MS4 stands for Municipal Separate Storm Sewer System. This system includes inlets, basins, man-made channels, storm drains, and various other stormwater conveyance systems.

In the United States, the Environmental Protection Agency (EPA) is charged with regulating stormwater pursuant to the Clean Water Act (CWA). Portions of the stormwater requirements of the federal CWA are administered under the Pennsylvania Department of Environmental Protection's (PADEP) Municipal Separate Storm Sewer System (MS4) Program. As part of our MS4 permit, we are faced with new unfunded mandates, resulting in the need to spend considerably more money over the permit cycle than ever before to improve water quality.

Similarly, based upon the year of installation and system materials used (such as corrugated metal pipes), there is a growing amount of degradation of stormwater infrastructure and increased cost to replace assets. Originally most of the stormwater infrastructure was installed by developers and dedicated to the Township, therefore the Township did not pay to install the initial infrastructure, but now needs to pay the cost for asset replacement. Higher intensity storms are also impacting the community, causing increased repair costs and creating a need for additional capacity to be built into the system to protect public health and private property.

Bethlehem Township is required to complete pollutant reduction planning and implement Best Management Practices (BMPs) to reduce pollution loadings entering our local waterways. In addition, there are six Minimum Control Measures (MCMs) that the Township is mandated to follow, each containing their own set of BMPs. The six MCMs are listed below with examples of their BMPs:

1. Public Education and Outreach on Stormwater Impacts: Distribute educational materials in the form of a newsletter, flyer, or a website that includes general stormwater educational information.
   
   
2. Public Involvement and Participation: Provide opportunities for residents to participate and provide input in the form of public meetings or other events.
   
   
3. Illicit Discharge Detection and Elimination: Develop and implement a plan for the detection, elimination, and prevention of illicit discharges to the storm sewer system.
   
   
4. Construction Site Stormwater Runoff Control: Develop, implement, and enforce an erosion and sediment control program for construction activities that disturb one or more acres of land.
   
   
5. Post-Construction Stormwater Management (PCSM) in New Development and Redevelopment: Develop, implement, and enforce a program to address discharges or post construction stormwater runoff from new development and redevelopment areas. Applicable controls could be the use of structural BMPs such as vegetated swales and detention basins.
   
   
6. Pollution Prevention and Good Housekeeping: Develop and implement an operations and maintenance (O&M) program that includes training components and plans to reduce polluted runoff from municipal operations.
   
   

While some BMPs or Best Management Practices are administrative or operational in nature, such as public education or street sweeping, others are structural and are used to improve water quality by reducing contaminants that enter local waterways. Structural BMPs are designed to reduce stormwater volume, peak flows, and nonpoint source pollution through evapotranspiration, infiltration, detention, and filtration. Examples of structural BMPs include stream bank stabilization, detention basin retrofits, rain gardens, bio swales, permeable pavement, street sweeping and installation of community rain gardens.

Stormwater management involves managing rainwater that is not absorbed by our lawns and gardens. Impervious surface on your property impacts the volume, rate, and pollutant load of stormwater runoff that will be managed by Bethlehem Township. Also, household tasks such as car washing and use of fertilizer can impact stormwater quality.

Impervious area is any surface which prevents or greatly reduces infiltration of water into the ground. This includes pavement (asphalt, concrete, etc.), rooftops, decks/patios, pools, sidewalks, and compacted graveled surfaces such as parking areas and driveways.

The Environmental Protection Agency (EPA) defines illicit discharges as "any discharge to the storm sewer system that is not composed entirely of stormwater." Illicit discharges can be from car wash wastewater, spills from roadway accidents, failed septic systems, and improper disposal of household toxins and detergents. These substances can either enter our waterways through direct connections or indirect connections. It is always good to monitor the stormwater inlets near your property. If you see someone dumping, please call the Bethlehem Township Office at 610-814-6400 or the PA DEP 24-hour hotline at 570-826-2511.

Bethlehem Township worked with the community to evaluate the stormwater program needs, including meeting with the Stakeholder Advisory Committee (SAC). Importance of stormwater management, level of service and condition of stormwater assets were all considered. In addition, known problems, scheduled stormwater improvements, and projects necessary to comply with regulatory requirements were used to project stormwater management expenses over the coming years. Ongoing administrative and operational expenses were also considered. These stormwater program costs were divided by the impervious area estimates in the Township to come up with the Stormwater Utility Fee.

