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Topic 3: Stormwater Pollution

2010 March 16

What, where, and how communities build will affect their residents’ lives including access to clean water. More pavement and non-porous surfaces mean less area where water can soak into the ground, where it recharges our water supplies and nurtures ecosystems. Stormwater that isn’t absorbed runs over these developed areas, picking up contaminants and sediments that eventually flow into rivers and streams.

•    In light of the principles of smart growth, including green infrastructure, what practices or approaches have you seen in urban settings that have been effective in supporting achievement of the CWA goals?

•    What additional practices or approaches do you believe hold potential to support achievement of CWA goals?

•    What actions can EPA and others take to promote these practices or approaches in support of achievement of CWA goals?

For more detail about why and how conference participants will be approaching this topic, please see the Discussion Document at right.

Editor's Note: The opinions expressed here are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.

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85 Responses
  1. Pam permalink
    March 31, 2010


    I hope there can also be an emphasis made on retaining open spaces.

  2. Pam permalink
    March 31, 2010

    In my opinion, using assets as efficiently as possible is the way of the future. That being said, stormwater needs to be viewed as an “asset” and homeowners and businesses should be encouraged to consider capturing roof runoff and recycling this water for irrigation or gray water purposes. We need to take advantage of this resource. We should learn from other countries like Australia where they have had significant water shortages and adopt some of the measures they have implemented.

    Encourage native plantings. Ban the sale and use of lawn chemicals and prevent people of excessive lawn watering.

    Enforce littering fines –

    Education is the best way to make any change. We need to start to get our kids ready through educational programs in the schools now. In the meantime, I believe people think with their wallets, so perhaps there can be some incentive for “good behavior” and fines for “bad behavior” – that might be the way to go.

  3. March 31, 2010

    The issues facing our nation’s water resources are diverse and complex. We appreciate the opportunity to participate in this open forum to discuss both challenges and solutions to this national, and international, concern.

    Protection and management of our nation’s public forest land, and urban & community forests, is vital to integrity of our water resources. Through innovative partnerships, the Arbor Day Foundation collaborates with organizations nationwide to advocate for, and fund, strategic tree planting in areas of great need.

    In the San Bernardino National Forest in southern California, the Arbor Day Foundation is working with the U.S. Forest Service to restore portions of the Santa Ana Watershed within San Bernardino destroyed by large fires in 2007. Millions of California residents depend on water comes from the forest, making the health and well-being of the California forest ecosystems and watersheds is critical.

    For 33 years, the Arbor Day Foundation has promoted strategic tree planting and care in communities through the Tree City USA program because of the many benefits urban trees provide, including: cleansing urban waste water; stabilizing streambanks; controlling erosion; managing stormwater runoff; preventing pollution; slowing the rate of flood water; and controlling water temperature.

    In reviewing the creative suggestions and comments throughout this Forum, the Arbor Day Foundation would like to extend the invitation to interested parties to attend the Foundation’s annual Partners in Community Forestry National Conference. The Conference highlights current research and best practices in urban forest management and sustainable partnership management, including the innovative stewardship of our waterways, and is attended by a diverse audience of stakeholders, including professionals, community decision makers, and non-profit organizations committed to sustainability. Only when we all work together will we reach our common goal of healthy communities and sustainable ecosystems for generations to come. For more information on the Partners Conference, please visit

  4. March 31, 2010

    Remember, stormwater BMP’s, LID, and all the “on site” stormwater management we are seeing recently is indeed necessary on any given development, but it is *NOT* sufficient to maintain watershed health. For that, we need to keep our natural areas and green infrastructure to maintain the natural water cycle and ecological services that keep water running cool, constant, and clean.

    We would support more focus by the EPA on watershed level land use planning in order to prevent more impervious surface, prevent the conversion of green infrastructure (natural lands) into developed land that then must be “fixed” with an ever increasing tool box of stormwater management devices/designs.

  5. March 31, 2010

    Please make Low Impact Development Designs part of the requirements for achieving stormwater permitting. Please include funding for states that will allow them to improve inspection and enforcement of stormwater protections. Please include more funding for stormwater education so that more people in the community, not just in industry, can learn about clean stormwater and how to recognize pollutant sources. Please create funding mechanisms for municipalies to train their engineers and staff the intricacies of Low Impact Development designs. Many are at a point where they understand the concepts of LID, but they do not understand how to implement the designs. This is critical.
    Thank you for the opportunity to comment.

  6. Janet Andersen permalink
    March 31, 2010

    To support CWA goals, encourage redevelopment of previously developed land rather than spreading into new areas which require additional infrastructure – roads, stores, etc. All the normal LID principles should apply. Encourage the use of permeable pavement, native plantings, and discourage lawn irrigation systems. Sump pumps should go into stormwater systems, not sewers. Encourage people to pick up their pet waste. That’s one area where community peer pressure can make a great difference. Ask car inspection and oil change stations to provide information on how much water can be ruined by even a little spilled or leaking oil. Limit use of pesticides, increase training to licensed applicators.

    It’s hard to demonstrate that smart growth makes a difference. We need help to show people that their actions have consequences. Encourage stream and groundwater monitoring, maybe provide comparisons of flooding in areas with different zoning or wetland practices? Or historical water tests results at various public water supply systems over the years – have the ones near more development changed in a statistically different way than those with less development?

    To promote CWA goals, we must mandate cluster zoning, LID, permeable pavement in new developments near wetlands. Wetlands provide free stormwater management – somehow reflect the cost when people build in buffer areas and increase permeable pavement.

    While not strictly a stormwater issue, existing groundwater must be protected, both quantity and quality. We must think more about the quantity of water required in mechanical and agricultural processes. Cost is not adequate to shift methods to a less water-intensive approach. We must protect existing aquifers from contamination. I applaud the EPA for taking a look at hydraulic fracking for gas well drilling, especially in light of the potential for groundwater contamination.

