Storm board readies MS4 annual report as TDEC schedules compliance review

The Storm Board was told at its 4:02 p.m. meeting that the Tennessee Department of Environment and Conservation (TDEC) has scheduled a compliance evaluation, to be conducted over Zoom, focused on Minimum Control Measure III (illicit discharge). Staff said they have submitted copies of ordinances and notice-of-violation records and expect the review to be straightforward.

The update centered on the board’s annual MS4 report, which covers July 1, 2022, through June 30, 2023, and must be filed by Sept. 30. Staff described transitioning to myTDEC’s new paperless reporting forms and said they have spent the last three months reconciling prior records to the new format to ensure permit compliance.

Board members were told staff will complete follow-up questions after the compliance evaluation and circulate the draft report for review before submission. The presentation emphasized ongoing record-keeping work and the likely multi-year effort to fully adapt to the new online reporting system.

"It's not really like a formal audit," a staff member said of the upcoming evaluation, "we're just gonna go over what ordinances we had in place for how we deal with illicit discharges." The comment reflected staff expectations that documentation submitted to TDEC — including notices and ordinances — already show the board's controls for illicit discharges.

The board did not take formal votes related to the MS4 report during the meeting; staff said they will return with additional details after the TDEC review and will make the draft annual report available for member review prior to the Sept. 30 filing deadline.