What Pennsylvania’s Proposed MS4 Updates Mean for Your Community

by Amanda Giamalis

Pennsylvania is preparing for one of the most significant shifts in local stormwater regulation in more than a decade. Last year, the Pennsylvania Department of Environmental Protection (PADEP) released draft updates to the state’s Municipal Separate Storm Sewer System (MS4) program, signaling a shift toward a very different approach to stormwater management across the Commonwealth. Now, these changes are poised to influence how municipalities plan infrastructure projects, allocate funding, and engage residents in protecting local waterways. 

PADEP’s draft updates propose replacing existing Pollutant Reduction Plans (PRPs) and Total Maximum Daily Load (TMDL) plans with newly required Volume Management Plans (VMPs). These VMPs establish a long-term goal: to manage stormwater from 88% of a municipality’s impervious surfaces within 50 years. For communities with limited budgets and extensive paved areas, this target represents both an environmental imperative and a planning challenge.  

To support this transition, PADEP has introduced an updated Maximum Extent Practicable (MEP) Calculator, designed to help municipalities assess feasibility and project costs. The tool will become a core component of MS4 compliance, including Notice of Intent (NOI) submissions required by September 30, 2026.

These changes have real-world implications for the people who maintain local infrastructure and the residents who rely on it. For municipal employees, the shift to volume management means new technical responsibilities—updating impervious surface mapping, adopting revised stormwater ordinances, tracking new inspection data, and meeting more rigorous reporting and response deadlines. Requirements such as responding to illicit discharge complaints within five days and adopting updated conveyance design standards significantly affect day-to-day operations in public works and engineering departments.

For residents, the impact is equally tangible. More intense rainfall and increased flood risk make stormwater management a critical public safety issue. The updated rules encourage better drainage, greener infrastructure, and long-term investment in flood-resilient public spaces. Homeowners with private stormwater systems will also take on new responsibilities for recordkeeping and inspections, helping ensure water management is consistent at both the municipal and household scale. Ultimately, the updates aim to protect property, reduce flooding, and support cleaner local waterways—benefits that touch every household and business in the community.

The new draft guidance also updates terminology, shifting from the familiar “Best Management Practices (BMPs)” to “Stormwater Control Measures (SCMs).” While this change may appear minor, it accompanies a major update to Pennsylvania’s modelstormwater ordinance, which permittees will be required to adopt. Notable proposed changes include:

  • Allowances for residential vehicle washing,
  • New conveyance design standards capable of handling the 100-year storm event plus 20%,
  • Higher rainfall rates are required for stormwater calculations,
  • A new requirement for homeowners with private SCMs to document inspections after every precipitation event for five years.

These changes will necessitate coordinated municipal planning, solicitor review, and updated public education efforts to ensure local ordinances do not conflict with other township codes.

The draft permit was published January 18, 2025, with public comments closing March 19, 2025. Though the regulations are not yet final, municipalities should begin preparing immediately. That includes budgeting for:

  • Development of new Volume Management Plans,
  • Potential updates to impervious area mapping,
  • Retrofitting municipal-owned stormwater basins and other existing SCMs to meet new requirements.

Key target dates include:

  • Notice of Intent (NOI): September 30, 2026,
  • Volume Management Plan (VMP): September 30, 2028.

Additionally, municipalities that have not yet completed their required PRP/TMDL reductions must finish these obligations before applying for permit renewal under the new system.

For many communities, these updates represent a substantial shift in regulatory expectations, technical requirements, and long-term planning. But they also present an opportunity: by refocusing on volume reduction, Pennsylvania municipalities can better mitigate flooding, improve water quality, and build resilience against increasingly severe storms.