A TRANSPORTATION AUTHORITY'S PERSPECTIVE ON AN ILLICIT DISCHARGE ELIMINATION PROGRAM

Under the National Pollutant Discharge Elimination System (NPDES) Phase I storm water regulations the Michigan Department of Transportation (MDOT) was required to obtain five storm water permits. MDOT also obtained coverage under a watershed permit for an additional municipality in the Rouge River Watershed. Each storm water permit covered the drainage systems within the MDOT rights-of-way within the six municipalities.As a component of the permits, the MDOT developed an Illicit Discharge Elimination Plan (IDEP). The IDEP required MDOT to investigate all of their storm water outfalls discharging to waters of the state and to other municipal separate storm sewer systems. Transportation authorities' drainage systems are different from those of municipalities in many terms including size, shape, degree of development, and management.NPDES Phase II regulations were going to require MDOT to obtain over 350 storm water permits and investigate over 10,000 storm water outfalls. Through negotiations MDOT and the Michigan Department of Environmental Quality (MDEQ) developed a more appropriate and cost effective permit and illicit discharge elimination approach for Phase II. MDEQ agreed to issue one statewide permit to MDOT instead of individual permits for each regulated community. The new IDEP requirements focused on targeting areas where illicit discharges would have the greatest effect on water quality in the State of Michigan. MDOT received this permit in January 2004.