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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. March 24, 2010

    provide a process for liscencing ‘green’ builders. I tried to do a ‘green’ project with a general contractor who wasn’t of the same mindset and it was a disaster. If public works projects could filter down to contractors with a ‘green’ stamp, it would facilitate ‘greener’ construction methods and designs.

  2. March 24, 2010

    Generally: Keep the watershed approach. This is the best way to direct our focus, to identify the problems, and to concentrate our efforts.

    Specificly: The EPA (and all state EPAs) should review Storm Water Pollution Prevention Plans (SWPPP) much more thoroughly – actually review the plan from the field rather than accept the plan if the contractor/developer has all the proper controls listed, whether they are appropriate or not.

  3. March 23, 2010

    Again, using pollutated, partially treated human waste-sewage sludge as fertilizer is a huge mistake. Many very large cities are bagging up their sludge as Class A, unregulated sludge and giving it away for free or selling it at stores. It is on Golf courses, schools, churches, lawns, gardens in the cities and towns everywhere.To test for only 9 heavy metals and 2 pathogens does not certify this material is “toxin free” and it is ridiculous for us to assume that it is. Class B sludge is being spread across this country on our farms. It leaches into the ground water, runs off the fields into streams and is flung into the air traveling across the countryside to other water ways. CAFOs have an enormous volume of waste. Unlike livestock that are out on pastures, their waste is gathered underground where it ferments alledgedly producing various superbugs etc. due to the unnatural feeding practices of antibiotics, steroids etc.. Livestock out on pastures have a different diet and their manure is out in sunlight and rain which will disperse it into the soil where it is used as a nutrient. There is a big difference between CAFO waste than a “Family Farmer” raising their animals the “conventional” way. The excessive amounts of chemical fertilizers and herbicides such as Atrazine are very harmful as well, more so than conventional animal manure waste as fertilizer. AGRI BIZ farming and using Sewage Sludge on farms are probably 2 of the most damaging things polluting our waterways. Until we change that I fear we won’t ever be able to clean up our water. We need to support our Family Farmers and encourage and help them instead of subsidizing AGRIBIZ.

  4. March 23, 2010

    I am concerned about post-construction NPS pollution by trash and litter from roadsides and parking lots. Urban storm drain inlets in my area lack any effective controls and every time it rains the river is a bobbing sea of cigarette butts, bottles and plastic bags. Meanwhile the TMDL process won’t even factor this pollution into the picture, all worried about nutrients and sediment. How will people care about protecting a river that is visibly an open sewer of trash? I start with the visible, then move to the invisible next.
    My sense is politically folks are worried about costs of upgrades, O&M of inlet filter cleaning and street sweeping and just not sure where to put any innovative BMPs as retrofits, green infrastructure that could solve the problem. First we have to admit this is a problem affecting recreation and do something about it under the clean water act.

    I am on a watershed group board for the past 9 years and every day I pick up at least 10 pieces of trash that could otherwise end up in the river, from the storm drains. It makes a small dent in the problem.

    Education is a large part of the solution but we need more support and pressure to mandate the other fixes, even as urban retrofits. Because Keep America Beautiful can only do so much. Why don’t we get the state DOTs to maintain their roadway buffers with native biodiverse vegetation instead of mowing? Conserving the streams and ditches instead of viewing them as mere conveyances of water.

    There is a big Pacific Garbage Patch bobbing offshore, in case we haven’t noticed. And 4 or 5 others elsewhere in international waters. The stuff is there for 20+ years killing all the large sea life, not to mention the unknown impact of plastic as it breaks down mechanically to smaller materials. Algalita Marine Research Foundation is shining a light on this.

    In some places my riverbank consists of silt filled shopping bags that hung up on sticks and sank. Floodways are full of beverage cans and bottles. The riverbed has dozens of tires per mile. No public agency is doing anything to solve this except the volunteers, and I fear our efforts are just a band-aid.

    Ohio has a great way of assessing and measuring water quality through biological indicators, IBI/ICI/QHEI which other states could learn from and emulate. Biodiversity and riparian corridors matter for water quality. A holistic approach to watersheds is important.

    Headwater streams are the capillaries of the river systems and they are still being lost too frequently. More emphasis on these would pay off. People need to view the street gutters as what they are: intermittent headwater streams that flow whenever it rains. Connecting everyone’s local sense of environmental health and quality of life to the watershed context is what is needed in every part of our nation. Unfortunately here our work is still just beginning, I think. Help us lead the way forward now, please!

    Thanks for the chance to provide this input.

  5. March 23, 2010

    • What approache have you seen in urban settings that have been effective in supporting achievement of the CWA goals?
    If a County Commissioner can be elected that cares and the political pressure from the Development Community can be withstood, then stormwater issues can be held to a minumum and corrected when found.

    • What actions can EPA and others take to promote these practices or approaches in support of achievement of CWA goals?
    a. When issues are brought to your attendtion by citizens, do not let them fall through the crack or be turned back to the citizen.
    b. The initial communications is critical. It the initial phone call or letter in response is not welcoming, there will not be a second chance.
    c. Truth to Power. Power does not want to hear truth. EPA has always got to be Truth to Power

  6. March 23, 2010

    Greetings EPA!
    The Solution may have basis on a single engineering fact. Sewers are most often gravity fed. Vulnerable to pressurization from loss of gap and uncontrolled input
    Most sewers have open grates. Air gap is required in sewer operation. Washout potential increases with mixed pipe systems and uncontrolled input.

