Introduction: MS4 (Municipal Separate Storm Sewer System) Permit
The MS4 permit covered a wide range of storm water practices and new requirements to prevent runoff of contaminants into waterways, especially during the rainy period. But it also included a section on “non-storm water runoff”. This segment was broken into two categories. The first had mostly to do with construction runoff for which an elaborate set of requirements would be instituted in advance of construction to avoid the discharge of contaminants. RRWPC did not oppose most of the new requirements.
It was the second component however, that we had serious concerns about, since it allowed “incidental” discharge of wastewater in summer resulting from wastewater irrigation. While the Regional Board denied that contaminants would be allowed to pollute our waterways under this permit, nevertheless, we believed that the safeguards to prevent this from happening were/are extremely weak. We have also taken and submitted many photographs of discharge into drainages leading to creeks. The Regional Board followed this with a Basin Plan Amendment that solidified the policy into their regulations with (in our view) inadequate provisions to prevent runoff.
Comments below specifically address development of the MS4 permit process. RRWPC has commented extensively on irrigation runoff in the other sections on recycled water.