It's that time - no, not to start holiday shopping, but time to think about your stormwater Annual Report.
Why so soon?
We realize that Phase II Small MS4 Annual Reports submitted last May are far from your minds, but it’s more than halfway through Permit Year 9. Municipalities are required to continue implementing their Best Management Practices and Stormwater Management Programs. Unless EPA finalizes the new Small MS4 General Permits and authorizes communities to discharge under the permit before Spring 2012, it is very likely that a Year 9 Annual Report will be due to EPA and MassDEP. Click here for EPA’s most recent Small SM4 General Permit Update.
Now is a great time to check progress on your community’s planned Permit Year 9 stormwater activities. EPA is increasing its attention to municipal stormwater programs, as shown by their recent enforcement activities including a number of fines for late or missing Annual Reports. It is more important than ever to complete Annual Reports on time. In addition, as construction season winds down and municipal responsibilities are transitioning from outdoors to indoors, some local stormwater managers have an opportunity to catch up on paperwork and filing.
What should you do?
- Look at your 2011 (Year 8) Annual Report. Most reports are available on EPA's 2003 Permit Archives website.
- Review the Annual Report. What did your community promise to do this year? Are you on track? What have you completed and when? What's left to do?
- Gather and organize paper records documenting all completed stormwater activities.
- Make every effort to complete activities planned for Permit Year 9 by March 31, 2012 and add documentation to your files.
How can Woodard & Curran help?
If you have any questions about EPA’s Stormwater Program, General Permit Requirements, or want guidance on your local stormwater program, please contact us.
Contact us for more information.