Salisbury Township's manager continues to resist calls from the township Environmental Advisory Council to hire a part-time Municipal Separate Storm Sewer System (MS4) expert.

In response to his stance, a township commissioner has asked the manager to put in writing how MS4 regulations will be implemented by the township.

The debate continues amidst possible adoption of the new township zoning ordinance, expected to be on the agenda of the 7 p.m. March 26 township meeting.

Township Commissioner Joanne Ackerman, the board's representative on the Environmental Advisory Council, during the March 12 township workshop, asked Salisbury Township Manager Randy Soriano to present a written plan to the board on how he will implement the MS4 regulations.

The Environmental Advisory Council sent a letter to commissioners, urging the hiring of an MS4 expert to enforce the technical regulations of the mandate.

"They'd [the Environmental Advisory Council] rather focus on two things [MS4 education and public outreach] that they can do good," Soriano told commissioners during the March 12 workshop when the letter was discussed.

Soriano reported to commissioners at the Feb. 26 meeting he received a letter signed by Kreg Ulery, township Environmental Advisory Council chairperson, requesting a part-time person be hired to enforce MS4.

The Environmental Advisory Council voted 4-0, with one member absent at its Feb. 18 meeting, to send its MS4 recommendation letter to commissioners.

The March 18 Environmental Advisory Council meeting agenda noted the council is to start working on the educational and public participation plan for the MS4 program.

"Do we need a part-time person? I don't think we need to hire anyone," Soriano told commissioners March 12.

"We can in-house it, working with the township engineer," Soriano continued. "I'd rather have our engineer deal with the other MS4 requirements."

The Environmental Advisory Council voted 4-0, with one member absent at its Nov. 19, 2014, meeting to urge commissioners to hire a part-time MS4 coordinator.

"What they're [the Environmental Advisory Council] thinking of is someone in the township who is retired," Ackerman said. "We have to stress how important this is. The fines are staggering: $30,000-plus a day.

"I would like to have everything in writing," Ackerman told Soriano. "Who's doing this and every month it's being reported to the board."

"Do we have anything in place to do this?" Commissioner Vice President Debra Brinton asked.

"What the township has to do is some form of record-keeping," Salisbury Township Consulting Engineer David J. Tettemer of Keystone Consulting Engineers said.

"The [the EPA] want to know what happens at each inlet for example, a car accident with an oil spill. What you need is someone to document this," Tettemer continued.

"When John's [Andreas, Salisbury Township director of public works] guys go out and sweep the streets, they [EPA] want to know the width and length of the street," Tettemer said.

Referring to a seminar he and Soriano attended in December 2014, Tettemer said, "They were very adamant: 'We need to verify that you're taking this seriously.'

"You have to have that information readily available, and they [EPA] will be coming," Tettemer said.

"If we have this data base ... rather than hire someone?" Brinton asked.

""The missing piece in this right now is someone to oversee the documentation and maintenance," Tettemer said.

"I can do the work," Soriano responded.

"Write up a plan and submit it to the board," Ackerman told Soriano.

"This is another function of government. My cost will be zero," Soriano said.

"We need to have a report by the end of May," Tettemer said.

"It's just more documentation of work that's already happening," Andreas said.

Soriano and Tettemer were to meet about the MS4 documentation requirement.

The MS4 program has six components, designated "Minimum Control Measures," that when implemented are said to reduce pollutants discharged in receiving waters.

The six control measures and actions required by the Pennsylvania Department of Environmental Protection, which is authorized to enforce the U.S. Environmental Protection Agency mandate, are:

1. Public Education and Outreach: Distribute education materials and hold outreach programs to inform residents about the impact of stormwater runoff on water quality.

2. Public Participation-Involvement: Provide residents opportunities to participate in stormwater management.

3. Illicit Discharge Detection and Elimination: Develop and implement a plan to detect and eliminate stormwater discharges into the storm- water system, in addition to detailed mapping of storm sewer system.

4. Construction Site Runoff Control: Develop, implement and enforce erosion and sediment control for construction sites.

5. Post-Construction Runoff Control: Develop, implement and enforce discharges of post-construction stormwater runoff from new development or redevelopment.

6. Pollution Prevention: Develop and implement reduction or prevention of pollutant runoff from municipal operations.

The MS4 order is intended to prevent lawn pesticides, animal manure, residents' cars' used oil and automotive fluids, swimming pool chlorine, household detergents and the like from getting into stormwater systems and, therefore, streams and rivers supplying the Chesapeake Bay Watershed, which includes Lehigh and Delaware valleys.

The DEP could level a $35,000 per day fine against municipalities for noncompliance.

Daily fines for noncompliance were supposed to have gone into effect at the end of 2014. However, the township has not been notified by the DEP of any fines relating to MS4 noncompliance.

Salisbury, along with other Lehigh Valley municipalities, received notice June 25, 2014, of a 30-day deadline to provide EPA with evidence of compliance.

Ten municipalities in Lehigh County and 20 in Northampton County are among 85 in northcentral and northeast Pennsylvania receiving notification letters.

In addition to Salisbury, municipalities in the Lehigh and Northampton counties circulation areas of Lehigh Valley Press under the order include:

Catasauqua, Whitehall Township, Macungie Township, Upper Milford Township, South Whitehall Township, Emmaus, Alburtis, Weisenberg Township, Fountain Hill, Lower Saucon Township, Hanover Township, Northampton County, Hanover Township, Allen Township, Northampton, Walnutport, Freemansburg, and East Allen Township.

A MS4 is composed of drainage systems, including streets, catch basins, curbs, gutters, ditches, man-made channels and storm pipes owned by a municipality.

As part of the federal Clean Water Act, a municipality is required to have a MS4 National Pollutant Discharge Elimination System permit to cover stormwater discharges and to maintain compliance with the permit.

The NPDES permit program authorized by the Clean Water Act controls water pollution by regulating point sources that discharge pollutants into waters of the United States. Point sources are conveyances such as pipes or man-made ditches.

The objective of the Federal Water Pollution Control Act, commonly referred to as the Clean Water Act passed by the United States Congress in 1972, is to restore and maintain the chemical, physical, and biological integrity of the nation's waters by preventing point and nonpoint pollution sources, providing assistance to publicly-owned treatment works for the improvement of wastewater treatment, and maintaining the integrity of wetlands.