    Storm pipes and tunnels are regulated under HOMELAND Security
    Priority Directive 7.
    The RISK to open sewers key word: “Sewer Weaponization”

    What is needed is a way to control, screen, and monitor the flow at the inlet to eliminate generally unwanted material from entering the system. Complete control of the flows at the surface inlet should also include a component for the TMDL mandate with a uniform means to measure surface pollution by taking advantage of drainage patterns. Such a plan should also prescribe via collected and reused surface washing to prevent and track pollution sources and abate with a physical source control so as to have a repeatable means of showing site characteristics in the pollutant loads being monitored via a singular flow control process understood as oil and water separation and screening.
    The idea is an integrated storm inlet flow control system that could be used to manage surface cleaning wash water so as to prevent an unwanted flow from entering the underground storm water conveyance system. Such an inlet would enable complete control over the flow at that inlet isolating it from the rest of the system. Plug and pump provides management of streets and parking lots with water. The scale of this idea brings up the obviousness that these systems need to be integrated into a watershed approach to managing pollutions and potential releases from industry transportation routes and onsite operations which might spill over in to local government land.

    What is needed. an inlet that will allow the streets to be cleaned with water again! A national inlet and prescription for managing the line between man and the natural water world. The limited use of water as a management practice provides a simplified, dust free approach to cleaning surfaces and managing maintenance of cracks insuring that the DOT road crew is not just pouring tar on top of weeds and dirt only to grow back shortly after.

  7. March 23, 2010

    Extend the scope of Section 438 of EISA (Energy Independence Security Act of 2007), which presently only covers federal construction, to all construction. This would decrease the quantity of stormwater being discharged to waterbodies dramatically. Section 438 applies to land disturbing projects with a footprint of greater than 5000 sq. ft. Its goal is to reduce post construction rainfall runoff to predevelopment rates. Think of the difference this would make on mega-mall, mega-store, or mega-housing development projects, as well as State DOT road projects!

  8. March 23, 2010

    Stop messing around with delicate sensibilities. The CWA was passed in the 70’s. 30 years latter were still talking about how much pollution can we withstand. Cities passing stormwater laws and then not enforcing them makes for confused developers and polluted waters. Federal law needs to require infiltration of the Water Quality Storm. Above all we need STRONG enforcement.
    In my area, cities have been begging the state for guidance. We give general guidlines and then wait to see what they come up with. We know the science, we know the problems, we know the solutions. Make it happen. Include all water bodies and headwater streams.

  9. Blayre permalink
    March 23, 2010

    The solution is very simple: the only way to stop pollution is to stop polluting.

    Everyone, including all businesses, need to stop using polluting chemicals. Finding natural, non-harmful alternatives to current chemcial usage is key. For example, I do laundry and all of my household cleaning with baking soda and vinegar.

    If farm production was natural and organic, not based on mass production, this would help as well. However, reality is difficult to face. I admit there are products I use (clothing, shoes, etc.) made with harmful dies and chemicals. It’s too difficult and expensive for the average consumer to completely buy safe products at this point in history. This is the root cause of all forms of pollution.

    Again, the only way to stop pollution is to stop polluting.

  10. March 22, 2010

    Save Maumee Grassroots Org. representing northeast Indiana specifically asked for:

    • Funding to develop and implement a watershed management plan for the Upper Maumee in Indiana/Ohio to improve the receiving waters in Ohio downstream.
    • Fix failing sewers and drinking water infrastructure – over 40 miles of 100 year old sewers lie under our city.

    • Stronger enforcement, oversight of NPDES (National Pollution Discharge Elimination System) permits; and fines for illegally discharging more than straight pipe permits allow.
    • Anti-degradation laws (passed down from federal law) need to be correlated and consistent between states and nations sharing the same receiving waters.
    • Create alternative designation for wetlands to be considered a vital “protected area” to alleviate flooding, pollution and green space need.
    • Floodplains should remain free and clear of structures and/or added fill dirt
    • No more phosphorus in waterways….limit fertilizer sales.

    Please check out the website for further information

  11. March 22, 2010

    Require all new developments to implement low impact development (LID) techniques. EPA’s own studies have shown LID saves developers money and protects water quality. Developers should have to capture the first inch of rain on site and treat 85% of the total suspended solids. I know much of this is party of the stormwater phase II requirements, but everyone needs to do this!

    Also require an undisturbed stream buffers of at least 50ft for all new development on streams!

  12. March 22, 2010

    Budgetary woes are having serious negative effects on municipal efforts to address stormwater management. All the regulations on the books are useless without people on the ground to observe, educate, offer options, and eventually enforce. What works? A wide-ranging public education program that is coupled with reasonable regulations and people to consult with offenders, followed by enforcement on failure to act.

    The bottom line for success means hiring adequate staff who understand adult education principles, who can use media to educate homeowner and commercial owners, and are provided with backing and budget to teach, consult, and enforce.

  13. March 22, 2010

    To be effective in reducing the impairment of our water bodies, I believe 3 areas are most important:
    1. Agricultural non point source pollution must be regulated and not just CAFOs. This is the low hanging fruit remaining in stormwater.
    2. Old municipal stormwater permitting requirements must be relaxed in favor of more effective watershed based approaches. They must be tailored to the specific challenges of the permittee.
    3. LID must become a normal way of developing. This will require a concerted effort of education & incentives and it must go beyond stormwater regulators.