  7. March 31, 2010

    The Great Lakes basin spans across eight U.S. states and Canada, with many tributaries and outfalls feeding into it. Each year, more than 24 billion gallons of combined untreated sewage and storm water is dumped into the Great Lakes. Although these discharges are less than 5% of the total amount of treated sewage discharged into the Great Lakes, bacteria and viruses are present in much greater concentrations in untreated sewage and so pose a significant health risk. Green infrastructure projects can play a role in reducing the load to these plants and EPA should encourage cities to incorporate such projects into local ordinances and building codes. EPA must also improve its enforcement of the nine minimum control policy and ensure deadlines for completion of long-term control plans are met.

    Impervious roads and parking lots, the major contributors and transporters of stormwater runoff, run well beyond the urban limits set by the U.S. Decennial Census and can be detrimental to the watersheds they run to. Watershed areas often span beyond city limits so the system as a whole needs to be considered when trying to preserve water quality. Expanding the areas subject to regulation beyond urban areas would help protect pollution sources to the Great Lakes not currently regulated and help address this public health concern.

    During the Great Lakes Stormwater Workshop in 2006, a list of major constituents of concern for the Great Lakes was compiled. It included total suspended solids (TSS), heavy metals, PCBs, mercury, E. coli, phosphorus, chlorides, and air volatile constituents (Final Report, 2006). As some pollutants are more prevalent in certain areas, consistent monitoring of those pollutants should be required, with limitations set. For example, the US Steel plant in Gary, Indiana has documented high levels of lead and arsenic, both of which are transported to surrounding waters during stormwater events. Discharges exceeded EPA benchmark values in many cases. The Alliance for the Great Lakes and others asked for improved monitoring and limits on stormwater discharges from this plant, but Indiana chose not to adopt many of our recommendations. EPA should require regular monitoring of stormwater pollutants, and the implementation of standards to measure against, to give each site a goal to reach.

    EPA’s rules must also explain how they will interact with existing and future TMDLs developed to address stormwater pollution from nonpoint sources. For example, the Indiana Department of Environmental Management (IDEM) developed an E. coli TMDL for Indiana’s Lake Michigan Shoreline and tributary waterbodies that appeared on the 2002 section 303(d) list due to the fact that there have been an average of more than 15 beach closures per year at the National Lakeshore and Indiana state park during the 1990 to 2000 period from violations of E. coli water quality standards. Nonpoint sources of pollution, such as stormwater runoff, were the focus of this TMDL. Other states have adopted similar TMDLs to address E. coli pollution from nonpoint sources. EPA should explain how both existing and future E. coli TMDLs will be addressed by new stormwater regulations.

  8. March 30, 2010

    Stormwater management was written into the original Clean Water Act. We are two generations hence and only moving at a snails pace in meeting goals and objectives. Most of the important barriers and facets to improved stormwater management include the following list. EPA needs to put effort and funding to adressing these.

    1. The people who make the ultimate decision are reticent to change. Even in the face of hard facts about the ineffectiveness of conventional stormwater management practices, the decision-makers all too often go with the status quo. We need to understand how and why this happens if we are ever to change it.

    2. ECONOMICS. The perception is that LID costs more. It has been shown to be less expensive for new developments on numerous occassions. For retrofits, more often LID is more expensive than conventional stormwater management. However NEVER are all of the true costs considered. Aside from capitol and maintenance costs, costs associated with the following MUST be inculded for a proper economic decision to be made: additional runoff, stream instability caused by additional runoff, water quality impairment, and treatment costs. Most commonly the taxpayer foots the bill for these costs because they are not included in the original stormwater management analysis or decision. This is not a very honest or fair way of dealing with stormwater. EPA needs to develop guidelines for valuing natural capital and services as well as the attendant benefits to social capital of improved environments.

    3. Sustainability needs to be factored into decision-making.

    4. Climate change needs to be factored into designs.

  9. March 30, 2010

    I am a stay-at-home mom with a master’s degree in envrionmental engineering with a focus on the effects of urbanization on water resources. Here is a brainstorming list of ideas:

    The single easiest thing one can do to make a dent in the problem is to ban the manufacture and sale of weed & feed products. Application of fertilizer should be separate from the application of herbicides. While this is but one step of many that needs to be done, it alone will cause a drop in the use of pesticides and perhaps some fertilizer as well in almost every inhabited watershed in the country.

    In addition, similar to cigarette packages, warning labels should be placed on the front of packages containing household chemicals (of all types) so that the average homeowner can become more aware of the potential dangers of the product. Warnings should not just be about direct human contact but potential dangers to aquatic life and drinking water as well.

    Development of watershed-based surface-and-ground water quality agencies should be encouraged, ones that cross city and county borders as needed. It would not be easy to hammer out details of how this would be done, but is the only logical way to manage water resources. Each agency could work on problems particular to the watershed, whether it is reducing pollution runoff to protect endangered salmon, cleaning up contaminated groundwater in an industrial zone, getting a river cleaned of invasive species, etc. (I was an intern at Puget Sound Air Pollution Control Agency, which worked to improve air quality for four counties — a similar idea.)

    Of course education of school-age kids about toxics and excess nutrients entering the waters of the nation should be incorporated into science curriculums at various grade levels. This work takes a generation to work, but we’re already seeing a shift in additudes among a percentage of the population.

    All business should be encouraged to pursue a cradle-to-cradle approach with their manufacturing and service activities. Start by banning styrofoam take out containers and charging for plastic bags. Have all waste management companies also provide for recycling and composting where they do not already do so. Have companies provide instructions on how to properly dispose, recycle, or compost their products and packaging, including stating the need to take unused product to a toxic waste facility if appropriate. Make it easy for end users to dispose of anything toxic at conveniently located facilites, paid for by the manufacturers (for example, we finally have free disposal of electronics in our area at certain locations, and even occasional curb-side pickup in some areas, paid for by the manufacturers, and we also have free toxic household waste dropoff facilities in the county, paid by taxes I think). The more that companies have to pay for the problems their products create, the more they will create products that don’t produce problems!

    Composting toilets and graywater systems should be allowed in building codes.

    Recognize that increased use of alternative energy will decrease the amount of pollutants reaching surface and ground waters through the burning of fossil fuels.

    Consider designating certain watersheds in each region as having special protection where possible, to create something of a wildlife chemical-relief corridor. Through zoning and other laws, allow no heavy manufacturing, no concentrated feedlots, wider buffers, organic farming encouraged, solar and wind energy encouraged, lower population density, restoration plans, etc.

