A Guide to the CWA Section 402 NPDES MSGP Permit Requirements, Process, and Compliance

The NPDES Multi-Sector General Permit (MSGP) is a critical component of the Clean Water Act's framework for regulating stormwater discharges associated with industrial activities. This comprehensive guide provides a deep dive into the NPDES MSGP, offering essential insights into the permit's applicability, requirements, and compliance obligations. Learn how to navigate the complex permitting process, from pre-application planning to post-permit monitoring and reporting. Understand the key considerations for developing a robust Stormwater Pollution Prevention Plan (SWPPP) and implementing effective best management practices (BMPs). Discover how to leverage innovative technology solutions, such as Transect, to streamline site selection, environmental due diligence, and ongoing compliance management. Stay informed about recent regulatory updates and access additional resources to support successful project outcomes. Whether you're new to the NPDES MSGP or seeking to enhance your expertise, this guide provides the knowledge and tools needed to effectively manage industrial stormwater discharges and protect our nation's waters.

GENERAL INFORMATION

NPDES MSGP Permit Key Details

Issuing Agency: The U.S. Environmental Protection Agency (EPA) administers the National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit (MSGP) under the Clean Water Act (CWA).

Year Established: The NPDES permit program was established in 1972 by the Clean Water Act.

Legal References: The MSGP is issued under the authority of CWA Section 402, which is codified in 33 U.S.C. §1342.

Date Last Amended: The current MSGP became effective on March 1, 2021, replacing the 2015 MSGP.

Permit Cycle: The MSGP is typically reissued every five years. The 2021 MSGP will expire on February 28, 2026.

Coverage: The MSGP covers stormwater discharges associated with industrial activity in several sectors, including manufacturing, mining, oil and gas extraction, hazardous waste treatment, and transportation.

Clean Water Act Section 402 NPDES Multi-Sector General Permit for Stormwater Discharges Associated with Industrial Activity (NPDES MSGP) Overview

The National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit (MSGP) is a key component of the U.S. Environmental Protection Agency's (EPA) efforts to protect the nation's waters from polluted stormwater runoff associated with industrial activities. The MSGP operates within the broader regulatory framework established by the Clean Water Act (CWA) of 1972, which set the goal of eliminating pollutant discharges into navigable waters and achieving water quality levels that protect aquatic life and human health.

Under CWA Section 402, the NPDES permit program was created to regulate point source discharges of pollutants into waters of the United States. The MSGP is a general permit that streamlines the permitting process for industrial facilities with similar operations and stormwater discharges. The permit requires facilities to implement best management practices (BMPs) and develop stormwater pollution prevention plans (SWPPPs) to minimize the discharge of pollutants in stormwater runoff.

The EPA is the primary agency responsible for administering the MSGP, although some states and territories have been authorized to implement the NPDES program. The permit has evolved over time to address emerging environmental concerns and incorporate new technologies and management practices. The current 2021 MSGP builds upon the foundation of previous permits, with updated requirements for corrective actions, inspections, monitoring, and reporting.

Which Resources Are Regulated By NPDES MSGP Permit?

The NPDES MSGP primarily regulates the discharge of pollutants in stormwater runoff from industrial activities into waters of the United States. The Clean Water Act defines "navigable waters" as "waters of the United States, including the territorial seas" (33 U.S.C. §1362(7)). This includes surface waters such as rivers, lakes, estuaries, coastal waters, and wetlands.

The MSGP aims to protect these water resources from the adverse impacts of pollutants that may be present in industrial stormwater discharges, such as sediment, nutrients, heavy metals, oil and grease, and toxic chemicals. These pollutants can degrade water quality, harm aquatic life, and pose risks to human health through contamination of drinking water sources and recreational waters.

By requiring industrial facilities to implement stormwater control measures and adhere to permit conditions, the MSGP helps to minimize the amount of pollutants entering waters of the United States. The permit also promotes the use of green infrastructure and low impact development techniques to manage stormwater runoff and protect natural hydrology.

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PROJECT APPLICABILITY & REQUIREMENTS

When NPDES MSGP Permits Are Required

The NPDES Multi-Sector General Permit (MSGP) is required for facilities engaged in specific industrial activities that discharge stormwater to waters of the United States, either directly or through a separate storm sewer system. The permit establishes mandatory requirements for these facilities to minimize water pollution from stormwater runoff.

