Executive Summary

Stormwater runoff is the leading cause of pollution in most water bodies across the United States (U.S. Enviornmental Protection Agency, 2013).  Runoff is generated when precipitation from a storm flows over an impervious surface and does not permeate into the surrounding area.  Urbanization has caused impervious surface coverage to increase every year.  A 2012 study by the United States Department of Agriculture (USDA) Forest Service showed that tree cover in 20 different cities decreased, on average, by 0.27% per year while impervious surface coverage has increased by 0.31% per year (Nowak & Greenfield, Tree and Impervious Cover Change in US Cities, 2012).  According to the Massachusetts Watershed Coalition, one acre of pavement can generate as much as one million gallons of runoff per year (Massachusetts Watershed Coalition, 2014).

As runoff travels over impervious surfaces, it can gather up the pollutants that are on the surfaces.  Common pollutants that stormwater picks up include dirt, fertilizer, gasoline, detergents, and oil.  After traveling over the impervious surface, the runoff is gathered in a catch basin and then discharged by an outfall into a nearby water body.  This system is called a Municipal Separate Storm Sewer System, or MS4.  A simplified version of this system can be seen in Figure 1.  As seen in the figure, runoff does not go to a treatment facility before it is discharged; this means that all pollutants the runoff picks up as it travels to the catch basin are carried to nearby water bodies.

Prior to the 1970s, stormwater was not regulated at all.  It was not until 1987 that the United States Congress mandated that the United States Environmental Protection Agency (USEPA) require that MS4s obtain a National Pollution Discharge Elimination System (NPDES) permit.  The first wave of permits went out in 1990 and required cities with populations over 100,000 to comply with the MS4 permit.  In 1999 the second wave of permits went out to all urbanized areas.  These MS4 permits required cities and towns to comply with six minimum control measures in order to reduce stormwater runoff pollution.  These six control measures are:

  1. Public education and outreach
  2. Public involvement and participation
  3. Illicit discharge detection elimination
  4. Construction site stormwater runoff control
  5. Post construction stormwater management in new development and redevelopment
  6. Pollution prevention and good housekeeping in municipal operations

Each measure specifies what towns must do in order to comply with the permit.  For example, for the illicit discharge detection and elimination control measure, towns must have their stormwater infrastructure mapped using a global positioning system (GPS).  While each measure has its own specifications, they also have their own costs.  Stormwater runoff is the largest contributor to water pollution in the country, but proper stormwater management can be very costly to towns.

According to Frederick Civian, the stormwater coordinator for the Massachusetts Department of Environmental Protection, municipalities anticipate the USEPA issuing a new Massachusetts MS4 permit within the next year. This permit is expected to have much more detailed tasks for municipalities to complete. For example, municipalities must complete water sampling for all outfalls. This task is new and is expected to be difficult to complete due to the scope of the task.  The task states that municipalities have five years to test all of their outfalls for pollutants such as chlorine, ammonium, and surfactants.  Some tests such as a bacterial test must be sent to a lab.  The difficulty comes in when towns do not have a person that has the expertise to take the outfall samples.

One way towns can cut costs is if they pool their resources together.  This can be accomplished by joining together in a group or coalition.  For our project we worked with the Central Massachusetts Regional Stormwater Coalition (CMRSWC) and analyzed what costs could be shared among CMRSWC members.

In order to comply with this new upcoming permit, towns will have to increase their spending towards stormwater related tasks.  In the next section we will discuss our project’s overall goal and the objectives we set to complete our goal.


The goal of our project was to evaluate the total cost of implementing the upcoming MS4 permit requirements for four central Massachusetts municipalities. In order to successfully complete our goal, we worked to accomplish the following five objectives:

1. Identify the costs that Upton, Oxford, Westborough, and Webster (the case study towns) currently spend in their respective stormwater programs to comply with the 2003 MS4 permit.

2. Identify the new costs towns will need to implement to comply with the upcoming Massachusetts permit.

3. Evaluate the costs we have identified by control measure

4. Identify benefits the CMRSWC offers to towns

5. Compare the costs between implementing the permit individually versus implementing the permit with the help of the CMRSWC

Through our background research and several interviews with key stakeholders we determined how to create our cost analysis for each of the towns. We conducted interviews with town engineers, consultant companies, directors of the department of public works, and relevant personal from each of the case study towns to identify costs that are relevant to the MS4 permit. When conducting these interviews, we asked specific cost questions about each stormwater related task the town completes. These interview questions were built around each of the towns documented stormwater reports.  Sample interview questions can be found in Appendix A.

During the course of our project we were able to go out and conduct field work in each of the case study towns.  For the towns of Upton and Westborough, we did three days of mapping stormwater structures such as outfalls, manholes and catch basins. We mapped these structures using an Asus tablet and a Leica global positioning system (GPS) unit. For Oxford and Webster we spent three days conducting dry weather inspections, water sampling, and marking outfalls. For water sampling, we used the Central Massachusetts Regional Stormwater Coalition’s sampling kits. These tasked helped us understand what each municipality must complete for the upcoming permit.


During our seven weeks working on this project, we assessed the cost of implementing the expected MS4 permit for four towns by conducting a case study for each of the four towns. In each case study, we learned what Upton, Webster, Westborough and Oxford have done to comply with the MS4 permit currently in place by researching their stormwater annual report and interviewing the town engineers, director of department of public works, contractors or relevant personnel. As stated above, we went to each town to conduct field work.  This gave us an idea of labor cost for each task

We developed several key findings after we finished our case studies as well as analyzing and compiling the data we have collected.

The overall yearly cost for each town to implement the MS4 permit in place now.