    “Daylight” storm sewers where feasible (during new construction)and make them as stream-like as possible.

  10. March 30, 2010

    There are a variety of elements within the NPDES storm water program that have a weak nexus between monetary costs and the associated environmental benefits. The following are examples where low or non-discernable water quality benefits will be achieved relative to the high costs of complying with NPDES Phase 2 permits:

    – IDDE investigations everywhere throughout an MS4 drainage system.
    – Immediate BMP retrofit requirements, rather than incremental installation of BMPs with federal assistance (e.g., highway projects).
    – Widespread grab sampling of storm water, which results in data of dubious statistical confidence.
    – Cleaning out BMPs at regular intervals whether they need it or not.
    – Too much reliance on modeled (vs. measured) water quality (e.g., exceedances of dissolved metals).
    – Questionable findings and WLAs within TMDL reports.

    In my opinion, public dollars for “protecting the environment” would be better spent on restoring wetlands/floodplains; fighting/preventing invasive species; preserving rare species habitat; increasing regulation and oversight on fishing, farming, and mining; and implementing measures to abate urban sprawl.

  11. March 30, 2010

    Education works. You can see from where we were to where we are today. People want to improve their environment and need to know what, where, and how to do so. Cost is always part of the picture. MS4’s and related need to have the permitting at the municipality level not the State. The state should be engaged to help and teach not make those who work hard to meet the requirement feel that they are going to be fined. Knowledge is power. When people know what they need to do they take the power to do it. We need to get our heads together to help the agriculture industry with out spending them out of business. We need to remember where our food comes from and create simple technology to help not try to put them out of business. Everyone likes to eat. Regulations are good. To much paper work is not. Let’s not over document every little thing we do in the permitting process. Let’s spend the time for more useful activities than filling out papper work.

  12. Derek Berg permalink
    March 30, 2010

    To achieve the goals of the clean water act EPA should provide sound guidance on the performance and life cycle costs of all types of stormwater BMPs. Currently, long term O&M data for many BMPs is sparse and the data that is available is highly variable.

    EPA’s current focus is almost exclusively on “green infrastructure”, and while these practices should be vital components of our stormwater strategy many sites will also need to incorporate other types of BMPs to fully meet stormwater goals. EPA should device a consistent evaluation process that can be applied to all BMPs to assess their ability to removal various pollutants. Rather than prescribing a limited suite of BMPs EPA should focus on establishing pertinent water quality goals and identifying the BMPs that are able to meet them. This approach not only results in the most diverse list of BMPs, but it also encourages innovation of new BMPs to meet water quality goals more effectively.

    Given the growing emphasis on infiltration it is crucial that we fully understand the potential to negatively impact ground water quality. It is also important to recognize that infiltration is not always a viable strategy due to site specific conditions. Clear guidance should be provided on when infiltration should not be considered and on how best to manage stormwater in instances when infiltration is not feasible.

    Given the widespread neglect of our existing stormwater infrastructure, EPA should work to ensure maintenance of existing and new stormwater infrastructure is executed.

  13. March 30, 2010

    After reading all the discussion documents and comments, my head is awash. On our watershed level, I would support reducing nutrient levels on a voluntary basis at the watershed level. Education appears to us to be the hardest and yet the most important aspect of working toward clean water. Children are the most approachable – ideas and habits can spread from them. All the rules and regulations won’t get cooperation if people are ignorant of the need or resentful of how processes are brought about. Rewards (the carrot) rather than punishment (the stick), might yet work. There is no doubt there are more nutrients in our waters – coming from somewhere/someone’s practices. Simpler (and fewer) words would help too!

  14. March 29, 2010

    I think some of these people are too well fed. We take care of our land, people, and inputs so they do us the most good. I don’t want fertilizer and anything else we pay money for to end up in water any more than anyone else does, so we are careful how we apply all of these things. We don’t need more regulations added to all of the ones we have already. EPA just needs to listen to people who farm and not a group of people who have no idea what is really happening. Thank You!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!

  15. March 29, 2010

    We share Peter Silva’s opening comments that the impacts of the Clean Water Act (CWA) and the work of the Environmental Protection Agency (EPA) have made our nation’s water resources cleaner and safer. Included in the CWA is the National Pollution Discharge Elimination System (NPDES) and associated Stormwater Regulations. Regardless of the disturbance (i.e. mining operations, oil and gas construction activities or general construction activities) stormwater runoff can have a significant impact on water quality unless appropriate measures are taken to minimize sediments and chemicals flowing from the waters of those disturbed areas.

    The NPDES Stormwater Program requires general construction site operators engaged in disturbance activities (clearing, grading, etc) that disturb 1 acre or more to obtain coverage under the NPDES permit for discharges. Part of this NPDES coverage requires the operator to develop a stormwater plan that implements effective best management practices (BMP’s) to mitigate the potential impacts. BMP selection includes the use of multiple sediment and erosion control strategies, as well as, industry manufactured products (i.e. sediment logs, silt fence, erosion blankets, hydraulically applied products, etc) and seed specifically designed to assist the construction operator in reducing the impacts of excessive erosion on the site.

    Notwithstanding current regulations, when visiting construction sites throughout the country it becomes very apparent many operators are not implementing effective BMP’s as required by NPDES. In most cases, the NPDES permit program is administered and enforced by authorized states. It appears that many states lack the people power or knowledge to effectively monitor and enforce the NPDES Stormwater Program.

    The private sector should not be overlooked as an important partner to both state and federal agencies as they implement and enforce NPDES. The erosion/sediment control and seed industries are well positioned and eager to provide assistance and products to government entities, as well as, mine operators, oil and gas producers, general construction site managers, developers, states, counties, municipalities and others to implement more effective best management practices (BMP’s) that protect our lakes, streams, coastal waters, fisheries and other wildlife in the true spirit required under law by the Clean Water Act.

  16. March 29, 2010


    Stormwater polciy and regulations need to be thrown out and started all over. To me, they are a piecemeal product of trying to fill the holes of other regulations.