NPDES MSGP Permit Exemptions

While the NPDES MSGP covers a wide range of industrial activities, certain stormwater discharges are exempt from the permit requirements. These exemptions are based on the characteristics of the discharge or the nature of the industrial activity.

Exemptions from NPDES MSGP permitting requirements include:

1. Stormwater discharges from agricultural and silvicultural activities: Runoff from orchards, cultivated crops, pastures, range lands, and forest lands is exempt from NPDES permitting requirements³.

2. Stormwater discharges from oil and gas exploration, production, processing, or treatment operations, or transmission facilities: These discharges are exempt if they consist solely of flows from conveyances or systems of conveyances used for collecting and conveying precipitation runoff and are not contaminated by contact with raw materials, intermediate products, finished products, byproducts, or waste products located on the site of such operations⁴.

3. Stormwater discharges associated with mining operations or oil and gas exploration, production, processing, or treatment operations, or transmission facilities that are not contaminated by contact with, or do not come into contact with, any overburden, raw material, intermediate products, finished product, byproduct, or waste products located on the site of such operations: These discharges are exempt from NPDES permitting requirements⁵.

To determine if a project qualifies for an exemption, facilities should carefully review the specific regulatory language and assess whether their stormwater discharges meet the exemption criteria. It is recommended that facilities consult with the relevant regulatory agency (either the EPA or the authorized state/territorial agency) to confirm the applicability of an exemption. This consultation can help ensure compliance and avoid potential enforcement actions.

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PERMIT APPLICATION & PROCESS

NPDES MSGP Permit Pre-Application Considerations & Planning

The NPDES MSGP permitting process typically involves several key phases and milestones, from the initial determination of permit applicability to ongoing compliance and reporting. The process begins with a thorough assessment of the industrial facility's operations, potential pollutant sources, and stormwater discharge points. This assessment helps determine whether NPDES MSGP coverage is required and, if so, which sector-specific requirements apply⁶.

Once permit applicability is confirmed, the facility must develop a comprehensive Stormwater Pollution Prevention Plan (SWPPP) that outlines the best management practices (BMPs) and control measures to be implemented to minimize pollutant discharges⁷. The SWPPP should be completed before submitting the Notice of Intent (NOI) for permit coverage⁸.

The NPDES MSGP process fits into the overall project life cycle by influencing key decisions and timelines related to site design, construction, and operation. Facilities should consider stormwater management and permit requirements early in the planning process to ensure adequate time for SWPPP development, BMP implementation, and NOI submission.

Typical NPDES MSGP Project Timeline:

• Month 1-2: Determine permit applicability and identify sector-specific requirements
• Month 2-4: Develop SWPPP and implement BMPs
• Month 4-5: Submit NOI for permit coverage
• Month 6+: Comply with permit requirements, conduct inspections, and maintain records

NPDES MSGP Application Requirements & Submission

To obtain coverage under the NPDES MSGP, industrial facilities must submit a complete Notice of Intent (NOI) to the EPA or the authorized state/territorial agency. The NOI is a standardized form that collects key information about the facility, its operations, and its stormwater discharges⁹.

Required components of the NOI include:

1. Facility information: Legal name, physical address, contact information, and location coordinates.
2. Site information: Total acreage, primary industrial activities, SIC/NAICS codes, and sector-specific information.
3. Discharge information: List of outfalls, receiving waters, and any impaired waters or TMDLs.
4. SWPPP certification: Certification that a SWPPP has been developed and will be implemented prior to commencing operations.
5. Endangered species protection screening: Documentation of eligibility with regard to endangered species protection requirements.
6. Historic properties screening: Documentation of eligibility with regard to historic properties preservation requirements.

The NOI aims to demonstrate that the facility has assessed its operations, identified potential pollutant sources, and developed a comprehensive plan to minimize stormwater pollution. By certifying the NOI, the facility operator acknowledges their responsibility to comply with all applicable permit requirements and implement the SWPPP effectively¹⁰.

The NPDES MSGP Review & Decision Process

Ideally, industrial facilities should initiate the NPDES MSGP permitting process well in advance of commencing operations or stormwater discharges. The EPA recommends submitting the NOI at least 30 days prior to the start of discharge to allow sufficient time for review and processing¹¹.

