The Central Massachusetts Regional Stormwater Coalition (CMRSWC) has created many technical tools and resources that can be utilized by a user or town other than its member communities (located in Massachusetts) that wishes to do so.
However, there are several things that the CMRSWC Steering Committee wants potential users to understand.
1. CMRSWC tools have not been approved or endorsed by regulators
Tthe CMRSWC works closely with USEPA Region 1 and the Massachusetts Department of Environmental Protection, and these regulatory agencies are very familiar with the products that CMRSWC has created.
However, neither agency has approved or endorsed any document or tool created by the CMRSWC.
Futher, use of a CMRSWC tool does not guarantee compliance with the Massachusetts MS4 Permit.
2. CMRSWC tools will not be 100% applicable for all facilities or communities
The CMRSWC created products that were:
a) requested by our member communities and
b) customized to fit the needs of our member communities.
There may be other state-, region-, or watershed-specific issues that make a tool not appropriate for use in a community, watershed, or for a specific facility. Use your best judgment about whether a tool or resource is appropriate for use in your community.
3. CMRSWC tools are not 100% perfect
The CMRSWC performed internal and external reviews of the tools and resources we have posted on this website. However, we do not claim that any or all documents are free of errors.
We encourage potential users to review a document thoroughly before adopting or using it, and to use their best judgment about whether it is appropriate for use in their community.
4. CMRSWC tools are not ready to go “off the shelf”.
The CMRSWC created tools and resources to save our member communities time and money, and have tried to make them comprehensive.
However, some tools absolutely require input from the user before they can be adopted and used to comply with the MS4 Permit.
A good example of this is the Stormwater Pollution Prevention Plan (SWPPP) Template. This document requires the user to enter specific information about their community, impaired waters, TMDLs (if they exist), facility location, activities at the facility, site layout, names and contact information for the Pollution Prevention Team members, locations of stormwater outfalls and infrastructure on the site, and much more. Printing the template, as is, will not provide the user with a SWPPP that satisfies the provisions of the MS4 Permit.
Similarly, the Standard Operating Procedures may be a useful tool in your community. However, if an SOP is not adopted in writing, if no training is provided to staff on that SOP (or staff are not aware of the SOP), and/or if inspections included in the SOP are not performed (or use a different form than the one provided), then the SOP will not help meet compliance.
We encourage potential users to review a document thoroughly before adopting or using it.
5. CMRSWC tools May Require Updates to Comply with the New MA MS4 Permit
Many CMRSWC tools were developed in 2012 & 2013 to comply with provisions in the 2003 Massachusetts MS4 Permit. While the CMRSWC did its best to anticipate the provisions that were likely to be included in the future/pending Massachusetts MS4 Permit, some tools will need to be updated when the MA MS4 Permit is finalized.
A good example of this is SOP 2 (Wet Weather Outfall Inspections), written in 2012 and located on our Standard Operating Procedures page. The objective of a wet weather inspection as described in this SOP is to capture the "first flush" of runoff from impervious surfaces in a specific catchment during a wet weather (storm) event, and represent the potential pollution that would discharge to a surface water body from a specific outfall early in that storm. It is now anticipated that the objective of wet weather outfall inspections in the future/new MA MS4
Permit will be to identify places where interconnections between the stormwater system and sanitary sewer systems may occur only during wet weather events, not to represent the "first flush".
The CMRSWC will update the publication date and Revision number, located in the footer of most files, when a document has been revised. We encourage potential users to carefully note the date and Revision number to determine whether that document reflects the 2003 MA MS4 Permit or a future one, and to carefully review a document thoroughly before adopting or using it.
6. CMRSWC tools are not intended to replace any tools already in use by any CMRSWC member
The CMRSWC created tools and resources to save our member communities time and money, improve consistency in the data collected in the region, and provide templates for SOPs for communities struggling to develop them internally.
However, if a CMRSWC member is using a different inspection form, already has a SWPPP, or has adopted a different SOP, there is no mandate for that member to switch to using the CMRSWC-created tool.
In the same way that use of CMRSWC tools does not guarantee compliance, use of CMRSWC tools is voluntary.