PEC Opposes HR 284

PEC sent the following communication to members of the House State Government Committee regarding HR284.

June 6, 2017

To:           Members of the House State Government Committee
From:     Pennsylvania Environmental Council
RE:           Consideration of House Resolution 284 (P.N. 1556)

Dear Representatives:

The Pennsylvania Environmental Council (“PEC”) respectfully urges you to oppose House Resolution 284, that calls on Congress to repeal Section 402(P) of the Federal Clean Water Act (CWA) relating to the permitting of stormwater discharges by regulated small Municipal Separate Storm Sewer Systems (MS4s).

At PEC, we work on stormwater issues across the Commonwealth and recognize both the challenges and opportunities presented in managing rainfall. Indeed, a growing number of the Commonwealth’s 900+ designated MS4 communities work with private, public, and nonprofit partners to finance and implement innovative stormwater water control initiatives that provide economic, social, and environmental benefits to their communities. That said, we also recognize the financial challenges faced by MS4 communities as they work to meet the program’s requirements.

While the language of the resolution focuses on the challenges of compliance, it does not recognize the multiple economic and quality of life benefits related to flood mitigation and reduction of water pollution that are direct results of properly managing and controlling excess rain water. The resolution further states that, beyond the federal program, Pennsylvania’s Stormwater Management Act adequately addresses stormwater within the Commonwealth. While the state Act’s regulations do provide standards and criteria for the management of stormwater from new construction and redevelopment projects, they do not address, as the federal program does, inadequate stormwater management infrastructure associated with existing development. That lack of effective infrastructure has resulted in flooding, loss of life, and other adverse impacts to business and public health.

Pennsylvania’s 86,000 miles of rivers and streams provide drinking water for millions of residents and a tremendous recreational and economic driver for the Commonwealth. The health of those waters is dependent upon wise and active stewardship and protection by the state. The MS4 program, as designed, helps to protect all of these uses.

For these reasons, we ask that you oppose this resolution. Thank you for your consideration.


John Walliser
Senior Vice President, Legal and Government Affairs
Pennsylvania Environmental Council
(412) 481-9400