Costs and Benefits of Transportation-Specific MS4 and Construction Permitting

Focus Area

Water Quality/Wetlands


Natural Resources







Research Idea Scope

TERI Administrator Note (January 2009): Idea selected for implementation with NHCRP 25-25 (Task 56) funding in 2009.

The cost of complying with the National Pollutant Discharge Elimination System (NPDES) continues to grow as more stringent effluent guidelines and Total Maximum Daily Load (TMDL) plans are implemented by the US Environmental Protection Agency and State water quality agencies.  A portion of these growing cost my be due to the incompatibility of the certain MS4 and construction general permit requirements with the linear nature of transportation facilities.  Permits for MS4s are developed in general to cover a wide variety of land uses and practices within designated municipal areas.  The construction general permits are geared to site-type development having a small number of outfalls to receiving waters. Typically state DOTs have applied their activities under the MS4s of the municipalities, often having to accept measures which can be irrelevant to transportation facilities. The construction general permits are used, but DOT projects generally do not fit the site-based measures imposed by these permits.  As a consequence, a number of DOTs have developed their own construction general permits to the address the linear nature and phased development of transportation corridors.  Also, there currently is a growing interest in developing transportation-specific MS4s.

Unfortunately, the costs and benefits of moving to NPDES permits that are specific to transportation have not been fully explored.  Research is needed to determine the cost to state DOTs as focused MS4 and construction general permit holders rather than as permitees regulated by the existing MS4 and construction authorizations

General Scope

Information would be needed in several areas to develop a relevant cost analysis:

1.      The administrative costs of permit development and implementation,

2.      The cost of environmental compliance for maintenance and operations,

3.      The cost of continued erosion and sediment control compliance,

4.      The cost of best practices for stream crossings, and other related topics,

5.      Costs where there is a need to develop environmental training geared specifically to long-term maintenance and operations. 

 The benefits that should be explored include:

1.      The incorporation of Context Sensitive Solutions (CSS) as part of a commitment to long-term maintenance,

2.      Environmentally sensitive project management, including long-term maintenance and CSS,

3.      Maintenance considerations as a part of overall project environmental management

 Recommended as an NCHRP new effort

Suggested By

SCOE, Natural Systems and Ecological Communities Subcommittee