  14. March 22, 2010

    Our rivers and streams have other problems that you cannot see with your eyes, but the visible part of the pollution of our flowing waters is what I am addressing. Floatables (floatable trash) are the improperly discarded plastic and glass bottles, aluminum cans, and cups, toys, tennis balls etc that are all turning our streams and rivers into wet moving landfills. Human individual responsibility and education certainly play a large part in this, but if these items could be redeemed for money or credit, maybe the hands that hold them and drink from them would not toss them after they are empty. From a volunteer cleanup of one backwater 2 acre slough in our urban state park in Jackson, Ms., we estimated 0.25 lb. of floating trash per linear foot of bank. In the urban reach (11 miles of our river) – the Pearl, plus lateral tributaries or urban creeks, that is, by my math, 26 tons of trash in the riparian woods that moves a little farther downstream with each flood. This is one urban area and it is not very big one even compared to other Southeastern US cities. Putting a large enough bounty on the recyclable portion of this mass of flowing garbage may help. Aluminum cans already attract can collectors- but the aluminum collection/redemption system could be strengthened. Making it easy for the plastic component to be recycled with some kind of redemption scheme also will help. At the state level here in Ms., the retailers, grocery stores and drink bottlers have a successful stranglehold on redemption schemes that are submitted as bills to the state legislature. Probably the same story in other states as well. We could redeem glass bottles at stores when I was a child. Why does all this plastic make a one way trip to the roadside and then move with gravity, rain, wind etc, into the river? The plastic bottle is a petroleum product, isn’t it? And it is being wasted on a grand scale (as are plastic grocery bags). If recycling needs container redemption programs to make it work better, the EPA could maybe study the legislative and other practical impediments at national and state levels and figure out how to make incentives work for people and ultimately for the waterways and the estuaries and oceans/gulf where this plastic gumbo is ultimately headed. If grocery chains, convenience store chains, Wal-Mart, Pepsi, Coke, Miller, Anheuser-Busch and Procter and Gamble/ Unilever are capable of thinking great environmental thoughts, they can surely apply some of that to the plastic bottle/container problem in our rivers.

  15. Ann Straut-Esden permalink
    March 22, 2010

    One area I have not seen mentioned is the local planning & zoning boards/commissions. Sometimes the people sitting on these boards are not educated about everything they should be before they are placed in this position of power. I will not knock these people for giving up their time (as most around here are volunteers), but I sure do wish there was some sort of mandatory classes/instruction required of these people (with yearly updates) so they were aware of not only their local laws, but the state and federal laws they usually forget about when approving new development/redevelopment in their towns.

  16. John permalink
    March 22, 2010

    Consider stormwater as a resource instead of a problem. Capture of stormwater through rainwater harvesting on-site and reusing it as a non-potable source of water would serve multiple purposes. It would reduce runoff volumes occuring during storm events (and reduce CSO bypass frequencies) and provide a large percentage of a sites water demand (water conservation).

  17. March 21, 2010

    The land application of sewage sludge is a travesty. In every given batch, there is no way of knowing what is in it, and the possible list is 80,000 items long. It is logical if the stuff was safe, you would have no reason to take it out of the effluent water in the 1st place. Seeing it applied for myself, slinging it in the air; smelling it myself and talking to farmers that have applied it and had to live through it at the detriment of other farmers within a two mile radius, (Customers won’t come near it, employees won’t come to work; people are getting sick from it, and the burden of proof lies with the victim. Who is kidding who? The stuff gets back into the water when it rains, perks into people’s well water, and we are hearing more and more complaints about food born illnesses. For all of your bragging rights about any of the good the EPA does, you can white wash all you want, but until you modernize your waste water science and put the burden of proof on the industry, you will have a hard time convincing me who you really work for.

  18. March 21, 2010

    In the seventies Congress authorized the construction of thousands of sewage treatment plants that were designed to remove hazardous industrial waste and other contaminants from sewage, so that the treated waste water can be returned safely to surface waters. However the removed pollutants do not go away; they concentrate in the resultant sewage sludge. As more treatment plants are built and old ones are being upgraded to solve storm water run-off, more sludge and dirtier sludge is being produced. To solve the sludge disposal problem, EPA exempted sewage sludge from solid and hazardous waste laws, so this contaminated waste can be used in rural areas as fertilizer.

    The Federal Clean Water Act defines sludge as a pollutant. Typical
    urban sludges contain not just nitrogen, but also thousands of industrial chemical compounds, most of which are not regulated or monitored, and some of which are highly toxic even in very small amounts. SLudge use has been linked to illnesses, deaths, degradation of farm land and GROUND WATER CONTAMINATION.
    We urge EPA to phase out land application and choose safer and more sustainable sludge disposal options that are truly beneficial, such as using sludge as a renewable source of non-fossil fuel energy.
    For additional information visit For documentation how facilitated transport of sludge pollutants can seriously impact ground water, visit

  19. March 21, 2010

    Reading all the comments in this string. There are a lot of good ideas in it. The one that hit me the most is the buffer and repair idea. Buffer zones should be rigorusly enforced and used with common sense. A 33 ft wide swath of grass guarding 800 or more tons of contaminated bedding sands from a creek is just a little bit much. the buffer zone should be planned accordingly to the ground truth of the situation instead of a model. After being put in use should have semi monthly inspections and monitoring. with testing of nearby waterways and conveyances it is guarding to make sure it is doing the job.

    We should repair and improve all of our filtration systems be it man made or natural. There is an idea on one of the thre subjects asked for comments about a work force to be created for this endeavor. To me these are the first critical things that need to be done. Laws are already on the books.

  20. March 19, 2010

    No-till and limited-till plans are growing in popularity nationwide and can be encouraged further.
    Educational materials on holding nutrients in place on soil can be disseminated widely. No one wants valuable nutrients to be wasted or washed away, but figuring out how to keep them where they belong despite the vagaries of nature can be costly. More progress is made with a carrot than with a stick.

