Executive Summary


In the United States, stormwater runoff is listed as the primary source of pollution for many bodies of water (EPA, 2002). Stormwater runoff is created from rainwater or melted snow when it flows across impervious surfaces. Impervious surfaces are manmade features that water cannot permeate, such as roads and parking lots (Weng, 2008). Stormwater runoff continues to flow across impervious surfaces until it enters a storm drain, which is a part of a Municipal Separate Storm Sewer System (MS4). The stormwater runoff then flows through the MS4’s pipes until it reaches an outfall and discharges into a surface waterbody, untreated and unfiltered. As stormwater runoff flows over impervious surfaces, it picks up pollutants such as pesticides from agriculture and microbial pathogens from animal waste (EPA, 2012b). These pollutants adversely affect the health of humans, animals, and the environment. For example, microbial pathogens are the water pollutants most responsible for compromising human health worldwide (Lerner & Lerner, 2008b).

Because pollution from contaminated stormwater poses a threat to the environment, the United States Environmental Protection Agency (USEPA) has taken steps to reduce the amount of stormwater runoff entering surface waterbodies. In 1972, a series of amendments were added to the Federal Water Pollution Control Act of 1948, which became commonly known as the Clean Water Act (CWA) (Jeffrey, 2007). The 1972 amendments to the CWA created a national permitting system called the National Pollutant Discharge Elimination System (NPDES) in order to manage point source pollution. According to the CWA, point source pollution is defined as “any discernible, confined and discrete conveyance” (Clean Water Act, 1972). When stormwater drains into an MS4, it is eventually discharged from an outfall. This discharge is a “discrete conveyance,” making it a source of point-source pollution. Due to the fact that the USEPA defines this conveyance as a point-source pollutant, it is regulatable under the CWA.

Following a mandate by Congress to the USEPA to do something about stormwater pollution, the MS4 permit was created under the NPDES program. Every municipality, defined as a city or town with corporate status and a local government, with an MS4 is required to obtain an MS4 permit in order to legally discharge stormwater into surface waterbodies. In order to meet the requirements of the MS4 permit, each municipality must be in compliance with six minimum control measures. The six minimum control measures detail steps that municipalities must take in order to reduce their stormwater runoff pollution. The MS4 permit also requires that municipalities submit an annual stormwater report to the USEPA detailing the municipality’s progress towards compliance with the MS4 permit (EPA, 2003). The most recent Massachusetts version of the MS4 permit was issued in 2003. However, a new draft permit for New Hampshire (NH) was released in 2013. A permit similar to the 2013 NH MS4 draft permit is expected to be issued for Massachusetts soon (78 FR 27964).

Although the MS4 permit serves the important purpose of mitigating the impact of the stormwater pollution entering America’s surface waterbodies, complying with it can be a challenge for many municipalities. Since municipalities have limited budgets and other responsibilities to fund, procuring the funding for MS4 permit compliance can be difficult. In order to better manage stormwater runoff and improve their compliance with the MS4 permit, 30 municipalities in Central Massachusetts have joined together to form the Central Massachusetts Regional Stormwater Coalition (CMRSWC). These 30 municipalities are able to improve their own stormwater management by working with their neighbor municipalities since stormwater runoff crosses town boundaries. The CMRSWC received funding from the Massachusetts government in order to work towards better compliance with the MS4 permit (Central Massachusetts Regional Stormwater Coalition [CMRSWC], 2012b).

Due to the challenges presented to municipalities by the permit, the Massachusetts Department of Environmental Protection (MassDEP) has taken on the role of an educational liaison for Massachusetts municipalities trying to understand the MS4 permit requirements (Massachusetts Department of Environmental Protection, 2013b). Over the course of this seven-week term, we, three junior level Worcester Polytechnic Institute (WPI) students, collaborated with Central MassDEP in order to assist municipalities in the CMRSWC with MS4 compliance.

In order to achieve our goal, we worked to fulfill the following objectives: (1) learn the specifications of the 2003 MS4 permit and 2013 NH MS4 draft permit; (2) assess the degree to which the municipalities of Grafton, Leicester, Shrewsbury, and Upton meet the requirements of the 2003 MS4 permit and assess the steps they would have to take to meet the 2013 NH MS4 draft permit requirements; and (3) finally, in anticipation of a new Massachusetts MS4 permit, create a tool to assist municipalities with meeting the 2013 NH MS4 draft permit requirements.

