Topic: Online MS4 Reporting
Joe Purohit, President, EcoLayers, Inc.
David Gibson, Executive Officer, San Diego Regional Water Quality Control Board
Andre Sonsken, Supervisor – Monitoring Programs, Transportation & Stormwater Department, City of San
Richard Gilb, Manager of Environmental Affairs, San Diego Regional Airport Authority
Abstract (Rough Draft):
Currently Phase 1 MS4 permits require the annual submission of written reports with maps and data in
the form of tables and/or Excel files to the regulatory agency (“Report”). The Report requirements are
finely scripted with regard to content and form of presentation. Report preparation involves considerable
amount of information exchange and interactions between internal departments and external
organizations, manual effort (staff, consultants, attorneys), and numerous iterations. Consequently,
reporting has become an expensive and time consuming activity for MS4 departments. Increasing, and
at times conflicting, regulatory complexity, tighter budgets, and risks of citizen lawsuits place additional
burdens on Reporting.
More significantly, water quality and programmatic data are difficult to use by both permittees and
regulatory agencies to develop more cost-effective and innovative solutions. Worse, since the Report
carries the statutory burden of demonstrating compliance, the Reporting requirements end up defining
the specifics of the compliance programs and processes regardless of their actual effectiveness. The net
result is a self-perpetuating schism between regulatory compliance and effectiveness.
To address these problems, the San Diego Regional Water Quality Control Board, the City of San Diego,
the San Diego Regional Airport Authority, and EcoLayers, Inc. have collaborated to pursue a pilot project
to assess the effectiveness and statutory acceptance of an online MS4 reporting system as an alternative
to current methods. Besides providing a significant reduction in staff time and costs for Report
preparation and submission by permittees, online reporting will allow MS4 department staff, other
departments, regulators, consultants and attorneys easier access to data, online analysis, and
interpretation for improved decision making and ultimately lowering the costs of implementing
The proposed paper will present the objectives and design of an online reporting system and its
implementation for the pilot project. Important considerations include ease of use, life-cycle costs,
adaptability to environmental and regulatory changes, and collaborative decision making. We will then
discuss the results of the pilot project and the long term implications of online reporting from the
perspectives of the permittees and the regulatory agency. Finally, we will conclude with a brief discussion
on how online reporting can be a key stepping stone towards integrated water management for better
solutions to local and regional water problems.