    If we can step back and agree that coumminites do not have the funds or resources to really be proactive on stormwater management we can then move forward with a different approach that is currently not working.

  17. March 29, 2010

    Require land use planning strategies as a stormwater best management practice and a part of watershed protection efforts.
    Abundant research over the past three decades has shown that site-level practices, in the absence of land-use strategies, cannot protect aquatic ecosystems from decline. Much of the literature suggests that the most effective means to protect water quality while accommodating growth and development is to limit new development to urbanized subwatersheds that have already been compromised. The Southeast is one of the fastest-growing regions in the country, and also one of the most sprawling in terms of land use. While it is important to manage stormwater of new development at the site scale, a number of planning principles to manage the creation of impervious surfaces at the watershed level would be more effective in preventing water quality degradation. We recommend requiring the following:

    1. Encouraging higher density development to accommodate growing populations on smaller impervious footprints.
    2. Promoting infill and redevelopment to reduce the amount of land consumed both within and outside of the development.
    3. Incorporating transportation planning to reduce the amount of pollutants associated with vehicle-miles traveled, and the amount of runoff generated by infrastructure such as roads and parking lots.

    As stated in EPA’s report entitled Protecting Water Resources with Higher-Density Development; low-density development, as compared to higher-density, can have a significant negative impact to water quality at the regional and neighborhood scales. This is the caveat to requiring low-impact development in our region. In the Upstate region, it is currently much more difficult to meet stormwater requirements on compact, urban sites than it is in areas where land is cheaper and more readily available. In particular, local municipalities feel very uncomfortable permitting the use of low-impact techniques on high-density development sites. Thus, applying stringent requirements for low impact development equally across all different types of sites could have the unintended consequence of encouraging sprawl.

    In recognition of the impact of planning for growth, the recently approved West Virginia MS4 permit provides incentives for brownfields redevelopment, redevelopment, mixed-use development, and high-density development. This approach to water quality protection should be used as a model for accommodating growth while protecting water quality when making changes to the stormwater rules.

  18. March 29, 2010

    Of course, all three approaches have to be given equal weight in the battle to keep our water ways clean: water shed protection, controlling nutrient levels, and storm water management. Florida has had good results from their efforts to reduce storm water run off. It has taken many years to get the responsible parties to act. Now that all levels of government are experiencing funding cut backs, some efforts have been put on the back burner. Buit at least they’re on the radar screen.
    Here in Port Orange, Florida, there’s a small body of water called Rose Bay. It was the receiving body for run off from a drainage canal that carried all kinds of heavy metals and petroleum wastes from commercial parking lots, pesticide and fertilizer run off from residential yards, effluent from the many residential septic tanks nearby, and other things that severely interrupted the food chain.
    In the early ’80’s a young Boy Scout working on a merit badge began doing water quality testing from a canoe with his dad. The levels of pollution he found, especially in the sediment samples, were off the charts. He turned his initial findings over to the county health department for verification and continued his sampling. The health department was impressed with the level of sophistication the boy and his dad used in maintaining accuracy and the integrity of his data. He wrote a letter to the editor that was noticed by a staffer at the St Johns River Water Management District, a state agency mandated with maintaining water quality standards in both ground and surface waters in this area. Years of run off had transformed the bottom of the bay from hard sand with aquatic grasses to a sludge and ooze filled embarrassment. Now, after many years and a number of broken promises, the bay will finally be dredged and the muck removed as hazardous waste. Work is scheduled to begin this summer. In addition, a number of remedies have been enacted to prevent the polluted run off from reaching the bay in the first place.
    In having to obey the law embodied in the Clean Water Act, the various government agencies that are finally getting their collective acts together will restore this once pristine body of water so that people can again eat the oysters found there. In the early ’20’s local seafood fanciers praised their quality. The local municipalities plead poverty and said there was no way they could fund the necessary alterations to the existing drainage system. Persistent application of the law encouraged them to locate funding sources.
    The most important benchmark for the EPA to maintain is a rigorous application of the law regardless of which party is in the majority in Congress or who sits in the White House. Difficult though this may be, it’s imperative if we’re to continue progress in cleaning up the nation’s water ways.

  19. March 29, 2010


    In light of the principals of smart growth, including green infrastructure, what practices or approaches have you seen in urban settings that have been effective in supporting achievement of a CWA goals?

    With regards to practices, it is the implementation or requirement of open / green space. Many of our municipalities now require a certain portion of a development to include a certain amount of open or green space as part of a development.

    With regard to approaches.—-Again, I referto the creation of comprehensive Watershed Management Plans. If these are created properly with community / citizen input , there will be buy in. and implementaion will be much easier.

    What additional practices or approaches do you believe hold potential to support achievement of CWA goals?

    As you may now guess if you have read all my responses to these topics, that I am partial to Watershed Management Plans. Created properly and implemented properly, they will achieve the goals of CWA.

    What actions can EPA and others take to promote these prqactices or approaches in support of achievement of CWA goals?

    I guess my answer to this question could be my “Executive Summary” to my respones to all I have written.

    EPA and others should encourage the creation and implementqation of comprehensive Watershed Management Plans. This should be done by prioritizing the issuance of grants to those watersheds that have. This would not only encourage watersheds to do so, but it would give EPA the assurance that the money is not only being spent wisely, but also EPA would know that the money is going to a watershed that has community / citizen buy in and that there will be in-kind contribution.

    I sincerely appreciate the opportunity to comment and share my ideas and our experiences on these topcs for EPA’s up coming conference.

    Respectfully submitted,

    George V. Barden
    Canandaigua Lake Watershed Inspector

  20. March 29, 2010

    One of the major components of the Clean Water Act is the NPDES Stormwater Programs Among other things, NPDES requires construction site operators to obtain permits for runoff. These permits require best management practices to mitigate erosion, silt, and other damaging impacts due to site disturbance. Regrettably, it is no secret that NPDES implementation on the ground is woefully inadequate. This is due to many factors, not the least of which is a lack of government resources.

