Section 405 of the Water Quality Act of 1987 mandates that municipal and industrial storm water discharges are point sources of water pollution and are subject to regulation under the National Pollutant Discharge Elimination System (NPDES) permit program. In response to Section 405, the EPA promulgated the Final Rule governing storm water discharges on November 16, 1990. The notice describes a two part permit application process for large and medium sized municipal separate storm sewer systems (MSSSS). A separate NPDES discharge permit application is required for storm water discharges associated with industrial activity. Compliance by all dischargers to the MSSSS will require the development and implementation of a municipal storm water management program. The management program will be incorporated as permit conditions of the municipality's NPDES discharge permit. It will identify priorities and procedures for inspection, and it will establish and implement measures to reduce the discharge of pollutants in runoff.