Regulatory Comment Letters

May 4, 2021

Letter to Massachusettes Department of Environmental ProtectionSWEMA feels that the communities making up the Commonwealth would benefit greatly from updated guidance on the vetting and use of innovative manufactured treatment devices (MTDs) for stormwater management.  Given the many urban areas across the Commonwealth, the use of MTDs is common, but a lot has changed since MADEP published the existing guidance on this subject.  The available MTDs have grown more diverse, many highly effective practices have been developed, and test standards and best practices have been refined considerably.  Also, the defunding of the MASTEP initiative has left a major void since the stormwater handbook specifically references this now an obsolete resource.

 

March 26, 2021

BMP Clearinghouse Follow-up on the Proposed Guidance to Replace Guidance Memo No. 14-2009SWEMA's response to the proposed DEQ guidance document.

 

January 20, 2021

TCEQ Review of Manufactured Treatment Devices; Needed Clarity on Review StandardsCompanies that desire to introduce their technologies to the Texas marketplace must show their technology meets the TCEQ criteria for MTDs. The current criterion includes an antecedent dry-period requirement between monitoring events of 72-hour minimum with less than 0.1 inches of rain. Current field monitoring programs consider a six-hour antecedent appropriate for stormwater monitoring.

 

December 7, 2020

Letter to Los Angeles Water Quality BoardSWEMA provided comments on California Regional Water Quality Control Board - Los Angeles Region - Draft Regional Phase I MS4 Permit

 

September 30, 2020

Letter to Florida Department of Environmental ProtectionSWEMA encouraged Florida DEP to build a state-wide, stormwater BMP evaluation program that should include an understandable and consistent process for evaluating new BMPs and encouraging acceptance of those that meet or exceed applicable performance standards to drive innovations within stormwater management.
 

March 23, 2020

Letter to Virginia's Governor Ralph NorthamSWEMA encouraged the Governor to sign the HB882 bill. 
 

February 27, 2020

SWEMA Reviewed and Provided Comment on the Minnesota MTD Research Enhanced Filtration CreditMinnesota drafted a document on MTD enhanced filtration credit. SWEMA was able to provide comments and get clarification on various points in the draft document.
 

January 27, 2020

SWEMA Comments on Virginia legislature House Bill HB882Virginia's legislator will be voting on House Bill 882 pertaining to stormwater. SWEMA provided comments on this pending legislation.

 

August 9, 2019

SWEMA Submitted Comments on EPA's Chapter 3 - Best Management Practices for Reducing Trash in StormwaterThis document lists BMPs commonly used to address trash/gross solids, both structural and nonstructural. This includes information on cost and efficacy along with highlighted applications. 

 

June 10, 2019

SWEMA provides input into Virginia's Department of Environmental Quality's Guidance MemoVirginia DEQ has drafted a document Interim Use of Stormwater Manufactured Treatment Devices (MTDs) Technical Criteria, Part IIB Water Quality Design Requirements. SWEMA members provided comments on this draft covering allowance for multiple pathways for approval of MTDs, increase percent total phosphorus (TP) removal, request a transition period from the interim guidance to the proposed guidance, and hydraulic loading rates.
 

January 31, 2019

SWEMA Submitted Comments on Proposed Changes to NJDEP Stormwater RegulationsThe Stormwater Equipment Manufacturers Association (SWEMA) strongly supports stormwater management strategies and regulations that incorporate advances in stormwater science, encourage innovation, and successfully protect and restore receiving waters at an affordable cost for our communities.  The New Jersey Department of Environmental Protection (NJDEP) proposed changes to the New Jersey stormwater regulation will not promote these objectives. SWEMA members offered information on the proposed changes.

 

January  16, 2018

SWEMA's Response to City of Indianapolis Update to the Applicable Standards for the Evaluation and Acceptance of Manufactured Stormwater Treatment DevicesThe Stormwater Equipment Manufacturer’s Association (SWEMA) understands that the City of Indianapolis is currently in the process of updating the applicable standards for the evaluation and acceptance of manufactured stormwater treatment devices.  Additionally, our understanding that once updates to the applicable criteria have been completed, all of the technologies currently approved by the City must be retested in full compliance with the updated criteria.
 

September 27, 2017

SWEMA's Response  to "Proposed Use of Structural Stormwater BMPs In Alexandria."The Stormwater Equipment Manufacturer’s Association (SWEMA) represents a diverse group of stormwater solutions providers and supporting associate and professional members. Due to the diverse perspective and expertise of its membership, SWEMA is uniquely qualified to provide a professional perspective on the “Proposed Use of Structural Stormwater BMPs in Alexandria” document that is currently being considered for implementation within the jurisdiction of Alexandria Virginia.
SWEMA believes that all Stormwater BMPs, manufactured treatment devices, and generic green infrastructure BMPs, have appropriate and suitable applications. To remove one sector of BMPs limits a designer’s ability to provide sound engineering solutions to solve complex environmental conditions. In the past, the City of Alexandria has been one of the most innovative jurisdictions in the country by promoting sand filters and various underground stormwater devices. We commend the City of Alexandria for its unique history concerning advancing stormwater management (SWM) both regionally and nationally. 
 

September 27, 2017

SWEMA's Response to the United States EPA and the Department of the Army, Docket ID EPA-HQ-OW-2017-0203The Stormwater Equipment Manufacturer’s Association (SWEMA) strongly supports the maintenance of the Waters of the United States Rule and definition as promulgated by the Environmental Protection Agency (EPA) and the Department of the Army in 2015 and rejects the recodification of pre-existing rules as proposed in Docket ID EPA-HQ-OW-2017-0203.
 

September 8, 2017

SWEMA Responds to the Virginia Department of Environmental Quality (VA DEQ) on proposed updates to the Virginia Clearinghouse Relative to MTDs.We appreciate the opportunity to provide feedback to the Virginia Department of Environmental Quality (VA DEQ) on proposed updates to the Virginia BMP Clearinghouse relative to manufactured stormwater treatment devices (MTDs). SWEMA’s membership has several concerns about the current state of the BMP Clearinghouse as it relates to manufactured solutions. We respectfully offer the following comments for consideration.

 

May 15, 2017

SWEMA's comments on Office of Water: Feedback on Reducing Regulatory Burden, Docket ID No. EP-HQ-OA-2017-0190. The Stormwater Equipment Manufacturer’s Association (SWEMA) strongly supports the maintenance and advancement of national stormwater regulations under the clean water programs of the Environmental Protection Agency (EPA) as well as the continued funding of the EPA.