In exactly two years - on March 10, 2003—NPDES Phase II permit coverage becomes mandatory for the 5,000 or so communities that fall under this new stormwater rule. As we often do in publishing, many of these cities are now counting backward. To meet the deadline, what do we need to accomplish between now and then? What needs to be done immediately? What should have been done yesterday?

The two years remaining are easier to plan for, of course, if you know exactly what has to be done. In this respect, the Phase II regs are both easier and tougher than Phase I. Easier because they're more flexible: In most cases, applying best management practices—rather than conducting analytical testing or using numerical limits to characterize water quality—is sufficient for compliance. Trickier than Phase I for just the same reason. The efficiency, appropriate uses, maintenance, and evaluation of structural BMPs are to many people a conundrum worthy of the Sphinx, and the freedom the Phase II narrative standard affords is downright frustrating.

So far, much of the frustration has been understandable. There is a bewildering number of products on the market and almost as many opinions on the best ways to control construction-site runoff. What works, and where, and how to maintain it? The answers often differ depending on local conditions and whom you ask. Figuring out how best to implement nonstructural BMPs like public education, erosion and sediment control plans, and recycling programs can be even more daunting.

But help is on the way from a couple of fronts. One is a national stormwater BMP database, created through an agreement between EPA and the American Society of Civil Engineers with the goal of making BMP performance data widely available. With this tool, local stormwater managers should find it easier to match up local problems and workable solutions. (Read more about the database on page 44.)

EPA's Environmental Technology Verification Program, www.epa.gov/etv/, promises to be another resource for eliminating confusion. Designed to speed up the entry of new technologies to the market, the program seeks participation from vendors, users, regulators—just about anyone with a stake in the outcome—in evaluating various environmental technologies, then publishes the results. By providing an "independent and credible" source of information, EPA hopes to remove some of the uncertainty that goes with employing brand-new technologies. Although few specific stormwater-related technologies have been verified to date, a pilot program on wet-weather flow technologies is examining systems that deal with urban wet- weather flows, uncontrolled stormwater discharges, combined sewer overflows, and sanitary sewer overflows.

The small MS4s that fall under the Phase II rule include some very nontraditional "municipalities" as well, not all of which have authority to ensure compliance but which still have to meet the rule's six minimum control measures: military bases, Native American reservations, state departments of transportation, parks, office complexes, hospitals, prisons, and universities. For these MS4s, some creative permitting options are available. These include joining as co-permittees with adjacent small MS4s, sharing stormwater management programs, piggybacking onto a neighboring MS4's Phase I permit, and referencing already-in-place state-, county-, or watershed-wide programs.

Nothing really ends, of course, at that March 2003 deadline. It's not so much a finish line as a little plateau on the way to the summit. Five years after that date, or by the end of the term of their first permits, Phase II MS4s must achieve fully implemented stormwater programs - with all the continued staffing, planning, and assessment that will entail. Still, there's a sense of accomplishment in reaching a plateau and taking a look around. We'll get there on March 10, 2003.

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