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AGENCY TESTIMONY

MS4 areas and challenges in implementing green infrastructure

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    Deputy Commissioner Licata addresses the challenges of implementing green infrastructure in Municipal Separate Storm Sewer System (MS4) areas, as proposed in Intro 1254. The bill would require DEP to install 2,400 greened acres in MS4 areas by 2035, but the department has concerns about this mandate.

    • DEP believes that the 'greened acre' metric is not the best indicator of progress for green infrastructure programs.
    • Green infrastructure may not be the most effective tool for stormwater management in all MS4 areas due to factors like high groundwater tables.
    • The bill's mandate may not be achievable given the limited time frame and available space in MS4 areas, which make up only about 40% of the city.