As of early 2013, we continue to await the issuance of EPA’s final MS4 (municipal stormwater) permits for Massachusetts…we will update this space as soon as there is news; the deadline for public comment passed almost two years ago (see below). We were pleased to see the many thoughtful and detailed comment letters generated by the environmental community and look forward to seeing these permits finalized.

MRA MS4 Comments

Support EPA’s Draft Stormwater (MS4) Permit for the Interstate, Merrimack and South Coastal Watersheds

Public Hearing:  Wed., March 9, 2011, at 11:00am at the Leominster Public Library, Community Room, 30 West Street, Leominster, MA 01453.

Public Comment Deadline: Midnight on Fri., March 11, 2011

What individual citizens and organizations can do:

1) Submit a comment letter supporting EPA’s proposed permit and ask friends and members of your organization to do the same. Letters can be very short!  EPA must receive written comments on the Draft Permits no later than midnight on Fri., March 11, 2011.  Written comments should be e-mailed to Kate Renahan, or sent via postal mail to Kate Renahan, U.S. EPA-Region 1, Office of the Regional Administrator, 5 Post Office Square-Suite 100, Mail Code-ORA01-1, Boston, MA 02109-3912.

2) Testify in person at EPA’s public hearing on Wed., March 9th which starts at 11:00am at the Leominster Public Library.  You usually have 3 minutes to speak.

3) Write an article or editorial in your community paper about stormwater pollution and the importance of the EPA stormwater permit.

For sample alerts, comments letters and more information on how to support and improve EPA’s Draft Stormwater (MS4) Permit for the Interstate, Merrimack and South Coastal Watersheds, go to Support EPA’s Draft Stormwater (MS4) Permit.

Why Stormwater?

The Massachusetts Alliance has chosen stormwater management as one of its priority issues because stormwater is largest source of water pollution in Massachusetts.  Stormwater pollution closes beaches and shellfish beds and damages habitat for fish.  Too much stormwater floods roads, basements and businesses, particularly in urban areas with lots of pavement and other impervious surfaces.  The role of the Alliance is to seek and create opportunities to improve stormwater management in the state, and to involve our members.

Beginning in 2010 and continuing into 2011, river advocates have an important opportunity to help reduce stormwater pollution in Massachusetts.  EPA is issuing Draft Storm Water General Permits that regulate storm water discharges in small Massachusetts communities with separate storm sewer systems (known as “MS4s”).  Each regulated MS4, usually a municipality, state agency or federal agency, is required to develop and implement a storm water management program (SWMP) that:

  • reduces contamination of storm water runoff
  • identifies and eliminates illegal discharges such as raw sewage to storm sewers
  • samples discharges from stormwater outfalls
  • educates specific audiences about the stormwater pollution and management
  • maintains or improves pre-development hydrology on sites of very large new development and re-development projects.

Stormwater Basics

Stormwater runoff is our most common cause of water pollution. Stormwater pollution is caused by the daily activities of people everywhere.  Rainwater and snowmelt run off streets, lawns, farms, and construction and industrial sites where it picks up fertilizers, dirt, pesticides, oil and grease, and many other pollutants on the way to our rivers, lakes, and coastal waters.  In the Massachusetts communities where residents depend on the river for their drinking water (Ex. 300,000 residents in the Merrimack Valley of Massachusetts), stormwater is especially problematic.

Photo courtesy of the Mystic River Watershed Association

Stormwater is also the cause of combined sewer overflows (CSOs) — a major water pollution concern in cities across the U.S. Combined sewer systems are sewers that are designed to collect rainwater runoff, domestic sewage, and industrial wastewater in the same pipe.  Most of the time, combined sewer systems transport all of their wastewater to a sewage treatment plant, where it is treated and then discharged to a water body. During periods of heavy rainfall or snowmelt, however, the wastewater volume in a combined sewer system can exceed the capacity of the sewer system or treatment plant and excess wastewater is directly discharged to nearby streams, rivers, or other water bodies.  These overflows, called combined sewer overflows (CSOs), contain not only stormwater but also untreated human and industrial waste, toxic materials, and debris.

Low impact development (LID), reduces the impact of stormwater runoff in built areas and promote the natural movement of water within an ecosystem or watershed.  LID is an approach to land development (or re-development) that works with nature to manage stormwater as close to its source as possible. LID employs principles such as preserving and recreating natural landscape features, minimizing imperviousness to create functional and appealing site drainage that treats stormwater as a resource rather than a waste product. There are many practices that have been used to adhere to these principles such as bioretention facilities, rain gardens, vegetated rooftops, rain barrels, and permeable pavements. Applied on a broad scale, LID can maintain or restore a watershed’s hydrologic and ecological functions.

Adapted from materials in the EPA Stormwater website ( and the EPA LID website (

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