MCSC discussion so far has raised these concerns and questions on Section 23:
MS4 cities could find a water quality trading program beneficial if it efficiently allows cities to implement the most effective water quality improvements and track the benefits of those projects. However, the program as proposed includes a series of new requirements for program development and tracking that differ from the requirements for BMPs managed by permittees under their SWPPP. The MS4 permit and SWPPP already provides a framework to manage inspection, maintenance, tracking and reporting on BMPs. A streamlined program would do more to encourage implementation of BMPs to improve water quality.
o Can the water quality trading program be streamlined to remove regulatory hurdles for approval (e.g. shorten 90 day review timeline, limit areas of review to specific requirements)?
o Can the water quality trading program be proposed in a manner that utilizes current MS4 requirements for inspection, maintenance, and reporting?
What is your city thinking about the water quality trading program?
lisa_admin.