    The erosion and sediment control and seed industries have an ongoing and vested interest in NPDES enforcement. These industries should not be overlooked as an important potential partner to both state and federal agencies as they are well positioned and eager to provide assistance both to government entities and to product end-users — mine operators, oil and gas producers, developers, and others. A host of sediment and erosion control strategies have been developed by the industry to meet NPDES requirements, including silt fencing, erosion blankets, and seed mixes specifically designed to minimize erosion.

    The erosion and sediment control and seed industries are proud of the critical role they play in protecting our nation’s precious water resources. They welcome the opportunity to engage in further dialogue as to how their resources and expertise might be more effectively utilized.

  21. Danelle permalink
    March 29, 2010

    Urban stormwater issues in my area are generally related to two issues: 1) aging infrastructure (SSOs and CSOs) and 2) impervious area. These are related problems, but will require different solutions.

    Aging infrastructure must be replaced with new systems that include stream-friendly practices. Should we be satisfied with a replacement that takes us from 50 overflows per year down to 3? Or can we find the financial resources to do better?

    We have a lot of work to do to improve the quality of stormwater, but even more importantly, we must improve the quantity. Flash flooding and channel erosion as well as loss of stable dry-weather flow must be managed/mitigated. This is the greatest threat to aquatic life in urban areas as well as a threat to stream-side landowners – the same landowners who will demand that the community spend tax dollars on paving the channels, a solution that is aesthetically and ecologically troublesome.

    We need to work at several scales to deal with the impervious surfaces in our watersheds. Residential rain barrels and rain gardens, curb cuts and pervious pavement, green roofing and wetland preservation are underutilized technologies and techniques. Interstate construction (especially where new lanes are added), new developments, and even small-scale infill housing should include methods for managing stormwater that go beyond the typical ‘get it out as quickly as possible’.
    – Along our nation’s highways (both urban and rural), create depressions in roadside ditches that will hold a couple of inches of water – not so deep as to cause safety concerns, but deep enough to retain some runoff on the landscape.
    – Begin a campaign for parking lot islands. There is no reason that these islands cannot be both aesthetically pleasing and provide a stormwater benefit.
    – Either tax new developments on the increases in impervious surface or offer tax incentives for those who develop without increasing the amount of runoff from their lot.
    – Offer incentives for communities that implement community-wide changes (rain gardens, tree planting, green roofing, etc.) in residential, commercial/industrial, and public areas that decrease their effective impervious area.

    There are many small solutions that will add up to large improvements if we can educate the right leaders and convince them that they need to make a change.

  22. March 28, 2010

    Stormwater waste is a difficult thing to handle with our ever sprawling wastewater treatment plant. The toxins and trash that run through our stormwater now is very harmful for human and ecological health. We need to support a new infrastructure that requires cities to run their waste water through treatment before it enters back into the environment. The city I currently live in here in Norman, OK currently tries to do this. While the entire city doesn’t have there stormwater from the streets coming in through its facility, it’s a start. The other problem is that we are not building cities in a efficient manner. If our cities offered more “green” initiatives in their infrastructure, I’m sure we would see a huge improvement in water quality in the stormwater. This doesn’t just include the cities itself, but how much access does the public have to dispose of hazardous waste properly, access to recycling, or even a simple trash bin. Our cities are spread out to much and initiatives like in Detroit, MI can help change this. Making everything closer and providing more greenspace in cities will help shape Americans minds on keeping a cleaner city. This shift will help, but more regulations are needed to keep us safe from our selfish ways that in the end can harm us. The core problem again is city infrastructure and what products we use. We could just throw money at the end result and try and clean up our mess, but it would be more cost effective to start with the main problem. It’s just like health care, we can throw money at the problem, but in the end the actual problem is not being taken care of.

  23. March 27, 2010

    RE: Soils and Stormwater

    Many stormwater Best Management Practices are soils-based, and many of the relevant soils are disturbed and/or anthropogenic — so-called “urban” soils, not properly mapped in conventional soil surveys. The NYC Soil Survey has pioneered in this area — mapped urban soils and conducted studies on soil infiltration rates (turns out land use is a key determinant of infiltration capability).

    On the NYC work, contact Rich Shaw at the NYC Soil Survey office (

    These goals should be promoted:

    – Whole Watershed Surveys. The Natural Resources Conservation Service should undertake soil surveys and soil survey updates for whole watersheds/sewersheds, even where more than one county is involved, and surveys and updates should adopt urban soil series pioneered by he NYC Soil Survey.

    – Comprehensive Soils Maps. NRCS should issue soils maps — including maps in its new Web Soil Survey system — that delineate all relevant soils investigations, including special site investigations, suitably flagging those that don’t meet NRCS certification standards and those that deviate from NRCS norms (e.g. identifying the presence of heavy metals and other toxics);

    – Interagency Coordination. NRCS and USEPA should take steps to better integrate NRCS soil surveys and soils research and USEPA initiatives for stormwater management involving soils-based best management practices.

    Robert Alpern
    140 Eighth Avenue, Brooklyn, NY 11215
    tel: 718/789-7692

  24. March 27, 2010

    Our non-profit group has been promoting a Retain the Rain program for several years. We have sold thousands of rain barrels, encouraged local governments to give tax breaks for installing rain gardens and swails. We have also been educating the public on the use of permeable pavers for driveways and sidewalks.

  25. March 27, 2010

    While water quality can be improved through increased use of LID, portions of the USEPA definition of class V injection wells hinders expanded use of LID. The definitions’ reference to “piping” or “distribution manifolds” is not useful. Whether surface to ground distribution is through PVC pipe (perforated or not) or a rock trench, the result is equivalent. The definition should make greater reference to the water source and specifically exclude cases where infiltration/perculolation of stormwater (and urban runoff) is the obvious intent of the system.

  26. March 26, 2010

    Water quality assessment for contaminant toxic risk needs to pay close attention to the water hardness (mg/l CaCO3). The ‘hardness dependent metals, especially, need to carefully relate to low calcium conditions because there is a wealth of sci lit that shows greatly increasing toxic effects as exchangeable Ca availability drops. I routinely see agencies responsible for assessing WQ data omit this step in assessment. The standards and criteria express this need, yet, it often is not paid attention to. When hardness ranges from 25 down to 4, a red flag should be placed on any H-dependent metal data. Toxics parameter data is critical for salmon recovery efforts in the Pacific Northwest, yet, few people understand the implications of the calcium issue within low-Ca waters that are prominent in freshwater salmon habitat in some of the watersheds that were most productive historically.

