment through their implementation are not difficult to design, but the cost of implementation often discourages effort to put them into use (MRSC, 2012).

1.3.4       Funding

Municipalities also noted the difficulty in maintaining their MS4 system up to the permit’s requirements.  While keeping a perfectly maintained MS4 system would be beneficial to the environment, it is much too costly to keep up such a high level of maintenance on a municipalities’ small budget. One example was the annual cleaning of catch basins.  While the issue is important, the increase of urban development and roadways makes it difficult for municipalities to clean the hundreds of new catch basins along with the existing ones with the limited resources they have. In addition, the new 2010 draft permit requirements are much stricter than the previous permit, adding burden to the already strapped financial budget and workload of municipal employees.

1.3.5       Statewide Illicit Discharge Detection and Elimination Program

Finally, we observed that the municipalities would benefit greatly if the EPA created a statewide Illicit Discharge Detection and Elimination program template, which would allow the municipalities to know exactly what is necessary to have in their IDDE program.  This would promote widespread compliance and understanding of the requirements. The municipalities found that some of the requirements of the IDDE program, outlined in the MS4 permit, were so vague as to render them useless. For example, the draft permit requires MS4 operators to conduct wet weather sampling.  However, it is not clear when the samples should be taken, during first flush of the storm, within three hours, within twenty four hours, etc.  Unclear requirements such as this would be resolved if EPA provided MS4 operators with an IDDE program template.

1.3.6       Utility of the Zoho Database

The implementation of the Zoho database will allow the participating municipalities to gauge where they lie in terms of MS4 compliance and promote communication with the MassDEP.  When conversing with municipalities on their thoughts of the Zoho database and its control measure specific applications, they felt as though its greatest use was the ability to provide the town with a structured way of filling out their annual reports throughout the year as information is collected. Bradford Stone, town engineer of Shrewsbury, helped revise the Construction, Post Construction and Good Housekeeping forms on the Zoho database in order for site specific information to be uploaded into it. The thoughts and critiques of the Zoho database allowed us conclude that the database could be an effective tool for the municipalities to input information pertaining to their annual reports.  However, municipalities do not want the implementation of the Zoho database to add work to their yearly efforts.  Therefore it is important for the DEP and future IQP’s to create a simple means of exporting the municipal data directly into an annual report format so that the municipal employees do not have to complete an annual report with the same information residing in the database.

1.4            Recommendations/Conclusions

The results of data collection gave us invaluable information pertaining to the municipalities’ MS4 permit understanding and compliance techniques.  We relayed this information back to the MassDEP in order to improve its role in assisting the Phase II municipalities and further development of the Zoho database. We have the following recommendations, which we believe will improve municipal compliance with the anticipated revised MS4 permit.

  • EPA to implement the use of the Leica tablet in conducting outfall and catch basin mapping as the standard for mapping for the MS4 permit
  • MassDEP to facilitate the development of a workshop to train municipalities on the use of the Leica tablet and how to fill out the PeopleGIS catch basin and outfall forms
  • EPA or MassDEP to develop a public education program on stormwater that municipalities can implement to raise awareness in their communities as opposed to the individual municipalities developing their own program
  • EPA or MassDEP to develop an IDDE program template that clearly states what they expect in terms of full compliance for the municipalities to implement and cater specifically to their municipal needs
  • Municipalities want more frequent communication with and guidance from the EPA and MassDEP on issues that arise in post-construction regulations
  • EPA needs to reassess the feasibility of municipalitiy compliance with good housekeeping permit requirements
  • Future IQP groups should continue to improve the Zoho database so it can be effectively utilized by municipalities and export relevant data to municipal annual reports

With stormwater posing so many significant repercussions to our communities, the lack of awareness of the issue is staggering.  During the course of this project we were able to gather information that led to recommendations that could help bridge communication between the EPA, MassDEP, and municipalities. This communication will strengthen the efforts of the municipalities to comply with the MS4 permit and raise the standards in stormwater management. We believe that the implementation of the Zoho database, with municipal feedback taken into account will promote a structured and progressive way of filling out the NPDES stormwater annual report while also encouraging oversight from the MassDEP and EPA.