The key steps in the NPDES MSGP review and decision process are:

1. NOI submission: The facility operator submits a complete NOI to the EPA or authorized state/territorial agency.
2. Completeness review: The permitting authority reviews the NOI for completeness and may request additional information if necessary.
3. Public notice: The NOI is posted on the permitting authority's website for a minimum of 30 days to allow for public review and comment¹².
4. Permit decision: If the NOI is deemed complete and no significant issues are raised during the public comment period, the permitting authority will grant coverage under the MSGP. The facility operator will receive a written notice of permit coverage.
5. Permit coverage begins: The facility is authorized to discharge stormwater under the terms and conditions of the MSGP as of the date specified in the notice of permit coverage.

The permitting authority will typically make a permit decision within 30 days of receiving a complete NOI, assuming no significant public comments or objections are received. The key approval criteria include demonstrating eligibility for coverage under the MSGP, developing a comprehensive SWPPP, and committing to implementing all required BMPs and control measures¹³.

NPDES MSGP Public Participation & Stakeholder Engagement

Public participation is an essential component of the NPDES MSGP permitting process, as it allows interested parties to review and comment on a facility's proposed stormwater management practices. The EPA encourages public involvement to promote transparency, accountability, and environmental stewardship¹⁴.

The primary mechanism for public participation in the MSGP process is the 30-day public notice period following NOI submission. During this time, the NOI is posted on the permitting authority's website, and members of the public may submit written comments or request a public hearing¹⁵.

Public input can take the form of:

• Written comments on the adequacy of the facility's SWPPP, proposed BMPs, or other aspects of the NOI.
• Requests for additional information or clarification regarding the facility's operations or stormwater management practices.
• Petitions for a public hearing to discuss significant issues or concerns related to the facility's stormwater discharges.

The permitting authority is obligated to consider all substantive comments received during the public notice period. If significant issues are raised, the agency may request additional information from the facility operator, require revisions to the SWPPP, or even deny coverage under the MSGP if the concerns cannot be adequately addressed¹⁶.

Public participation helps ensure that industrial facilities are held accountable for their stormwater management practices and that the interests of local communities and environmental stakeholders are considered in the permitting process. By fostering open communication and collaboration, public involvement can lead to more effective stormwater pollution prevention and improved water quality outcomes.

Common Challenges and Pitfalls in the NPDES MSGP Permit Process

Industrial facilities pursuing coverage under the NPDES MSGP may encounter several common challenges and pitfalls throughout the permitting process. These can include:

1. Inadequate SWPPP development: Failing to develop a comprehensive, site-specific SWPPP that addresses all potential pollutant sources and includes appropriate BMPs and control measures¹⁷.

   • Strategy: Engage experienced stormwater professionals or consultants to assist with SWPPP development and ensure all requirements are met.

2. Incomplete or inaccurate NOI submission: Submitting an NOI that lacks required information, contains errors, or fails to demonstrate eligibility for permit coverage¹⁸.

   • Strategy: Carefully review the NOI form and instructions, double-check all information for accuracy, and provide detailed responses to all applicable questions.

3. Failure to implement or maintain BMPs: Not properly implementing, maintaining, or documenting the BMPs and control measures specified in the SWPPP¹⁹.

   • Strategy: Develop a detailed implementation plan, assign clear responsibilities, provide adequate training, and conduct regular inspections to ensure ongoing compliance.

4. Inadequate recordkeeping and reporting: Not maintaining required records, such as inspection reports, monitoring data, and corrective action documentation, or failing to submit annual reports²⁰.

   • Strategy: Establish a robust recordkeeping system, set reminders for reporting deadlines, and designate a responsible individual to manage compliance documentation.

5. Noncompliance with sector-specific requirements: Not fully understanding or complying with the additional requirements applicable to specific industrial sectors, such as benchmarks, effluent limitations, or monitoring requirements²¹.

   • Strategy: Thoroughly review the sector-specific fact sheets and guidance documents, consult with industry associations or stormwater experts, and develop sector-specific compliance plans.