  27. March 26, 2010

    EPA should push harder on states to require or provide incentives for the use of Low Impact Development (LID) techniques in new development to improve stormwater quality. We have had great success incorporating the use of LID into our local subdivision and zoning regulations as a requirement. After a short learning curve the development community has become very proficient at incorporating swales, rain gardens and other low-impact design features into new developments, providing significant water quality improvements at low cost. If we can do this in a small, mostly-conservative rural community it can be done anywhere.

  28. March 26, 2010

    This comment applicable to all three approaches for better monitoring of our water. The list contained in CERCLA deserves input from the EPA in view of new compounds being introduced by industry. A “Fast Track” means for addition and detection in our waters is needed.
    Gene Nettles

  29. March 25, 2010

    Our family owns and operates Maple Ridge Bison Ranch in the town of Ischua in Catt County in Western New York. We have worked with our local FSA/USDA and the Catt County soil and water group located in Ellicottville N.Y. The recomendations these organizations provided we established a CREP program along the stream beds of our farm. We placed fences along both sides of the stream a least 35′ away from the center of the stream. This provides a 35′ plus buffer zone between animal waste and water. We also planted various types of trees and srubs between the stream and the fencing. Because we fenced in our stock water supply we put in fenced in stock water ponds to provide our bison with fresh water.

    These are a few things we did to improve our enviroment. If you are willing to use some of the resources available FSA/USDA and the local SOIL AND WATER GROUP alot can be done to clean up our streams.

    Please feel free to contact me if you have any questions.

    Have a great day


  30. March 25, 2010

    Our agency has had some success with working with innovative landscape architects and city planners to change the codes so that more green infrastructure designs can be implemented within the city-parish. Having people that are familiar with the landscape codes and development codes are essential to this process so they can understand the impediments to new designs for urban storm water.

    We still need to do a lot of education to convince the drainage engineers that green infrastructure does not necessarily equate to increased flooding. It is also still difficult to compete with all of the other infrastructure demands such as waste water treatment system upgrades and roads and highways. Cities and parishes are more focused on these issues so getting them to embrace the new concepts of storm water management continues to be an uphill climb.

    We see progress but not many green roofs yet. People must see how the costs are beneficial and affordable over the long-term before they will really take the risk to implement new designs that may not work or may not be what people are used to seeing. The EPA and Center for Watershed Protection have really helped with their guidance documents, webcasts and webpages, but more encouragement to utilized SRF and other funding sources to implement these innovative storm water designs are still needed.

    The Healthy Watersheds Initiative is a step in the right direction and should allow the states to prioritize where to spend their funds and focus their limited resources. Good ideas and should lead to stronger partnerships with NGOs and other agencies.

  31. March 25, 2010

    Controlling polluted stormwater runoff is a huge challenge. One thing that can be done to prevent the problem from getting even worse, is to improve planning to reduce increased loading. Offering assistance to local land use planners and managers can reap huge dividends to prevent new stormwater impacts. You shouldn’t just offer guidance and information. You need to proactively reach out to those who can most benefit from having this information.

  32. March 25, 2010

    – In light of the principles of smart growth, including green infrastructure, what practices or approaches have you seen in urban settings that have been effective in supporting achievement of the CWA goals?

    The best example of this is what I have seen in Seattle, WA and Portland, OR. Smart growth and green infrastructure principles are embraced and the public is enjoying the great benefits of these practices. In addition these practices go far in achieving the goals of the CWA.

    -What additional practices or approaches do you believe hold potential to support achievement of CWA goals?

    Meaningful enforcement. Enforcement that is not meaningful is worthless. For many violators, a small fine is just the cost of doing business and many times is much less expensive and time consuming than following the rules.

    We need a nationwide ban on flushing any and all pharmaceuticals, including OTC drugs. It’s bad enough that humans excrete the un-assimilated compounds into the waste stream, but to deliberately flush is exceedingly egregious.

    It is known that pharmaceuticals and endocrine disruptors are entering our waste stream, and not being removed by typical waste water treatment. Therefore, we are effectively medicating our streams. Fish with tumors and two sexes indicate that this is a serious problem. The practice of land application of sludge that comes from wastewater treatment plants is dubious at best and needs to be curtailed.

    Agriculture is going to have to start cleaning up the pollution they create. Agriculture one of the few industries that do not pay for what they pollute – same goes for oil and gas.

    The hits the CWA took from the US Supreme Court need to be fixed. Terminology like “navigable” water needs to be tightened so that polluters cannot get away with polluting upstream waterways that eventually harm water and people downstream.

    Remove any and all environmental management capacity from the US Army Corps of Engineers. Why do we have two Federal Agencies doing the same thing? Dredge and fill, 404 permits, etc., should be handled by the USEPA.

    Outlaw the practice of burying streams. Burying streams is contradictory to the tenets of the CWA.

    As communities grow, the increase in impervious surfaces must be ameliorated. And, it can’t be a suggestion that few will adopt. Green Infrastructure/LID practices to manage stormwater is proven to work, and the ancillary benefits are very great.

    – What actions can EPA and others take to promote these practices or approaches in support of achievement of CWA goals?

    In my experience people don’t change just because something is promoted or suggested. Inertia is hard to overcome. If you want people/industry/government to actually do practices that support achievement of goals of the CWA, then they will have to be required.

  33. March 25, 2010

    The following comments are extracted from the Ground Water Protection Council’s Ground Water Report to the Nation: A Call To Action, Section 6 Ground Water & Stormwater Management (full text can be found at

    Local governments nationwide are beginning to utilize Low Impact Development (LID) along with other stormwater management approaches to deal with water quality problems associated with urban development and redevelopment. Many have revised their ordinances and building codes and incorporated these concepts into holistic growth-development plans. However, it is critical that they acknowledge and address the potential for transferring a problem from surface water to ground water resources. The key to protecting both surface and ground water is to make sure that we select best management practices that proactively address the generation and treatment of potential stormwater contaminants before they enter the hydrologic cycle.