The fee will be paid by all property owners who own developed property in the Township, whose property has impervious surfaces over 300sf. Tax exempt properties will be charged because it is a fee and not a property tax. Property taxes are based on the assessed value of the property whereas the stormwater utility fee is based on impervious area. Tax-exempt properties will be charged a stormwater utility fee similar to other utilities including electric, water, and sewer.

The stormwater fee is based on the amount of impervious area rather than assessed property value, so the cost is assigned to the properties that have a greater impact on stormwater runoff. There is no correlation between assessed property values and the amount of impervious surface on a given property. This makes it inequitable to base the stormwater fee on the assessed value of the properties. An advantage of a fee-based system is that credits can be offered to property owners. Bethlehem Township has developed a credit policy to provide fee reductions to property owners. A credit cannot be offered give such a credit on a tax-based system.

The amount will differ depending on how much impervious area is on a property. The fee structure is shown below.

All stormwater revenue will be placed into a dedicated fund used only for Bethlehem Township's stormwater program, such as the operation, maintenance, and improvement of stormwater infrastructure. The funds will cover costs associated with the following:

• Operation and Maintenance of Stormwater Infrastructure - Bethlehem Township will own roughly 95 linear miles of stormwater pipes, 4,500 inlets, over 30 stormwater detention basins, and additional related infrastructure. Enhanced maintenance of these facilities is necessary to reduce flooding, improve public safety and extend the useful life of the asset.
  
  
• Regulatory Compliance - The Township is required by state and federal regulations to reduce stormwater pollution and improve water quality for local streams.
  
  
• Capital Improvement Projects - Flood mitigation projects are being planned in the Easton/Santee, Walnut Street, and various other locations throughout the Township. Additionally, improvements are planned for more than a dozen detention basins.

If you believe you are being incorrectly charged, you may submit an appeal to have this information reviewed. The Credit and Appeals Manual provides information on how to submit an appeal. Further information and applications can be found on the Township's website.

Yes. The stormwater utility fee will allow for credits. Credits are a percent reduction in the stormwater utility fee for offsetting utility program costs. The Credit and Appeals Manual provides further information. The credits include:

• Low Impact Parcel - Credits for properties with less than 10% Impervious (applied automatically)
• Structural BMP - BMPs that result in Rate/Volume Reductions and/or Water Quality improvements
• Educational Credit - Support MS4 education, such as at schools or churches
• Stormwater Partnership Credit - Opportunity for cooperation via additional credit opportunities

Aerial orthophotography of the entire Township was taken. This orthophotography was converted for the use in Geographic Information Systems (GIS) software. In GIS, the impervious area features were identified and plotted throughout the Township. County GIS data showing parcel boundaries was overlaid with the impervious area dataset to determine the estimated amount of impervious area per property.

Even if your property has never flooded and/or there are no nearby storm sewers, the stormwater that flows off your property must be managed by Bethlehem Township. Stormwater management is a community-wide service that benefits the whole Township, and the program costs need to be distributed to all property owners. The fee will also help cover other services provided by the Township, such as stormwater system maintenance and permit compliance. Since there are additional services provided by the Township, property owners who manage the majority of stormwater onsite will still pay a fee to help cover the additional services provided by the Township beyond their property lines.

A new stormwater bill will be issued annually. You may elect to pay this bill quarterly using installment coupons, or you may pay in full at a discounted rate. These bills will be mailed by Berkheimer and will not be sent directly from the Township.

If the unoccupied property contains impervious area (vacant residential structures, empty commercial/industrial buildings, driveway, etc.), it will be charged. These properties continue to generate stormwater runoff just the same as an occupied property.

Property owners are not being charged for rain falling on their property nor is the fee tied to the quantity of rainfall. Instead, the charges are correlated to stormwater runoff associated with impervious area on the property. As rain falls on impervious surface, it collects pollutants. The amount of pollutants contained in stormwater can be correlated to the amount of impervious surface on your property. Additionally, proper stormwater management is vital to ensuring flood risk is minimized. Through the implementation of the fee, a dedicated funding source will be in place to help manage stormwater in flood prone areas.