Municipal Separate Storm Sewer Systems (MS4) National Pollutant Discharge Elimination System (NPDES) permits and NPDES Construction General Permits (CGPs) are usually written in broad terms with a general bias towards municipalities and site-based construction activities. The requirements of these stormwater permits typically do not recognize the unique linear nature of highway projects, the administrative organization of state Departments of Transportation (DOTs), and other challenges that DOTs face in implementing stormwater programs. Given these challenges, different permitting approaches for DOTs, such as MS4 permits and CGPs that are developed specifically for DOTs, would likely be more cost effective overall than one-size-fits-all permits, both in meeting water quality goals and reducing permitting conflicts. This project investigated alternative DOT NPDES permitting approaches and evaluated the costs and benefits of the alternatives. The goal of this study was to assist DOTs in developing practical and defensible NPDES permitting strategies for highway environments.
The specific research objectives of the study include:
1. Characterizing current DOT NPDES permit types and conditions for MS4 and GCP permits;
2. Assessing the costs and benefits associated with alternative DOT NPDES permitting strategies;
3. Recommending strategies for obtaining NPDES permits specific to DOTs; and
4. Recommending strategies for DOTs to promote communication with regulatory agencies.
The project final report is available here.