    USEPA and some states have embraced Low Impact Development (LID), which emphasizes reducing impervious areas, disconnecting impervious areas from one another, and treating stormwater so that it can infiltrate the ground near the source. The real challenge will be to make these approaches standard practice at the local level and to ensure that they are designed and maintained properly so that ground water is not degraded.

    Many of the potential stormwater contaminant sources from various land use types (e.g., agriculture, suburban, urban, industrial, and commercial areas) can take a the variety of paths to ground water (e.g., UIC Class V stormwater injection or drainage wells, bioretention facilities, land-surface runoff into rivers and streams, and land-surface infiltration into shallow aquifers).

    Traditional stormwater management techniques collect runoff from impervious surfaces and convey it to various discharge points, often by way of detention basins or other treatment structures. As a result, large volumes of untreated or minimally treated stormwater rapidly discharge into ground and surface waters. A better ways to manage stormwater is to replicate the predevelopment hydrology of a site and mimic nature’s processes for treating stormwater. In this scenario, stormwater management becomes an integral part of site and building design, rather than an afterthought.

    This new stormwater management paradigm can be found under the umbrella of Low Impact Development (LID), a hydrology-based approach to land development that is designed to reduce impacts to watersheds through the use of a variety of best management practices (BMPs). It is based on the premise that natural systems can accomplish a great deal if they are not overwhelmed with large volumes of stormwater or inordinate pollutant loadings.

    A key aspect of LID is to reduce the amount of impervious surface on development sites, thus reducing the amount of runoff that must be managed. This approach relies on thoughtful site design, decentralized stormwater management, native vegetation, landscaping, and small-scale hydrologic controls designed to minimize, capture, treat, and infiltrate stormwater.

    LID seeks to design the developed environment so that it remains a functioning part of the hydrologic system. It provides technological tools to plan and develop most types of urban sites to maintain or restore a watershed’s hydrologic and ecological functions. For example:

    *Reducing impervious surfaces to decrease surface runoff and promote stormwater infiltration into the ground. This often involves protecting and encouraging trees and open space, minimizing pavement, and using permeable surfaces (e.g., permeable pavement, turf block, gravel).

    *Disconnecting impervious areas by directing runoff elsewhere (e.g., directing residential downspouts to landscaped areas or rain barrels, and eliminating roadside curbs, where appropriate, to allow water to run off over the shoulder).

    *Intercepting stormwater by capturing rainwater before it comes into contact with an impervious surface (e.g., trees, ecoroofs, roof gardens).

    *Detaining and infiltrating stormwater in small vegetated areas, allowing it to soak into the ground or move more slowly into the storm system (e.g., planter boxes, infiltration basins, swales, soakage trenches, drywells, rain gardens).

    LID is an important means for maintaining stream baseflows, minimizing loss of recharge to aquifers, maintaining stream and wetland buffers, addressing flood concerns, and reducing stormwater pollutant loads from developed areas.

    While the LID approach has both strong environmental benefits and great possibilities to enhance the developed landscape, it is important to note, that many LID techniques are not always applied from the perspective of potential impacts to the three-dimensional watershed, which includes ground water. Without considering ground water, even LID techniques can allow polluted stormwater to impact ground water. Techniques that capture, treat, and infiltrate stormwater onsite continue to be developed, improved, and widely used, federal and state regulators and local communities must keep in mind the potential impacts to ground water resources by considering both aquifer sensitivity and the quality of stormwater.

    Infiltration drainage systems typically allow stormwater from impervious surfaces to be temporarily stored and then released into ground water over a period of time. However, a New Jersey study found that “infiltration of stormwater through detention and retention basins may increase the risk of ground water contamination, especially in areas where the soil is sandy and the water table shallow, and contaminants may not have a chance to degrade or adsorb onto soil particles before reaching the saturated zone” (Fischer et al., 2003).

    An 18-month study monitoring swales and detention pond systems receiving stormwater runoff from interstate highway, residential, and commercial land use areas in Florida found that most stormwater can likely be infiltrated with minimal impacts (Harper, 1988). The study indicated that removal processes in soils are likely to reduce most infiltrated pollutants; however, some pollutants are more likely to cause problems than others, and these must be more carefully considered in infiltration projects. The author cautions that critical pollutant source areas should be avoided and that pretreatment before infiltration to remove particulate forms of the pollutants should be considered.

    Concerns associated with stormwater infiltration involve the design life of the systems and the potential to contaminate ground water if they are not applied appropriately and monitored and maintained so they function as intended. Earlier generations of infiltration BMPs (e.g., infiltration trenches, retention ponds) tended to clog with silt, largely because they were not properly sited, designed, installed, or maintained. Once clogged, such systems do not work and may even degrade surface water quality by allowing re-suspended sediment to run off into receiving waters. (NHDES, 2001)

    While there is more and more interest in using infiltration BMPs for surface water pollution control, we have relatively little information on the transport of pollutants around and through infiltration systems. What is the risk to ground water resources from recharging polluted stormwater? There are situations where infiltration is simply not suitable because the potential to contaminate ground water is too great (e.g., stormwater from industrial sites, petroleum storage facilities).

    A study by Robert Pitt and others (1994) found that some pollutants in stormwater may have an impact on ground water in certain circumstances. These pollutants include nutrients (e.g., nitrates), pesticides (e.g., lindane and chlordane), other organics (e.g., 1,3-dichlorobenzene, pyrene, fluoranthene, VOCs), pathogens, heavy metals (e.g., nickel and zinc), salts (e.g., chloride, road salts).

    Pollutant threats vary with land uses and human activities. For example, as detailed in the Pitt study, pesticides tend to be found in urban runoff from residential areas, especially in dry weather flows associated with landscaping irrigation runoff. Volatile organics are mostly found in industrial areas. Zinc is often found in roof runoff and areas where galvanized metal comes into contact with rainwater. Road salts are at their greatest concentrations in snowmelt and early spring runoff in northern areas.

