February 6, 2015
Press Statement
For Immediate Release
Contact: David Flores, Baltimore Harbor Waterkeeper, 410-254-1577 x112
Halle van der Gaag, Executive Director, Blue Water Baltimore, 410-254-1577 x105
BALTIMORE CITY STORMWATER PERMIT
IMPLEMENTATION PLAN NEEDS MORE WORK
Plan Needs Strengthening to Clean Up City Streams and Harbor
BALTIMORE, MD - Blue Water Baltimore found serious legal and technical deficiencies in
Baltimore City's plan to comply with its state stormwater permit, known as the Municipal
Separate Storm Sewer System (MS4) permit. The plan, which the City was required to
submit in December, 2014, had a 30-day public comment period that followed submission
of the plan to the State.
Blue Water Baltimore's comments, which were filed last week, were also signed by seven
other nonprofit conservation organizations. While the plan outlines some of the programs
required by the City's stormwater permit, many required elements are missing entirely or
require far greater detail.
In its comments, Blue Water Baltimore highlights numerous deficiencies in the City's
permit implementation plan and describes measures to improve accountability of the City's
stormwater cleanup efforts.
"Baltimore has a major problem with urban polluted runoff," said Halle van der Gaag,
executive director of Blue Water Baltimore. "In order to protect our residents from toxic
contaminants, localized flooding and property damage due to stormwater runoff, we need a
plan that supports a more comprehensive restoration program that offers transparency
and accountability to city taxpayers.”
"Frankly, the City has a lot more work to do," said Baltimore Harbor Waterkeeper, David
Flores. "The plan fails to meet state and federal requirements to reduce pollution from
nutrients, toxics and harmful fecal bacteria. If we want to clean up Baltimore Harbor and
our neighborhood streams, we need a much stronger plan that achieves the requirements
of the permit."
The State's stormwater permit for Baltimore City and the City's permit implementation
plan, which is required by the permit, are mandated by the federal Clean Water Act, and
enforced by the Maryland Department of the Environment (MDE). The purpose of the
3545 Belair Road • Baltimore, MD 21213 • 410.254.1577 • www.bluewaterbaltimore.org
State's stormwater permit and the City's permit implementation plan are to restore and
maintain the health of the City's waterways and reduce pollution that comes from
stormwater runoff, in accordance with local and Bay pollution diets known Total Maximum
Daily Loads (TMDLs).
Among the detailed findings in its comments, Blue Water Baltimore states:
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The plan does not meet the state and federal legal requirements for TMDL
compliance schedules and deadlines, and does not adequately monitor progress
towards achieving goals.
The City did not comply with the public participation requirements by failing to
provide a 30-day comment period before MDE began consideration of the permit.
The plan does not adequately explain how the City will prevent illicit sewage
discharges into City waterways.
The plan does not include required details on a public strategy to improve
prevention of trash and litter from entering the City’s waterways, nor is there a plan
to disseminate information to the public.
The plan needs more detailed financial analysis, including funding sources and how
revenue will be expended.
The City provides insufficient detail about how it will verify credit programs.
The City improperly excludes programs to address stormwater pollution at
Baltimore’s drinking water reservoirs and wastewater treatment plant.
"Baltimore and other counties in Maryland have the opportunity to use their stormwater
fee programs to establish robust, transparent permit implementation," said van der Gaag.
"Baltimore needs an enforceable permit with a strong implementation plan for our city so
we can achieve our goals of safe and healthy urban waters for city residents and tourists.
We ask the City Department of Public Works to use our comments and those of other
diverse stakeholders to make meaningful revisions in a timely manner."
The complete set of comments can be found on the Blue Water Baltimore website.
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Blue Water Baltimore’s mission is to restore the quality of Baltimore’s rivers, streams and
harbor to foster a healthy environment, a strong economy, and thriving communities. We
work towards a future when our neighborhood streams are safe for fishing and swimming
and our clean harbor is the pride of our city. Find out more at www.bluewaterbaltimore.org.
3545 Belair Road • Baltimore, MD 21213 • 410.254.1577 • www.bluewaterbaltimore.org