MS4 stands for Municipal Separate Storm Sewer System. This system is owned and operated by a public body, in our case the Township, and 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 2019 MS4 permit, Bethlehem Township is faced with new unfunded mandates, resulting in the need to spend considerably more money over the five-year permit cycle than ever before to improve water quality.

Bethlehem Township is required to complete pollutant reduction planning and implement Best Management Practices (BMPs) to reduce pollution loadings entering our local waterways. Over the 2019 permit term (2019-2024) we are required to reduce sediment by 10%, phosphorus by 5% and nitrogen by 3%. 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.
   
   

Stormwater management BMPs--or Best Management Practices - are control measures used to improve water quality by reducing contaminants that enter local waterways. BMPs are designed to reduce stormwater volume, peak flows, and nonpoint source pollution through evapotranspiration, infiltration, detention, and filtration. Examples of 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 may impact the quantity 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. All residents utilize the stormwater system, and everyone should play a role in supporting its maintenance and upkeep.

Impervious area is any surface which prevents infiltration of rainfall into the soil. 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.

The Stormwater Utility Fee is the result of discussions between Bethlehem Township and the Stakeholder Advisory Committee (SAC). Importance of stormwater management, level of service and stormwater needs were all considered. In addition, a list of known problems, scheduled stormwater improvements, and future projects necessary to comply with future regulatory requirements were used to project stormwater management expenses over the next 5 to 10 years. These overall stormwater system costs will be divided by the impervious area in the Township to come up with the Stormwater Utility Fee.

All residents with impervious surfaces on their property will pay a fee. The amount will differ depending on how much impervious is on a property. The fee structure is shown HERE.

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.

The fee will be paid by all property owners who own developed property in the Township, whose property has impervious surfaces (roofs, driveways, sidewalks, walkways, roads, parking lots, etc.). Non-profits will pay because it is a fee and not a property tax. Property taxes are based on the assessed value of the property and the stormwater utility fee is based on how much a property contributes to stormwater runoff. Tax-exempt properties are required to pay for other utility charges including electric, water and sewer and the stormwater utility fee is no different.

All developed properties contribute stormwater runoff and should pay the stormwater fee; however, some properties are exempt from taxes. Unlike taxes, which are used for general services that the Township provides, the revenue from the stormwater fee can only be used for stormwater management and cannot be redirected for other uses.

The stormwater fee is based on the amount of impervious surface rather than assessed value, so the cost is shifted to the properties that create more stormwater runoff. There is no correlation between assessed values and the amount of impervious surface on a given property. This makes it unfair to base the stormwater fee on the assessed value of the properties. An advantage of a fee-based system is that we can offer credits to property owners who reduce the quantity of stormwater or improve the quality of stormwater leaving their property. Bethlehem Township has developed a credit policy to provide reductions to property owners who make improvements which assist in meeting the Federal/State requirements. We cannot give such a credit on a tax-based system.

If you believe you are being charged for in incorrect amount of Impervious Area, you may submit an appeal to have this information be reviewed. The Bethlehem Township Municipal Authority Credit and Appeals Manual provides information on how to submit an appeal. Further information and applications can be found on the Township's Stormwater Forms Section

Yes. Bethlehem Township's stormwater utility fee will allow for credits. Credits are a monthly percent reduction in the stormwater utility fee for having and maintaining infrastructure which reduces the quantity of stormwater or improves the quality of stormwater leaving a property. The Bethlehem Township Municipal Authority 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 photographs of the entire Township were taken. These photos were then geometrically corrected for the use in Geographic Information Systems (GIS) software. In GIS, the impervious area features were identified and plotted throughout the Township. This information can then be utilized to determine the amount of impervious located on each property.

All properties produce stormwater runoff that contribute to pollution and flooding downstream. 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 residents. All property owners benefit from the management of stormwater along public streets which they travel. 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.

Undeveloped property is property that has not been altered by improvements such as buildings, parking lots, structures, or the addition of any other impervious areas. Since there are no impervious areas on these properties, undeveloped properties will not be charged a stormwater fee. Similarly, properties with under 300 sf of impervious area will be treated as undeveloped properties.

Portions of the Township have had a stormwater system in place for many years; however, there are many areas of the Township that do not have the appropriate infrastructure to handle the rainfalls we are seeing today. In recent years, there has also been an increased emphasis on stormwater management. New and revised state and federal regulations require a comprehensive stormwater management program. The stormwater utility fee ensures that Bethlehem Township receives adequate financial support to meet its responsibilities to manage the stormwater system more closely, identify and eliminate illegal discharges, provide public education, and other regulatory requirements. The fee will also be used to cover the cost for increased inspection and maintenance of aging infrastructure, implementation of flood reduction projects and the ability to rehabilitate/replace infrastructure that's reached the end of its useful life.

Property owners are not being charged for rain falling on surface. Instead, the charges apply to runoff that's discharged into the stormwater system when it rains. 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.