    The Pitt study emphasizes that control of these compounds requires various approaches, including source-area controls, end-of-pipe controls, and pollution prevention. However, “with a reasonable degree of site-specific design considerations to compensate for soil characteristics, infiltration may be very effective in controlling both urban runoff quality and quantity problems.” In keeping with the LID
    approach to stormwater management, the study encourages use of the natural filtering and sorption capacity of soils to remove pollutants, but cautions that the potential for some types of urban runoff to
    contaminate ground water through infiltration requires some restrictions, including adequate pretreatment or diversion of polluted waters away from infiltration devices.

    Stormwater infiltration is of greater concern now because federal stormwater requirements under the National Pollutant Discharge Elimination System (NPDES) encourage infiltration of stormwater as a
    means of avoiding an NPDES permit for a discharge to surface water, and because more states are recognizing the potential for reducing hydrologic impacts of urbanization by recharging a prescribed amount of stormwater.

    In a 2005 Ground Water Protection Council (GWPC) survey of state regulatory personnel, more than half of the states that responded indicated that they encourage stormwater infiltration, where feasible, over surface discharge. The majority of responders indicated that some type of authorization is needed for installing units designed to direct stormwater into the subsurface, both infiltration systems and direct discharge systems. The type of authorization required ranges widely, from UIC rule authorization to different permitting mechanisms, such as sensitive area permits, stormwater general permits, or individual permits.

    Several states have enhanced protection/restrictions for introducing stormwater into the subsurface (more protective or otherwise segregated) in or near source water protection areas, wellhead protection areas, vulnerable aquifers, or other sensitive ground water areas. Site-specific case studies have documented ground water contamination from stormwater drainage wells.

    USEPA’s current stormwater guidance, Potential Ground Water Contamination from Intentional and Nonintentional Stormwater Infiltration (Pitt et al., 1994), developed under the NPDES stormwater program, is probably not sufficiently protective of ground water resources. For example, the guidance promotes the use of Class V stormwater drainage wells as BMPs to prevent the release of pollutants to surface waters. However, the placement of diverted stormwater underground via such wells may endanger underground sources of drinking water. States need state-of-the-art technical and best management practices guidance to protect ground water from stormwater discharges. At a minimum, a complete compilation and synthesis of case studies on ground water contamination from stormwater discharges is needed. It is inefficient for the states to individually research this subject whenever they are revising their stormwater rules and/or guidance, when much of the same research could be applied nationally.

    Another federal and state regulatory issue related to ground water impacts from stormwater is the definition of Underground Injection Control (UIC) Class V wells. Based on the definition published in the 1999 Class V Rule, stormwater Class V wells include stormwater drainage structures that are wider than they are deep, such as improved sinkholes and subsurface fluid distribution systems.

    Yet there are still some categories of stormwater drainage structures that fall into a gray area as to whether they are considered Class V wells. Thus, they may present risks to underground sources of
    drinking water similar to those posed by Class V stormwater drainage wells. Federal and state UIC Class V Programs and NPDES Stormwater Programs must work together to clarify such issues and educate communities on how to best manage and regulate stormwater to protect all water resources effectively.

    One factor that may have a bearing on how states approach stormwater infiltration is a determination as to whether infiltration is considered to be an “aquifer recharge system” or a “stormwater disposal system.” The GWPC survey indicates that the majority of states view stormwater infiltration as disposal, suggesting that recharge is not addressed with the same level of concern for ground water quality as it would be if it were treated as a drinking water source. State drinking water, UIC, and stormwater regulatory programs need to coordinate the manner in which they control stormwater discharges to ground water. They also need stormwater monitoring (surface or ground water) requirements for units that infiltrate or directly discharge stormwater to ground water.


    To USEPA:
    Establish better coordination among federal stormwater management, ground water protection, underground injection control (UIC), and water quality monitoring programs so that programmatic overlaps and opportunities for collaboration in protecting surface and ground waters can be identified and initiated. Accord the protection and recharge of ground water and protection of surface water equal importance when regulating and providing guidance to state stormwater programs. For example:
    • Develop and field-test BMPs specifically designed to manage stormwater in a manner protective of ground water in different hydrogeological settings (e.g., karst, sand and gravel).
    • Ensure that states may utilize Clean Water Act §319 funds to conduct research and demonstration projects, and to develop and field-test BMPs specifically designed to manage stormwater in a manner that is protective of ground water.

    To State Agencies:
    Establish better coordination among stormwater management, ground water protection, underground injection control (UIC), and water quality monitoring programs so that programmatic overlaps and opportunities for collaboration in protecting surface and ground waters can be identified and initiated. Review stormwater management plans and total maximum daily load (TMDL) determinations from a ground water program perspective to ensure protection and conservation of the resource.

    To Local Governments:
    The day-to-day work of managing stormwater rests, for the most part, with local governments. In fact, communities may have several stormwater requirements that they must meet. For example, the federal NPDES Stormwater Phase II requirements require many urban communities to develop comprehensive stormwater management programs. States may also have comprehensive stormwater management policies or requirements that communities must meet. However, both must have a ground water component to be fully effective.

    Communities need to develop their own comprehensive stormwater management programs. Local governments are making the land-use decisions that will either make or break the health and well-being of their water resources. Local governments need to recognize that they have this responsibility and develop storm sewer management programs. Protect all water resources through local stormwater management activities, and require the use of stormwater BMPs (including ongoing maintenance and monitoring), stormwater utilities, and stormwater management plans that are designed to conserve and protect both surface water and ground water and promote natural ground water recharge.

    Michigan ground water stewardship program
    Lemon Grove, CA
    University of New Hampshire Stormwater Center
    Texas Edwards Aquifer Protection Program

  34. Small Farmer permalink
    March 24, 2010

    Article 1, Section 8 of the U.S. Constitution does not authorize Congress to legislate in the area of the environment
    , therefore, it is unconstitutional. All 50 states of the Union have their own version of the EPA as authorized under the 10th Amendment. There is no need for a federal agency. The states of the Union can handle their own environmental needs as authorized by their legislatures.

  35. March 24, 2010

    Outlaw the use of coal tar; coal-tar-based sealcoat products have a mean polycyclic aromatic hydrocarbon (PAH). See this study:

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