From the case studies, we discovered the total cost Upton, Oxford, Webster and Westborough was spending for each of their stormwater programs. We divided the cost by one-time costs and yearly costs. For example, mapping stormwater structures and bylaw creation were included as one-time costs while street sweeping and catch basin cleaning were included in yearly costs. According to the permit, all programs must be completed in five years so we divided the one-time costs by five to get a yearly equivalent cost. For the town of Upton, the total yearly cost is $52,950. For town of Oxford, the yearly cost is $143,664. For town of Westborough, the yearly cost would be $307,500 which $220,000 of that is to be paid for the general staff (number given to us which signifies the labor cost for all stormwater related tasks and personnel). For town of Webster, the total yearly cost is $235,780.

The cost for all municipalities to comply with the new permit.

We also divided costs between baseline costs and varying costs.  Baseline costs were costs that did not range widely between towns.  For each of the factors we identified as baseline costs, we also created a range that we expect each town will fall under. The table below showcases the costs we have identified as a baseline cost.  A table below outlines some of the costs we’ve identified as baseline costs as well as their price range.

Table 1. Sample baseline cost


Low Estimate [$]

High Estimate [$]

Public Education and Outreach



Public Involvement and Participation



Create an ordinance or bylaw for sediment control for construction sites



Have a staff member inspect BMPs present within construction sites



Have a staff member to continue inspecting BMPs after construction is finished



Create an ordinance or bylaw for detecting and eliminating illicit discharges




Varying costs include replacing pipes and catch basins, best management practices (BMP) maintenance, and mapping.  Each of these tasks varied widely between the four towns we studied.  We found that as the towns’ population increased, their cost for both what they are doing now and what we estimate they will have to do, went up.  Below is a chart of the population versus expected cost for the new permit.

Figure 2. Population vs. future cost

The table below shows some of the varying costs for two control measures separated by towns.

Table 2. Sample varying costs

Control Measure

Costs [$]





Illicit Discharge, Detection, and Elimination Program





Good Housekeeping and Pollution Prevention






The cost that can be shared among municipalities in Central Massachusetts Regional Stormwater Coalition (CMRSWC).

Some of the costs that members of the coalition share are the Leica units, maintenance on tools, one-on-one support, People GIS training, sustainable financing and access to the CMRSWC website. The table below details programs that the CMRSWC offers.

Table 3. Sample shared costs


Costs [$]


Average cost for towns in the coalition

Average cost for towns not in coalition

Tata & Howard invoices




People GIS




Central Massachusetts Regional Planning Commission




Virtual Town Hall Website Development and Hosting




Graphic Designer




Public Education and Outreach Tools




Tablet Devices (13)




Water Quality Meters and Kits




Mapping/GIS Tools (includes two Leica’s)








**People GIS agreement is assumed to be written for 30 municipalities, so we assumed that this amount would divide by 30 to find price per town. This could not be the case so we took the dividend as the lowest amount possible**

The “Coalition” column illustrates the total expenditures the CMRSWC has spent for each of the programs listed.  In order to find an equivalent cost that each municipality receives from membership we took the total expense and divided it by 30.  This gave us a number that each of the 30 municipalities receive which can be seen in the “Average Cost in Coalition” column.  Finally, we looked at what the cost would be if a municipality would individually implement each of the tasks listed which can be seen in the last column, “Cost for singular town”.  As can be seen in the table, if a town were to implement the programs offered by the CMRSWC it would cost roughly $37,000.

Cost that this project did not include.

For this project, we focused our efforts on the cost of compliance with the six control measures in MS4 permit. However, due to the time limitation of our project, we excluded some potential costs of compliance with the MS4 permit. Sanitary Sewer Overflow (SSO) and Total Maximum Daily Load (TMDL) are two important requirements in the MS4 permit. However, the towns we worked with did not report any SSO’s and Webster was the only town with a TMDL, so we did not account for the cost of these two programs in our findings.


After completing our study we have many recommendations for the MassDEP, Central Massachusetts municipalities, and future project groups. We offer these recommendations with the hope that municipalities can prepare for the upcoming MS4 permit and can expand their stormwater management programs. Additional research should be done on additional cost drivers of the MS4 permit and future permits.

The Coalition should Share Additional Resources with Member Municipalities

One recommendation we have for municipalities is to increase the amount of resources member municipalities share. Right now major resources the CMRSWC offers include water sampling kits and the Leica units.

The Coalition Should Provide Additional Training Opportunities to Member Municipalities

Another recommendation for the municipalities is to attend the training for sampling and mapping. In some towns, there are only one or two employees that can complete these tasks but in others they do not have a single employee. If municipal employees are trained on these tasks, it will be less costly compared to hiring a consultant to come in and complete the task for them

Future Research Should be Done on the cost of TMDLs and SSOs

For future projects, we recommend the project groups use our data and information collected to further research costs of the MS4 permit. One specific factor is the cost of TMDL’s which was not included in our report. These TMDL’s can range widely and only apply to specific municipalities.

Future Research Should be Done on Additional Funding Opportunities Available to the Coalition

Another future project we recommend would be identifying funding mechanisms for implementing a stormwater utility. A municipality like Shrewsbury has passed a stormwater utility but has not found a way to charge residents fairly. Some ideas for charging a stormwater utility include charging through impervious surface area, total area, a flat residential rate or others.


It is our hope that after reading our report, towns will have a better understanding of the upcoming Massachusetts permit and its associated costs.  The costs and methods presented should help towns realize and perhaps, prepare for the financial implications of the new anticipated MS4 permit. The task will be difficult but with correct awareness and actions, towns will be able to be in compliance and more importantly, work to preserve our environment.