Here is the EPA's capsule summary of MS4 over the past 23 years, plucked from the EPA web page linked above: 

Phase I, issued in 1990, requires medium and large cities or certain counties with populations of 100,000 or more to obtain NPDES permit coverage for their stormwater discharges. There are approximately 750 Phase I MS4s.  Phase II, issued in 1999, requires regulated small MS4s in urbanized areas, as well as small MS4s outside the urbanized areas that are designated by the permitting authority, to obtain NPDES permit coverage for their stormwater discharges. There are approximately 6,700 Phase II MS4s.

In Pennsylvania and in Lebanon County, MS4 Phase II kicked in in 2003, administered for the EPA by the PA-DEP.  Neither agency provided local municipalities with any kind of funding or technical guidance for what was & remains a highly complex & technically intricate law.  Over the next seven years, Lebanon County's public officials mostly ignored the EPA's mandates, and little was done at the local, state, or federal levels to bring municipal stormwater discharges into compliance. Meantime water quality in the Chesapeake Bay continued to deteriorate. Those seven years of local inaction (2003-2010) are the main reason why local public officials are scrambling to comply with the law today.

At the federal level, Barack Obama's EPA took a moderately more aggressive stance on clean water issues than George W. Bush's, and finally in 2010, after seven years of foot-dragging in Lebanon County, the EPA in Washington took action.

The EPA Lowers the Boom

In April 2010, the EPA announced that 79 municipalities across the Chesapeake Bay watershed were in violation of the Clean Water Act. Ten of the 79 were in Lebanon County.  Each jurisdiction was ordered to comply through a "Findings of Violation and Order for Compliance and Information Request," as seen in the following PDF files:  EPA to Lebanon County  •  Lebanon City  •  Cornwall Borough  •  Jonestown Borough  •  North Londonderry Township,  •  North Cornwall Township  •  North Lebanon Township  •  South Lebanon Township  •  Swatara Township  •  West Lebanon Township.

After the EPA lowered the boom, public officials across Lebanon county, as across the Chesapeake Bay watershed, faced a looming crisis. Failure to comply with the EPA's MS4 mandates & regulations would bring lawsuits & stiff fines. Ignoring the law was no longer an option.

A year later, in April 2011 the LCCWA was created, spearheaded by Lebanon County Planning Department Executive Director Kris Troup. Conceived as a loose coalition of public officials who would meet every month or two to share information and coordinate efforts to the extent practicable, the group included representatives from most of the townships & boroughs in Lebanon County and the Lebanon County Conservation District. The only non-governmental organization to participate in LCCWA meetings at this early stage was the Quittapahilla Creek Garbage Museum in Annville.

Later that fall, in September 2011, the PA-DEP issued a revised & updated set of of compliance requirements, titled "National Pollutant Discharge Elimination System (NPDES) Stormwater Discharges From Small Municipal Separate Storm Sewer Systems (MS4s) General Permit (PAG-13)".  For local officials, this was & remains the MS4-compliance Bible. A couple of months later, in November 2011, the PA-DEP issued a clarifying memorandum on MS4, framed as responses to FAQs that local officials across South-Central PA had likely been bombarding it with.

Meantime, in October 2011, the City of Lebanon finally enacted a stormwater law to comply with EPA mandates. In January 2012, the EPA slashed the fine being levied on the City of Lebanon from a possible high of $177,000 down to $21,600. City officials grumbled & cried foul, as described in the Lebanon Daily News on January 24, 2012, (especially after the EPA rejected its "green" proposal for Stoever's Dam Lake in lieu of a fine), but the EPA stuck to its guns. My sense is they did it to set an example, and to drive the lesson home that municipalities can't just ignore the law for years — especially on such a vitally important issue — and expect a feathery slap on the wrist.

Why those seven years of inaction on MS4 among Lebanon County public officials?  Lots of reasons. For many, ignoring the law seemed a viable & sensible option, with George W. Bush's EPA fostering a culture of noncompliance without penalty or sanction. Feeding into that national dynamic was a host of more local factors:  institutional inertia; the specter of raising taxes in a region with a long & deep tradition of local control, anti-tax sentiment, and suspicion of the federal government; the patchwork quilt of more than two dozen local jurisdictions (one city, 7 boroughs & 18 townships) that worked — and continues to work — powerfully against county-wide & regional planning initiatives. Some likely figured that the MS4 law would eventually be watered down or repealed.  Critically important here, as noted above, was that the EPA and PA-DEP provided no funding, and the law itself was highly complex, requiring considerable technical expertise to even understand its requirements. Then in 2008-2009 came not only Barack Obama's EPA but the worst economic downturn since the Great Depression.  In the end, for roughly seven years (2003-2010), the easiest choice for most local public officials in Lebanon County was to take the path of least resistance and do nothing.

In early 2013, the LCCWA received a federal grant to be administered by the National Fish & Wildlife Foundation (www.nfwf.org) to hire the firm Land Studies, Inc. to assist in developing its organizational structure and take the first steps toward formulating a Strategic Action Plan. By summer 2013, the LCCWA was deliberating whether to formalize the group through a Memorandum of Understanding among its members, which it did in November 2013.

In May 2014, Kris Troup resigned from the Lebanon County Planning Department to take a job in North Londonderry Township, and the chairship of the LCCWA briefly devolved to Stephanie Harmon of the Lebanon County Conservation District.  In July 2014, Harmon passed the LCCWA baton to the newly hired Planning Department Executive Director Bob Sentz, who delegated most LCCWA responsibilities to Assistant Director & Community Planner Julie Cheyney.  In July 2015, Bob Sentz resigned his position, leaving the LCCWA in the hands of his former assistant Julie Cheyney.  At the present writing, the LCCWA and its constituent members continue to scramble to comply with an ever-changing set of federally-mandated rules & regulations.

Thus are the chequered origins of the Lebanon County Clean Water Alliance — a necessary & valuable coalition of public officials and community organizations focused on watershed & water quality issues that should have been organized back in the mid-2000s, and should do much more to genuinely engage ordinary citizens across Lebanon County about the importance of clean water, complying with federal mandates, and cleaning up the Chesapeake Bay.                   

—Michael Schroeder