Graduation Year


Document Type




Degree Granting Department

Environmental Science and Policy

Major Professor

L. Donald Duke, Ph.D.

Co-Major Professor

Robert Brinkmann, Ph.D.

Committee Member

J. Edwin Benton, Ph.D.


urban drainage, municipal separate storm sewer system, Florida industry, environmental policy


Stormwater pollutants originating from industrial facilities can lead to degraded

water quality, even in residentially dominated regions of the country. The National

Pollutant Discharge Elimination System permit program regulates stormwater pollutants

generated at industrial sites using Multi-Sector General Permits (Generic permits) for

industrial facilities and a permit requirement for Municipal Separate Storm Sewer System

(MS4) operators. All industrial facilities within 11 broad categories of industry are

responsible for self-identifying the need to comply with the Generic permit, and

subsequently, implementing self-selected pollution prevention strategies. MS4 operators

are required to identify and inspect “high risk” industrial and commercial facilities that

may be contributing substantial pollutant loads to the MS4, in addition to other

requirements. This is partially in recognition that compliance with the Generic permit has

been poor. This dual level of regulations is designed to enhance water quality protection,

however, the reliance on local inspectors to develop a definition of “high risk” has led to

irregular implementation.

This research developed a methodology to identify industrial facilities and then

screen out facilities that may not require inspection by the MS4 operator. Phone

questionnaires were administered to 250 industrial facilities. Results were validated using

fenceline visits and on-site inspections with local inspectors. Overall compliance by

participating facilities with the Generic permit was approximately 10%.

Neither the Generic permit nor the MS4 permit has been effective because

numerous facilities have gone unregulated. Currently, the Generic permit has attempted

to regulate too many facilities, many of which may not be affecting water quality. MS4

“high risk” inspections have not improved compliance with Generic permit either

because of the prioritization of facilities. The reliance on local interpretation, which

requires MS4 operators to select a definition of “high risk” based on their desired level of

water quality protection and available resources, can potentially exclude many facilities

from inspection. Adopting a definition of intensity for regulating industry may both

improve compliance with the General permit, ensure water quality protection, and

improve resource usage.