  21. March 19, 2010

    (Relocated from Topic 2)!
    Thank you for taking stock of where we are in water pollution- comments so far are encouraging, and great progress is being made. EPA deserves much credit!
    Some serious problems in groundwater and stream pollution deserve increased public and industry awareness, much as water conservation efforts by many communities are paying off, even though it has taken much effort. So should we shrug off stream polluters? We can and should go after fixing the things we now can and need to fix. It will take years and many contaminants may not be controllable-yet. Let the mindset begin; start with those things we can control but may not have tried yet. Or perhaps dismissed as too small to worry, or always been there naturally; Stormwater runoff can’t be prevented–etc.
    Contaminants in streams threaten all down streamers and oceans and bays cling to them despite apparent dilution, to “within limits.”
    Selecting one among many “fix it targets” FLOODS deserve more preventive attention than they get. National loss in flood claims exceeds $8.0BIL/year plus cleanup and deductibles that are not even tabulated by anyone (NWIS has best try). Considering that most of that flood water has left various levels of pollution in other ground water plus basements, fields, farms, businesses, schools, etc., its time has come. We set out to study just this area in two local counties and streams carry much potential pollution to the harbors and beyond.
    We do not need to push geotextiles but they do offer a new solution to capturing large enough potential flood waters (which can now be better tracked or predicted). If we test, identify source, and tag basics with estimated volumes we could add an investigative tool at very low cost. Running down the smoking gun is a new threat to those who ignore regulation of polluting the environment presuming they will not leave a trail. We have patented a tool for this for other purposes like capture and fix streams, but in application it has to be looked at seriously because it will provide jobs that can pay for themselves. USACE will test this marvelous textile in June in Mississippi for another good purpose, and they started looking at it in 1989 so it is catching on as a strong new tool in water management. It has definite application in places like Florida which can be useful in infiltration of aquifer with high quality water, to attack a much polluted aquifer problem where reservoirs are too costly.
    Fixing floods before they flood, and capturing significant amounts of polluted water so it can properly be treated (and returned or marketed) is now possible. It involves as many as eleven federal agencies to work together. And it is a project that will take time to do it right but will pay for itself with environmental dividends. Details are available.

  22. March 19, 2010

    In the Last Green Valley up in Union, CT, there are many lakes, rivers, streams, watersheds, and reservoirs. These lakes and streams feed our wells and continue throughout CT and MA feeding millions of other wells. However, the town has decided the best coarse of action, would be to allow blasting on a mountain within 100 feet of a reservoir that feeds these rivers, streams and wells. The sediment and pollution runs off, polutes the watershed, kills the fish, and no one has the authority to stop the blasting. The best part is that once the blasting is completed, a Truck Stop plans to move in causing more pollution, sediment, and contamination. The state ignores our plea for help, the town is more concerned about the potential for tax revenue rather than our health, the EPA can do nothing, the DEP can do nothing, and the Last Green Valley can do nothing. So, who is in charge of making sure our waterways are not contaminated and that someone gets punished for doing so? There should be strict rules, regulations, fines, imprisonment, and clean-up required for businesses and towns that fail to follow these guidelines. We only have one planet, and the chance to save it, is NOW!

  23. March 19, 2010

    I am an Extension Educator for Ohio State University. It is difficult to get the developers, landscapers, and others necessary to educational events on urban storm water programs because there are not proper regulations, codes and ordinances in place as an incentive to encourage practices like rain barrels, rain gardens, rooftop gardens, etc. If there were more incentives for them to implement these practices I think we could do more to prevent issues from storm water that impact water quantity and quality.

  24. March 19, 2010

    I agree with much that has been said already. For my part, I believe that there are a couple of major avenues to address.

    First, start with public education (as has already been discussed) that includes local leaders in neighborhood communities that encourage residents to make better choices.

    Second and directly related, encourage and create programs/incentives/laws that support natural lawns and do away with highly manicured (and chemically controlled) green lawns. This will require a cultural shift, which is difficult no doubt but really necessary.

    Third, focus on the big problem areas like industrial farming/factories and other industrial centers- and make them accountable with stringent laws without loop holes. Someone already mentioned the dairy industry; beef, pork and chicken factories also need to be included in that. The amount of untreated waste that fills up in the outside lagoons enters the waterways with alarming consistency and frequency. Of course the food industry is supported in the political arena making it difficult to impose policies that will potentially make life difficult for the factory farmers. However, someone has to be willing to start making changes for the better- from the foods we eat to the type of lawns (or natural prairie areas, for example) that we maintain around our houses.
    Thank you.

  25. March 19, 2010

    The best way to protect water is to protect the head waters.

    This is the heart of our river systems throughout the US.

    Protecting water is protecting our homeland security. People truly do die without it. When it is manipulated or in most cases in WV polluted or buried the people suffer health impacts because they are forced to live without clean healthy water. The head waters of streams throughout the US starts here in WV. We are being impacted directly as people who have always depended on this water to be clean and healthy.

    The practice of valley fills and mountaintop removal coal mining is filling our streams with massive valley fills. This is not only polluting our water but it has pushed in our flood plains in the valleys. Our rivers now start at the tops of striped of mountains during rain events. The flooding from this process has turned our water into a weapon of mass destruction and depopulation in the name of getting to the coal underneath our mountains to flip on the switch.

    I am fortunate enough to have spent all my life in the second most bio diverse region in the world. Southern WV has been my home all my life. Now the coal companies are destroy this place and its people. The manipulations of permits and the long processes have allowed the destruction of many communities in Southern WV and there is many more currently being impacted.

    We should first and foremost protect our streams and people by banning the practice of mountaintop REMOVAL coal mining, sludge dams and valley fills throughout Appalachia and the US. Then we should do as much as humanly possible to restore healthy waters in streams and wells of the US by beginning here at their head waters. Supply training and jobs to former MTR employees in the idea of repairing the damage to our land, streams and people.

    We must move first to stop the most water impacting practice ever known to mankind.

    First we start protecting water! My opinion is that the last 8 years has been an attack on our water resources. I think now is the time that we BEGIN to enforce laws instead of bending or breaking the laws. The previous administration has got the coal industry spoiled much like a spoiled child. Now its up the the Obama administration to take the candy away from the spoiled child with rotting teeth. We must begin a transition. We CANNOT keep blowing up mountains and poisoning water to create electricity. This is inhumane. I pray for the day when we can have coal free electricity, united renewable energies workers of America, clean water and healthy land for our grandchildren. I think we are smart enough to do this before we end up with no coal, no electricity, no water and no plan for our future generations.

    reinstate the Bufferzone rule
    reinstate the clean water and enforce it
    ban the practice of mtr, sludge dams and valley fills
    Employee people in this process.
    This would be a start. The work has only begun at this point.

