Developing Successful Runoff Control Programs for Urbanized Areas in Prepared by: Northern Virginia Soil and Water Conservation District Fairfax, Virginia fulfillment of Grant # X-820828-01-0/1/2 from the Nonpoint Source Control Branch, Office of Water, U.S. Environmental Protection Agency Final Report July 1, 1994 ------- ------- TABLE OF CONTENTS ACKNOWLEDGEMENTS u j EXECUTIVE SUMMARY l DEFINING THE PROBLEM OF URBAN RUNOFF MANAGEMENT , - 4 Introduction Purpose and Intended Audience of this Manual 4 Brief History of Runoff Control 5 How Urban Runoff Adversely Affects Water Resources . / The Need for Urban Runoff Management 7 Retrofitting Developed Areas J« Local Governments' Compliance with Federal and State Regulations 11 Summary of Selected Federal Water Quality Programs 12 BRIEF SURVEY OF CURRENT METHODS AND TECHNIQUES 14 Types of Urban Runoff Retrofit Techniques - - 14 Nonstructural Methods to Control Urban Runoff 15 Structural Runoff Controls for Highly Urbanized Areas 16 DEVELOPMENT & IMPLEMENTATION OF AN URBAN RUNOFF CONTROL PROGRAM 19 Important Program Elements 19 Building a Strong Institutional Foundation - -1 Assessing Institutional Resources 23 Setting Priorities/Selecting Management Practices 25 How To Overcome Roadblocks to Implementation 26 Funding Options/Alternative Funding Approaches : - 31. Elements of Successful Programs/Solutions 34 Conclusions and Recommendations 34 INTRODUCTION TO THE CASE STUDIES 3? City of Alexandria, Virginia 3° Southeastern Massachusetts 42 City of Austin, Texas 5^ City of Orlando, Florida r3 County of Fairfax, Virginia Cities of Eugene and Portland, Oregon 76 GLOSSARY 90 BIBLIOGRAPHY 92 ------- ------- ACKNOWLEDGEMENTS ict (NVSWCD), This report was researched and written by Robert losco, Specialist, Northern Virginia Soil and Water Conservation Fairfax, Virginia. The author would particularly like to acknowledge the contributions of Jean R. P^karrVicTchaiLan and Director, NVSWCD, and Norman T. Jeffries, former Executive Director, NVSWCD. They reviewed many drafts and provided valuable Sights. In addition, the entire NVSWCD staff deserves thanks for providing the overall assistance necessary to complete this project. The project was funded by Grant # X-820828-01-0/1/2 from the Nonpoint Source Control Branch, Office of Water, U.S. Environmental. Protection Agency Washington, DC The EPA Project Officer for this grant was Rod Frederick, Chief, Urban Sources Section, Nonpoint Source Control Branch. The following individuals provided review comments: Earl Shaver Delaware Department of Natural Resources Dover, DE Warren Bell City Engineer City of Alexandria, VA Leslie Tull Environmental Officer City of Austin, TX Kevin McCann Storm Water Utility Bureau City of Orlando, FL Dave Janik & Bernadette Taber Buzzards Bay Project Marion, MA Noel Kaplan Office of Comprehensive Planning Fairfax County, VA 11 ------- ------- Jack White Department of Environmental Management Fairfax County, VA William Henry Department of Public Works Fairfax County, VA Deborah Evans Department of Public Works City of Eugene, OR Tom Liptan Bureau of Environmental Services City of Portland, OR Dale Lehman Woodward-Clyde Consultants Gaithersburg, MD William Tate U.S. Environmental Protection Agency Washington, DC Robert Goo U.S. Environmental Protection Agency Washington, DC Dov Weitman U.S. Environmental Protection. Agency Washington, DC 111 ------- ------- Executive Summary This manual defines the institutional and programmatic issues which are crucial to the success of runoff control programs in already urbanized or urbanizing areas. These nontechnical factors are often decisive in determining the effectiveness and success of such programs. The manual describes strategies which local communities can use to develop the institutional frameworks needed to implement runoff control programs. The strategies are described in the program development section of the manual and in the case studies presented. Each community will have different urban runoff management needs, environmental concerns and available resources. Yet, building an effective program requires certain common key steps. This manual lays out the essential elements, which will also be useful in preparing the management plans required by various Federal regulations and programs. In addition, retrofitting for runoff control may be necessary in some urban areas to achieve the water quality improvements necessary under current Federal and state mandates. The Coastal Zone Act Reauthorization Amendments of 1990 (CZARA), §6217, required the development of the Guidance Specifying Management Measures for Sources of Nonpoint Pollution in Coastal Waters (USEPA, 1993). States with coastal zone management programs are required to develop coastal nonpoint pollution control programs consistent with these Management Measures. The "Existing Development Management Measure" of Chapter Four (Urban Areas) requires development and implementation of programs to reduce pollution from existing development. The National Pollutant Discharge Elimination System (NPDES) Storm Water Permit Program, established by §402(p) of the Clean Water Act, requires permits for certain municipal and industrial storm water discharges. In addition, this program requires the development of storm water management plans for the areas covered by the permit, which usually includes urbanized areas. Both of these programs could involve the use of retrofits to achieve water quality improvements. While program requirements may differ based on the specific regulatory authority, the goals of these programs are complementary and many of the same management practices are applicable and satisfy the requirements of both programs. The case studies presented in this manual provide examples of the innovative ways in which many local governments are meeting the requirements of multiple programs to improve water quality. However, communities need to refer to ------- applicable state and Federal regulations to assure that they are in compliance with all regulatory requirements. The manual describes ways that local governments can approach the issues surrounding the implementation of urban runoff retrofit technology even when the control options are limited. It reviews appropriate "ultra-urban" technologies for situations where more conventional, land-intensive control practices are not feasible. Specific recommendations are summarized to help program implementation personnel develop strong institutional frameworks and create effective urban runoff control programs. The recommendations presented are largely based on the program implementation experiences of the case study communities featured in the manual. They include: Problem Identification Identify problems clearly at the outset Define runoff control program objectives, requirements, and penalties Priority & Goal Setting Consider innovative and cost effective retrofit methods « Prioritize retrofit alternatives and set realistic goals to implement Adequate Funding Identify stable and/or dedicated funding sources for urban runoff management programs Utilize cost-share approaches among agencies Utilize economic incentives to reduce amounts of stormwater discharges, e.g., utility fee reductions for reduced amounts of impervious surface Identify opportunities for public/private partnerships to conduct nonpoint source pollution control activities Obtain participation and support from private interests who will benefit from urban runoff control programs ------- Multilateral Approaches Use teams or multi-agency work groups wherever possible Create effective institutional structures Identify related Federal state and local programs and assess their storm water control effectiveness and degree of interaction Designate a lead agency to coordinate program development and implementation Designate sufficient agency staff to support implementation projects ------- DEFINING THE PROBLEM OF URBAN RUNOFF MANAGEMENT Introduction This manual recommends strategies for communities to use to develop the institutional frameworks necessary for the successful implementation of urban runoff control projects/ including retrofit projects in developed areas. It provides practical information for local government personnel who wish to develop such programs. While each community will have different runoff management needs and available resources, building an effective program requires certain common steps. This manual describes the step-by-step procedures necessary to develop effective programs to reduce nonpoint source pollution from urban runoff in developed areas. Institutional factors have a significant impact on the effectiveness of urban runoff control programs. Because the development of institutional frameworks is vital to effective program implementation, this manual emphasizes program development, rather than specifying technical requirements for programs. (Technical manuals for the implementation of urban runoff controls are listed in the Bibliography.) It recommends strategies and outlines the step-by-step procedures which are necessary to develop urban nonpoint source pollution control programs. Finally, in the accompanying case studies, this manual describes some approaches which local governments have successfully used to implement urban runoff control programs. Purpose and Intended Audience of this Manual This manual provides specific guidance to help local governments implement urban runoff programs. It does not track all regulatory requirements; these will differ by state and locality. Rather, it addresses certain elements of urban runoff control programs that are often problematic for municipalities considering program implemention. It is designed to help them through the program development and implementation process. A local government wishing to develop an urban runoff control program for developed areas needs to base its approach on local conditions. This manual describes the basic issues in sufficient depth, with the use of examples, to enable a local government to design an effective program based on its particular needs. The audience for this manual includes public agencies such as local environmental regulatory agencies; regional and local planning agencies; councils of governments; planning commissions, departments of public works, soil and water conservation ------- districts, and other agencies concerned with land use, development, and urban runotf management. However, the general public also needs to be included along with interested environmental groups and elected officials as part of the process of managing urban runoff problems and issues; this manual seeks to impart a basic level of knowledge about these issues to the nonprofessional or nontechnical person. The purpose of the case studies is to present alternatives for local governments to consider in formulating solutions to urban runoff problems. They have been chosen to provide examples of innovative and successful alternatives in the field. Brief History of Runoff Control Urban runoff has not always been recognized as a major contributor of pollutants. Historically, urban nonpoint source pollution has been overlooked by surface water- regulation agencies at the local, state and federal levels. Efforts to control surface water quality degradation concentrated on point sources. Urban nonpoint source pollution control focused on street sweeping, used motor oil recycling, and public education.1 In addition, local governments have historically been concerned mostly with urban runoff quantity control. Water quality concerns have now become equally important for municipalities because of federal and state mandates. During the first fifteen years of the national program to abate and control water pollution, EPA and the states have focused most of their water pollution control activities on so-called "point sources," such as discharges through pipes from sewage treatment plants and industrial facilities. These point sources have been regulated by EPA and the states through the National Pollutant Discharge Elimination System (NPDES) permit program established by Section 402 of the Clean Water Act. Congress also amended the Clean Water Act in 1987 to require EPA to establish phased NPDES requirements for storm water discharges. Storm water discharge permits will provide a mechanism for monitoring the discharge of pollutants to waters of the United States and for establishing appropriate controls.2 The attempts to control point source pollution have reduced pollutant loads and Murray, James, "Nonpoint Pollution: First Step in Control," in Design of Urban Runoff Quality Controls, Roesner et al, eds. American Society of Civil Engineers (New York, 1989), p. 378. 2USEPA, "Overview of the Storm Water Program," Office-of Wastewater Enforcement and Compliance, Permits Division. Washington, DC: March, 1993. ------- considerable progress has been made in restoring and maintaining water quality. However, the abatement of point source pollution did not solve all water quality problems. Recent studies and surveys by EPA and by state water quality agencies indicate that the majority of the remaining water quality impairments in our nation's rivers, streams, lakes, estuaries, coastal waters, and wetlands result from nonpoint source pollution and other nontraditional sources, such as urban storm water discharges and combined sewer overflows. Congress amended the Clean Water Act in 1987 to focus greater national efforts on controlling nonpoint sources. Section 319 of the Act was enacted to establish a national program to control nonpoint sources of water pollution. In addition, Congress enacted Section 6217 of the Coastal Zone Act Reauthorization Amendments (CZARA) in 1990 to address the impact of nonpoint source pollution on coastal waters. In recent years EPA introduced the Watershed Protection Approach (WPA) as a flexible framework for focusing and integrating current efforts and exploring innovative methods for achieving environmental objectives. The WPA focuses on four major elements: 1) identifying specific geographic locations; 2) integrating available authorities to deal with all pollution sources; 3) involving all stakeholders in analyzing and creating solutions; and 4) measuring effectiveness against clearly established objectives. These key elements are derived from experience gained over the past few years in many states and other EPA efforts such as the Clean Lakes and National Estuaries Programs. ------- How Urban Runoff Adversely Affects Water Resources Urbanized areas and areas in which development has altered the natural hydrology and infiltration characteristics of the land typically experience increased surface runoff. Land development alters the natural balance between runoff and natural absorption areas by replacing them with greater amounts of impervious surface. The result is increased rates and volumes of surface runoff. The negative impacts of urbanization on water quality has been well-documented in a number of sources, including the Nationwide Urban Runoff Program (NURP) and the States' reports written in response to the requirements of §305(b) and §319 of the Clean Water Act. For example, the States report that urban runoff and storm sewers are the second leading source of water quality impairment of lakes and estuaries, and the third leading source of water quality impairment of rivers in the United States. As a consequence of. the increased quantity and rate of runoff, greater amounts of pollutants are carried into receiving waters, and water quality degradation increases. Other negative impacts include the increased susceptibility of eroded land to flooding, other hydrologic changes, and wildlife and in-stream habitat degradation. [See Box 1] The Need for Urban Runoff Management Many American cities contain areas in which buildings, parking facilities and urban streets and walkways cover almost one hundred percent of the land surface. This creates runoff conditions but offers no room for structural urban runoff quality management facilities such as extended dry detention or wet ponds. Even when redevelopment occurs within these areas, high land values usually require replacement by similarly intense land uses in order to provide economic viability for the project. Conventional best management practices (BMPs) are difficult, if not 3USEPA, The Quality of Our Nation's Water: 1992, Office of Water, EPA Document 841-S-94-002, March 1994, p. 10. ------- impossible, to implement in this context. In such situations, innovative BMP applications requiring little or no above ground coverage are necessary in order to meet increasingly stringent Federal and state urban runoff pollution control requirements. In highly urbanized areas, the use of innovative urban quality control retrofitting is the primary option to improve the water quality of surface waters which receive runoff discharges from older urbanized areas. 8 ------- Why worry about urban runoff? What is the problem with urban runoff anvwav? Storm water runoff picks up pollutants and debris as it traverses developed areas, particularly parking lots and streets. During storm events, pollutants are picked up and flushed directly into local lakes, creeks, and streams, without being filtered by the soil or natural vegetative cover. This endangers water quality. Better pollution control is needed to reduce the amount of contamination affecting these water bodies. Isn't new development the cause of all these problems? New development, in many localities, has to meet strict regulations on the quality and quantity of storm water runoff. However, many of our current water quality problems are caused by runoff from older, developed areas. We can't solve the problem without retrofitting older stormwater control devices or installing them where none currently exist. How can we solve this problem? As the public becomes aware that there are problems with urban runoff quality, and begins to take action, the water quality of area streams and rivers should improve. As people learn that the storm drain at the end of the street flows straight to a nearby stream, they will be more interested in what drains to, or is dumped in, the street catch basin. They will also press their elected officials to incorporate stronger stormwater treatment standards into both new development and redevelopment projects in their community. How urban runoff affects water resources. ------- Retrofitting Developed Areas As urbanization occurs, and areas of impervious surface increase, maintenance of water quality becomes increasingly difficult. Retrofit of structural controls is often the only feasible alternative for improving water quality in developed areas. Ideally, as land is developed best management practices would be implemented to control present and future urban runoff problems. However, controlling pollutants in runoff from new development alone will not solve existing water quality problems. Therefore, retrofitting is necessary. It is also the primary option for developed areas to improve urban runoff water quality. Impervious surfaces in developed areas may cover 100% of the land surface. Retrofitting is a process that involves the modification of existing surface water runoff control structures or surface water runoff conveyance systems which were designed to control flooding, so they will also serve a water quality improvement function. Retrofitting should also be considered as an opportunity to improve existing water quality best management practices. Existing practices may be inadequate or performing poorly, or they may simply lack the pollutant removal capability of newer BMP designs. The least expensive and most practicable retrofit opportunities often involve the improvement of existing urban BMPs. BMP retrofits are a widely used technique. The opportunity to improve existing urban BMPs at modest cost, or to convert older dry storm water detention ponds, for example, into more efficient wet extended detention ponds is afforded by a retrofit approach. Factors such as the presence of existing development, or a community's financial constraints, may limit runoff management options; targeting may be necessary to identify priority pollutants and select the most appropriate retrofit methods. This is particularly true in highly urbanized areas where land is limited and the use of conventional pond systems is restricted. In highly urbanized areas, sand filters or water quality inlets with oil grit separators 10 ------- may be appropriate for retrofits because they do not limit land usage. Sand niters, however, may be a better alternative for treating hydrocarbon runoff from small sites than oil grit separators because sand is a superior filtering medium. Recent research^ questions the effectiveness of oil grit separators at removing hydrocarbon pollutants. Urban runoff retrofitting for nonpoint source pollution control includes a broad range of different techniques which attempt to reduce the adverse impacts of urban runoff on receiving waters. The types of retrofit techniques will differ depending upon where they are placed in the storm drainage network. Local Governments' Compliance with Federal and State Regulations The current storm water management requirements and drainage needs in major population centers are significant. EPA storm water permit regulations require large (>250,000) and medium (>100,000) size municipalities to have storm water discharge permits for discharges from their storm sewer . systems under the National Pollutant Discharge Elimination System (NPDES) storm water permit program. Large- and medium-size municipalities nationwide are now applying for these permits which will require implementation of comprehensive storm water management programs to control storm water runoff. In addition, Section 6217(g) of the Coastal Zone Act Reauthorization Amendments (CZARA) of 1990 requires States to develop coastal nonpoint source pollution control programs, including a management program to control runoff from existing development. The new coastal zone requirements are only applicable, however, in areas which are not subject to the NPDES storm water permitting regulations. 