Comment 1

Response to Public Comments on the MS4 Permit ANR thanks everyone who took the time to review and comment on the draft MS4 permit. The final permit is a better document as a result of your efforts. Our responses to major comments are provided below. Comment 1. (CLF)The proposed permit is duplicative of other stormwater permits issued by ANR. • The numerous permits are confusing and make it difficult for citizens to participate. • Conditions of the permits are sometimes contradictory. • Permits use inconsistent terminology. To consolidate and simplify the process we recommend: • Re-issuing the Watershed Improvement Permits (WIP) as federal NPDES permits. • Redefining MS4 permits to include the entirety of WIP watersheds and use of the MS4 permits in lieu of WIPs to address stormwater discharges to impaired waters and compliance with the Lake Champlain TMDL. • Conducting a comprehensive review of state and federal stormwater laws and regulations and creating a program that minimizes duplication and overlap. Response 1. The impact of stormwater on water quality is not a one-dimensional issue. Multiple solutions are required for a multi-faceted problem. Each of the stormwater permits issued by ANR addresses a distinct aspect of managing stormwater. Each of the following permit programs was developed at a different time by separate actions of federal and state authorities: • State individual and general permits for management of ...