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ACTION PLEASE BY:
June 2, 2010

The U.S. Environmental Protection Agency (EPA) announced  on May 10 that it is seeking public comment on a revised draft Information Collection Request (ICR) for municipal separate stormwater sewer system (MS4) utilities as part of a proposed rulemaking effort to strengthen national stormwater regulations.  This is an updated version of the stormwater ICR that was previously released for public comment by EPA in October 2009.  EPA is not formally asking MS4 utilities to complete the ICR survey form at this time but instead is requesting comment on the scope and potential burden of the survey.  Once finalized, the ICR will be used by EPA to gather information as part of its rulemaking process to develop a new national stormwater rule.  The Agency is accepting comment on the revised ICR until June 9, 2010.

As a result of the public comments received in response to the previous version of the ICR survey, including comments  submitted by NACWA, EPA has made some changes to the survey form for MS4 utilities.  Most notable is EPA’s decision to create two separate survey forms for municipal stormwater utilities, one for regulated MS4s and one for non-regulated MS4s.   In reviewing the revised ICR survey, NACWA is pleased to see that EPA has incorporated a number of the suggestions made by the Association in our comments filed in response to the earlier version of the ICR released last October.  However, NACWA is still concerned that the revised ICR will be overly burdensome for municipal stormwater utilities to complete.

NACWA is requesting comment from its members to aid the Association in formulating a response to EPA regarding the revised ICR survey forms for MS4 utilities.  For those NACWA members currently operating a permitted MS4 program, please review the draft ICR survey form for regulated municipal stormwater system, available by clicking here .  For those NACWA members that may operate a MS4 program that is currently not regulated, please review the draft ICR survey for non-regulated stormwater systems, available by clicking here .  NACWA would also welcome comment from its affiliate members on either of the two survey forms.  NACWA is particularly interested in member comments on the content of the ICR survey forms, including whether there are certain questions that should be clarified or changed, whether there are additional questions that should be added, and whether the forms may be overly burdensome for utilities to complete.

Please submit any comments on the ICR to Keith Jones, NACWA’s General Counsel, at This e-mail address is being protected from spambots. You need JavaScript enabled to view it by June 2, 2010.  In addition to sending comments to NACWA, members are also encouraged to submit comments directly to EPA.  Additional information on the ICR and EPA’s stormwater rulemaking process is available on EPA’s website.