4 Schueler, Thomas R., "Hydrocarbon Hotspots in the Urban Landscape: Can They Be Controlled?" in Watershed Protection Techniques. Volume 1(1), February 1994, p 11 3-5. ------- The increasing stringency of federal, state and local regulations are all examples of the emphasis being placed on minimizing both point and nonpoint source pollution from urban runoff. Summary of Selected Federal Water Quality Programs Coastal Zone Management Act of 1972 (CZMA) established a program to encourage states to develop comprehensive programs to protect and manage coastal resources Coastal Zone Act Reauthorization Amendments of 1990 (CZARA) S6217 mandated state coastal programs to address nonpoint source pollution affecting coastal water quality and required the development of the Guidance Specifying Management Measures for Sources of Nonpoint Pollution in Coastal Waters which states are to incorporate into their coastal nonpoint source programs National Pollutant Discharge Elimination System (NPDES) Storm Water Permit Program established by §402(p) of the Clean Water Act; requires permits for certain municipal and industrial storm water discharges Clean Water Act $319: Nonpoint Source Control Program initiated-a national program which resulted in state nonpoint source management programs to control nonpoint sources of water pollution and protect groundwater Clean Water Act 5320: National Estuary Program focused point and nonpoint pollution control on geographically- targeted, high priority estuarine waters; controls are selected and implemented on a watershed basis EPA's Watershed Protection Approach voluntary effort to align traditional regulatory and nonregulatory programs to support watershed protection in an integrated, holistic manner i 12 ------- While program requirements may differ based on the specific regulatory- authority, the goals of these programs are complementary and many of the same management practices are applicable and satisfy the requirements of multiple programs. The case studies presented in this manual provide examples of the innovative ways in which many local governments are meeting the requirements of multiple programs. This manual will help communities develop and implement pro-ams to improve water quality. However, communities need to refer to appSle strand Federal Regulations to assure that they are in compliance with all regulatory requirements. For example, some communities are not subject to NPDES permit requirements but may be subject to requirements under the Coastal Zone Act Reauthonzation Amendments of 1990 ("CZARA"), and vice versa. In addition, some states have fd"mo^regulatory programs that may govern the management of storm water or runoff in the absence of Federal requirements. Other communities may not be XctTo any regulatory requirements at this time, but the public is increasingly aware of runoff problems and their causes and some control of runoff is becoming inevitable. 13 ------- BRIEF SURVEY OF CURRENT METHODS AND TECHNIQUES Types of Urban Runoff Retrofit Techniques5 Retrofit techniques can be differentiated depending upon where they are placed in the storm drainage network. Some of these are described below: Source retrofit: Use of techniques that attenuate runoff and/or pollutant generation before it enters a storm drain system, e.g., reducing impervious areas, using pollution prevention practices Open channel retrofit: These are installed within an open channel below a storm drain outfall, e.g., an extended detention shallow marsh pond system. Natural channel retrofit: Depending on the size of the channel and the area of the floodplain, a natural channel may provide several retrofit options Off-line retrofit: Involves the use of a flow-splitter to divert the first flush of runoff to a lower open area for treatment; used where land is available for off-line treatment Existing BMP retrofit: The retrofit of an existing BMP to improve its pollutant removal efficiency or capacity (ability to detain flow) or both. In-line retrofit: Used where there are space constraints that prevent the use of diversions to treatment areas. Urban runoff retrofits involve a broad range of different techniques intended to reduce the adverse impacts of urban runoff on receiving waters. [See Box 2] The overall goal should be to achieve some reasonable degree of hydrologic control and pollutant removal (in relation to cost-effectiveness) as a result of the retrofit. Otherwise, the retrofit is not worth doing. 5 as identified in MWCOG, Watershed Restoration Source Book, 59. . 14 ------- Technical factors affect the site-specific suitability of particular retrofit technologies. A checklist of these factors includes: land use ; climate size of drainage area soil permeability " , slopes depth to water table space requirements type and condition of the water resource to be protected depth to bedrock : pollutants to be addressed maintenance access Nonstructural Methods to Control Urban Runoff Land use controls can be a cost effective means to control urban runoff. They have a maintenance cost/multiple use advantage over structural BMPs in many cases, and should be employed in redevelopment situations where appropriate. Furthermore, land use controls may be necessary along with structural measures in order for a jurisdiction to meet its water quality goals. Strategies for implementing land use controls may include limits on impervious surfaces, encouragement for the preservation of open space, and promotion of cluster development The use of nonstructural and structural best management practices for controlling urban nonpoint source pollution can also be required as a condition of development approval. Zoning Zoning is a powerful tool which communities can use to control the type of development or redevelopment allowed within their boundaries. Following are some examples of zoning controls that can be used to protect water resources: cluster development: constructing dwellings close together to preserve open space down-zoning: changing an established zone to require a lower density conditional zoning: allowing certain activities only under specified conditions that protect water resources 15 ------- overlay zoning: placing additional zoning requirements on an area that is already zoned for a specific activity or use; through the use of resource overlay zoning, high pollution activities can be controlled in sensitive areas open space preservation: protecting open space and buffer zones near water bodies, e.g., greenways or riparian corridors Structural Runoff Controls for Highly Urbanized Areas6 1. Innovative Practices In areas where impervious materials cover almost one hundred percent of the surface, conventional BMPs requiring large amounts of land and good soil conditions are usually not feasible. These types of BMPs include dry ponds, wet ponds, constructed wetlands and various sorts of infiltration devices. On sites where standard BMPs are not feasible, one should consider the use of unconventional or innovative BMPs sometimes known as "ultra-urban" BMPs. These systems are designed to function by gravity flow between the components. They include: 1) sand filtration systems; 2) underground sand filters consisting of multiple chambers; 3) surface sand filters such as double-trench systems; and 4) peat/sand filtration systems. Each is briefly described below: Sand filtration systems: The City of Austin, Texas has developed a BMP which consists of a sedimentation and filtration basin and is appropriate for use on redevelopment sites where topography, space limitations and high value land do not allow the use of traditional BMPs. These filtration systems are primary water quality control structures. In order to ensure the long-term effectiveness of these systems, it is necessary to protect the filter media from excessive sediment loading. A sediment trapping structure is required to be located prior to the filtration basin. Austin sand filter sytems are particularly well-suited to regional storm water control. Underground sand filters with multiple chambers: This is a system consisting of a structure containing three chambers, one each for pre-treatment, filtration and discharge. The first chamber is a pre-treatment facility performing the same function as a water quality inlet, removing floating debris and material such as oil and grease. 6 A more detailed description of these controls and their effectiveness is provided in the Alexandria Supplement to the Northern Virginia BMP Handbook, [see Bibliography] 16 ------- The second chamber is a filtration device, while the third is a clear well discharging directly to the storm sewer system. The District of Columbia uses underground sand filters as in-line facilities for both storm water quality and peak flow attenuation. One of the major advantages of the D.C. sand filter is that it does not take up any space on the surface, allowing full use of high-value urban land. This aspect makes it particularly attractive to land developers. *»«*> «»nH filter systems: This system is usually referred to as the Delaware sand filter because it was developed for use in Delaware. Unlike the other filters described in this section, the surface sand filter system is intended to be an on-hne facility, processing all runoff leaving the site up to the point where the overflow limit s reached It consists of two parallel concrete trenches, one for sedimentation, the Stotoffltotion. A major advantage of this filter design is that it requires a depth o only 30 inches from the ground surface to the bottom of the paved trench, making it useful in areas with high water tables. The simplicity of the design also facilitates maintenance. P^can filtration systems: Peat/sand filters are filtration developed as alternative wastewater systems. Peat is an excellent natural filter of many types of effluents and pollutants and is just beginning to be used for urban mnotf quality management. A peat/sand filter system should be considered for use TdevelopmLts of several acres where the pollutant removal requirement is higher - San couldPbe expected to be achieved through the use of other ultra-urban BMPs. In addition, peat/sand filters require less site area than most conventional BMPs. " However it should be noted that, under certain conditions, peat filters can become net exporters of nutrients. Use of Publir Ri^hts-of-Wav A retrofit technique which has been identified for use in a land-limited context is the use of public rights-of-way as an opportunity for runoff controls such as wet ponds vegetated swales or meandering vegetated channels. This would include the use of land under bridges and overpasses, the median strips of roads and highways, and the exit ramp rights-of-way off major highways. 17 ------- 2. Retrofit Capability of Selected BMPs7 Extended Detention Ponds: Frequently used in retrofit applications, particularly within dry storm water management ponds. Wet Ponds: Occasionally used in retrofit situations, particularly within dry storm water basins Constructed Storm Water Wetlands: An effective retrofit technique. Can be achieved by adding wetland features to dry storm water basins. Infiltration Trenches: Limited by soil conditions. Infiltration Basins: Not recommended for retrofit settings, especially in the coastal zone. Porous Pavement: Limited by soils which have been modified in most urbanized watersheds and are not capable of providing adequate infiltration. Sand/Peat Sand Filters: Designed as end-of-pipe retrofits in several applications. A double-trench version has been designed for parking lot retrofits. Grassed Swales: Although not suitable for ultra-urban areas because of the difficulty of preventing erosion in highly impervious areas, retrofit option may involve installing check dams to increase contact time in existing swales. Filter Strips: Although the percentage of impervious surface in highly urbanized areas limits the usefulness of this practice as a water quality control device in ultra- urban settings, this type of retrofit is appropriate if enough land is available. Water Quality Inlets: Although water-quality inlets are often used in ultra-urban areas, their low pollutant removal capability limits their usefulness as a retrofit technology. " More detailed information on the retrofit capability of these practices can be found in A Current Assessment of Urban >Best Management Practices. [see Bibliography] 18 ------- DEVELOPMENT & IMPLEMENTATION OF AN URBAN RUNOFF CONTROL PROGRAM While the program elements discussed in this section are considered important to program development and success, they do not necessarily fulfill all regulatory requirements which may be applicable to a given municipality. Planners and program managers should check on all relevant program requirements when developing their programs. Important Program Elements An urban runoff control and retrofit implementation program involves both technical and programmatic components and should include the following elements: technical capability use of appropriate technology implementation authority/enabling legislation funding mechanism or resource commitment institutional support structures The case studies which are part of this manual demonstrate that local motivation is critical to the successful implementation of urban runoff controls. Also, successful implementation will not occur without a strong local commitment of personnel and resources. Regulations, ordinances, enabling legislation, design criteria, construction specifications, inspections and enforcement, and operations and maintenance procedures should all be clear and explicit. Appropriate technology for implementing runoff control measures must exist and must be at an affordable cost to the agency. If the foregoing are not present, implementation or continued successful program performance may not occur. 19 ------- Important Elements for Program Success Technical Capability Design Criteria for Selection of Appropriate Technology Implementation Authority/Enabling Legislation x f "*<* Dedicated Funding Mechanism ^ Vt" < - Staffing/Training/Institutional Support/Operations & Maintenance The box above depicts some of the key elements for- developing and conducting a successful urban runoff control program. All of them may significantly affect program outcome: technical capability and the choice of an appropriate technical solution implementation authority and a dedicated funding mechanism the often-neglected elements of program staffing, proper training, strong institutional support, and the proper operations and maintenance procedures 20 ------- Building a Strong Institutional Foundation Urban runoff management program practitioners strongly support the view that the success or failure of urban runoff control programs depends upon effective institutional frameworks. The following elements are often cited as crucial to program success: Programmatic: adequate problem assessment BMP targeting and selection methodology (e.g., on-site vs. regional facilities) appropriate design criteria adequate staffing and training responsibility for success of total program vested in a single agency at an appropriate level of authority Funding/Implementation: dedicated program funding, such as a storm water utility fee ease of operation and maintenance procedures administrative mechanism to ensure O & M is performed Each of these elements must receive adequate institutional support if a successful urban runoff control program is to be implemented. In order to develop the necessary institutional frameworks, the local government should focus sustained attention on the institutional aspects of program development. There should be a recognition that developing an institutional framework is essential to support a successful multi-agency, long-term urban nonpoint source runoff program. 21 ------- How can communities develop a successful program? Each local government may have mmmmmmmmmmmm^i^mm^^^^^mm^mi^m^fm different tasks to complete to create a successful program. However, certain common threads run through all the case studies described in this manual and these can be instructive in helping local governments to put together effective urban runoff control programs. A strong motivation to act is essential. Frequently the strongest motivation to act is economic. In the mm^^^^^^^i^^~^~^^ Southeastern Massachusetts area case study, the closure of thousands of acres of shellfish beds due to contamination by storm water runoff resulted in millions of dollars of lost income to local residents and serious disruption to local economies. For other communities, such as Austin, TX, protection of drinking water supplies is a high priority. Still others, such as Orlando, FL, are concerned about the water quality of the hundreds of lakes within its metropolitan region. Teamwork is essential to accomplish Pick the right people and the right your goals. organizations. The experience gained ^^__________^___^______ from the case studies proves that ^^*mam^mmfg^*m^^*m^*~m teamwork is necessary to achieve the desired results. The nature of the urban runoff problem means that any solution will cut across departmental, bureaucratic and organizational boundaries. The high cost of storm water control projects, especially retrofits, makes cost-sharing among organizations particularly advisable. So identify the key players early and make good working relationships a high priority. Don't neglect the important role of private organizations and interests. The need for adequate staffing and training should be recognized. 22 ------- Assessing Institutional Resources Two initial goals should be considered by a local government interested in developing an urban runoff control program: 1) developing or improving its institutional capacity to mitigate the urban runoff water quality problems which it faces 2) ensuring that its institutional capacity matches its technical ability to deal with the problem. Implementation personnel should evaluate the following factors as part of an initial assessment of institutional structures: Identify the kev agencies and personnel Determine who the key players are in the relevant agencies. Typically, there are four major groups involved in the institutional water quality decision-making process: 1) legislative 2) regulatory 3) consulting professionals 4) "users" such as developers, clients, citizens (also includes environmental advocacy groups) The program manager should be aware that the typical bureaucratic organization of institutions into branches, divisions, departments, etc., can hamper the ability of the organization to carry out its program goals and hinder program effectiveness. The most successful programs find ways to break the bureaucratic logjam. Identify all relevant existing programs and assess their effectiveness This may involve looking at an array of water quality programs scattered across different agencies and departments. Look for opportunities to modify these programs to reach the desired goals. Make sure that existing governmental structures are capable of implementing proposed programs. Finally, identify- what new programs are needed. 