What is an MS4?
The initialism “MS4” (pronounced M-S-4) is short for municipal separate storm sewer system. It is used to refer to an entity who is regulated by an MS4 Clean Water Act permit or the separate storm sewer conveyance system.
Stormwater discharges from MS4 conveyances (e.g., pipes and ditches) do not flow to a local wastewater treatment plant. Instead, they are going directly into our local creeks, streams, and rivers without treatment. This is concerning because of the potential pollutants stormwater runoff can carry to our local waterbodies from various land uses.
Indiana MS4 Program Background
The Indiana Department of Environmental Management (IDEM) has updated its Clean Water Act, National Pollutant Discharge Elimination System (NPDES) stormwater Phase II MS4 general permit (GP). An MS4 is defined as “a conveyance or system of conveyances (including roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, man-made channels, or storm drains)” that is (1) designed or used for collecting or conveying stormwater and (2) is owned or operated by a city, county, or other governmental entity (including federal and state entities). The term “MS4” specifically excludes (1) combined sewers and (2) systems that are part of a publicly owned treatment works.
The first MS4 GP became effective in 2003. Approximately 180 Indiana Counties, Cities, Towns, Conservancy Districts, Universities (including Purdue), Colleges, etc. were designated by IDEM and US EPA as being subject to permit coverage and are referred to as “MS4s”. On April 13, 2022, IDEM issued notification to approximately 45 additional local entities that IDEM has designated them as new MS4s.
Components or MCMs of MS4 Program
The primary components of the MS4 program are permit requirements called “Minimum Control Measures” or MCMs and are the following:
- Public Education and Outreach – includes educating the general public and selected stakeholders
- Public Participation/Involvement – includes complying with official public notice requirements and engaging the general public
- Illicit Discharge Detection and Elimination (IDDE) – is intended to minimize non-stormwater discharges by finding and fixing issues with the separate stormwater conveyance system; includes mapping of the system and screening of stormwater outfalls as well as a local ordinance requirement
- Construction Site Runoff Control – includes a local ordinance requirement that includes at least all the requirements of the IDEM construction stormwater general permit
- Post-Construction Runoff Control – same as MCM #4 plus requires MS4s to include Low Impact Development and Green Infrastructure programs
- Pollution Prevention/Good Housekeeping (PP&GH) – includes requirements for maintenance of the separate storm system conveyance and for all municipally owned operations and facilities
Indiana LTAP Model Stormwater Management Ordinance and Technical Standards
MCMs 3, 4, and 5 (IDDE, construction, and post-construction) require MS4s to develop and implement a local ordinance or ordinances. To assist with promoting statewide consistency among these local ordinances, several regulated MS4 communities requested that an entity such as LTAP develop a model stormwater management ordinance for them to use.
LTAP accepted this challenge, and these documents are now ready! The ordinance and technical standards meet the minimum IDEM requirements for general permitting and also contain recommended requirements for stormwater management.
You can download the ordinance and technical standards here:
New Permit Requirements for Mandatory Training
IDEM released the final version of their newly updated MS4 GP which became effective on December 18, 2021. This newly updated permit contains several new and more robust requirements including the following training activities with their mandated compliance schedule:
Learning Management System (LMS)
MS4 program PP&GH training specifically targeted at new hire and seasonal staff has the shortest compliance deadline with the greatest MS4 community need. LTAP decided to develop materials to address these deadlines first in their on-line LMS. The LMS contains five PP&GH modules and one covering the federal Spill Prevention Control and Countermeasures program.
Future MS4 training modules may become available on LTAP’s LMS for the remaining Minimum Control Measures (MCMs). To access these modules, visit our Learning Management System.
PP&GH LMS Fact Sheets
To clarify the purpose, learning objectives, and content of the LMS modules, seven fact sheets have been developed. The first fact sheet gives an overview of all of the modules. The other fact sheets each focus on the detailed content for a specific module.
A literature review of existing PP&GH materials was conducted as part of developing the PP&GH LMS modules. These materials were divided into groupings consisting of brochures, fact sheets, guidance documents, videos, websites, and other materials. These materials can be found in our Learning Management System under the corresponding training modules.