By proactively addressing these common challenges and pitfalls, industrial facilities can navigate the NPDES MSGP permitting process more effectively, avoid delays or compliance issues, and ensure ongoing protection of water quality.

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TECHNOLOGY SOLUTIONS FOR PERMIT COMPLIANCE

Leveraging Technology for NPDES MSGP Permit Compliance

Technology plays an increasingly important role in streamlining and enhancing NPDES MSGP permit compliance by providing powerful tools for data management, site assessment, and monitoring. By leveraging digital solutions, industrial facilities can improve efficiency, accuracy, and transparency in the permit compliance process²².

Common technology tools and platforms used in the industry include:

1. Geographic Information Systems (GIS): GIS software enables facilities to map and analyze site characteristics, such as topography, drainage patterns, and land use, which are essential for developing effective stormwater management plans.

2. Stormwater Modeling Software: Modeling tools help predict stormwater runoff volumes, pollutant loads, and the performance of various BMPs, allowing facilities to optimize their stormwater management strategies.

3. Environmental Data Management Systems (EDMS): EDMS platforms provide a centralized repository for storing, organizing, and analyzing environmental data, including stormwater monitoring results, inspection reports, and corrective action documentation²³.

4. Remote Sensing and Aerial Imagery: High-resolution satellite imagery and aerial photography can help facilities assess site conditions, identify potential pollutant sources, and monitor the effectiveness of stormwater control measures.

5. Mobile Applications and Field Data Collection Tools: Mobile apps and field data collection tools enable facility personnel to conduct inspections, document findings, and record maintenance activities in real-time, streamlining the compliance monitoring process.

By incorporating these technologies into their NPDES MSGP compliance programs, industrial facilities can enhance their ability to identify and address potential stormwater issues, optimize BMP performance, and ensure ongoing permit compliance.

Transect: An Innovative Solution for Site Selection & Environmental Due Diligence

Transect is an all-in-one environmental due diligence solution that combines cutting-edge software with hands-on field experience to revolutionize site selection and permitting for industries such as solar, wind, renewable energy, and more. By integrating advanced geospatial analysis, real-time data updates, and expert environmental insights, Transect empowers developers and permit applicants to make informed decisions and streamline their projects²⁴.

Key features and benefits of Transect include:

1. Swift site pinpointing and suitability analysis: Transect's powerful geospatial tools enable users to quickly identify potential sites and evaluate their suitability based on a wide range of environmental, social, and economic factors.

2. Real-time data updates and critical issues identification: Transect provides access to the most up-to-date environmental data and regulatory information, allowing users to identify and address critical issues early in the site selection and permitting process.

3. Versatility across multiple industries and project types: Transect's flexible platform can be customized to support site selection and permitting for various industries, including solar, wind, renewable energy, and more²⁵.

4. User-friendly interface and intuitive workflow: Transect's intuitive user interface and streamlined workflow make it easy for users to navigate the site selection and permitting process, even without extensive environmental expertise.

5. Efficiency gains and cost savings: By automating many of the time-consuming tasks associated with site selection and permitting, Transect helps users reduce costs, minimize delays, and accelerate their projects.

6. Proactive risk mitigation and compliance assurance: Transect's comprehensive environmental analysis and real-time data updates enable users to proactively identify and mitigate potential risks, ensuring ongoing compliance with NPDES MSGP permit requirements.

Transect's unique capabilities can help developers and permit applicants streamline their site selection and permitting processes, reduce costs and delays, and ensure ongoing compliance with NPDES MSGP permit requirements. By leveraging Transect's advanced technology and expert insights, users can:

• Quickly identify suitable sites and evaluate their environmental constraints
• Access real-time data and regulatory updates to inform decision-making
• Automate key aspects of the site selection and permitting process
• Proactively address potential compliance issues and minimize project risks
• Optimize stormwater management strategies and BMP selection
• Streamline data management, reporting, and documentation requirements

With Transect, developers and permit applicants can navigate the complex world of environmental due diligence with confidence, ensuring that their projects are sited, designed, and operated in a manner that meets NPDES MSGP permit requirements and promotes long-term environmental stewardship.