23 ------- Determine the motivations and goals of the key agencies They may be acting in response to a perceived problem such as a health hazard or to a water use impairment. Remember that not all organizations are subject to the same level of political pressure. Determine whether political support exists This includes both established and grassroots structures. Political support for environmental issues becomes especially significant in times of resource constraints and competing interests. Identify appropriate pollution control techniques Consult a BMP manual, such as those listed in the Bibliography, for the types of control mechanisms appropriate to a particular site. Identify funding options This might include study of the feasibility of a dedicated funding source such as a storm water utility and development of a fee structure. Consider the limitations of available technology The potential for solving a problem may be limited by many factors over which the implementing authority has no control. This includes performance limitations of technology as well as any site-specific constraints. Conclusion The importance of developing institutional structures cannot be overstated. Effective urban runoff management is greatly helped by the presence of strong institutional mechanisms. Furthermore, the case studies support the conclusion that where urban runoff quality control is institutionalized through dedicated funding mechanisms such as storm water utilities, innovative and comprehensive programs (including retrofit activity) are the rule. 24 ------- Setting Priorities/Selecting Management Practices Urban nonpoint source runoff problems may be numerous in a given area and the solutions are often complex. Funding to solve these problems is usually limited so it is necessary to set priorities so that the worst problems can be targeted for attention. A ranking methodology should be developed for a specific study area (e.g., a watershed) in order to encourage a phased approach and to allocate scarce resources optimally. Once particular waterbodies and sources have been targeted for action, the local government can then determine the most cost effective approach to solve the problem. The following factors should be considered in the ranking process: waterbody importance type of use (recreation/aquatic life/drainage) status of use (impaired or denied uses) level of use pollutant loads The key point to be made about the ranking process is that it should reflect local issues and concerns. The ranking factors can be assigned different degrees of weight based on the degree of local importance. In evaluating and selecting appropriate control practices, local governments should consider: Does the practice selected meet any applicable regulatory requirements? Is the selected control buildable and effective? Relying upon structural controls is different from the use of source controls and regulatory or non-structural controls. Complex structural controls pose both construction and future maintenance challenges that should not be overlooked. Use the following as a checklist of the tests which the proposed BMP should pass to be considered for implementation: Does it meet regulatory requirements? Is it effective at pollutant removal? Can it gain public acceptance? Is it technically implementable/easily maintained? What are the associated costs? 25 ------- The process of setting priorities and targeting urban runoff problems is a complex process consisting of many factors and should be performed in a systematic manner. How To Overcome Roadblocks to Implementation Two of the biggest "roadblocks" to implementation of urban runoff control retrofit projects are high cost and shortage of funding and the lack of available land in urbanized areas. Many participants in the urban runoff management and planning process describe the extreme difficulty of implementing urban runoff retrofits because of the lack of available land at highly urbanized sites and the lack of funding for these typically expensive projects. The most difficult sites are those where land for siting control practices is severely constrained or non-existent. The high cost associated with retrofitting older urban storm drainage systems requires a careful evaluation of pollutant reduction goals and the targeting of control practices. Land Availability In the urban context, land may be strictly limited and/or its value may be prohibitive for some uses. Practices requiring large land areas are simply not feasible. The three most used control devices for storm water quality management, vizv dry ponds, wet ponds, and infiltration devices, are not always suitable for urban retrofit situations because of space constraints or underlying soil conditions. On sites where these types of conventional practices are not feasible, innovative and experimental approaches should be tried. Newer ultra-urban technologies that take up little or no above-ground space should be used. Performance monitoring should be done to verify effectiveness. Cost of Implementation The extremely high cost of retrofit projects - engineering studies, land acquisition, and the actual construction costs - raises the question of how realistic these projects are for many local governments to achieve. In addition to initial project cost, there is also the continuing and long-term cost associated with operations and maintenance. Some ways to reduce the high cost of these projects include: utilizing state or federal cost-share programs where available (e.g. FEMA floodplain "buyout" or EPA nonpoint source grants) * encouraging multi-jurisdictional efforts to spread the cost and benefits soliciting volunteers and in-kind contributions to reduce project cost 26 ------- . creation of special districts or dedicated funds such as storm water utilities low interest state revolving fund (SRF) loans for nonpoint source control projects The use of high value urban land is the biggest obstacle to implementing retrofits for many municipalities. Land which would ordinarily be generating revenue for the municipality is removed from the tax rolls. This is a clear institutional disincentive to implement retrofits in highly urbanized areas. If a local government considers water quality improvement as a goal desired by the community, then the revenue loss might be viewed differently by the public, and would be easier to justify politically. Localities are increasingly turning to methods of returning the costs of storm water discharges to individual property owners, through mechanisms such as storm water utility fees or storm drainage and flood control fees. The goal of these programs is to provide economic incentives to property owners to reduce the amount of storm water discharges from their land by offering credits for implementation of best management practices, as well as to reduce the burdensome cost to already fiscally-strained jurisdictions. 27 ------- Increasing Public Awareness To ensure adequate support for urban runoff control programs, the public needs to be educated about the nature of urban nonpoint source pollution and the benefits of controlling urban runoff. These issues are not readily understood by large segments of the public. The need to heighten public awareness cannot be overemphasized. Urban runoff control programs must have public backing and involvement to succeed. There is broad general support for environmental concerns and this support can be translated into political support for urban runoff control programs. However, adequate funds must be devoted to public information and education programs about the nature, causes and solutions of urban runoff and urban nonpoint source pollution. The public must recognize the seriousness of urban runoff pollution, and understand the importance of local commitment for a successful urban runoff management or retrofit program. Public education is an essential tool for increasing public awareness and generating political support. Educational efforts typically include: program meetings and presentations program materials such as newsletters, fact sheets, brochures, and posters homeowner education programs media campaigns coordination with activist groups for program support 28 ------- Creating a Stable Funding Mechanism Runoff control programs are usually implemented at the local level. Local communities generally have limited budgets and limited staffing which impedes effective implementation. Sources of funding at the Federal and state levels are also limited and uncertain, and cannot be counted upon to provide total project funding. One successful institutional response by many municipalities has been the establishment of storm water utilities. Some jurisdictions have used storm water utilities to fund the basic "hardware" of urban runoff management, while others have included funding for watershed planning and retrofitting programs. Special taxing districts, such as a watershed improvement district, can levy taxes and borrow money to engage in a wide range of nonpoint source pollution control activities. A special taxing district is similar to a school district or a sanitary district and functions as a special governmental unit in a particular area. Real estate within its boundaries is appraised and taxed to fund program activities. The purpose of a dedicated funding source such as a storm water utility or a special taxing district is to provide a stable and reliable method of financing storm water management programs. The development of comprehensive and effective programs requires a secure funding base. [More information on funding options is provided below.] 29 ------- Policies and Procedures vs. Programs and Institutional Frameworks. Effective prevention and control of urban runoff pollution requires both defined policies and procedures, and effective programs and institutional structures. Just having policies on paper is no guarantee of an effective program. Institutions must be organized in such a way as to implement the policies and carry out the procedures. Indeed, the implementation phase is just the final step in an often long process of planning and preparation. It must be accompanied by a real institutional committment to change ineffective and outmoded structures, to break through political or bureaucratic impasse, and to see that programs function effectively. The question for the local program manager is: Are the local government's agencies organized to efficiently and effectively carry out runoff control activities? Are the various agencies involved clear about their responsibilities? Responsibilities of each involved party can become a major issue when urban nonpoint source control projects involve multiple agencies, as they almost always do. The responsibility of each agency involved in an urban runoff control project should be clearly spelled out. The complexity of developing and implementing urban runoff control programs, including the special considerations relative to retrofit situations, means that the following distinct phases should be well-known to the program manager:8 planning phase: analyze, evaluate, plan preparation phase: prepare budget, allocate resources, and obtain permits pilot project phase: test selected BMPs full-scale implementation: construct selected BMPs evaluation/documentation: evaluate program effectiveness 8 U.S. Environmental Protection Agency, "Evaluating Nonpoint Source Control Projects in an Urban Watershed," in Nonpoint Source Watershed Workshop. Seminar Publication tt EPA/625/4 - ,91/027. 30 ------- Funding Options/Alternative Funding Approaches Implementation of urban runoff control programs at the local level often requires non-Federal funding. Now that governments at all levels are facing fiscal constraints, alternative funding sources are becoming increasingly important. Following is a discussion of some of these approaches: Local governments with strong institutional frameworks have led the way in the development of utilities specifically designed to abate NFS = pollution or targeted at a particular type of NFS pollution: Local governments are using the utility concept to develop institutional approaches incorporating homeowner responsibility for some runoff management practices (e.g., septic system maintenance, small construction grading and landscaping permits requiring best management practices to control runoff) Storm water utilities are spreading all over the country as a way of providing a dedicated funding source for urban runoff control projects; a storm water utility is to storm water what a sewage utility is to sewage and a water utility is to drinking water. It is a dedicated funding source or "stand alone" service unit within the city government which generates revenues through fees for service. It is responsible for the operation, construction and maintenance of storm water management devices and for storm water system planning. State revolving loan funds were very successful in the early years of point source pollution control and are now being adapted to nonpoint sources: State revolving loan funds, originally established for states to upgrade sewage treatment facilities through construction grants, may also be used to fund a wide variety of nonpoint source control projects and best management practices (BMPs) 31 ------- Special fees and taxes are another source of dedicated project funds for nonpoint source pollution control: This approach involves the use of user fees/special taxes to fund nonpoint source pollution projects and programs, such as special taxes and fees on the sale of fertilizers and pesticides, waste disposal, and underground storage tanks Some innovative approaches being used to fund urban nonpoint source pollution control programs include: : Special tax districts, such as watershed improvement districts, which can be created to protect highly valued water bodies. Checkoff on tax forms to fund restoration and conservation programs. Revenue bonds, which are long-term municipal bonds guaranteed solely by the dedication of project funds. Public/private partnerships can be used to pay for capital and/or operating expenses, for storm water facility projects when neither could fund them alone. An annual nonpoint source pollution control tax based on property size and land use (not on value) is being used in Puget Sound, Washington. The sale of special license plates in Maryland and Virginia has raised substantial amounts of money to restore the Chesapeake Bay. Types of Funding Mechanisms Available to Local Governments General funds The use of general funds may require the re-allocation of existing revenues. Long-term borrowing Large structural BMPs may require funding through bond issues. 32 ------- Pro-rata share fees These fees are typically based on an assessment of the development's potential to contribute to urban runoff problems. Storm water utilities Utilities typically assess a fee based on the percentage of a site's impervious area. Special assessment districts Funds for projects in a district can be raised by assessing fees to landowners in the district. 33 ------- Elements of Successful Programs/Solutions The case studies presented in this manual were selected as examples of exemplary local government initiatives in the area of urban runoff control and/or retrofit implementation. The case studies included are all "success stories," and they display certain common elements. Among these are the following: strong institutional motivation to act on problem political and/or grassroots support for action skilled personnel knowledge of available technologies dedicated funding source, such as a storm water utility fee an environment of institutional cooperation and a long-term commitment to work together targeting strategy/process to maximize use of limited resources Many communities are recognizing the benefit of preventing ecological and habitat destruction to avoid the very high costs associated with the restoration of degraded resources. The most successful communities take a pro-active stance with regard to regulatory requirements, and use proper planning techniques to prevent degradation of water resources. They are realizing the economic, environmental and social benefits of protecting the existing ecosystem through land use controls, development restrictions and urban'best management practices. Conclusions and Recommendations Effective urban runoff control programs are built upon numerous institutional, economic and technical factors. The most successful programs examined in this project displayed a strong institutional or programmatic focus, in additional to having a strong motivation (usually economic) to act on a problem. Furthermore, the case study communities displayed strong political and/or grassroots support for community action as well as skilled personnel. Solutions must be tailored to each communities' particular circumstances, but the following recommendations may assist the interested community to more quickly develop an urban runoff control or retrofit program for developed areas. 34 ------- Recommendations Identify and obtain stable, if not dedicated, funding sources for urban runoff programs, including retrofit programs. Utilize cost-share approaches among agencies to maximize resource impact and obtain participation and support from private interests benefitting from urban runoff control projects. Use team or multilateral approaches wherever possible; given the nature of urban runoff problems, most solutions will need to cut across bureaucratic and organizational boundaries. Focus effort initially on building institutional structures to support comprehensive urban runoff control programs. Identify water quality problems and prioritize retrofit alternatives. Identify all existing related programs and assess their effectiveness and modify where needed. Consider innovative, cost effective, and environmentally responsible ways of retrofitting. Utilize economic incentives (such as tax or fee reductions) to motivate property owners to employ runoff control and/or retrofit strategies. Make retrofit projects a condition of approval for redevelopment projects. Create a single management agency charged with overall responsibility to plan and coordinate program implementation and conduct and/or monitor operations and maintenance activities. Designate agency staff to support implementation of projects. Do adequate retrofit planning and realistic goal setting. Select knowledgeable contractors or contractors with a good track record in water quality and urban runoff control projects. 35 ------- Supervise, even direct if necessary, the construction phase of ail projects. Educate developers, consultants, contractors, politicians and the general public about urban nonpoint source pollutions issues. Identify opportunities for public/private partnerships to conduct nonpoint source pollution control activities. 