During the initial stage of our project, we met Frederick Civian, MassDEP’s Stormwater Coordinator, and Andrea Briggs, Deputy Regional Director for the Bureau of Administrative Services for MassDEP, who gave us professional advice and the expectations of this project. Then, we conducted document analysis on the 2003 MS4 permit, the 2013 NH MS4 draft permit, and the 2013 annual reports of the four municipalities in order to understand the permits’ requirements and to gain insight on municipal compliance with both permits. While analyzing the municipalities’ annual reports, we created a spreadsheet for each municipality in order to track which requirements of the 2003 MS4 permit they were in compliance with. However, after analyzing these documents and creating the spreadsheets we were left with many questions about the permits’ wording and the state of the four municipalities’ MS4 compliance.

After we collected data  from the document analysis, our team conducted several interviews with MassDEP employees, municipal employees, and environmental consultants who helped municipalities map and file their 2013 annual reports. During the interviews, we asked which control measures these municipalities focus on the most, which control measures they have the greatest difficulty with, which municipal departments work on stormwater-related tasks, and for suggestions for a tool for assisting municipalities with meeting the requirements of the 2013 NH MS4 draft permit. By asking these questions, we learned information that helped MassDEP further understand municipalities’ challenges with the MS4 permit.

In addition to conducting interviews, our team assisted the towns of Leicester and Upton with mapping catch basins and outfalls, which the 2013 NH MS4 draft permit requires. We utilized both a Leica CS25 GPS unit and an iPad during our fieldwork. Fieldwork gave us the opportunity to observe the state of the municipalities’ MS4 systems and directly connect with the people who face the challenges of dealing with stormwater runoff. Additionally, it allowed us to gather information on the benefits and downsides of each mapping device.

Using the knowledge gained from our previous methods, we created a checklist and fact sheet of the 2013 NH MS4 draft permit requirements. The checklist and fact sheet provide an easy way for municipal employees to track their town’s compliance with the 2013 MS4 draft permit. We hope that the checklist and fact sheet will allow municipal employees to save time, while still ensuring permit compliance. As a result, municipal employees will be able to reduce their municipalities’ stormwater pollution and have additional time to meet their other important responsibilities to the town. In addition to providing us with the information necessary to create a fact sheet and checklist, our methodology also led us to several findings.

During the course of this project, we worked with the towns of Grafton, Leicester, Shrewsbury, and Upton in order to learn about the challenges municipalities face with MS4 permit compliance. We discovered several findings, the most significant of which are: (1) both permits have unclear wording; (2) many municipalities lack a dedicated source of funding, sufficient manpower, and enough time to implement the current permit and draft permit requirements; (3) the 2013 NH MS4 draft permit’s additional requirements will make municipal compliance difficult; and (4) regionalization of stormwater management provides benefits to municipalities.

Unclear Wording in the 2003 MS4 Permit and 2013 NH MS4 Draft Permit
Both the permit and draft permit have some vaguely worded requirements. For instance, we determined that the wording of the Public Education requirement of the 2003 MS4 permit caused confusion about whether education regarding the dangers of illegal dumping counted as education directed at industrial groups. Other sections of both the permit and draft permit require permittees to “consider” the implementation of certain stormwater practices or stormwater management plans. According to Newton Tedder, a Physical Scientist of the USEPA, the vague wording of the 2003 MS4 permit was intended to encourage municipalities to begin working on stormwater management without overwhelming municipal employees with requirements (N. Tedder, December 3, 2013). He informed us that sections of the 2013 NH MS4 draft permit were also written in an intentionally-vague manner in order to give municipalities flexibility with permit compliance. However, many municipal employees are confused with both permits’ vaguely-worded requirements, which leads to problems with the implementation of certain control measures.

Lack of Funding, Manpower, and Time
The biggest challenges that municipalities face with MS4 permit compliance are lack of funding, manpower, and time for implementation. For example, many municipalities struggle with the mapping requirement of the IDDE control measure. This is because municipalities may contain upwards of 350 outfalls and 5,000 catch basins. Since municipalities have limited funding, they often cannot hire the additional staff that they would need in order to map all of their stormwater structures in enough time to satisfy the requirements of the 2013 NH MS4 draft permit.