  26. March 19, 2010

    There should be more stringent regulations on construction sites. Limiting the size of an area to be cleared at any given time or the length of time a site can be cleared. There should be greater enforcement. Often times the “fine” is seen as a cost of doing business. Flood plains/riparian areas should be protected from development. As stated in earlier comments, everytime a new development is constructed, streams have more water to handle thus the stream becomes unstable and degrades. Stream buffers are important to dissipate the discharge from constructed storm water ponds. The buffer width may have to vary depending on the amount/velocity of the discharge.

  27. March 19, 2010

    The two basic problems facing control of developed areas are ignorance and motivation. Both cost money to remedy. A mail and broadcast media effort with house to house contact can involve the children and adults of a community by educating them on how they are poisoning their own community. For the property owners this may help mitigate their ignorance, and motivate simple inexpensive solutions on their part. Motivating the professionals involved in managing these waters will also require money directed to their budgets that can be used to repair and /or replace aging infrastructure already in place. These approaches can help limit the need for wholesale replacement of existing routing and treatment facilities.

  28. March 18, 2010

    Before we start throwing money on storm water problems, we first should review what was done in the past and learn from our mistakes, especially when we start addressing existing combined sewer systems.

    Sewer systems, more then centuries ago, were first built to collect the wash water from streets, since most life happened on streets, while human waste was collected and used in the agriculture. Only when indoor plumbing became available, were the houses hooked up to the existing sewer systems and these became combined sewer collection system, first discharging directly into rivers and later connected to sewage treatment systems with the necessary CSO’s (Combined Sewage Overflows) to take care of large rain storms.

    Since it was assumed that rainwater was clean, opinions prevailed to created separate sewer systems, one system for municipal sewage with treatment and one for storm water without treatment. Many, especially older cities, still have combined sewer collection systems and concerns are raised about their overflows, since they partly consist out of raw sewage and rainwater. This, in some countries with combined systems has led to limiting the overflow rates from 2 times to 5 times the average daily flow. So only when due to large rain storms the flows increases above 5 times the average daily flow, overflows are allowed. The rain water in the separate systems meanwhile has been proven to also cause pollution too, so now special treatment for storm water is considered. Another problem in separate sewers is related to faulty hook-ups.

    Sewage treatment started more then a century ago, mainly to prevent odor problems. After primary treatment (settling tanks) failed and realizing that a rotting process caused the odor problems, which could be prevented by keeping this process aerobic, secondary sewage treatment solved this odor problem. However, since such treatment incorporates liquid/solid (settling) separation, they also are sensitive for hydraulic loadings, limiting their treatment capacities and thus not suitable to treat the varying sewer flows from combined sewer collection systems.

    Although ‘secondary sewage treatment’ solved the odor problems, it does not treat the nitrogenous (urine and protein) waste in sewage, now called a nutrient. This waste besides exerting an oxygen demand, just like fecal waste, is also a fertilizer for algae, thus causing eutrophication often resulting in dead zones and red tides. Since ‘secondary treatment’ clearly does not meet any of the set goals of the Clean Water Act, they eventually will have to be improved, but before we make the same mistake by improving primary treatment with secondary, by now adding tertiary treatment, we first should evaluate other sewage treatment processes. This however only can be done if we also correct our present BOD testing procedures, which was the cause that nitrogenous waste in sewage was ignored and made it impossible to evaluate the real treatment performances of sewage treatment plants.

    Had we tested properly in the past, we also would have found that the oxidation ditch process, as developed by Dr. Pasveer around 1950, not only provided much better sewage treatment, both carbonaceous and nitrogenous waste, but also at much lower cost compared to conventional systems. Since the original concept was based on a sequencing operation, engineers quickly ‘improved’ the design by adding clarifiers and by doing so also introduced hydraulic sensitivities, similar to conventional systems. This probably in the future will prove to have been a mistake.

    Many older cities with combined sewer collection system and conventional sewage treatment are presently looking at what to do to solve their CSO problems and their lack of sewage treatment. Based on the past, the recommendation probably will be, to build a separate sewer collection system with some form of storm water pre-treatment and expanding the present secondary treatment with a tertiary treatment. This solution will be extremely expensive, but still be ‘environmental’ questionable.

    Much better would be to close the existing CSO’s and replace the existing secondary treatment with non-hydraulic sensitive treatment facility, based on the original oxidation ditch principle. Since this process does not require any sunlight, this facility can be built under ground and will probably cost even less than adding a tertiary treatment process to an already inadequate secondary treatment process. Such process would be much more reliable to provide advanced sewage treatment and will be much easier to operate, while solving two problems.

  29. March 18, 2010

    Urban Watershed problems I see serving on the local Planning Commission include contractors who are required to install water detention areas (infiltration and slow release) that become water retention (kept full) lakes that transfer 100% of storm water downstream and magnify the spikes of flow and erosion and flooding that taxpayers have to cover. A home or business lot on a pretty lake brings a high price, but even a higher price to the community in replacing old storm water systems downstream with bigger ones to handle additional flow.

    Properly designed dams can continue to release water at a reasonable rate while providing the capacity needed to catch and hold large rain fall events. There is NO enforcement on this common practice.

    I also appreciate comments above about the need for riparian plantings and measurable infiltration plans. Many cities and counties have contracts to scalp the grass short along roads and ditches creating faster water run off and little infiltration. Again taxpayers are paying for mistakes that will cost them more to fix down stream. ALL the problems downstream can be mitigated or fixed upstream with slower flow and greater infiltration.

    Glad to see that the philosophy of the Corp of Engineers has changed over the years. Our nation has suffered for many years from the effects of straightened and faster flowing rivers.