36 ------- Introduction to the Case Studies The following case studies exemplify many of the institutional, regulatory, planning and implementation issues discussed throughout this manual. They describe the experiences of selected local governments in dealing with the problem of urban runoff management in developed areas. Many of the approaches described in the case studies are highly innovative and will be useful guides for other localities considering the implementation of urban runoff control and/or retrofit programs. This manual utilizes the case studies to illustrate some approaches which localities are successfully using to manage urban runoff problems. It provides examples of jurisdictions where institutional frameworks have been successfully developed to support urban runoff management and retrofit programs. Institutional issues are given great emphasis in the case studies, as in the main narrative, because institutional issues, rather than purely technical ones, are believed to be a common obstacle to the successful implementation of urban runoff management projects. The case studies demonstrate the many different ways communities have developed and implemented urban runoff management programs. Each program is unique, based on the magnitude and negative impact of that community's urban runoff problem, the available resources and existing pollution control programs, and the existing regulatory context in which the local government is operating. ------- Citv of Alexandria, Virginia Introduction Municipalities are being confronted by increasingly stringent local, state, and Federal environmental regulations. Complying with these regulations is a challenge. The approach taken by the City of Alexandria, Virginia is a case study which illustrates this point. Alexandria is situated on the tidal Potomac River, across and down river from Washington, DC. Because of its location, the City must comply with Virginia's "Chesapeake Bay Preservation Act." The Act's implementing regulations required the City to designate "Chesapeake Bay Preservation Areas" within its boundaries. The City as a whole was designated to be a preservation area. This designation means that development and redevelopment of land in the City must achieve specified storm water management criteria. For permitted development, nonpoint source pollution loads cannot exceed pre-development loads based on average land cover conditions. For redevelopment of land currently served by water quality best management practices (BMPs), nonpoint source pollution in post-development runoff cannot exceed the load existing prior to redevelopment. For redevelopment of land not currently served by water quality BMPs, a ten percent reduction in nonpoint source pollution in runoff must be achieved when compared to the load existing prior to redevelopment. Meeting these storm water management criteria in Alexandria has indeed been a challenge. Implementing conventional water quality BMPs to control the quality of storm water discharges is often either economically impractical or physically impossible because of a number of factors such as a lack of physical space, extremely high land values, a high water table, or unsuitable soil conditions. The City has met the challenge by adopting and adapting for local use a class of BMPs dubbed "ultra- urban." Ultra-urban BMPs are non-conventional BMPs that are particularly suited for use in highly urbanized areas. They are based on sand filter technology and are currently used "in other parts of the United States. Alexandria has installed four of these ultra- urban BMPs in intensely developed areas. In order to facilitate the use of sand filter technology, the City has published design criteria for various ultra-urban BMPs in the Alexandria Supplement to the Northern Virginia BMP Handbook. The Alexandria Supplement states that the standard types of BMP facilities such as dry ponds, wet ponds, and infiltration devices are not suitable for use in large areas of Alexandria because of space limitations or poor soil conditions. The planner, developer, or engineer is therefore urged to consider the use of unconventional or 38 ------- innovative BMPs. It should be noted that infiltration is not the preferred method in Alexandria and will only be approved where it can be clearly demonstrated that it } will work Most areas of Alexandria do not contain soils that are conducive to the use of infiltration devices. (Marine clay is the prevalent soil type in Alexandria and the region.) To complicate the problem, Alexandria, in common with many older cities developed in previous centuries, has sections of combined sanitary and storm sewers. During heavy or prolonged storm events, combined sewer overflows (CSOs) may occur, discharging directly into streams. Alexandria has applied for an NPDES permit for the CSOs from the Virginia Department of Environmental Quality. Strategy The development of design criteria to guide local developers, culminating in the Alexandria Supplement to the Northern Virginia BMP Handbook, resulted from the City's engineering staff consulting with jurisdictions across the country where similar ultra-urban technology is being proposed or has been implemented. It should be noted that the City's strategy of implementing ultra-urban BMPs was essentially driven by the lack of available land and alternatives. Most other BVPs were fairly easily screened out because of the severe space constraints. Available technology aside, the other principal strategy issue requires that opportunities be seized as they arise, usually from redevelopment. The general strategy employed in the implementation of these retrofits was one of exploiting any available opportunities. Cooperation was solicited from developers. The double trench Delaware sand filters which were implemented did not take up any valuable land above-ground and this was a strong selling point for bottom-line conscious developers. This allowed them full economic use of the land. The focus has been on available sites. Parking lots have been the chief sites suitable for the Delaware sand filters, and implementation has been limited to them. One advantage of the Delaware sand filter for Alexandria is that it requires a total depth of 30 inches from the ground surface to the bottom of the paved trench. This is critical in portions of the city where the depth to groundwater is minimal. In addition, the simplicity of the system and the ready accessibility of the chambers for regular maintenance makes the Delaware-type filter very suitable for site conditions which are typical in Alexandria. This type of system is appropriate for up to five acres of 100% impervious cover. Two [District of Columbia] underground vault sand filter systems were installed on a 3-acre townhouse development in the Winter/Spring of 1994. The principal advantage of these systems is that they may be placed under streets, and in cells of 39 ------- parking garages, allowing full economic use of the surface areas. The cost of implementing sand filter technology varies due to site-specific conditions. Most of the devices already implemented in Alexandria were prototypes, making accurate cost estimates difficult. However, a range based on the characteristic design of the Delaware, Austin, and District of Columbia designs can be estimated. The costs of Austin sand filters, typically suitable for large-scale sites, range from $13,000 to $19,000 per impervious acre. The D.C. sand filter, which is characterized by an underground vault with sediment and filtration chambers, originally cost around $35,000 per unit, but through economies such as pre-cast concrete and standardized design, costs have come down considerably to the $12,000 to $16,000 range. It should be borne in mind that the early models of these systems are essentially prototypes and that costs are highly variable. Economies of scale are likely to come about through routine implementation. The use of prefabrication and modular units may further reduce costs in the future.9 Effectiveness of Ultra-Urban BMPs compared with Conventional BMPs Most of the (Delaware) double-trench sand filters implemented to date in Alexandria have not been subjected to long-term monitoring and Delaware does not rate these systems for nutrient removal efficiency. Based on long-term monitoring of sand filtration systems done by Austin, Texas, the Delaware system is rated at 80% suspended solids removal rate. Alexandria, however, recognizes a TP (total phosphorus) removal rate of 40%.10 The Virginia Chesapeake Bay Local Assistance Department has provided a grant to the City of Alexandria to monitor the performance of the first two Delaware sand filters constructed in the city. Other Institutional Issues This case study illustrates the benefit of having a committed public official dedicated to implementation of nonpoint source pollution control technology. The City Engineer has implemented retrofits mostly on his own initiative, having had relatively few bureaucratic obstacles to overcome. 9 Warren Bell, A Catalog of Stormvater Quality Best Management Practices for Ultra-Urban Watersheds. Presented at the National Conference on Urban Runoff Management in Chicago, on April 2, 1993. IL 10 Ibid. 40 ------- There are other programs described in case studies in this manual where institutional support comes from the "grass roots." It is vital to have public support for pollution control programs, but building support for these programs may sometimes require that public officials take the lead and steer programs past the numerous bureaucratic obstacles. For more information... For more information on the City of Alexandria's program, call the Transportation and Environmental Services Department at (703) 838-4320. 41 ------- Southeastern Massachusetts This case study looks at storm water retrofit projects in the following areas of Cape Cod: Buzzards Bay/Buttermilk Bay: 1) Spragues Cove Storm Water Remediation Project (Town of Marion) 2) Broad Marsh River Storm Water Remediation Project (Town of Wareham) 3) Electric Avenue Beach Storm Water Demonstration Project (Town of Bourne) 4) Hen Cove NFS Pollution Mitigation Project (Town of Bourne) Town of Yarmouth Town of Orleans Existing Nonpoint Pollution Problems on Cape Cod A Cape Cod Section 208 planning study identified the following pollutants in storm water runoff from urban sources at various locations on the Cape: Organics: Oil and grease (hydrocarbons), benzene, xylene, and toluene from auto emissions or atmospheric deposition. Runoff from roads into Buzzards Bay is estimated to contribute 33,000 Ibs. of petroleum hydrocarbons a year to the Bay. Inorganics: Nitrates, phosphates, ammonia, chloride, sodium, calcium, potassium, barium, iron, cadmium, chromium, copper, lead, and zinc have all been identified in runoff from a section of Route 28 near Falmouth. Biological: Bacteriological contaminants (mostly fecal coliform) in storm water runoff were strongly implicated in the closure of shellfish beds in Buttermilk Bay (Bourne). I. Case Studies Buzzards Bay Area In Buzzards Bay, over 8,000 acres of shellfish beds are believed to be closed as a i 42 ------- direct result of storm water contamination. This represents an estimated economic loss of $24 million to communities in the Buzzards Bay area.11 The Buzzards Bay Comprehensive Conservation Management Plan (CCMP) adopted in 1992 calls for the prevention of new storm water discharges to the Bay, as well as the remediation of existing discharges that pose a threat to water resources. The plan also calls for towns to inventory and prioritize storm water discharges for remediation. After towns have evaluated their storm water needs, they can proceed based on available resources Funding, however, is one of the most significant factors affecting the ability of Southeastern Massachusetts area towns to deal with their urban runoff problems. The development of the Buzzards Bay CCMP resulted in some significant accomplishments for the Buzzards Bay region: it established overlay district protection to limit nitrogen inputs to marine waters of Buttermilk Bay (a first in the nation) it resulted in the development of regional strategies, approaches and enforceable mechanisms as part of the Massachusetts Coastal Zone Management program 1. Electric Avenue Beach Strategy and Rationale An existing storm water system was retrofitted at Electric Avenue Beach in Bourne, Massachusetts as a demonstration project as part of the Buzzards Bay Project (a joint project of the Massachusetts Coastal Zone Management Program and the U.S. Environmental Protection Agency). The project was undertaken in response to high fecal coliform bacteria levels found in wet weather storm drain discharges to Buttermilk Bay, a tidal embayment in the towns of Bourne and Wareham at the northern end of Buzzards Bay. The Buzzards Bay Project funded the implementation of a storm water infiltration system in order to test the effectiveness of these systems in removing bacterial and nutrient contamination from the storm water runoff entering Buttermilk Bay. The storm water infiltration system was designed to intercept a one-year design storrn from the adjacent watershed and to avoid direct discharge of the first flush to the Bay. Instead, the flow enters a settling tank for removal of solids and floatable waste and is then discharged to infiltration galleys. The only flow which is 11 Buzzards Bay Project, "Bay Watch," (Newsletter) Spring/Summer 1993 Vol. 7 (5), p. 1. 43 ------- discharged from the original outfall is from a one-year storm or better. Monitoring provided by the Barnstable County Health Department has confirmed a reduction in bacterial loading. There are other points which make this project noteworthy: the infiltration galleys are preceded by oil/grit chambers designed to reduce clogging in the infiltration devices because the infiltration devices are very dose to the beach area, the distance to groundwater is approximately two feet - groundwater sampling has not shown any contamination, however a substantial reduction in construction costs was achieved by utilizing personnel from the Town of Bourne's Department of Public Works One of the unique aspects of this demonstration project was that the EPA Region I and Buzzards Bay Project oversight staff utilized the Department of Public Works personnel from the Town of Bourne for construction of the storm water infiltration system. The significant institutional consideration here is that the experience gained by Town staff in the design of the demonstration project could be used for the construction and maintenance of additional storm water infiltration systems. This enhances the storm water quality control expertise of Town personnel and further institutionalizes the process. Effectiveness At the Electric Avenue demonstration project site in Bourne, monitoring indicates that the retrofit structures are removing over 95% of the fecal coliform from storm water runoff. 2. Hen Cove Monpoint Source Pollution Mitigation Project Storm water runoff pollution was implicated in the closure of shellfish beds and a swimming beach in Hen Cove. The Buzzards Bay Project assisted the Town of Bourne in retrofitting the adjacent storm drain systems so that pollutants are not discharged directly to the Cove. Strategy and Rationale The Hen Cove project targeted specific storm drain systems which currently allow direct discharge of untreated storm water into the Cove. The mitigation project incorporated the use of leaching chambers and the surrounding soil to treat the "first flush." (During heavier or more severe storms, excessive runoff will overflow into the 44 ------- conventional storm drain system.) Several individual leaching chambers were placed under the road surface throughout the watershed (there are 13 so far). At each location, runoff from the road will be diverted into a storm drain with a settling I basin to allow sediments and other solids to settle out. From the storm drain inlet, the storm water is then piped under the road surface into leaching chambers. The leaching chambers are pre-cast, perforated concrete structures which are surrounded by crushed stone. Storm water is temporarily stored in the chambers and in the voids between the crushed stone until it seeps into the surrounding soils. Groundwater monitoring will determine the success of this approach by determining the amount and type of pollution attenuation in the surrounding soils. 3. Spragues Cove Storm Water Remediation Project The Buzzards Bay Project is working with the Town of Marion, Massachusetts, to reduce pollutants associated with storm water runoff entering Spragues Cove. Spragues Cove is a small, shallow embayment on the shore of Sippican Harbor. Currently its three-acre area of valuable shellfish beds is closed for shell-fishing because it exceeds both state and Federal bacteria standards for shellfishing. The largest storm drain system drains approximately 64 acres of watershed directly in the Cove. The mitigation project will incorporate the use of a constructed wetland system to treat the "first flush." Strategy and Rationale Several treatment alternatives for the storm water draining into Spragues Cove were considered: No action. The drainage system continues to function and shellfishing areas remain closed because of high fecal coliform counts Mechanical treatment methods such as chlorination, ultraviolet light, ozone and reverse osmosis Physical methods of treatment such as infiltration, settling or constructed wetlands The Town of Marion reviewed the alternatives and decided that a constructed wetland system met the objectives of the project. The system will include a settling basin, marshland vegetation, and an open, deep water pool. The settling basin allows for coarse sediments and particulates to settle out prior to entering the wetland treatment system. In the wetland itself, physical and biological processes will treat and remove pollutants from the water. The restored wetland system will have a hydraulic detention time of over 14 days. 45 ------- The wetland system will be constructed where a salt marsh previously existed. The site was filled decades earlier with dredge spoil from nearby Sippican Harbor. In addition to providing water quality improvements, the restored wetlands system will enhance the fish and wildlife habitat in the area. Currently the site has little habitat value. Effectiveness Existing research on using wetlands to treat wastewater for fecal coliform indicates that at least 95 percent or greater is typically removed. Fecal coliform counts associated with storm water from the Spragues Cove outfall are significantly lower than previously recorded levels. The water quality monitoring plan will be part of the quality assurance/quality control (QA/QC) plan required by the U.S. Environmental Protection Agency. Costs and Funding The Town of Marion and the Buzzards Bay Project obtained $25,000 through the Massachusetts Department of Environmental Protection's 319 grant program. The Town provided an in-kind match valued at $35,000 to cover the cost of construction, equipment and labor. The Town also donated the land on which the wetland system will be constructed (estimated value of $100,000 per acre). A total of two to three acres of land will be utilized for the project at a total cost of $200,000 to $300,000. Additionally, the U.S. Fish and Wildlife Servide granted the Town $10,000 for the project under the Wetland Restoration Program. Planning and technical assistance will be provided by an interdisciplinary team from the Soil Conservation Service (SCS). 4. Broad Marsh River Storm Water Remediation Project Broad Marsh River is a tributary to the Wareham River estuary. It is located in the Town of Wareham in the northern part of Buzzards Bay. The entire Broad Marsh River has been closed to shellfishing and some beaches closed to swimming due to high fecal coliform concentrations. The most significant source of pathogens and fecal coliform pollution in the river is associated with storm water runoff from discharges from adjacent storm drain systems. Other potential sources, such as migratory waterfowl and boats, have been deemed insignificant. The primary objective of the storm water remediation project is to reduce the amount of pollution (mostly fecal coliform) from storm water runoff entering Broad Marsh River. 46 ------- Strategy and Rationale Several alternatives were considered for the treatment of storm water runoff from storm drain systems adjacent to the Broad Marsh River: No action. Fecal coliform pollution would continue unabated and result in the continued closure of shellfishing beds and many beach closures for swimming. Extended detention basins, wet ponds or constructed wetlands would be used to detain the first flush of runoff for at least 24 hours. Infiltration structures such as infiltration basin at the end of each storm drain system, or a series of leaching chambers under the existing road surface The selected alternative was the use of leaching chambers placed under the road surface. The rationale for selecting this alternative is typical in many retrofit situations; detention basins were rejected because, as an "end-of-pipe" practice, they require considerable commitment of land to function properly. Since there are 16 storm water outfalls to this section of the Broad Marsh River, there would have to be 16 detention basins and this would require the acquisition of a large amount of land, including some dwellings. This choice was not deemed feasible. Infiltration basins located at the end of a pipe have a similar need for large land commitment. The leaching chamber option was chosen because leaching'chambers placed under the road surface would minimize the disruption to the present drainage system and would not require a large land commitment. Effectiveness This project is not yet fully established. However, to demonstrate the effectiveness of the leaching chambers, the project will monitor a minimum of three chambers. Costs and Funding The Buzzards Bay Project was initially unable to fund the Broad Marsh River project. However, the Buzzards Bay Project together with the Town of Wareham, requested funding under the Massachusetts Department of Environmental Protection's 319 (Nonpoint Source) Program and successfully secured funding in the amount of 1,450 to help reduce pollution loadings from storm water runoff. 