This is what we know so far.

Storm Water Permitting Update

Municipal Separate Storm Sewer System (MS4s) – Nontraditionals: K-12 and Community College Districts:

Phase II Small MS4 Permit Reissuance

  • School Districts and Community College Districts will be designated in next iteration of the permit (early 2021)
  • Anticipate that 700-800 public school districts and 300-400 community college districts will become permittees.
  • Requirements will include implementation of the Trash Amendments and Urban Pesticide Amendments
  • Permit will cover all owned and operated sites

What WILL the MS4 permit require of schools?

  • Creating a map of storm water drainage on school property
  • Identifying areas throughout the district that could generate storm water pollution
    • Maintenance yards
    • Auto and wood shops, agricultural and horticultural areas, lunch areas, etc
    • Identify practices to reduce the risk of pollution from these areas
    • Conduct visual monitoring of storm water runoff
  • Training on storm water best management practices for staff
  • Continue implementing construction general permit
  • Designing and building new construction to meet requirements for storm water runoff quality and quantity
  • Making information on school storm water program available on public website
  • Documenting activities and report annually

From the State Board: What is the MS4 permit NOT going to require of schools?

Paying annual fees:

  • No fees for school districts that join cities/counties already paying a fee.

Ramping up the program:

  • Immediate implementation of full program without a phase-in-period.
  • Requirements build upon themselves over the five-year permit term

Allocating classroom time to storm water education

  • State Board has received numerous comments about tight controls already placed on curriculum and classroom time

Conducting extensive sampling

  • Much of your monitoring may be visual

Retrofitting existing structures

  • Requirements focus on improving structures as they are newly built or remodeled

What might the State Board want schools to do?

  • Coordinate with existing MS4 programs for regional consistency
  • Participate in watershed level projects for synergistic benefits

What can you do to prepare?

  • Get involved (join CASH and CASQA)
  • Comment on draft permit language
  • Signup for State Board Lyris Notices
    (instructions to the right)

For more information/updates:

CASH: Ian Padilla 

CASQA NonTraditional Subcommittee Co-chairs:

Rachael Keish

Patrick Kuga 

Subscribe to get State Board Lyris email notices:

  • Go to the State Water Board 
  • Click the arrow next to “Water Quality”
  • Check the box for “Storm Water Municipal Permitting Issues”