    Thanks for the opportunity to share ideas.

  30. March 18, 2010

    We have the best method in the world for fracting gas wells. Sure there is a possiblity of contaminating water. Our earth is not solid, it is composed of faults etc. We must get our country on the road to being self sufficent in energy. Were we worried back in the 1930’s if a well blew out and spilled oil everywhere. No. These same oil fields helped us win World War II. Geological Engineer

  31. March 18, 2010

    There is a lack of public awareness about stormwater, where things dumped down storm drains end up, and non-point source pollution. I see a great need for public education to try to change certain behaviors (i.e. dumping oil or other toxic chemicals down storm drains, not cleaning up leaf litter, grass clippings, or pet waste, and the effect of development and impervious surfaces on the local hydrology). Here in the southwest, we rely heavily on the rainfall to saturate the ground, recharge aquifers, and to keep our creeks flowing and our lake levels high. New developments should be planned with water supply and NPS in mind and required to draft a stormwater retention plan before they are permitted to break ground. As it is, private developers come in and build developments, get rich, and leave the municipalities with the stormwater, erosion, and NPS problems that they can’t effectively address without drastic and expensive retro-fitting. Thinking ahead, having a long-term vision, and taking preventative measures will lessen our stormwater issues to a great extent.

  32. Brian Smith permalink
    March 18, 2010

    I write a blog about alternative energy ideas. One of the ideas I’ve had is to divert stormwater overflow to areas of the Western US that need water. THIS SOLVES TWO PROBLEMS AT ONCE !! It would create jobs building the National Aqueduct system to route the stormwaters westward. It would move stormwater from places like Pittsburgh, where flooding pollutes drinking water to Western states where there are fresh water shortages. Green engineering technologies, like solar powered- archimedean water screw pumps could be used to pump the water into huge tanks, and these lead west where needed. In Arizona and California there are serious legal battles going on over water rights. Check out my blog at: if you want to see some new ideas. Thanks !

  33. Lori permalink
    March 18, 2010

    Eliminate combined sewer overflows into streams and opt for a more environmentally friendly sewer waste desposal system.

  34. March 18, 2010

    1. We need more money to clean up existing problems. 319 funds are well-spent and much appreciated, but the amount of money that is available is just a drop in the bucket. Even less money is available to help with regulated stormwater.
    2. We need to stop creating new problems. We need to spend less time talking to each other, and more time aimed at instigating a paradigm shift in thinking about our built environment. We know that impervious surface is a problem. Why aren’t we working harder to talk to the people who are actually installing or enabling new impervious surface? We know that rainfall patterns are changing. Why aren’t we reaching the people who are designing and building infrastructure that is undersized from the day it goes in the ground? Stormwater regulation is good, but we aren’t creating an understanding of why it’s necessary. We need that too.
    Thanks for this opportunity to air a couple of pet peeves.

  35. March 17, 2010

    i believe we need to tighten up our stormwater regulations to simply keep up with what rules have been enacted. this is because climate change is making for more large storms, and of course the stormwater problem is largely from large storms, not gentle drizzles. yet we continue to act as if what historically was a 100 year storm, is now and will in the future be a hundred year storm. yet that is totally incorrect. for instance, in the last 10 years, our area in the washington ‘burbs has experienced 4 storms that classify as “100 year storm events” (as well several “very rare” droughts that stunt plant growth and make the soil most prone to erosion in the next storm) — probably not a coincidence, but climate change. we also now generally get several of the “2 year storm events” per year. these ratings of storm events are antiquated. so, when big construction project, like those of State Highway, are required to contain only the level of rainfall in a “2 year storm event”, we are most likely to get several storms that overfill their design capacity (even assuming they built and maintained it properly, which they often do not do). and the inevitable overflow causes unnecessary sediment etc running into the streams. this is just one small part, but i feel need to be addressed.

  36. March 17, 2010

    Cost share money to finance retroactive stormwater BMP’s in residential settings previous grandfathered by Phase II. I heard a rumor “Phase III” might do just that?

    Enforcement capability targeting polluters like people who blow grass clipping into gutter, people who do not clean up after their dog, or apathetically toss trash onto the road. Greater enforcement of regulations currently on the books.

    Eliminate combined storm sewer systems. Ours are separate in NC but there are still overflows during heavy storms. Waste water treatment plants must be designed to accommodate larger storms as their frequency is more common than probability would recon.

  37. March 17, 2010

    Use the recommendations of the National Research Council report titled, “Urban Stormwater Management in The U.S.” and mandate LID in new construction and use numeric limits for permits that are enforceable – for industrial, municipal and construction permits so both dischargers and regulators have more certainty in compliance and enforcement.
    In addition the public needs to be part of the solution, as fuzzy as education can be most college educated adults have no idea all the oil, nutrients, pesticides and sediment goes mostly untreated into our drinking water sources and recreation areas – if you’re lucky enough to still be able to swim in your waterbody.
    Also need a lot of guts and courage by politicians as they just happily agree when the public says they demand clean water and aren;t willing to pay for it. If we don’t pay for it who’s going to get clean water for us, Santa Claus? Sadly our political leaders only respond to crisis so once we have lost our clean water they will act but after the cost has risen even more.
    Clean water is the biggest challenge of global warming and pollution is the biggest limiting factor for clean water.
    Thank you for providing this forum.

  38. March 17, 2010

    The Pollution Control Hearing Board in Washington State recently ruled that low impact development is “AKART” under the clean water act.

    In Washington we have come to realize that there is no stream protection without watershed protection. And the best watershed protection is to preserve the native vegetation and soils in the watershed. If that is no longer an option, LID is not just our best hope, but our only hope to save streams. The highest standard for LID in Washington requires that no discharge to surface water be permitted following development. Furthermore, a portion of the site must be retained (or restored) in native vegetation.