5. Town of Yarmouth In 1991, the Town of Yarmouth implemented the retrofit of a drainage system to 47 ------- eliminate the direct discharge of storm water runoff containing high fecal coliform counts to the Bass River. The drainage system was retrofitted to direct the flow into a retention basin to allow storm water to percolate through a gravel bed. This design also allowed for evaporation to remove pollutants. The retrofit substantially reduced fecal coliform counts from pre-retrofit levels and improved the water quality in several ways: it has reduced velocity, encouraging infiltration it further reduced the velocity through infiltration and evaporation fecal coliform counts are lower even after similar pre-retrofit rainfall events Effectiveness Water quality monitoring performed by the Barnstable County Department of Health Laboratory both before the retention basin retrofit and afterward revealed substantially reduced fecal coliform counts.12 6. Town of Orleans The Town of Orleans, Massachusetts is a community on Cape Cod which has extensive coastal waters, including three estuaries. These waters contain important commercial shellfishing areas. In 1988, several areas within the Town's waters were closed to shellfishing due to bacterial contamination. Through sampling of storm drain outfalls and receiving waters, and from a review of existing water quality data, the Town identified storm water runoff as a significant source of contamination from bacteria and other pollutants to its coastal waters. Strategy and Rationale Three drainage areas were targeted as having significant adverse impacts on water quality in sensitive areas and in need of remediation. The Town's strategy was to: 1) identify the three high priority areas for development and implementation of pollution control measures; 2) establish a storm water management committee; 3) screen BMP alternatives to choose best available means to remove bacteria and solids; and 4) appropriate funds for study of conceptual approaches and engineering designs and for construction of the BMPs at the three high priority sites. 12 Town of Yarmouth, "Effects of Route 6 Storm Drainage Improvements on Water Quality in Bass River," November 11, 1992. 48 ------- Prior to undertaking the projects, which are scheduled for completion in May, 1993, the Town acted on the consultant's recommendations and took the following actions: scoped potential solutions focus on BMPs for control of bacteria and solids prior to choosing BMPs, Town conducted field investigations, which included the following steps: mapping drainage systems analyzing pollution treatment alternatives sizing treatment facilities designing O & M programs The BMP selection process identified the most feasible and cost effective practices for use in the three drainage systems which were to be retrofitted. In addition, the Town of Orleans Storm Water Quality Task Force was set up to insure the project's technical quality and to address local concerns. A range of BMPs were considered for control of bacteria and solids and their associated nutrients. The following BMPs were considered for this project, because they are targeted for the control of solids and bacteria: extended detention ponds retention basins infiltration trenches (subsurface leaching gallies) filtration beds A system of sub-surface leaching gallies was used at three sites because of limited land but suitable soil conditions; one site consisted of a detention basin upstream of a filter bed structure because soil conditions were too poor to permit infiltration. Institutional Issues The Town's principal institutional motivation for implementing the retrofit projects was the adverse economic impact of closed shellfish beds. Abating and controlling the bacterial contamination from storm water runoff was directly tied to economic concerns and this was a very strong motivation for the Town to organize a task force and to act on the problem. The Town appropriated funds to develop conceptual approaches and engineering designs, as well as for the construction of the necessary BMPs. II. Regional Cooperation: Role of the Cape Cod Commission The Cape Cod Commission works with towns on Cape Cod on various matters 49 ------- including local transportation projects. In Barnstable County, shellfish bed closures were the principal motivation for the Commission to become involved with storm water issues. The Commission trys to de-politicize issues and use all "levers" available, including state environmental review processes, such as coastal zone management consistency review, to affect outcomes. Strategy The strategy employed by the Cape Cod Commission utilizes several different components to maximize the leverage which the Commission can employ to facilitate implementation of storm water retrofit projects on Cape Cod. They try to use all the "levers" available, such as coastal zone management consistency review and the implementation of the Buzzards Bay Management Plan as part of the National Estuary Program (EPA). The Cape Cod Commission works as a coordinator [much like MWCOG in Anacostia watershed restorations] with the Massachusetts Department of Public Works (Mass DPW) and local governments on storm water remediation and retrofitting as part of local transportation projects. The Cape Cod Commission (through the Cape Cod Marine Water Quality Task Force) has developed a process for prioritizing storm water drainage mitigation projects. This process includes the development of a numerical index to rank proposed projects. The worksheet is keyed to the concerns o'f Barnstable County, viz., the safety and harvestability of shellfish beds, as well as the safety of areas used for swimming and recreation. For more information... For more information about the Buzzards Bay Project and other programs in Southeastern Massachusetts, call the Buzzards Bay program office at (503) 748-3600. 50 ------- City of Austin, Texas Background The City of Austin, Texas, stretches from the Texas hill country of the Edwards Plateau, eastward to the Blackland Prairie and the Gulf Coastal Plain. A unique environment results from this rapid geologic and ecologic transition. The Colorado River flows directly through the City. Three riverine lakes - Lake Travis, Lake Austin and Town Lake - are the three most downstream reservoirs of a chain of reservoirs on the Colorado River known as the Highland Lakes. These reservoirs are the City's main water supply, as well as being tourism and recreational resources. Another key water resource in the area is the Edwards Aquifer, a limestone aquifer on the western side of the City. The aquifer is the sole source of water supply to several communities south of Austin. These water resources are potentially threatened by water pollution resulting from storm water runoff and other sources of nonpoint pollution. In response to this threat, the City has developed one of the best watershed protection programs in the country. The keystone of this program is the Comprehensive Watersheds Ordinance. Development of the Comprehensive Watersheds Ordinance In order to protect water resources from degradation due to urban nonpoint source pollution, the City enacted several watershed protection ordinances in 1988. These ordinances were combined into a single code which applies to the entire city and to its extraterritorial jurisdiction. The City of Austin Land Development Code and the Environmental Criteria Manual provide guidance for water quality management. The 1988 regulations became the basic building blocks of the Austin storm water management and BMP implementation and retrofit program. The original catalyst for the consolidation of the existing watershed protection ordinances was the comprehensive planning effort known as "Austin Tomorrow." This plan identified nonpoint source pollution as a potential threat to Austin's environmental and economic well-being. Monitoring of Austin's creeks and lakes followed this study and in 1978 the Lake Austin Watershed Ordinance became the first water quality related ordinance and nonpoint source pollution control ordinance to be adopted in the region. In 1981, the City of Austin joined the EPA-sponsored Nationwide Urban Runoff 51 ------- Program (NURP) study and began monitoring its storm water structural controls in 1982. Subsequent watershed protection ordinances were passed from 1980-1984 to cover additional environmentally-sensitive areas. By 1986, the City of Austin had had eight years of experience with watershed protection ordinances and appointed the Comprehensive Watersheds Ordinance Task Force to develop the consolidated ordinance and provide final review and recommendations for implementing the consolidation of the numerous existing ordinances. Overview of the Comprehensive Watersheds Ordinance The Comprehensive Watersheds Ordinance (CWO) was directed at preventing urban runoff pollution by placing requirements on proposed new development with Austin and its extraterritorial jurisdiction. Although the Comprehensive Watersheds Ordinance originally existed as a stand-alone document, it has since been incorporated into the City's Land Development Code. In addition, there have been several amendments to it since 1986 and more are anticipated in the future to better protect various sensitive areas. Nevertheless, knowledge of the evolution of the Ordinance is helpful to understanding Austin's strategy for urban nonpoint source pollution control. Specific pollutants were not addressed in the Comprehensive Watersheds Ordinance. Control of specific pollutants was instituted only for the sensitive Barton Springs Zone, which recharges the Edwards Aquifer. Several ordinances for the protection of this sensitive area have been put in place over the last several years. The Ordinance required a range of widely accepted and proven structural and nonstructural nonpoint source pollution controls to be included in new development projects. These controls included best management practices (BMPs) such as impervious cover limitations, water quality buffer zones, protection of critical environmental features, limitations on disturbance of the natural stream, erosion control practices, sedimentation and filtration basins, and wastewater disposal requirements. One significant aspect of the ordinance was the use of nonstructural controls to prevent and mitigate nonpoint pollution associated with development. The rationale behind this approach was that impervious cover limitations and buffer zone requirements have been proven to maintain the basic hydrologic balance. Protection of non-drinking water supply watersheds in the eastern side of Austin were not given high priority. Downstream of Town Lake the Colorado River is not used for drinking water supply. Furthermore, clay soils dominate on the eastern side of the City; therefore, maintaining infiltration and recharge is not a critical goal in these watersheds. 52 ------- Effectiveness of the Ordinance The City of Austin standard sand filter design requires the first half inch of runoff from a site to be diverted into a sedimentation basin and then filtered through sand. This design is based on eight years of monitoring filter ponds of different designs.13 The demonstrated removal efficiency of the sedimentation/filtration ponds for total suspended solids is 75% to 97%. An important consideration learned from the Austin experience regarding effectiveness is that maintenance is critical to ensure BMP effectiveness, yet timely maintenance is problematic at both a local and nationwide level. Another is that the best protection for water resources is believed to be afforded by a combination of structural and non-structural controls as provided for in the Comprehensive Watersheds Ordinance. Structural controls alone are not always effective, nor can they prevent an increase in pollutants from high intensity developments. Austin's non-degradation strategy for contributing watersheds is to limit the percent of impervious cover in new developments and to reduce post-development pollutant loads through a menu of storm water control practices, and a program of retrofitting storm water treatment measures in developed areas. Austin has incorporated this strategy into the framework of the City of Austin Land Development Code through a mechanism known as an "impervious cover cap." The impervious cover cap is established by setting a Maximum Sustainable Removal Rate for storm water treatment measures at 90%; beyond this point, storm water control measures cannot be relied upon to reduce the pollutant loads associated with additional impervious cover down to the pre-development level. This strategy aims to reduce excessive reliance on storm water treatment measures because of their inherent limitations and risk of failure due to lack of maintenance and their need for replacement. Impervious cover levels, on the other hand, do not change over time, do not require maintenance, and their life span is infinite provided their nature is unchanged. However, the Austin program recognizes that modification of the City's development regulations would provide only a partial solution to the problem of water quality degradation. It sees retrofitting of structural storm water controls as the only way to reduce pollutant loads from existing development and development projected but not 13 Parrish, John H. and Stephen Stecher, "Nonpoint Source Pollution Control in the City of Austin." City of Austin, Environmental and Conservation Services Department, March '1991, p. 5. 53 ------- yet built.14 The Austin program has recognized that, in light of the growing trend toward limiting building density and/or impervious cover as a means of nonpoint source control in residential areas, there is a need to establish a clear linkage between development density or impervious cover and pollutant loadings. In addition, the city recognized that more study is needed on the effects of types of land use on the quality of storm water runoff. The City's Storm Water Monitoring Program has provided the city an opportunity to evaluate the effectiveness of its varied array of storm water quality controls, and also to assess whether they are over- or under-designed relative to site conditions. First Flush of Runoff and its Effects on Storm Water Control Structure Design15 Austin's Environmental Resource Management Division published a report (1990) showing that the first 1/2 inch of runoff did not necessarily carry the bulk of the storm load. This was contrary to the prevailing assumption that the first 1/2 inch of runoff in a storm washes off 90% of pollutants from the impervious cover. The report suggested that for a development with 90% impervious cover, only 40% of the total storm load would be washed off in the first 1/2 inch of runoff. The implication of the report for control structure design was that a control structure designed to capture and treat only the first 1/2 inch of runoff would only remove about 40% of the total annual load. The bypass or untreated annual load could be substantial. The report did not suggest an alternative structural control design; it merely raised the issue of a substantial amount of pollutant load in excess flow from a structure designed to capture and treat the first 1/2 inch. Changes to the City's Land Development Code in December 1993 resulted in the treatment volume increasing with the amount of impervious area on the site, starting at .50 inch plus .10 inch per 10% increase in impervious cover over 20% of the site. However/ urbanized watersheds should be targeted for priority control based on other findings. Another Austin study confirms that storm water runoff pollutant loads increase with watershed imperviousness, and that loading rates of urbanized 14 Ibid., p. 15 15 City of Austin, Environmental Resource Management Division, "The First Flush of Runoff and Its Effects on Control Structure Design." June, 1990. 54 ------- creek watersheds were significantly higher than those from small suburban sites.:fi Sand Filter Program The City of Austin has developed a sand filtration best management practice for use in storm water quality management. The sand filtration systems are the primary water quality control structures. The City had previously implemented a storm water monitoring program in 1984. This study was conducted to determine annual removal efficiencies of six storm water quality control structures, including three filtration basins, one wet pond, one sedimentation (dry) pond, and one retention/filtration basin system. The structures were monitored between 1984 and 1989, and comparative measurements of inflows and outflows were taken to determine concentrations of pollutants. Effectiveness of removal for the following parameters was measured: Fecal coliform Total suspended solids (TSS) BOD/COD Nitrogen Phosphorus Heavy metals The study17 concluded that the sand filtration basin is an effective structural control measure for most of the described pollutant parameters. Sand filtration is a demonstrated success in Austin, although officials concede that maintenance is sometimes inadequate and sporadic.18 There have also been some isolated technical and/or design failures, such as slope erosion and construction failures which have resulted in inadequately performing BMPs. "City of Austin, Environmental Resource Management Division, "Stormwater Pollutant Loading Characteristics for Various Land Uses in the Austin Area." March, 1990. 17City of Austin, Environmental Resource Management Division, "Removal Efficiencies of Stormwater Control Structures." Final Report, May 1990, p> 16. "Personal communication with Les Tull, Engineer, City of Austin, Texas, May 25, 1993. 55 ------- Strategy The Austin sand filter program was implemented in response to regulator)' requirements, viz., the consolidation and enactment of several watershed protection ordinances in 1988. In addition, political pressure to act came from citizens demanding action to protect water quality. The City of Austin's Land Development Code and Environmental Criteria Manual provide documentation and guidelines for the City's water quality management efforts. - - , . - '" -.-*", *%** Prior to enactment of the watershed protection ordinances, the City implemented a storm water monitoring program in 1984 to evaluate storm water control measures and to develop a database to quantify the effects of impervious cover and land use on water quality and also to evaluate the effectiveness of various structural storm water control measures already in use. The basic strategy and philosophy guiding the Austin program has been to make . new development and redevelopment pay the costs attributable to its impact and to mitigate all impacts of new development. While this has been the strategy, it has not been possible to accomplish this for all aspects of the development process, such as permits and review. In addition, the City assumes responsibility for maintaining water quality controls for single-family development. This approach includes a provision for payment of a fee in lieu of constructing BMPs so as riot to restrict development. "Fee in lieu of" funds are used for retrofit projects for existing development, but only within the most highly urbanized and developed watersheds classified as "urban" in the Land Development Code.19 There are many components to the Austin storm water management amd urban nonpoint pollution control program. These include retrofit watershed master planning, source control of pollutants, and public education. A current emphasis is on the public education component, which includes videos and posters with the theme of abating urban nonpoint source pollution. Austin's strategy sees the key to a successful nonpoint source control program as the targeting of critical areas to achieve high pay-off returns. The City's focus is on potential deterioration of local water supplies, viz., Lake Travis, Lake Austin, Town Lake and the Edwards Aquifer. The Comprehensive Watersheds Ordinance requires the strongest nonpoint source controls in those developments in watersheds which contribute to the drinking water supply. Targeting new development is seen as a cost effective method of preventing future nonpoint source problems. Required controls which are prescribed in the Ordinance 19 Ibid. 56 ------- can be included in the initial land planning. Since the primary controls set forth in the Ordinance are non-structural, raw land cost is the main cost for new development associated with nonpoint source controls. However, structural controls are also used and these have a cost to the developer. Since impervious cover limitations are the most important non-structural control specified in the Ordinance, retrofitting existing development has proven to be difficult. Retrofitting structural controls has also been difficult, due to limited location and high land costs. The City's retrofit program uses public education as its main tool to build and keep the necessary public support for storm water management programs through the use of videos, posters, and other media. In addition, Austin has initiated a process of storm water retrofit master planning as a way of maximizing the scarce public resources available for this purpose. Developing a strategy for controlling nonpoint source pollution from urbanized watersheds is particularly difficult, and much more complex than preventing nonpoint source pollution from developing watersheds. Retrofitting BMPs in urban areas is still a "pioneering" activity and involves considerable experimentation and cost. While there are an increasing number of localities pursuing retrofit strategies, there is no broad national experience with retrofit implementation. BMP selection in