POST-PERMIT COMPLIANCE & MANAGEMENT

NPDES MSGP Permit Conditions & Compliance Obligations

An NPDES MSGP permit typically includes a range of conditions and requirements designed to minimize the impact of stormwater discharges on receiving waters and ensure compliance with the Clean Water Act. These conditions may include²⁶:

1. Stormwater Pollution Prevention Plan (SWPPP) implementation: Permittees must develop and implement a site-specific SWPPP that outlines the best management practices (BMPs) and control measures to be used to minimize pollutant discharges²⁷.

2. Effluent limitations and benchmark monitoring: Permittees may be required to meet specific effluent limitations or benchmark concentrations for certain pollutants, based on their industrial sector and the receiving water's characteristics²⁸.

3. Inspections and visual assessments: Permittees must conduct regular facility inspections and visual assessments of stormwater discharges to identify potential issues and ensure the effectiveness of BMPs²⁹.

4. Corrective actions: If inspections or monitoring results indicate that BMPs are not effectively controlling pollutant discharges, permittees must take corrective actions to address the issue and prevent future violations³⁰.

5. Training and employee education: Permittees must provide training and education to employees on stormwater management practices, spill prevention, and emergency response procedures³¹.

6. Recordkeeping and reporting: Permittees must maintain records of inspections, monitoring results, corrective actions, and other permit-related activities, and submit annual reports to the permitting authority³².

Understanding and adhering to these permit conditions is critical for maintaining compliance with the NPDES MSGP. Failure to comply with permit requirements can result in enforcement actions, penalties, and potential damage to the environment. Permittees should carefully review their permit conditions, develop a comprehensive compliance plan, and regularly assess their performance to ensure ongoing adherence to the permit requirements.

NPDES MSGP Monitoring, Reporting & Recordkeeping Requirements

NPDES MSGP permits include ongoing monitoring, reporting, and recordkeeping requirements to ensure that permittees are effectively managing their stormwater discharges and complying with permit conditions. These requirements may vary depending on the industrial sector and the specific terms of the permit, but generally include³³:

1. Monitoring: Permittees must conduct regular monitoring of their stormwater discharges, including visual assessments, benchmark monitoring, and effluent limitation monitoring, as specified in their permit. Monitoring frequency may range from quarterly to annually, depending on the parameter and the facility's compliance history³⁴.

2. Reporting: Permittees must submit annual reports to the permitting authority, summarizing their monitoring results, inspection findings, corrective actions, and other permit-related activities. These reports are typically due by January 30th of each year, covering the previous calendar year³⁵.

3. Recordkeeping: Permittees must maintain records of all permit-related activities, including monitoring results, inspection reports, corrective action documentation, training records, and other supporting information. These records must be retained for at least three years after the permit expires or is terminated³⁶.

Accurate and timely monitoring, reporting, and recordkeeping are critical for demonstrating compliance with NPDES MSGP permit conditions. Permittees should develop a comprehensive data management system to ensure that all required information is properly collected, analyzed, and stored. This may involve the use of electronic databases, spreadsheets, or specialized environmental management software.

Failure to comply with monitoring, reporting, or recordkeeping requirements can result in enforcement actions, penalties, and potential permit revocation. Permittees should carefully review their permit conditions, establish clear roles and responsibilities for compliance tasks, and regularly assess their performance to ensure ongoing adherence to these requirements.

Enforcement and Penalties for Non-Compliance with NPDES MSGP

Non-compliance with NPDES MSGP permit conditions can result in a range of enforcement actions and penalties, depending on the severity and duration of the violation. The Clean Water Act provides the EPA and authorized states with the authority to take enforcement actions against permittees who violate their permit conditions or fail to meet monitoring, reporting, or recordkeeping requirements³⁷.

Potential consequences of non-compliance include:

1. Administrative orders: The EPA or authorized state may issue an administrative order requiring the permittee to take specific actions to address the violation and return to compliance. This may include implementing additional BMPs, increasing monitoring frequency, or submitting corrective action plans³⁸.

2. Civil penalties: The EPA or authorized state may assess civil penalties of up to $56,460 per day per violation, as of 2023³⁹. The actual penalty amount will depend on factors such as the severity of the violation, the permittee's compliance history, and the economic benefit derived from the violation.

3. Criminal penalties: In cases of willful or negligent violations, the EPA or authorized state may seek criminal penalties, including fines and imprisonment. Individuals may face fines of up to $50,000 per day per violation and up to three years in prison, while organizations may face fines of up to $500,000 per day per violation⁴⁰.