    If no discharge is allowed from developed property, the problems with stormwater quality, illicit discharges, nutrients, sediment, and channel morphing either disappear or are greatly reduced.

  39. March 17, 2010

    I think one of the simplest and most cost effective methods would be to require the creation of retention areas constructed to replicate natural wetlands which would be used to offset any increase in impervious surfaces created as a result of road construction and residential and/or commercial development.

    For example:
    Each highway on/off ramp should be a reservoir to collect and filter runoff with similar structures created along rights-of-way to mitigate additional runoff caused by road expansion.

    Residential applications could range from rain gardens in the case of a single family home to larger wetlands complexes in the case of a subdivision sized development.

    Commercial offsets could be accomplished locally or at some geopgraphical distance in the case of urban development such as a city’s “downtown” district which would make creation of a nearby offsetting wetland impractical.

    This approach has a number of beneifts, particulary in relation to cost, since equipment necessary to create such retention areas is on-site during the construction process. Such wetlands also provide significant wildlife benefits and require little maintenance once established.

    Thanks to the Agency for soliciting input on this extremely important topic.

  40. March 17, 2010

    Sanitary sewer overflows end up in stormwater. People illegally dump into manholes causing blockages and overflows. Manholes need to be locked to prevent access.

  41. Mandy Barre permalink
    March 17, 2010

    All development projects must retain stormwater on site and reuse it for landscape and groundwater charge. Filtration should be included for the excess. Further LID must be enforced stringently. In my area, the vast majority of runoff is contaminated with sediment from improperly graded land without usable and effective BMPs. More fines should be kept locally to assist with the stormwater enforcement.

  42. March 17, 2010

    The Forest Service’s urban tree canopy assessment program has been very successful at getting communities to establish tree canopy goals to help improve water quality – A key component of the assessment is high-resolution land cover mapping. We have developed techniques that automatically extract high-quality (~95% overall accuracy), 7-class (including 3 impervious surface types), high-resolution (1m or better) land cover data from readily available imagery to support the Forest Service on this front. It’s hard to take action if you don’t know what the situation is. High-resolution land cover mapping is one of the most important pieces of information that local decision makers can have. You can find out more about these techniques on our blog –

  43. March 17, 2010

    Recent Studies have found that over 40% of water polution in the U.S. waterways comes from the illegal dumping of used motor oil.

    According to the EPA;

    1) One gallon of used oil can contaminate 1 million gallons of fresh water.

    2) as much as 200 million gallons of used motor oil is improperly dumped each year in the U.S.

    3) in a city of 5 million, the used oil that drips onto roads then runs off with rain into rivers and oceans is the equivelant of a tanker spill into the waterways.

    I am the CEO of a company that is working in conjunction with the USDA to comercialize revelutionary patented motor oils made from soy oil. These motor oils which were developed by researchers at the USDA, are more effective than fossil fuel oils and are 100% biodegradable. I would like to participate in your efforts to clean up our waterways. please include us in your communications and discussions.


  44. March 17, 2010

    I applaud the overall objective of the CWA and truly await the day when broad implementation of a national stomwater management plan has been championed, not just referenced. Allowing the EPA to direct federal and state agencies towards the remediation of sensitive water bodies is long over due, and has been hindered by large industries for far to long.

    To address the various aspects of Topic 3, I believe that the central objective of the EPA should be to focus on defining the reach of the agency for regulatory control of water bodies. The evasion of communities, manufacturers or any polluter in general that has the budget to take a legal avenue versus implementing any Stormwater quality and quantity control measures is the central element to achieving the objective of the CWA. Based on my work experience in the field, I’ve found that enforcement of the regulations stipulated in the CWA for meeting NPDES (Section 402), SPCC (Section 311), TMDL (Section 301), etc is rare. Following the Supreme Court ruling in the case of Solid Waste Agency of Northern Cook County v. USACE, the increased tempo for forcing polluters to clean up their illicit discharges suddenly shifted after 2002.

    Today the majority of communities that strive to attain LEED certification or any green infrastructure rating is primarily on a voluntary basis. That voluntary aspect to appear conscientious of the environment is the primary driving force in the industry to date. The most effective tools I’ve seen to turn large businesses, especially commercial building owners/leasers is to show the potential cost savings that can be achieved by adopting the USGBC’s LEED requirements(to give an example). Convincing people that adopting green infrastructure is rarely difficult, the matter of who’ll pay for the infrastructure is another matter. It seems that the implementation of a stormwater management plan is only undertaken when there are potential monetary rewards i.e. fewer beach, lake, river closures that bring in revenue for the community and those green practices will pay for themselves in the long run. Having the EPA mandate that the community prevent discharges, limits defined by a conceptual site model (CSM) if necessary, and not allow large industries to legally challenge or wiggle out of treating their illicit discharges should be the central most objective of the EPA. I believe that once a national entity has the ability to regulate and enforce what is discharged into our water bodies, without continuous legal side stepping, that the elimination of pollution in our water bodies will begin to rebound.

    Thank you for the chance to comment.

  45. March 17, 2010

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

    As residents of a rural area with a nearby creek, we notice every time a new business is built nearby, the creek floods quicker and more severely. It goes over the road and strands all the residents on our road. Each time it floods, it picks up more debris and fertilizers from people’s yards and fields. This could be eased by requiring new businesses such as Walmart to plant sod on their huge roofs to absorb and slow rainwater, and to plant raingardens to slow the runoff from the huge parking lots before it goes into the stormwater system and overwhelms it.

    The creek keeps getting wider and we lose more land to it every heavy rain. Less land = less absorbtion of rainwater = vicious cycle.

  46. March 17, 2010

    Please pass the above discussion on to people and entities which might benefit from this suggestion.
    Jim Miller
    jimmiller5417 -at-

  47. March 17, 2010

    The great mid-American River system is the cesspool for thousands of cities, industries and farms. Many of the pollutants include soils which have been “washed” with industrial agricultural chemicals (non-point pollution) which when the soil is eroded, move to the rivers. These pollutants then grow algae and other micro-organisms, some of which create dead zones in the Gulf of Mexico.