retrofit situations is also problematic; for example, wet ponds are an excellent BMP for controlling nutrients, yet they are often very difficult to site under retrofit conditions. Non-degradation Strategy20 Austin has developed a non-degradation strategy for a particularly sensitive and important area known as the Barton Springs Zone, which covers several watersheds. The strategy is "design-based" rather than being entirely a technology- or performance-based approach. The design-based approach requires that compliance be designed into a project before it is built based upon best available scientific and engineering principles. This strategy includes a City-funded program for retrofitting storm water controls. Other elements of the non-degradation strategy include: strengthening existing regulations by limiting exemptions limiting impervious cover to levels at which generated pollutants can be 20Parrish/Stecher, "Nonpoint Source Pollution Control in the ,City of Austin," March 1991., p. 12 57 ------- reduced to background levels by an array of storm water control practices Importance of Non-structural Controls in Austin's Program One of the distinctive features of Austin's storm water management strategy is the emphasis given to the use of non-structural controls. The basic assumptions of this approach are the following:21 structural controls alone cannot prevent an increase in pollutants from high intensity development maintenance requirements are high for structural controls compared to the maintenance needed for impervious cover limitations and buffer zones sole dependence on structural controls is not wise for protecting the City's water resources; a combination of structural and non-structural controls is the best strategy Institutional Issues Austin created a city department of environmental conservation, the Environmental and Conservation Services Department, in 1987. Its central focus is resource conservation and environmental protection, as distinct from public works. This department is co-equal with other City departments. It oversees the work of public and private agencies under its jurisdiction. This institutional arrangement is clearly intended to provide support for effective environmental and regulatory (enforcement) action. The Environmental and Conservation Services Department and the Department of Public Works "share" a drainage utility (storm water utility). Drainage projects are funded with fees from the drainage utility. "Storm water" is not separately identified on the utility bill, nor described as such officially. Costs and Financing Most storm water programs are funded by the drainage utility, or drainage fee. Public works drainage projects in the Capital Improvements Program are paid for with bond sales which are repaid with tax (general fund) revenues at this time. 21Parrish/Stecher, "Nonpoint Source Pollution Control in the City of Austin," p.6 58 ------- Development is expected to "pay for itself," that is, development must pay for the cost of controls associated with that development. However, in reality, development fees pay for approximately 30% of the land development review and permit programs. Nevertheless, the program's emphasis on non-structural controls means that the cost for the City is considerably lower (because of less monitoring and inspection) than if structural controls were the sole means of control. The Austin program also takes the view that preventing adverse water quality impa"cts from nonpoint source pollution- is much less expensive than ti^ift^-t .water quality after it has been degraded. One of the stated goals of the ' Comprehensive Watersheds Ordinance is to avoid the cost of retrofitting existing f * ' 1ir ** *' development. There are significant costs throughout the institutional structure related to control of nonpoint source pollution. Preventing NFS pollution can avoid or reduce other costs such as wastewater treatment, the need for dredging lakes and waterways, and health risks associated with toxics pollution. The Austin view is that the cost of restoration, retrofitting, dredging, advanced types of water treatment, development of new water supplies, and lost recreational and economic values can easily dwarf the cost of prevention.22 Other NFS Control Programs The City of Austin has also initiated non-structural and low-structural development controls to limit impervious surface areas for storm water management purposes. - They have established a critical zone in which no construction is allowed, as well as a transition zone where development is limited or not allowed in order to preserve riparian areas. Other programs which the City has instituted to control urban nonpoint source pollution include the following pollution prevention and source control programs: household hazardous waste collection: provides for safe disposal of hazardous materials street cleaning and litter collection program xeriscape and integrated pest management (IPM) programs: minimizes inputs to the environment from fertilizers and pesticides; both approaches stress the minimal use of the least harmful substances to control pests and weeds; IPM is encouraged in municipal operations 22Parrish/Stecher, "Nonpoint Source Pollution Control in the City of Austin," p.7 59 ------- BMP Siting Considerations There is a diversity of opinion as to whether it is better to construct large regional BMPs or numerous smaller BMPs closer to pollutant sources. The preferred approach in Austin is to construct numerous smaller BMPs and capture water as close to the source as possible for the following reasons: 1) need to capture less water to achieve the pollutant removal desired 2) capital and maintenance costs are less if the BMPs are smaller 3) maintaining the natural hydrology is easier with smaller BMPs - in addition, the need for groundwater recharge is addressed, whereas if channeling water further down the watershed was done, groundwater recharge would not occur (or recharge of polluted water could occur before the runoff reached the treatment device) 4) protection of smaller waterways from pollution and channel erosion Summary and Conclusion Austin has attempted to come to terms with its nonpoint source pollution problems through implementation of the Comprehensive Watersheds Ordinance and other ordinances since 1986. The City recognizes the actual and potential costs of nonpoint source pollution as it relates to safeguarding of drinking and groundwater supplies, maintaining tourism and recreational opportunities, and protecting wildlife habitat, to name a few. Austin is "ahead of the curve" in terms of meeting EPA and state water quality goals. These efforts will continue to pay benefits into the future. The development and implementation of the Comprehensive Watersheds Ordinance could be a model for other local governments in their efforts to control nonpoint source pollution. Relevance of Austin's Watershed Approach for Other Jurisdictions Austin's Comprehensive Watersheds Ordinance is easily transferable to other jurisdictions and to other hydrogeologic conditions. The Texas Water Commission cited Austin's Ordinance as-an example of the kinds of controls which local governments in Texas could implement as part of the Nonpoint Source Management Plan which the state submitted to the U.S. Environmental Protection Agency. 60 ------- Because the Ordinance is based on BMPs instead of on design or performance standards, it is widely applicable to other situations and does not require specialized staffs for its implementation. The Ordinance is accompanied by a technical manual which specifies the technical aspects of the controls which it requires. Numerous other jurisdictions in Texas have adopted watershed protection ordinances based on the same framework as Austin's. Governmental entities across the country have requested copies of the Comprehensive Watersheds Ordinance for guidance on how to protect their water resources and control nonpoint source pollution. 61 ------- Austin's Program at a Glance Steps to Implementation 1) Comprehensive Planning Process: "Austin Tomorrow" 2) Appointed Watershed Ordinance Task Force 3) Consolidation of Watershed Protection Ordinances 4) Passed Comprehensive Watershed Ordinance 5) Targeting of Critical Areas: Austin's strategy uses targeting of critical areas to achieve cost effective control. Controls for New Development Identify Candidate Retrofit Sites Retrofit Program A strategy for controlling nonpoint source pollution from urbanized watersheds involves considerable coordination, experimentation and cost. 1) Use Public Education to Build Support 2) Use Retrofit Master Planning to Maximize Scarce Resources For more information... For more information about the City of Austin's program, call the Environmental and Conservation Services Department at (512) 499-2501. 62 ------- City of Orlando, Florida Introduction The City of Orlando, Florida has taken a pioneering role in trying to solve its water quality problems related to urban storm water runoff. Protection of its numerous lakes and wetlands has been a primary motivation for action. Within the corporate limits of Orlando there are some 83 named lakes, which lie within five major drainage basins. The City has the distinction of having been designated a "National Storm Water City of the Year" by the U.S. Environmental Protection Agency. It earned this distinction because of its aggressive storm water management and retrofit program. . Some of the innovative storm water treatment systems and retrofit methods used in Orlando include storm water wetlands, alum injection, exfiltration, lake aeration, sediment control devices, trash screens and shoreline and littoral zone vegetation. Some of the other approaches being used in Orlando are: storm drain retrofits and water quality enhancements when performing corrective maintenance (e.g., vertical volume recover}7 unit for drainage to Lake Lawsona) exfiltration basin retrofits to existing city storm drains littoral zone enhancement and revegetation with native aquatic plants creation of storm water wetlands for pre-treatment of runoff entering lakes (e.g., Lake Lorna Doone) depressional landscaping to encourage runoff infiltration (e.g., Lake Ivanhoe) One of the many major retrofit projects in the Orlando area is the Lake Greenwood urban wetland, which is a wetland and storm water management system in an urban environment close to downtown Orlando. 63 ------- Evolution of the Florida Storm Water Program/Major Regulatory Components The major components of Florida's storm water program are three pieces of legislation: the 1982 storm water permit requirements for new development; the 1987 Surface Water Improvement and Management Act (SWIM), which provided a framework for watershed planning; and the 1989 storm water legislation, which established program goals and extended program coverage to existing agricultural and forestry sources. The Surface Water Protection and Management section of the 1989 storm water legislation provides the regulatory framework for the Florida storm water management program, particularly the watershed approach. This program was enacted by the Florida legislature to restore the state's degraded water bodies and to protect those still in good condition. The landmark 1989 storm water legislation was intended to integrate the various existing storm water laws and programs into a comprehensive watershed management program. Most importantly, the 1989 law emphasized the watershed approach to correcting existing storm water deficiencies and it gave a regulatory impetus to retrofitting. The 1989 law also established the State Storm Water Demonstration Grant Program which provides matching grants for. storm water treatment projects undertaken by local governments which have implemented storm water utilities. The grant program is clearly an inducement to Florida municipalities to set up storm water utilities. Lessons Learned in Florida's Storm Water Program The Florida storm water program has been successful at minimizing storm water problems associated with new growth, but it has been much less successful in restoring water bodies degraded by storm water discharges. The piecemeal approach cannot address one of the state's largest problems, however, the problem of retrofitting drainage systems, which includes: retrofitting of existing storm water drainage systems to reduce pollutant discharges to state waters correcting storm water infrastructure deficiencies related to the state's rapid growth Livingston stresses that the solution is comprehensive and coordinated work 64 ------- throughout the watershed.23 He emphasizes the need to address land use, water resources, and infrastructure planning within a watershed context. He also states that a dedicated funding source, such as a storm water utility is also important for maintaining an effective program. Lessons Learned in Orlando The Orlando experience suggests that one of the requirements for successful urban runoff control and retrofit projects is the importance of control of the project and the need to write very good specifications so that water quality goals are met. Engineers and consultants may have an economic incentive to design BMPs which may not be commensurate with the implementing authority's water quality goals. Experience reveals that engineers and consultants may sometimes have a mechanistic approach to problem solving and therefore advocate a hydraulic solution rather than water quality one in some instances. They know how to get the water off-site as quickly as possible, but this is not necessarily commensurate with a water quality solution. The best way for the implementing authority to ensure success is to be in control of the project, to know the solution that is necessary, and then see that it is done correctly. Greenwood Urban Wetland The Greenwood Urban Wetland in Orlando is a constructed urban wetland located within a 522-acre drainage basin. Storm water runoff collected within the 522-acre sub-basin flows into Lake Greenwood, which lies at the lowest point in a 4.5 square mile urbanized area. The artificial wetland was built to alleviate flooding, to pre- treat storm water runoff prior to discharge into drainage wells (which discharge water to the upper Floridan acquifer), and to re-use the stored water to irrigate an adjacent cemetery and park. City-owned land which was previously vacant was excavated to form a series of ponds and a bypass stream leading to five drainage wells. The storm water quality enhancement component of the wetland plan came about as a result of the City's concern for protecting its groundwater supply. Proximity to groundwater is a prime concern in most of Florida. "Livingston, Eric H., "Lessons Learned from a Decade of Stormwater Treatment in Florida." Bureau of Surface Water Management, Florida Department of Environmental Regulation, Undated. 65 ------- The storm water "treatment train" concept was incorporated into the Lake Greenwood urban wetland. The BMPs included in this treatment train are: a sediment and trash screening device; a littoral zone with vegetation; and aerators to increase microbiological activity. Effectiveness of the Greenwood Urban Wetland Water quality monitoring of Lake Greenwood was begun in 1987 - one year prior to the beginning of construction of the wetland. This was done to obtain a baseline profile and to ascertain the trophic state of the lake. Both before and immediately after construction, the lake exhibited eutrophic to hyper-eutrophic conditions. After completion of the project, the lake's trophic state indices were in the mesotrophic range. Prior to construction, the water quality of Lake Greenwood was not in compliance with Florida Class III (recreation and wildlife propagation) water quality standards. Since construction, there have been no water quality standards violations of any parameters tested, including EPA-listed pesticides. Further monitoring of the storm water treatment system is being planned for wet weather pollutant removal efficiencies and further hydraulic analysis. An ongoing storm water monitoring program was begun in 1991. Based on the preliminary sampling data, it is clear that the Lake Greenwood urban wetland storm water management system has enhanced water quality within the lake and also the quality of the water discharged to the drainage wells (which discharge to a major acquifer). Development of Orlando's Storm Water Utility Storm water projects in Orlando have traditionally been financed out of general fund revenues, as is common in most municipalities. In addition, Orlando has used revenue from a state gasoline tax for projects which also have a road/transportation component. Depending upon general fund revenues, however, often results in projects being deferred to pay for more critical governmental functions such as police and fire. The City has adopted an aggressive program of storm water system repair and replacement, pollution control, and lake enhancement. This problem has been funded in the past through the City's general property tax budget, but this source is no longer adequate for the scope of the problem today, particularly in view of increasingly stringent state and Federal water pollution control requirements. To provide for the effective management and financing of a storm water system within the City of Orlando, the City established a storm water utility. The storm 66 ------- water utility generates its revenue through user fees. A storm water service charge i±, levied on every parcel of land in the City. The fee is based on the amount of storm water which a particular parcel passes on to the storm water drainage system. The storm water utility is responsible for the operation, construction and maintenance of storm water management devices, for storm water system planning and lake management. Packed Bed Storm Water Filter Artificial Wetland24 One innovative project which was proposed by the City and implemented through a consultant was the "packed bed filter." This experimental storm water BMP will be used (just coming on line in July 1993) to treat a small but highly urbanized portion of the drainage basin which flows into Clear Lake. The project was initially proposed in response to concerns about the lake's water quality. The drainage basin for Clear Lake consists of over three square miles of highly developed urban area. This retrofit technique became necessary because best management practices (BMPs) for new development are not appropriate in the highly urbanized and completely built-out Clear Lake basin. This innovative method of storm water treatment was selected both for its presumed pollutant removal efficiency, as well as the necessity of using a BMP which could function within a limited area where land utilization constraints exist. The packed bed filter is an example of technology transfer - a common wastewater treatment technique which has application to urban storm water pollution treatment. The filter utilizes a treatment train of two components, one of which is a packed bed filter system planted with wetland macrophytes for nutrient uptake. Put more simply, the system is a packed-bed filter (similar to a trickling filter) with hydroponically-growing aquatic plants. During dry weather or low flow conditions, the device will treat water from Clear Lake using the continuous flow to maintain the planted beds. The device has a limited storage volume, so a decision was made that in order to maximize the removal of the most pollutants, the goal would be to capture less than the first one-half inch of runoff from a larger acreage than a greater amount from a smaller acreage. It is hoped that this will result in the treatment of a dirtier waste stream and reduce the amount of pollutants reaching the receiving waters of Clear Lake. 24Dyer, Riddle, Mills & Precourt, Preliminary Engineering Report: Packed Bed Filter. Prepared for the City of Orlando, FL, April, 1991, p. 4-3. 