Menomonee Watershed Permit Adopted

Thanks to Jake Zimmerman, Water Resources Engineer for WDNR, for providing this introduction to the recently released Menomonee River Watershed MS4 permit.

The recently issued Menomonee River Watershed MS4 Permit sets the stage for other MS4 (municipal separate stormwater sewer system) permits in the Southeast Region. The ‘Watershed’ permit includes improvements to the minimum control measure requirements, outlines new expectations for working towards TMDL (Total Maximum Daily Load) pollutant reduction goals, and lays the foundation for a benchmark approach to water quality improvement. The new permit is a product of collaboration between permittees, their consultants, multiple NGOs, and DNR Staff. This collaboration allowed for a permit that continues existing group efforts, sets more clear expectations, and provides additional opportunity for a joint effort to happen in the future. 

With completion of the Milwaukee River TMDL in March 2018, Menomonee River Group MS4 permittees were given new pollutant reduction goals for Total Suspended Solids (TSS), Total Phosphorus (TP), and fecal coliform. Many of these MS4s expressed the need for additional planning time to prepare a strategy for addressing the goals which are much higher than the existing 20% TSS standard. However, it was also necessary for the permittee to provide ‘reasonable assurance’ the TMDL goals will be met in the future by demonstrating some water quality improvements during their first permit term.

To align the need to plan and take action, DNR challenged each MS4 to identify additional actions, BMPs, or projects (i.e., “benchmarks”) that they could achieve during the next permit term.  After a few group meetings and many individual discussions, DNR reviewed the proposed actions for each MS4, then crafted permit language to reflect appropriate progress towards the pollutant reduction goals.  DNR also incorporated permit language that required additional review and ongoing planning to ensure additional time was provided to adequately assess all available alternatives and prepare for identifying additional ‘benchmarks’ for the next permit term.  This approach is rooted in adaptive stormwater management, or Plan, Do, Check, and Act.

One unique element of this permit is the flexibility for collaboration to meet permit requirements. While each MS4 has individually assigned benchmarks to achieve over the permit term, the co-permittees can work together to achieve these goals. A MS4 tasked with completing a storm water quality improvement project may elect to build something individually or choose to partner with a neighboring MS4 on a different project outside their MS4 boundary. This allows the MS4s to focus efforts in the watershed to those areas that need the most improvement in storm water controls. Lastly, while not all collaborative approaches were identified prior to permit reissuance, the partners will be able to continue to evaluate many alternatives they can collaborate on as they develop longer term storm water plans to achieve the TMDL reduction goals. 

I want to thank each MS4, their consultants, the NGOs, and all the DNR staff for their time spent developing this permit. Whether it was meeting coordination, benchmark development, or reviewing drafts, I could not have done it without your help. I look forward to continuing the momentum and seeing improvements to the streams, rivers, and lakes in SE Wisconsin. 

Check out the Menomonee River Group MS4 Permit, as well as the accompanying fact sheet, below.