MS4 Program

Lehigh County Conservation District is dedicated to preventing/reducing pollutants from discharging into our surface waters – rivers, streams, lakes, ponds and wetlands.. 

Municipal Separate Storm Sewer Systems

MS4 Program Plan is to identify Lehigh County’s MS4 requirements and to provide an outline as to how the County will comply with these requirements.

Public Education and Outreach

Learn how to reduce the contamination of Stormwater. reducing pollutants from discharging into our surface waters – rivers, streams, lakes, ponds and wetlands.

Public Participation and Involvement

Opportunities for participation are generally available through the LCCD’s watershed program.

Municipal Separate Storm Sewer Systems

A municipal separate storm sewer is any conveyance or system of conveyances (including but not limited to streets, ditches, and pipes) that is:

  • owned by a municipality or other public body (created under state law) having jurisdiction over disposal of sewage, industrial wastes, stormwater or other wastes;
  • designed or used for collecting or conveying stormwater;
  • not a combined sewer (i.e., not intended for both sewage and stormwater); AND
  • not part of a publicly owned treatment works (POTW).

MS4s are categorized as Large, Medium and Small based on criteria in the federal regulations at 40 CFR 122.26. Large and Medium MS4s must apply for NPDES permit coverage. Small MS4s must apply for NPDES permit coverage or a waiver if they are located in an urbanized area as determined by the latest Decennial Census by the Bureau of the Census, or if they are designated as needing a permit by the Pennsylvania Department of Environmental Protection (PADEP). 

Waivers may be granted in lieu of permit coverage if the criteria in 40 CFR 122.32(d) or (e) are met.

Large and Medium MS4s must apply for individual NPDES permits in Pennsylvania, as no NPDES General Permit exists for these MS4s.

NPDES permits for MS4s require, in lieu of numeric effluent limitations, implementation of a stormwater management program. There are six program elements designed to reduce the discharge of pollutants to the maximum extent practicable. 

The program elements, titled Minimum Control Measures (MCMs), include:

  • Public Education and Outreach 
  • Public Involvement / Participation 
  • Illicit Discharge Detection and Elimination 
  • Construction Site Runoff Control 
  • Post-Construction Stormwater Management 
  • Pollution Prevention / Good Housekeeping for Municipal Operations. 

Permit coverage is generally for a 5-year term with a requirement to submit a renewal application or a Notice OF Intent (NOI) at least 180 days prior to the expiration date of coverage.

Lehigh County is considered a non-traditional municipal MS4 and has developed an MS4 Program Plan to identify Lehigh County’s MS4 requirements and to provide an outline as to how the County will comply with these requirements.  This Plan is reviewed annually and revised/updated as needed. 

Lehigh County’s MS4 Program Plan documents the proactive efforts planned by the County under this program. These requirements primarily correspond to the county infrastructure and properties (facilities, parks, athletic fields and drainage infrastructure), but also include public information and outreach on stormwater issues. The ultimate purpose of this plan is to maintain or improve water quality in the area designated as within the MS4 boundary in Lehigh County. The County’s Program Plan has been revised and submitted to PADEP on December 31, 2014. 

In addition, permits require the submission of periodic reports (annual reports or progress reports every other year); submission of Total Maximum Daily Load (TMDL) plans that document how an MS4 will reduce pollutants discharged in stormwater to achieve wasteload allocations (WLAs) in TMDLs (if the MS4 discharges to waters with an EPA-approved TMDL with WLAs); and submission of Chesapeake Bay Pollutant Reduction Plans that document the steps MS4s will take to reduce the discharge of nitrogen, phosphorus and sediment to the Chesapeake Bay (if the MS4 discharges to waters that drain to the Bay). The County’s MS4 Progress Report was submitted to PADEP on December 31, 2014.

The MS4 program for Lehigh County is administered by the Lehigh County Conservation District (LCCD) through a Memorandum of Understanding between the County and the LCCD. 

The County’s Program Plan and MS4 Reports are available for review through right to know. Copies of the County’s Program Plan and MS4 Reports are kept at the following addresses:

Lehigh County Conservation District
4184 Dorney Park Road, Suite 105
Allentown, PA 18104

Lehigh County Government Center
General Services Department
17 S. 7th Street
Allentown, PA 18101-2400

Public Education and Outreach

The Phase II Regulations require an MS4 permittee to develop a program to educate the public about the impact of Stormwater discharges on local waterways and the steps that citizens, businesses, and other organizations can take to reduce the contamination of Stormwater, thus preventing/reducing pollutants from discharging into our surface waters – rivers, streams, lakes, ponds and wetlands. Runoff from rain or snow melt that cannot be absorbed into the ground has the ability to carry pollutants, such as oils, soil/sediment, chemicals and lawn fertilizers directly to our surface waters and is known as Stormwater pollution. 

The LCCD staff provides education and outreach to the citizens of Lehigh County on topics including Watershed, Non-point Source Pollution and Prevention, Agricultural Activities, Stormwater Management, Erosion and Sediment Control, Sediment Pollution Prevention. The targeted audience typically reached by LCCD includes Schools, Agricultural Community, Watershed Groups, Developers, Design Engineers, Earth Moving Contractors, Municipal Employees, and the Community at large.

Healthy waters attract people to live, work, and play on or near them and improve our quality of life. Polluted waters  has a negative impact on our drinking water sources and maintenance of drinking water facilities, aquatic life, recreation and food sources.

You can take the following steps to help protect the quality of our waters:

  • Use fertilizers sparingly, never exceeds the products application rates
  • Sweep driveways, sidewalks and roads (rather than washing them with water)
  • Never dump anything down a storm drain
  • PLant native grasses in bare spots in your yard, set mowers at 3 inches to help retain turf density
  • Compost yard waste
  • Avoid using pesticides
  • Direct downspouts to lawns and away from paved areas
  • wash your vehicle at the car wash instead of in your driveway
  • Conduct routine maintenance on your vehicle, check for fluid leaks, recycle motor oil
  • Clean up after your pet to minimize bacteria reaching our waterways
  • Regularly inspect and pump your septic tank/system

Practicing these simple steps will help to reduce the pollution runoff from the Stormwater that leaves your yard and driveway

Please visit the LCCD’s publication webpage page for Newsletter articles about Stormwater topics. [NOTE: No Publications page currently exists. Need to create this page, and need content for this page.]

For more information regarding public education and outreach please visit PADEP’s website below.

Public Participation and Involvement

The Phase II Regulations require MS4 permittees to provide opportunities for public involvement in the planning and implementation of activities related to the development and implementation of the permittee’s Stormwater Management Plan.

The County’s MS4 Program Plan is review and revised/updated annually as needed. Revisions to the County’s Plan are presented during an LCCD Board meeting and thus entered into the Board meeting minutes. An opportunity for public feedback and input regarding the County’s Plan is available during the LCCD Board meetings. Dates and times of these meetings are available on our Event Calendar below.

The County’s Program Plan and MS4 Reports are available for review through right to know. Copies of the County’s Program Plan and MS4 Reports are kept at the following addresses:

Lehigh County Conservation District
4184 Dorney Park Road, Suite 105
Allentown, PA 18104

Lehigh County Government Center
General Services Department
17 S. 7th Street
Allentown, PA 18101-2400

Opportunities for participation are generally available through the LCCD’s watershed program.