 Upton 7

Figure 1: Mapping of an outfall in Upton on November 22, 2013

As seen in Figure 1, we mapped an outfall in Upton. The process of mapping outfalls was very time consuming. First, we needed to find an outfall by looking into catch basins and determining which direction the stormwater was flowing. We also tried looking for pipes in the catch basins to determine the direction in which the outfall was located. After determining the approximate direction of the outfall’s location, we walked in that direction and searched for the outfall. In Upton, our team worked with Aubrey Strause, a professional engineer and the owner of Verdant Water, over the course of roughly six hours. During that time, we mapped three outfalls and approximately 30 catch basins. Based on this speed, our team estimates that if a municipality has 5,000 catch basins, municipal employees or environmental consultants would need to work for approximately 1,000 hours in order to map all of the municipality’s catch basins.

Table 1: A comparative table of municipal data

Grafton Leicester Shrewsbury Upton
Population at the 2010 census 17,765 10,970 35,608 7,542
Area (sq. miles) 23.33 24.64 21.73 21.8
Type Semi-rural Rural Suburban Suburban
Department in charge of stormwater – DPW- Conservation Commission – Highway Department- Sewer Department – Engineering Department- Highway Department – DPW- Conservation Commission
Number of people available to work on stormwater management 10 DPW employees (1 engineer and 1 worker at a time) 2 employees from Highway Department (1 superintendent, 1 worker) 3 employees from Engineering Department 5 DPW employees including 1 supervisor and 4 workers
Number of Outfalls ~ 350 89 ~ 520 72
Number of Catch Basins ~ 2,500 ~ 2,500 ~ 5,600 Unknown
Area of Impervious Surfaces (sq. miles) 2.48 (10.64%) 1.41 (5.73%) 4.02 (18.48%) 1.42 (6.5%)


Additional Requirements of the 2013 NH MS4 Draft Permit
As previously stated, the 2013 NH MS4 draft permit requires municipalities to map additional stormwater structures, such as catch basins. We anticipate that many municipalities will have difficulty fulfilling this requirement as a result of the previous challenges discussed with funding, manpower, and time. Additional requirements within the IDDE section of the permit mandates municipalities to complete water quality sampling of outfalls during both dry and wet weather. Water quality sampling, especially during wet weather, requires multiple individuals to be mobilized simultaneously, and as mentioned above, many municipalities have upwards of 350 outfalls (B. Stone, November 12, 2013).

Additionally, we anticipate that municipalities will face challenges with the Public Education control measure of the 2013 NH  MS4 draft permit. Section of the 2013 NH MS4 draft permit requires municipalities to send at least two messages to each of four target audiences during the permit term of five years. Additionally, municipalities must space the messages sent to each audience by one year. Since the 2003 MS4 permit requires municipalities only to address residential and industrial groups, this control measure has gained many additional requirements (78 FR 27964; EPA, 2003).

Utility of Regionalization
Municipalities that work together in order to meet the requirements of both the 2003 MS4 permit and 2013 NH MS4 draft permit can better overcome the various challenges that the permits present. For instance, the CMRSWC has proved to benefit the four towns we worked with and has also benefitted the other 26 member communities as we saw firsthand during the CMRSWC’s meetings and workshops. The CMRSWC has annual training workshops, and on November 20 our team attended this year’s training workshop. During the workshop, municipal employees were taught how to use the CMRSWC’s Leica GPS unit in order to perform mapping. Municipal employees were also taught how to perform water quality testing. Since the skill sets of municipal employees attending to stormwater tasks in each municipality is varied, this training provides a way for municipal employees to learn about methods to meet the requirements of the MS4 permit that may be unfamiliar to them. Overall, the use of shared resources and the collaborative effort towards meeting the requirements of both the 2003 MS4 permit and 2013 NH MS4 draft permit has proved to be a valuable asset to the 30 participating Central Massachusetts municipalities in the CMRSWC.

After accomplishing the tasks set forth in our methodology and discovering the findings partially detailed in the section above, we developed a set of recommendations for the USEPA, MassDEP, future researchers, and Central Massachusetts municipalities. We believe that through these recommendations, municipalities will be better able to mitigate the impacts of stormwater runoff, leading to cleaner, more usable surface waterbodies. Additionally, we believe that these recommendations will allow municipal employees to save time meeting the MS4 permit requirements and allow more time to focus on their other responsibilities. Some of our key recommendations are detailed below. These recommendations are those that we believe will make the most significant impact on stormwater management and MS4 compliance across Central Massachusetts.

