Upper Missouri Waterkeeper Submits Comments on DEQ’s Draft MS4 Permit to Improve Permit Terms and Protect Local Water Quality
Earlier this week Upper Missouri Waterkeeper submitted a technical comment letter to the Department of Environmental Quality (DEQ) concerning the proposed 5th draft version of DEQ’s Municipal Separate Storm Sewer System (MS4) General Permit. As development pressure continues unabated across the state, mitigating stormwater pollution – one of the fastest growing sources of pollution directly linked to building impervious surfaces – is critical to protecting water quality.
“Proactively managing stormwater to reduce its negative impacts on water quality through thoughtful planning and responsible development strategies is common sense and can prevent costly cleanup down the road – a win-win for the environment and taxpayers,” said Guy Alsentzer, Executive Director of Upper Missouri Waterkeeper. “By including mandates for green infrastructure, low impact development, and natural filtration techniques in the statewide stormwater permit, we can create a science-based playing field that ensures Montana’s growth doesn’t become a zero-sum game for our world-class waterways.”
Noted critiques of the letter include establishing long-term and incrementally increasing targets for pollution reduction; establishing incentives and disincentives for timely compliance; prioritizing green and natural infrastructure best management practices to promote water and climate resiliency; establishing an accountability framework for monitoring and evaluating pollution reduction projects; and using census population data and water quality data to bring new developing areas into the MS4 permit program.
The letter, in part, states:
“… we applaud the advances made in the draft permit and recognize the Department’s
work to improve Permit terms and, in turn, to improve local water quality. At the same time, we see critical gaps in long-term goal setting, technical requirements, and monitoring that have the potential to jeopardize the success of the program.”
Waterkeeper will continue to work with the Department to support the MS4 Program and minimize the impacts of growth on local waterways, our blue ribbon fisheries, and drinking water sources.