67 ------- Pollutant Removal Efficiency Cosiderations for Packed Bed Filters Although the packed bed filter implemented by the City of Orlando has only recently been brought on line [July 1993], there are certain operational considerations for packed bed filters as they relate to treating urban storm water runoff. Packed bed systems intended to treat storm water do not have to meet the strict effluent quality criteria that would be required for wastewater. Indeed, the concentration of pollutants in storm water most closely resembles tertiary treated wastewater with the exception of solids concentrations. This is one reason why the packed bed storm water treatment system was designed to treat a larger flow with lesser removal efficiency than a higher removal rate from a smaller flow. The packed bed filter employs the concept of a "treatment train." The concept of a treatment train of BMPs involves a series of unit operations designed to remove the largest amount of contaminants from runoff, typically greater than the pollutant removal achievable through individual unit operations. The packed bed filter system is a new technology and a transfer of technology from wastewater treatment systems to storm water management systems. As an experimental practice for storm water treatment, many elements need to be monitored for their relation to long-term effectiveness: hydraulic residence time bed media plant materials for the packed beds depth travel length velocity liners Use of Alum for Treatment of Storm Water Runoff One technology showing promise is the use of alum to treat storm water runoff. Two lakes in Orlando, Lakes Dot and Lucerne, and one in suburban Winter Park, Lake Osceola, are having their storm water inputs from large urbanized drainage basins pre-treated with alum. The alum treatment concept was initially tested on Lake Ella in Tallahassee. Alum treatment of storm water runoff was selected after an analysis of the pollution abatement alternatives. Conventional storm water management techniques such as retention, detention, or exfiltration were deemed not feasible due to space limitations, or because of the poor infiltration capacities of watershed soils. The alum is injected and mixes with the storm water in the storm sewer lines. Floe accumulation begins 68 ------- immediately and the floe settles on the lake bottom. Alum injection is wastewater treatment technology being adapted to storm water quality control. There is still some question whether it can be considered a retrofit technology, but its use as a pollution abatement alternative involves many of the hallmarks of a retrofit situation: infeasibility of conventional storm water management techniques such as retention/detention infeasibility of using exfiltration systems due to limitations of available space and poor infiltration capacities of watershed soils Another Case Study in Florida Lake Tackson Regional Storm Water Management System Rapidly urbanizing areas in the Megginnis Arm watershed were causing water quality degradation in Lake Jackson in Leon County near Tallahassee. A regional storm water detention system was designed and constructed through a cooperative effort of the Florida Department of Environmental Regulation, the Northwest Florida Water Management District, and with funding from EPA's Clean Lakes Program and the State of Florida. The facility consists of a wet detention pond with a heavy sediment basin at the inflow, a sand filter system designed to filter particular pollutants from storm water, and a three-cell constructed wetland designed to remove dissolved pollutants such as nutrients. Construction of the system was completed in 1983 at a cost $2,664,389. Maintenance operations, which consist of sediment and clay removal from the top of the filter fabric do not exceed $30,000 per year. Effectiveness of the Lake Tackson facility Florida State University researchers conducted a long-term storm water sampling program of the facility and its individual components. Overall, the facility has performed up to design specifications within the constraints of space and the technical level of the equipment used. However, the increasing urbanization of the watershed has resulted in larger volumes of storm water draining into the facility, well beyond its design capacity. To overcome these deficiencies, the facility was enlarged to provide longer detention of more storm water, allowing the facility to 69 ------- detain larger storms and limiting the discharge of untreated storm water into Lake Jackson. Lessons learned from Lake Jackson experience Some of the lessons learned in the construction of the Lake Jackson regional storm water management system include the following design considerations: storage volume and the amount of water bypassing the system are critical design elements; the system should be designed based on maximum anticipated buildout in the watershed ' ;-. -1- 'p'*1 ''-.'" *-. '-^jh''<^%! *», :' adequate funding must be provided to operate and maintain the system wetlands systems require some maintenance such as dredging to remove accumulated sediments and organic matter; they will not work indefinitely without maintenance For more information: For more information about the City of Orlando's program, call the Storm Water Utility Bureau at (407) 246-2370. 70 ------- County of Fairfax, Virginia Regulatory Context Fairfax County, Virginia is subject to the following Federal and State legislation and programs: Amendments to the 1987 Clean Water Act requiring NPDES permits for storm water discharges Virginia storm water management regulations (at local option) Erosion and Sediment Control Law Chesapeake Bay Preservation Act Section 404 of the Clean Water Act (wetlands protection) Water quality requirements under the Reauthorization of the Clean Water Act pending Congressional consideration in 1994 The County may also be subject to some requirements related to recent coastal zone legislation to which Virginia as a coastal state would be subject. States must develop a coastal nonpoint source pollution control program as a requirement of the Coastal Zone Act Reauthorization Amendments of 1990 (CZARA). The State programs must be approved by EPA and NOAA by 1995. Background25 Fairfax County has been involved in storm water control for more than 30 years. During the 1950s and 1960s, the emphasis was on storm water conveyance and channelization, which included delineation of flood plains and implementation of flood control projects. Beginning in 1972, on-site storm water detention was required for all new development. In the 1980s, water quality BMPs were required for new development in the southern areas of the County draining to the Occoquan reservoir, the major source of drinking water for Fairfax County. In addition to the Master Drainage Plans which were prepared for all watersheds in "County of Fairfax, Virginia. Draft. National Pollutant Discharge Elimination System. Municipal Storm Water Discharge Permit Application, Part 2. November 1992. 71 ------- the County during the 1970s, a supplemental Regional Storm Water Management Plan was prepared in 1988. This plan provides for regional storm water control ponds to control both quantity and quality. Wherever opportunities exist, the County intends to expand the implementation of regional storm water management ponds from the current pilot project involving seven watersheds. Implementation of the planned storm water control facilities over the past 20 years has resulted in expenditures of approximately $60 million, financed primarily through storm bonds. There are presently over 1,500 storm water management facilities located in the County. In addition, there are 30 major lakes and over 100 smaller lakes and ponds which function as BMPs and provide water quality benefits in Fairfax County. In 1989, the Fairfax County Board of Supervisors adopted the "Regional Storm Water Management Plan." The adoption of this plan marked a shift in philosophy on implementing storm water management from reliance on on-site controls to what are viewed as more effective regional controls. Current Activities The Fairfax County Department of Public Works is currently in the process of obtaining various permits or implementing programs designed to provide water quality improvements. These activities include: obtaining an NPDES permit from the Virginia Department of Environmental Quality; part 2 of the application has been submitted and the County is awaiting approval from the State implementing on-site best management practice (BMP) requirements for new developments in Chesapeake Bay Preservation Areas to protect water quality implementing a regional storm water management program to provide water quality improvements for both existing and new development, and to protect downstream wetlands and habitat implementation of stream channel erosion protection projects adopted a Water Supply Protection Overlay District requiring BMPs in the watershed of the County's water supply reservoir re-zoned much of the Occoquan watershed [water supply reservoir] to Residential/Conservation District (R-C) with 5 acre minimum lots adoption of an Environmental Quality Corridor Policy to protect land 72 ------- and surface water resources Ongoing Activities As part of the County program to comply with NPDES requirements, there is a 5- year monitoring program of selected storm water outfalls. The outfalls were selected based on different land uses and, based on the final monitoring results, typical pollutant loadings for each land use will be extrapolated. There are approximately 44 regional storm water management facilities in the Difficult Run watershed alone. The County currently spends approximately $1 to $2 million per year on capital construction for storm water control facilities. However, prior to the recent downturn in the economy, typical drainage facility expenditures totalled $2 million to $4 million per year. Due to current economic conditions, the Fiscal Year 1994 appropriation has been reduced to $341,000. To pay for these costs out of declining general fund revenues is becoming difficult for the County and this has led to discussion about establishing a storm water utility as a dedicated source of funding for storm water management and control. A storm water utility feasibility study is currently in progress. Role of the Chesapeake Bay Preservation Act In Virginia, the Chesapeake Bay Preservation Act (CBPA) is a significant storm water management program through its BMP requirements and use of buffers such as the environmentally sensitive Resource Protection Areas (RPA). The regulatory requirements of this program need to be considered by developers and local governments such as Fairfax County, in addition to other storm water management regulations. Proposed Management Program The County's proposed management program consists of the following elements: continuation of ongoing requirements and programs such as implementation of the Chesapeake Bay ordinance which requires structural BMPs on all new development implementation of suitable water quality control facilities providing inspection and maintenance of storm water management facilities 73 ------- increased public awareness of the importance of clean storm water The County recognizes that the proposed management program will require additional County funds and is currently evaluating the feasibility of establishing a storm water utility to provide a dedicated funding source for storm water management. The County will look for opportunities to retrofit storm water devices and to implement additional regional ponds in all the County's watersheds in existing developed areas that are now without water quality controls. The County's Comprehensive Land Use Plan also encourages the retrofitting of existing storm water management ponds to become more effective BMPs. Regional Storm Water Management Plan In 1989, the County Board of Supervisors adopted a "Regional Storm Water Management Plan" which proposed 134 regional ponds in the most rapidly developing watersheds in the County. The adoption of this plan marked a shift in Fairfax County's approach to implementing storm water management from onsite controls to regional controls. This shift was based on the belief that regional controls are more effective. Concerning the retrofit of existing facilities, proposed development plans are reviewed by the Department of Public Works for opportunities to implement regional storm water management to supplement the pilot Regional Storm Water Management Plan for developing watersheds. In addition, the feasibility of retrofitting existing or porposed flood management projects to include water quality is evaluated. Non-structural BMPs: Environmental Quality Corridors Environmental Quality Corridors (EQCs) are the primary non-structural best management practice used by the County to protect water resources. Although the core of the EQC system will be the County's stream valleys, lands may be included within the EQC system if they achieve any of the following: habitat quality corridor-like quality aesthetic quality pollution reduction capability The stream valley component of the EQC system includes the following: 100-year flood plains and flood plain soils soils with development constraints adjacent to wetlands, streams, and steep slopes 74 ------- additional areas where above-described buffers are insufficient to protect water resources Current Funding/Future Funding of Water Quality Programs26 There are ongoing County water quality programs which are supported out of the General Fund. These programs are: monitoring programs emergency response public awareness public facilities maintenance The County's NPDES permit application clearly states the necessity of developing new funding sources for implementation of capital improvement projects for water quality. The following point illustrates the tenuousness of funding water quality improvement projects out of general or bond funds: The currently approved bond referendum funds have almost been expended, and the latest storm bond referendum was defeated by voters in 1990. Neither the general or storm bond funds can be relied upon to provide stable funding for future storm water quality capital improvement needs. Yet the County estimates that $11.79 million per year will be required to implement regional storm water management over the next decade, and to provide for maintenance of these facilities. County staff are determining the feasibility of establishing a storm water utility to provide long term capital as well as maintenance funds for the County's storm water control facilities. In the interim, two methods to fund capital construction of water quality control improvements are being pursued. These are: use of storm drainage pro rata share program funds; and proffer agreements with developers. Both of these sources are relatively insignificant at the present time, due to the downturn in economic activity. For more information... For more information about Fairfax County's program, call the Storm Water Management Branch at (703) 324-5800. 26 ibid. 75 ------- Cities of Eugene and Portland, Oregon City of Eugene Background The City of Eugene developed its Comprehensive Storm Water Management Plan (CSWMP) in response to Clean Water Act regulations requiring medium-size cities and counties to improve and manage the quality of their storm water. The plan is a model of a rational and comprehensive approach to dealing with the problem of runoff from urbanized areas. From its beginning as a conventional program emphasizing flood control and rapid conveyance of storm water runoff off-site, the City has developed a plan which does not merely conform with, but exceeds, the evolving Federal mandates for water quality management. The principal motivation for initiating development of the Comprehensive Storm Water Management Plan in 1991 was the imminent promulgation of a Federal mandate (NPDES) requiring jurisdictions of medium size (between 100,000 and 250,000 population), to reduce discharges of pollutants to receiving waters from storm water runoff. The Comprehensive Storm Water Management Plan The City's storm water management program goes further than meeting Federal and state water quality requirements. It has taken the problem of meeting its legal requirements and turned it into an opportunity to offer a broad-based solution through a multiple objective approach to protecting, enhancing and restoring the City's water quality. The multiple objective approach of the Eugene plan includes storm water management. Wetlands adjacent to Amazon Creek and other drainage channels are considered to be hydrologically connected to the City's storm water conveyance system. The plan recognizes the central role that wetlands play in storm water management. According to the plan, the five-year start-up phase of the storm water management program includes major program activities such as planning and administration, capital projects (including retrofitting), operations and maintenance, enforcement and inspections, and public communications and outreach. The City has already developed a storm water utility and user fee structure. The City, however, did not have the necessary organizational structure and programmatic resources in place to address the many issues involved in managing 76 ------- storm water quality. It determined that the proper way to address the whole range of storm water issues was within a coordinated, comprehensive framework. Among the factors which influenced its decision to develop a comprehensive strategy were the following: commitments already made to implement the recently approved West Eugene Wetlands Plan (see below), as well as how the new mandates could be incorporated into this Plan a new proposed plan, the Natural Resources Functional Plan, aimed at protecting the city's riparian and waterways corridors; this plan calls for the City's urban runoff management plan to address the relationship between riparian habitat, water quality and flood conveyance implementation of other goals and policies contained in the city's general land use plan The CSWMP encourages this multiple objectives approach to storm water management, including flood control, water quality treatment, and natural resources protection. In addition, it strengthens the existing ordinances and implementation activities already in place. Relation of the Wetlands Plan to Storm Water Plan Amazon Creek is the central drainage feature of Eugene. The channelization of Amazon Creek (completed in 1959) significantly altered the hydrologic and hydraulic conditions of the area. Although flood control benefitted the community and allowed agriculture, commercial, and residential development to spread westward in the city, it also had the unfortunate effect of hydrologically isolating surrounding wetlands. This isolation and the subsequent draining of wetlands resulted in environmental degradation. Consequently, wetland restoration is a high priority for the City of Eugene. It proposes to begin this process through a demonstration project called the Lower Amazon Creek Restoration Project which aims to restore the hydrologic interchange with surrounding wetlands/and restore fish and wildlife-habitat; and other associated water resource values. This will be accomplished through the removal of levees, in whole or in part: through modifying culverts; and through breaching levees at selected locations. In addition to restoration of historic wetlands, the city is developing a program to use constructed wetlands for storm water quality treatment. The City is interested in using these constructed wetlands to control (pre-treat) pollutants in urban runoff 77 ------- which enters a natural wetland system in West Eugene. This idea grew out of the preparation and planning to develop the West Eugene Wetlands Plan (WEWP), with the goal being the preservation of the natural system through the pre-treatment of runoff from areas of the City. Without such treatment, the degradation of the remaining existing natural wetlands would be a virtual certainty. Storm water management is seen as critical to the success of the WEWP, and to the survival of the wetlands themselves. The use of constructed wetlands as a treatment process for urban runoff is emerging as an alternative to conventional processes. Some of the advantages to using constructed wetlands to temporarily store or treat storm water include: water quality improvement flood, erosion and storm damage reduction replenishing surface and ground water supply provision of fish and wildlife habitat aesthetic or amenity benefit27 Regulatory Issues There are numerous Federal laws and regulations, executive orders, as well as comparable state and local regulations and ordinances which regulate activity in wetlands or potential wetland areas. Current Federal policy forbids the use or modification of natural wetlands to treat storm water. Nevertheless, the following points should be borne in mind: wetlands are functionally part of many municipal separate storm sewers wetlands in urban areas may be dependent on storm water for their very existence Therefore, the strict application of regulations which forbid the degradation of wetlands can have unintended consequences in watershed and wetland planning. The City of Eugene experience suggests that flexibility should be allowed when determining the level of appropriate protection for wetlands and that this can be accomplished through a planning process which involves the local community as well as Federal and state agencies which regulate these resources. "City of Eugene, OR. Conceptual Engineering Design for Water Quality Workshop. Final Report. Department of Public Works, City of Eugene, OR, undated. 