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50 The Authority │ April project constraints including severity and correctability. This critical step confirms project viability and refines preliminary credit calculations before projects are selected for concept designs and inclusion in the RAS/VMP. Ultimately, this structured approach allows permittees to develop and execute the RAS or VMP - a definitive roadmap of projects slated for design and implementation within the 5-year permit cycle. By prioritizing areas with high impervious cover and diversifying the project portfolio with a variety of BMP/ SCM types, permittees ensure the final plan is both robust and adaptable. This methodology transforms the technical assessments and matrix rankings from the initial phases into a concrete action plan, providing a cost-effective, defensible strategy that maximizes credit yields and ensures long-term regulatory compliance. To learn more about this topic, visit us at the PMAA conference in September! Design and Implementation The next phase following planning and concept is design and implementation. It can often be a challenge for small municipalities to dedicate personnel to the review of stormwater designs and the overseeing of construction implementation. Designs can include existing dry pond retrofits, stream and floodplain restoration, tree planting, regenerative step pool conveyance systems, riparian buffer plantings, rain gardens, and more. Maintenance and Tracking Effective maintenance and tracking are essential counterparts to planning and implementation. Success requires consistent monitoring of restoration credits and permit-term goals, backed by a meticulously updated RAS or VMP. It’s imperative that critical data for project completion be tracked, including BMP type, impervious acres or volume treated, costs, and completion dates. This data will help to inform future planning efforts. Furthermore, an adaptive approach to future permit terms, combined with rigorous inspection and maintenance, ensures that facilities function as designed and continue to meet restoration targets. Proven Success The draft PAG-13 is an acknowledgment that the Maryland model of runoff volume reduction through impervious area management is a viable path toward water quality restoration. By moving away from abstract pollutant reduction percentages and toward the tangible management of runoff volume, Pennsylvania is following a road map that Maryland permittees have already successfully navigated. This alignment not only streamlines regional restoration efforts but also provides Pennsylvania municipalities with a proven framework for success. S References: 1. https://mde.maryland.gov/programs/water/StormwaterManagementProgram/Documents/2025.08.22%20-%20SHA%20 Basis%20for%20Final%20Determination.pdf 2. https://greenport.pa.gov/elibrary/PDFProvider.ashx?action=PDFStream&docID=9086761&chksum=&revision=0&d ocName=08+-+NPDES+GP+FOR+STORMWATER+DISCHARGES+FROM+SMALL+MS4S+VMP+INSTRUCTIONS&nativeE xt=pdf&PromptToSave=False&Size=185512&ViewerMode=2&overlay=0 3. https://mde.maryland.gov/programs/water/StormwaterManagementProgram/Documents/Final%20Determination%20 Dox%20N5%202021/MS4%20Accounting%20Guidance%20FINAL%2011%2005%202021.pdf 4. Redefining Urban Areas following the 2020 Census 5. PAG-13 Draft Permit: https://greenport.pa.gov/elibrary/GetDocument?docId=9086653&DocName=04%20-%20 NPDES%20GP%20FOR%20STORMWATER%20DISCHARGES%20FROM%20SMALL%20MS4S%20PERMIT.PDF%20 %20%3Cspan%20style%3D%22color%3Agreen%3B%22%3ECOMMENTS%20DUE%20MARCH%2019%2C%20 2025%3C%2Fspan%3E%20%3Cspan%20style%3D%22color%3Ablue%3B%22%3E%3C%2Fspan%3E 6. Current Phase II MD Permit: https://mde.maryland.gov/programs/Water/StormwaterManagementProgram/Documents/ NPDES%20PII%20FINAL/Muni%20PII%20permit%20final%20042018.pdf T he success of M aryland permittees proves that while the D raft PAG-13 requirements are challenging , they are entirely achievable through structured planning and standardized processes .