    Fortunately, Asian carp feed on these micro-organisms, thus reducing some of the pollution. However, the native fish population pays the price because of the disruption of their food chain. Studies now estimate that Asian carp (mostly Bighead and Silver) make up 95% of the fish biomass in most of these rivers. The Asian carp population has exploded over the past few years and now threaten the seven billion dollar fishing industry of the Great Lakes. See: Asian Carps of the Genus Hypophthalmichthys (Pisces, Cyprinidae) ― A Biological Synopsis and Environmental Risk Assessment; ; Also see the Youtube documentaries: Part 1:; Part 2:

    Would a compromise work? First by reducing the Asian carp population by removing the breeders and secondly, by managing the carp population so as to allow native fish to recover. That way we allow the Asian carp to continue cleaning nutrients from the rivers and re-establish the native fish. There are additional benefits, namely the beneficial use of the harvested carp.

    The ACBSR final report concluded that the physical removal of the carp was the best working solution. Mention was made of training vast numbers of fisher folk on how to catch carp. Bait and hook does not work since the carp are filter feeders. Only purse (or hoop) nets seem to work for skiff quantities. What is needed is a commercial approach to harvesting carp.

    Carp Catchers Cooperative has such a plan (on paper). See: Carp Catchers Co-op,–+A+BRIDGE+OVER+TROUBLED+WATERS

    Carp Catchers Cooperative will be formed as a social entrepreneurial enterprise (L3C – Limited Liability Company), will build a fleet of three ships which will be able to harvest two tons of fish per hour. Currently, we have completed our initial material take-off and weight calculations and has a good start on the sourcing and pricing of materials and equipment. We have extensive research notes on nearly all technical aspects of the project. We are in need of about $300,000 grant with which to complete our working drawings, sourcing and pricing and submission to regulatory agencies for approval. Please take a look at the Youtube videos and visit our website, then send me an email as to how you can help.

    Jim Miller, President
    Mutual Aid Society of America, Inc.

  48. March 17, 2010

    Thank you for the opportunity to comment.

    I am concerned that the countries focus on bigf agriculture being a significant source of water pollution. Certainly farms large enough to require an NPDES permit produce a lot of manure each day which is utilized as nutrients for the crops they grow. The large dairy farms who can afford the cost, have installed manure digesters and are producing energy from the methane as well as a bi-product that is harmless and often used for bedding for their cows or a soil conditioner. We should be providing cost sharing for manure digesters. Large operations must have sufficient manure storage to hold at least 180 days of manure. But we should be providing cost sharing for manure digesters.

    NPDES permitted farms are the most regulated farms in the nation and bad operators have caused large runoff problems. I realize that the penalties/fines assessed don’t clean the water. But on the other hand large operations, CAFO’s for the most part are not in violation of their permits. There is no doubt that both EPA and state agencies vested with the duty to protect the land and water ignore smaller operations. A cow produces 8-18 lbs of manure depending on it’s size. All water runs downhill and eventually ends up joining other waters. Small farms managing 10 to 500 cows produce manure at the same rate large farms do. There are more cattle housed on small farms than on permitted farms in the nation. Regulators for the most part are ignoring this major source of water pollution. Dairy cows that are pastured leave cow pies all over the pasture. When it rains that manure joins with the rainwater and is transported to a body of water. The same goes for smaller farms that must spread manure everyday because they lack storage. States have little to no money to offer small farmers a cost share in practices or facilities that would reduce the amount of manure running off of their farms every day of the year.

    The nations regulation of large CAFO’s has significantly reduced the amount of runoff from those operations. We need to be address the manure runoff problems from all operations with livestock of any kind.

    Thanks for the opportunity to contribute to the conversation.

  49. March 17, 2010

    Thank you for the opportunity to comment.

    I am concerned that the countries focus on bigf agriculture being a significant source of water pollution. Certainly farms large enough to require an NPDES permit produce a lot of manure each day which is utilized as nutrients for the crops they grow. The large dairy farms who can afford the costs, have installed manure digesters and producing energy from the methane as well as a bi-product that is harmless and often used for bedding for their cows or a soil conditioner. We should be providing cost sharing for manure digesters.

    NPDES permitted farms are the most regulated farms in the nation and bad operators have caused large runoff problems. I realize that the penalties/fines assessed don’t clean the water. But on the other hand large operations, CAFO’s for the most part are not in violation of their permits. There is no doubt that both EPA and state agencies vested with the duty to protect the land and water ignore smaller operations. A cow produces 8-18 lbs of manure depending on it’s size. All water runs downhill and eventually ends up joining other waters. Small farms managing 10 to 500 cows produce manure at the same rate large farms do. There are more cattle housed on small farms than on permitted farms in the nation. Regulators for the most part are ignoring this major source of water pollution. Dairy cows that are pastured leave cow pies all over the pasture. When it rains that manure joins with the rainwater and is transported to a body of water. The same goes for smaller farms that must spread manure everyday because they lack storage. States have little to no money to offer small farmers a cost share in practices or facilities that would reduce the amount of manure running off of their farms every day of the year.

    The nations regulation of large CAFO’s has significantly reduced the amount of runoff from those operations. We need to be address the manure runoff problems from all operations with livestock of any kind.

    Thanks for the opportunity to contribute to the conversation.

  50. james scarbrough permalink
    March 17, 2010

    Why does EPA not force the state of georgia to issue a MS-4 permit to the state og ga DOT as required.
    DOT is just another BIG developer and should have to meet the same requirements as other land disturbing developers.
    What is fair for one is fair for all. Each developer should have to bear their fair share of preventing non-point source pollution.

Comments are closed.