Future Researchers: Research the Logistics of Creating a Stormwater Utility
We recommend that future researchers research the logistics of creating a stormwater utility, which is a utility established in order to provide a consistent source of funding for stormwater management. Creating a stormwater utility would provide a municipality with a dedicated and consistent source of funding. However, the process of creating a stormwater utility is complicated and can be difficult to accomplish due to political reasons. The cost of the stormwater utility falls on a municipality’s residents, and no politician wants to propose a new tax. Due to the difficulties in creating a stormwater utility, we also recommend that future researchers research alternate dedicated and consistent sources of funding for stormwater management.

USEPA: Encourage Regionalization of Stormwater Management
Through our project, we have witnessed the enormous benefits that regionalization of stormwater management can have to member municipalities. It allows them to share resources that each municipality might not own, such as GPS units or water quality sampling kits. It also allows municipal employees to receive training that they would not otherwise have access to, such as training on how to use the aforementioned GPS units and water quality sampling kits and presentations on IDDE. Additionally, regionalization allows municipal employees to build relationships with employees from other municipalities, leading to the potential of future collaboration.

Despite the benefits that result from regionalization, there are also drawbacks. It is very difficult to organize a large group, especially when its members come from as vastly different backgrounds as the members of the CMRSWC. Because of this, municipalities considering regionalization will need dedicated leadership in order to make the group work together efficiently. Due to the variation in background of the municipal employees, training cannot be tailored to one specific audience. Some municipal employees from engineering department may have extensive knowledge on topics such as water quality sampling while other department such as DPW may have none. As a result, training on water quality sampling can be immensely beneficial to some members from DPW, but a waste of time for others from engineering department.

Municipalities that have sufficient resources, such as staff and stormwater knowledge, may not benefit from regionalization. However, through our research we learned that even municipalities with significant stormwater knowledge and staff still face challenges with meeting the MS4 permit requirements. Therefore, for many municipalities, regionalization will provide a chance at compliance with the MS4 permit that they would not otherwise have. If more municipalities facing challenges with MS4 permit compliance follow the CMRSWC’s example, they will also experience benefits with meeting the requirements of the MS4 permit.

Municipalities and MassDEP: Pilot the 2013 NH MS4 Draft Permit Checklist and Fact Sheet
Our team recommends that MassDEP test the utility of the checklist and fact sheet that our team created for tracking compliance with the 2013 NH MS4 draft permit. Since the 2013 NH MS4 draft permit is 60 pages long, it is time consuming for people to complete reading the permit and it is difficult to remember every requirement. Municipalities can use the checklist as a tool to quickly track what they have done and not done. When they are looking for an explanation of a certain requirement on the checklist, then they can use fact sheet to clarify the requirement. The fact sheet condensed the requirements of 2013 NH MS4 draft permit into approximately 20 pages. If MassDEP finds that the checklist and fact sheet will benefit municipalities, we highly recommend that the 30 municipalities of the CMRSWC pilot the checklist and give suggestions about further adjustments. If the municipalities also find the checklist and fact sheet helpful, we recommend that MassDEP make the checklist and fact sheet available to all Massachusetts municipalities.

Although municipalities in Massachusetts still face challenges meeting the requirements of the 2003 MS4 permit and 2013 NH MS4 draft permit, the checklist and fact sheet we created in this project will assist municipalities with compliance with the upcoming MS4 permit. By working collaboratively with MassDEP and four Central Massachusetts municipalities, we saw firsthand how municipalities have difficulty meeting the permit’s requirements for a variety of reasons. However, we saw that municipalities are very enthusiastic about reducing the impacts of stormwater runoff. We hope that the tools we created and data that we uncovered will allow the four municipalities we worked with to make the progress they desire towards complying with the 2013 NH MS4 draft permit. We also hope that the additional 26 municipalities of the CMRSWC can benefit from our research and deliverables. Further, we hope that our recommendations will extend to other municipalities in Massachusetts and other states in order to reduce stormwater runoff and lead to cleaner surface waterbodies across the country.