Small MS4 Update: 4 Things to Do Now to Be Ready for Your Next Annual Report

Small MS4 Update: 4 Things to Do Now to Be Ready for Your Next Annual Report

Fall is officially here, and just like last year, it’s not too soon to start thinking about your stormwater Annual Report. Yes, you submitted a Year 9 Phase II Small MS4 Annual Report last May and next May feels a long way off, but it’s more than halfway through Permit Year 10.

EPA Region 1 has stated new Small MS4 General Permits will not be finalized anytime soon, which means a Year 10 Annual Report will be due to EPA and MassDEP by May 1, 2013. Click here for EPA’s most recent Small MS4 General Permit Update.

Now is a great time to check progress on your community’s planned Permit Year 10 stormwater activities. Even though EPA doesn’t appear to be taking the permits seriously, it is increasing focus on municipal stormwater programs, with enforcement activities and comprehensive audits continuing at a relatively high rate, including leveling fines for late or missing Annual Reports. That means it is more important than ever to complete Annual Reports on time. You may also find that as summer construction season winds down, there’s more time to catch up on paperwork and documentation.

What should you do?

  1. Look up your 2012 (Year 9) Annual Report. Most reports are available on EPA’s 2003 Permit Archives website.
  2. 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?
  3. Gather and organize paper records documenting all completed stormwater activities.
  4. Make every effort to complete activities planned for Permit Year 10 by March 31, 2013 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.


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