4. Permit revocation: In severe cases of non-compliance, the EPA or authorized state may revoke the permittee's NPDES MSGP permit, effectively prohibiting the facility from discharging stormwater until a new permit is obtained⁴¹.

Common violations that may trigger enforcement actions include failure to develop or implement a SWPPP, failure to conduct required inspections or monitoring, failure to submit annual reports, and exceedances of effluent limitations or benchmark concentrations⁴².

To mitigate enforcement risks, permittees should promptly report any instances of non-compliance to the permitting authority and take immediate corrective actions to address the issue. Maintaining open communication with the permitting authority and demonstrating a good-faith effort to return to compliance can help reduce the severity of enforcement actions and penalties.

ADDITIONAL RESOURCES & UPDATES

Recent Changes & Updates to NPDES MSGP Permit

The NPDES MSGP has undergone several significant changes and updates in recent years, reflecting evolving environmental regulations, legal decisions, and best management practices. Some of the most notable changes include:

1. 2021 NPDES MSGP: The EPA issued the 2021 NPDES MSGP, which replaced the 2015 MSGP, effective March 1, 2021. The 2021 MSGP includes several new requirements and modifications, such as:

   • Streamlined authorization process for low-risk facilities
   • Updated benchmark monitoring requirements for certain sectors
   • Increased emphasis on stormwater control measures and best management practices
   • Enhanced corrective action requirements and deadlines
   • Expanded eligibility for stormwater discharges to federal CERCLA sites

2. Hawai'i Wildlife Fund v. County of Maui: In a 2020 decision, the U.S. Supreme Court held that the Clean Water Act requires a permit for discharges of pollutants that originate from a point source and are conveyed to navigable waters through groundwater, if the discharge is the "functional equivalent" of a direct discharge. This decision may impact certain facilities with subsurface discharges that reach jurisdictional waters⁴³.

3. Navigable Waters Protection Rule: In 2020, the EPA and the U.S. Army Corps of Engineers issued the Navigable Waters Protection Rule, which revised the definition of "waters of the United States" (WOTUS) under the Clean Water Act. The rule narrowed the scope of jurisdictional waters compared to previous regulations. However, in August 2021, a federal district court vacated the rule, and the agencies have announced their intent to revise the WOTUS definition through a new rulemaking process⁴⁴.

Facilities subject to NPDES MSGP requirements should carefully review these changes and updates to ensure ongoing compliance with the most current regulations and legal interpretations. Consulting with environmental professionals and legal counsel can help facilities navigate the evolving regulatory landscape and adapt their stormwater management practices accordingly.

Additional Resources & Information

The following additional resources provide valuable information and guidance for facilities subject to NPDES MSGP requirements:

1. EPA's NPDES MSGP Website: The EPA maintains a comprehensive website dedicated to the NPDES MSGP, which includes links to the current permit, fact sheets, sector-specific guidance, and related resources.

2. Industrial Stormwater Monitoring and Sampling Guide: This EPA guidance document provides detailed information on stormwater monitoring and sampling procedures, including best practices for sample collection, analysis, and data management.

3. Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators: This EPA guide offers step-by-step instructions for developing and implementing a SWPPP, including templates and examples.

4. NPDES eReporting Tool (NeT): The EPA's electronic reporting tool, NeT, allows facilities to submit NOIs, NOTs, Annual Reports, and other NPDES MSGP-related documents electronically. (https://www.epa.gov/npdes/stormwater-discharges-industrial-activities#ereporting)

5. Industrial Stormwater Fact Sheet Series: The EPA has developed a series of fact sheets that provide sector-specific guidance on stormwater management practices, benchmark monitoring requirements, and best management practices. (https://www.epa.gov/npdes/stormwater-discharges-industrial-activities-fact-sheets-and-guidance)

6. BMP Database: The International Stormwater BMP Database is a comprehensive source of performance data for various stormwater best management practices, which can help facilities select and design effective stormwater control measures.

These resources, along with the support of environmental professionals and regulatory agencies, can help facilities navigate the complex requirements of the NPDES MSGP and develop effective stormwater management programs that protect water quality and ensure ongoing compliance.