September 16, 2024

MS4 General Permit Renewal: Compliance, Deadlines and Resources

Municipalities subject to the requirements of the Phase II Small Municipal Separate Storm Sewer Systems (MS4) General Permit (TXR040000) must obtain coverage under the new permit by Feb. 11, 2025.

The Texas Commission on Environmental Quality (TCEQ) renewed the Small MS4 General Permit on Aug. 15, 2024. Municipalities are required to comply with the General Permit by developing or updating your Stormwater Management Program (SWMP) and submitting a Notice of Intent (NOI) to TCEQ unless your organization is eligible for one of two options to waiver out of the program. NOIs and waivers must be submitted using the NetMS4 electronic reporting system.

Remind me, what is a Small MS4?

A small “municipal” separate storm sewer system (MS4) is a storm sewer system owned or operated by a public entity like a city, flood control district, county or public agency. It includes ditches, curbs, gutters, storm sewers and similar means of conveying runoff that do not connect with a wastewater collection system or treatment facility before discharging into water bodies.

A regulated Small MS4 is an MS4 in an urban area with a population of 50,000 or more at the time of the 2020 U.S. Census. MS4s located partially or entirely within the boundaries of the 2000 or 2010 urbanized area or the 2020 urban area with a population of 50,000 or more in that urban area (not the municipal population) are subject to the Small MS4 general permit conditions.

Are you in a regulated area? Click to view the map.

Timeline of activities for compliance:

How Freese and Nichols can help with compliance:

For 130 years, Freese and Nichols has been helping municipalities meet their long-term and emergency needs. From 16 offices across Texas, our experts have provided Phase II MS4 program consulting services for more than 20 years to over 30 municipalities to meet EPA stormwater quality protection mandates.

We bring multiple levels of expertise to MS4 program management:

Permit Coordination Assistance:

• MS4 permit reauthorization assistance.
• Stormwater Management Program development.
• EPA and TCEQ coordination for permit renewal, inspections and compliance support.
• MS4 annual reporting to TCEQ.
• Data management systems for documentation and recordkeeping compliance assurance, integration with asset management and/or work order systems.

Specific MS4 Program Activities:

• Storm system mapping inventory and condition assessment.
• Illicit Discharge Detection and Elimination inspections.
• Stormwater ordinance reviews and updates for MS4 requirements.
• Construction site stormwater inspections.
• Standard operating procedures and checklist development.
• Public education and outreach, including websites, fact sheets and in-person engagements.
• Facility inspections for good housekeeping practices.
• Structural control inspections.

To learn more, contact your Freese and Nichols Client Representative or any of our MS4 team members:

Ryan Deal, Stormwater Compliance Specialist, ryan.deal@freese.com or 817.735.7594
Brooke Salisbury, Environmental Scientist, brooke.salisbury@freese.com or 817.735.7299
Katie Leatherwood, Water Quality Discipline Lead, katie.leatherwood@freese.com or 817.735.7503
Kimberly Buckley, Environmental Group Manager, kimberly.buckley@freese.com or 817.735.7332