78 ------- Eugene's Existing Storm Water Program The City's current storm water system has historically been focused on providing flood control services. With its emphasis on storm water conveyance and flood control, the existing program was in conflict with Federal mandates for water quality management. Since the natural water quality treatment systems, such as riparian areas, waterway corridors and wetlands have been extensively replaced with conventional, structural conveyance facilities, ways need to be found to not only stem the removal of natural systems, but seek opportunities to preserve them. The CSWMP recognizes this goal and integrates it into the plan. The City is faced with significant and complex issues as it seeks to transform its existing storm water management program to meet the challenge of complying with Federal mandates and heightened citizens' expectations. The framework of the CSWMP will allow it to do this within a comprehensive planning context. The City already has a dedicated revenue source to fund general and storm sewer capital projects, the storm water utility user fee. It is the major revenue source for the existing program, and is expected to be the principal revenue source for the new, expanded program. The City has reviewed and analyzed current policy in light of evolving Federal water quality mandates, and has refined its policy to include the following: that all users of the storm water system contribute to the financing of the program that property owners be encouraged to incorporate practices beyond the minimum required through the use of financial incentives such as fee reductions, etc. Retrofitting and Eugene's Storm Water Management Plan Eugene's CSWMP contains a specific capital facilities best management practice (BMP) for retrofitting existing facilities, where feasible and appropriate, to achieve water quality goals. These retrofits may include the installation of in-line sediment 'traps, detention/infiltration facilities, wetlands or riparian (re)vegtation, or simply the modification of flood control facilities (i.e., storm drain inlets, retention basins, of drainage channels) to function as water quality facilities. Additionally, the capital facility BMP directly addresses the NPDES requirement that the City assess the existing drainage and flood control facilities in order to determine if retrofitting them would improve water quality. 79 ------- The capital facilities program includes retrofitting as one of the major activities scheduled during the five-year start-up phase of the City's comprehensive storm water management program, with retrofit implementation commencing around 1996. The activities conducted as part of the retrofitting component of the Plan, include: preparing a master list of existing facilities with relevant retrofit considerations for each type conducting an inventory of existing flood control facilities that will provide information necessary to determine whether retrofits of these facilities are feasible or not reviewing inventory results to select sites and facilities where retrofits would be most appropriate developing a preliminary plan for retrofitting, with a schedule and estimated costs developing funding plans for retrofits Eugene's Public Outreach Effort An important feature in the evolution of the City's program are the numerous methods for disseminating information about the development of the storm water management program. These methods range from neighborhood newspapers such as the Eugene Storm Water Connections, with general information about the City's storm water management program, to more targeted information sheets, brochures, and stickers, to community workshops to introduce citizens to storm water pollution issues. 80 ------- Important Elements in Eugene's Program The importance of the West Eugene wetlands to the overall stormwater management plan. the integration of natural resource elements into the overall stormwater management framework and looking at the watershed and how it functions as an integrated unit . The significance of the multiple objective planning approach and why it could be a model. opportunity to address urban runoff issues from a comprehensive perspective, including wildlife habitat, recreation, resource conservation education, etc. The high level and quality of citizen involvement and how this reduces conflict. widespread citizen involvement with two-way communication and feedback mechanisms facilitates consensus decision-making 81 ------- For more Information... For more information about the City of Eugene's storm water program, contact the Storm Water Program Coordinator at (503) 683-6839. 82 ------- City of Portland Introduction The City of Portland, Oregon, has developed innovative and comprehensive urban runoff control strategies to meet the water quality requirements of Federal and state legislation. Its program encompasses a wide range of activities for controlling both point and nonpoint source pollution. The range of activities alone - from transportation improvements to improved pesticides management - serves to illustrate the diffuse nature of nonpoint source pollution. Portland's storm water management program has been designed to be a constantly evolving program which implements the management practices that succeed, modifies or eliminates those that do not, and seeks to develop the most efficient and productive practices throughout the program's life. Based on a. balanced economic and environmental approach, its goal is to develop and implement the most successful municipal storm water permit program in the Pacific Northwest. Storm Water Permit Program (NPDES) Activities The City of Portland, whose total population is roughly 450,000, has been classified as a medium-size municipality for the purposes of the NPDES storm water permitting program because less than 250,000 people are served by its municipal separate storm sewer system. A significant portion of the city is served by combined storm and ' sanitary sewers, which are subject to other Clean Water Act regulations. Under Oregon state-wide land use planning law, each city must define an urban growth boundary (UGB) within which urban development is confined. Once approved, they have the force of law. Within Portland's urban growth boundary, six other agencies operate "municipal-like" separate storm water conveyance systems. Together with the City, the six have become co-applicants for the Portland NPDhb storm water permit application. The co-applicants include Multnomah County, Multnomah Drainage District #1, Peninsula Drainage Districts #1 and #2, the Port of Portland, and the Oregon Department of Transportation. Although the permit has not yet been issued, the seven co-applicants are currently conducting a number of programs and practices that directly or indirectly improve the quality of storm water. While the NPDES permit application is a joint effort of all the co-applicants, each co-applicant has responsibility for implementation of their individual storm water management plan. Significantly, from an institutional point of view, the City's NPDES program implementation schedule has been developed to coincide with the majority of the co- 83 ------- applicants' fiscal year budget schedules. The goal of this action is ease of implementation, but it also represents a concrete and very sensible method for facilitating institutional cooperation. NPDES Program Implementation Strategy Portland's NPDES program strategy is to build on a foundation of existing urban runoff control practices. The City developed.existing management program (EMP) fact sheets corresponding to each regulatory requirement. Portland's proposed NPDES management program emphasizes and builds upon existing storm water controls and management practices. The program intends to limit the introduction of new practices as much as possible, but where appropriate it will phase in new practices during the life of the permit. However, BMPs were developed to meet NPDES requirements not covered by existing programs. The co-applicants have grouped .BMPs into implementation categories: public education and involvement operations and maintenance procedures industrial and commercial controls illicit discharge controls new development standards structural controls planning/system preservation and development Nonpoint Source Program Activities - Some Examples 1. Used Oil Recycling Program The City has a comprehensive solid waste and recycling program, which includes used oil curbside pickup that properly recycles used oil. Although many jurisdictions maintain used oil recycling programs, few offer pickup of used motor oil as in Portland. (The City also provides yard debris, cardboard, paper, newspaper, and metals residential curbside pickup.) 2. "Skinny Streets" Program The City Office of Transportation has implemented new design standards for certain street categories in an attempt to reduce environmental impacts, such as minimizing the impervious area of new streets and preserving existing vegetation. 84 ------- 3. Snow and Ice Control Sand and gravel materials are used at varying levels and picked up as soon as possible after a storm has passed, which may take a few days or several weeks. By comparison, many jurisdictions remove these materials only after the winter has passed, if they collect them at all. 4. Pesticide/Herbicide Application All applicators participate in an Integrated Pest Management (IPM) training program. In addition, the City Planning Bureau has landscape requirements which reduce the need for pesticides, herbicides, and fertilizer through the use of native plantings. They are also developing an environmental seed mix. Approach to Institutional Issues The process by which the Portland NPDES permit co-applicants put together their storm water permit application reveals some of the institutional issues which impact upon the ability of a jurisdiction to carry out effective storm water management. The seven jurisdictions have different institutional motivations and agendas and degrees of political accountability and these factors affect how they approach and deal with the problem of urban runoff management and control. For example, the Oregon Department of Transportation (ODOT), one of the seven co- applicants in the permit process, has as its mission the building of roads, not managing storm water. Nevertheless, the ODOT maintains hundreds of miles of storm sewer pipes that collect and transport storm water surface runoff, in addition to open ditches and dry wells. It also has responsibility for 14 major storm sewer outfalls in Portland. The ODOT, however, is not subject to the same direct political pressures to pursue its storm water management goals as, for instance, the City of Portland. The same holds for the special drainage districts, the Port of Portland and other co-applicants. This presents the potential for different outcomes. Such a divergence of institutional interests and objectives could potentially limit the effectiveness of the storm water management program. However, the Portland experience illustrates how potentially problematic institutional issues can be dealt with early in the program planning process and the result is likely to be a more effective urban runoff control program. In the process of developing the storm water management plan, the City's consultants worked with all the co- applicants to define and clarify issues related to their proposed BMPs. As part of this process they considered: 85 ------- the department or division within the agency which would be aftected by or involved with the implementation of the BMP; the agency's existing conditions related to the BMP, and the tasks necessary to implement it; the degree to which the implementation of the BMP is likely to affect existing staff and/or resources The fact that the process used in Portland considers these sometimes subtle but important institutional concerns increases the probability of a successful outcome. It also points up the importance of "issue scoping" and framework development to ensure program effectiveness. Program Funding The City finances its storm water management activities through the levy of a drainage fee which is based on the amount of runoff allowed to flow into the storm sewer system. In 1992, the City initiated a storm water drainage discount program. Discounts in the drainage fee are given to propoerty owners who limit the quantity of storm water discharged from their property. The discount may be as high as one hundred percent. Discounts for water quality are not cuurently included in this program, but the City code permits the imposition of such a fee and discount program in the future. The existing discount program is directed at sites with on-site disposal systems. 86 ------- BMP Selection and Screening Factors used in Portland's Planning Process Life Cycle Costs - The approximate cost of initial implementation and future operation. Regulatory Requirements - Does it meet existing and anticipated Federal, state and local regulations? 4 , Pollutants - Does it offer reasonable control of the targeted pollutants? Implementability - Is it likely to be accepted and funded by the various public agencies, city departments, and the general public? Reliability - Does the BMP function predictably and is it effective over time? Environmental Impact - Consider the environmental impacts and benefits of the BMP. Equitability - How are the costs and benefits of the BMP distributed? 87 ------- Portland's proposed NPDES stormwater management plan is innovative and has the following components: It emphasizes non-structural source controls including education and maintenance programs. It builds upon existing programs such as curbside recycling, household hazardous waste collection, etc. If encourages regional efforts and programs. It emphasizes cooperation among its NPDES co-applicants to improve water quality. It phases in management plans to allow for budgetary and resource constraints. Portland's NPDES program highlights 88 ------- Portland's Compliance Strategies Consider urban runoff issues as permanent issues which require a long-term planning approach. Share information and ideas and look for opportunities to cooperate on projects, or share costs with other jurisdictions, etc. Work closely with regulatory personnel throughout permit period to discern their objectives, priorities and intentions. Be creative and proactive in complying with permit and regulatory requirements. For more information... For more information about Portland's urban runoff management program, please call the Bureau of Environmental Services at (503) 823-7236. 89 ------- Glossary Best Management Practice (BMP): A practice or combination of practices that are determined to be the most effective and practical (including technological, economic, and institutional considerations) means of controlling point and nonpoint pollutant levels compatible with environmental quality goals. Constructed urban runoff wetlands: Those wetlands that are intentionally created on sites that are not wetlands for the primary purpose of wastewater or urban runoff treatment and are managed as such. Constructed wetlands are normally considered as part of the urban runoff collection and treatment system. Drainage Basin: A geographic and hydrologic sub-unit of a watershed. End of Pipe Control: Water quality control technologies suited for the control of existing urban storm water at the point of storm sewer discharge to a stream. Due to typical space constraints, these technologies are usually designed to provide water quality control rather than quantity control. First Flush: The delivery of a disproportionately large load of pollutants during the early part of storms due to rapid runoff of accumulated pollutants. The first flush of runoff has been defined several ways (e.g., one-half inch per impervious acre). Impervious cover cap: A mechanism which establishes a Maximum Sustainable Removal Rate for storm water control measures at 90%. The City of Austin, Texas has incorporated this concept into its Land Development Code. It is designed to avoid over-reliance on storm water control measures and recognizes their inherent limitations and risk of failure due to lack of maintenance. Impervious surface: A hard surface area that either prevents or retards the entry of water into the soil mantle as under natural conditions prior to development and/or a hard surface area that causes water to run off the surface in greater quantities or at an increased rate of flow from the flow present under natural conditions prior to development. Common impervious surfaces include walkways, driveways, parking lots, concrete or asphalt paving, etc. 90 ------- Municipal separate storm sewer systems: Any conveyance or system of conveyances * ^teJ^^vemment entity, is used for collecting .or conveymg storm water, and is not part of a publicly-owned treatment works (POTW). NPDES: National Pollutant Discharge Elimination System, created by Section 402 of the Clean Water Act. Post-development peak runoff: Maximum instantaneous rate of flow during a storm, after development is complete. ofan oTder urban runoff management structure, or a combinauon of mrprovement and new construction. Ultra-urban: Non-conventional BMPs that are particularly suited for use in highly urbanized areas; based on sand filter technology Urban runoff: That portion of precipitation that does not naturally percolate into the ground or evaporate, but flows via overland flow. Watershed- A drainage area or basin in which all land and water areas drain or flow toward a central collector such as a stream, river, or lake at a lower elevation. The land area that drains into a receiving waterbody. 91 ------- Bibliography Anacostia Watershed Restoration Committee, The State of the Anacostia - 1989 Status Report. Metropolitan Washington Council of Governments, 1989. City of Alexandria, VA. AWandria Supplement to the Northern Virginia BMP Handbook. Prepared by the Department of Transportation and Environmental Services. Adopted February, 1992. City of Austin, TX. "The First Flush of Runoff and Its Effects on Control Structure Design." Environmental Resource Management Division, June 1990. Citv of Austin, TX. "Storm Water Pollutant Loading Characteristics for Various Land Uses in the Austin Area." Environmental Resource Management Division, March 1990. City of Austin, TX. "Removal Efficiencies of Storm Water Control Structures. Final Report." Environmental Resource Management Division, May 1990. City of Eugene, OR. Conceptual Engineering Design for Water Quality Workshop. Final Report. (Undated) Dav Garv E, and C. Scott Crafton, Site and Community Design Guidelines for Storm Water Management. Virginia Polytechnic Institute and State University, Blacksburg, VA, 1978. - ' Bell, Warren, "A Catalog of Storm Water Quality Best Management Practices for Ultra-Urban Watersheds." Presented at the National Conference on Urban Runott Management in Chicago, IL on April 2,1993. Buzzards Bay Project, "Bay Watch" (Newsletter), Spring/Summer 1993 Volume 7(5). Dyer, Riddle, Mills & Precourt, Preliminary Engineering Report: Packed Bed Filter. Prepared for the City of Orlando, FL. April 1991. County of Fairfax, VA. Draft. National Pollutant Discharge Elimination System. Municipal Storm Water Discharge Permit Application. Part 2. November 1992. County of Fairfax, VA. Policy Plan: THP Countvwidp Policy Element of thq Comprehensive Plan for Fairfax Countyr Virginia. 1990 Edition. Adopted by the Board of Supervisors, August 6,1990. Finnemore, EJ. and W.G. Lynard, "Management and control technology for urban 92 ------- 3rm water pollution," in WaterPollntion Control FederationJournal. Volume 5*7), Iyl982. egulation, Tallahassee, FL ower Colorado River Authority, T PR A 1 xfce Travis Nonpoint Source Pollution f.mrnl Ordinar - Tarhni<-al Manual January 1991. ^' Mew York: 1989) G 1992 watorsh,.d Restorer, Source Book. Metropolitan Washington ' Governments, Department of tomronmental Programs, Washington, DC As.es.ment nf TTrim NOAA/USEPA rnagta] Nonpoint pmintinn Control Pro^m: Program Development Gul^nce. National Oceanic and Atmospheric Administration/ U.S. p . Environmental Protection Agency, January 1993. Novotny, Vladimir, and Gordon Chesters, H.nrtbnn otny, Vlamr, an oron , . Management. (New York: Van Nostrand Remhold Company, 1981) Parrish John H and Stephen Stecher, "Nonpoint Source Pollution Control in the City of Austin "City of Austin, TX, Environmental and Conservation Serves Department, March 1991. Council of Governments, 1992. Schueler, Thomas R., "Hydrocarbon Hotspots in . Controlled?" in Watershed Pro^rtinn Techniques. Volume 1(1), February 93 ------- Document No. , 1990. Vannouth (MAX Town o, "Effects of^ute 69J Drainage Irnproven^ents on Water Quality in Bass River," November 11, 1992. 94 ------- |