SPECIAL PANEL
ON COMBINED SEWER OVERFLOWS
AND STORM WATER MANAGEMENT
IN THE DISTRICT OF COLUMBIA
September 1998
US. EPA Headquarters Library
10nno Mai/code 3201
\A/ PTnsylvania Avenue NW
Washmgton DC 20460
Recommendations
Actions the District of Columbia should take immediately
Implementation of a watershed approach and cooperation with Maryland
Federal agency responsibilities
Public information and participation actions
Improved assessment and monitoring programs
Pollution prevention, including a "war on trash**
Financing wet weather pollution prevention and control
Chesapeake Bay Program
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PANEL MEMBER AGENCIES Washi"Qton
on
Anacostia Watershed Citizens' Advisory Committee
Anacostia Watershed Society
Audubon Naturalist Society
Center for Watershed Protection
Citizens' Advisory Committee, Chesapeake Bay Program
District of Columbia Department of Health
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SPECIAL PANEL ON CSOs AND STORM WATER MANAGEMENT
IN THE DISTRICT OF COLUMBIA
OUTLINE OF PANEL RECOMMENDATIONS
September 1998
A. STRENGTHEN CURRENT WET WEATHER CONTROLS AND PLANNING IN THE DISTRICT OF
COLUMBIA
A.1. Take near-term actions to optimize control and treatment of D.C. combined sewer overflows
through the use of existing facilities and programs.
Pursue repairs in progress to yield near-term CSO pollution control benefits
- Repair and upgrade swirl concentrator by Fall 1999.
- Rehabilitate Main/O Street and Eastside pump stations.
- Complete repair/replacement of the fabridams in the year 2000.
Complete evaluation of Nine Minimum Control measures by July 1,1999.
Control trash in Anacostia River
- Continue trash removal operations.
- Give priority to evaluation and installation of end-of-pipe solids arid floatables controls.
A.2. Carry out required CSO "long-term control planning" in a way that supports an integrated
D.C. wet weather (CSO and storm sewer) pollution prevention and control program.
Phase 1: Evaluation and planning of CSO options.
- Rain leader disconnection in CSO areas
- Methods for reducing ground water flows in sanitary sewer system
- Street cleaning strategies
- Increased storage of combined sewage in existing facilities
- Improvements in NMCs
Phase 2: Evaluation and study of integrated wet weather source control options within combined
sewer system.
- Storm water 'best management practices' (BMPs) addressing erosion, new construction
controls, illegal discharges and roadway runoff, pollution prevention
- Coordinated street and catch basin cleaning to enhance wet weather pollution prevention
results
- Alternative intake designs
- Sources of hydraulic loading in the O.C. sewer system and opportunities for reducing this
loading
- Use of Federal/other open space for off-line storage
- Detailed long-term CSO control plan
A.3. Strengthen the District's storm water management program, in compliance with Federal
requirements.
* D.C. must complete and submit to EPA its storm water management plan in compliance with
NPDES regulations, and clarify organizational responsibilities for these management functions.
* EPA should issue draft MS4 permit, integrating wet weather requirements and fostering Federal
landowner cooperation, before the end of 1998. Consider D.C. as model for integrating CSO
and storm water planning.
* Ensure coordination/integration with other agencies and similar efforts, especially D.C. WASA's
long-term control plan for CSOs.
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A.4. Strengthen the District's erosion control and storm water regulatory program.
* Strengthen the District's erosion control and storm water management program.
- Strengthen technical criteria and procedure for granting waivers and variances
- Expand Inspection and enforcement
- Consider 'low impact development practices"
* Consider using environmental revenues to support program administration.
B. STRENGTHEN INSTITUTIONAL CAPABILITY TO IMPLEMENT AN INTEGRATED WET
WEATHER POLLUTION PREVENTION AND CONTROL PROGRAM BASED ON A WATERSHED
APPROACH
B.1. Strengthen the Role of the Anacostia Watershed Restoration Committee.
* Enhance oversight and decision-making process.
Strengthen information resource capabilities.
Strengthen public education and outreach role.
B.2. Establish a Rock Creek watershed coordinating committee.
Concentrate on defining issues in the Rock Creek watershed to be addressed by the committee.
Explore funding options.
Assess the need for a formal agreement, similar to the Anacostia Watershed Restoration
Committee.
B.3. Conduct an integrated watershed assessment for the Anacostia River and tributaries.
Initiate an integrated watershed assessment (IWA) to investigate physical, chemical, biological,
and economic factors affecting water quality in the Anacostia River.
Ensure results from the IWA will assist other efforts, such as TMDL development and WASA's
CSO planning effort.
Include full participation of stakeholder agencies and a strong public participation effort.
C. PLACE STRONG EMPHASIS ON FEDERAL AGENCY ACTION BECAUSE WATERSHED
RESTORATION GOALS CANNOT BE MET WITHOUT IT
C.1. Accelerate wet weather pollution prevention and control on Federal lands and at Federal
buildings and associated facilities.
Identify regulatory requirements relating to storm water pollution prevention and control and
evaluate compliance.
Complete storm water management plans; include quality and quantity issues.
Provide input for D.C.'s long term CSO control plan.
implement new storm water management controls.
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C.2. Focus Federal financial support and other assistance on wet weather pollution prevention
and control priorities.
* Examine ongoing programs relevant to wet weather pollution prevention and control within the
watershed.
Identify how ongoing programs can assist in the successful implementation of panel
recommendations.
C.3. Convene a federal work group to facilitate communication and provide leadership.
» Create a Federal Agencies workgroup that represents landholders and other agencies that
provide assistance (e.g., technical, regulatory, financial) within the watersheds. Use work group
to coordinate and support implementation of Federal actions and activities in the watersheds.
Facilitate communication among Federal agencies and between Federal agencies and other
agencies (e.g., county, state, D.C.).
Identify legal requirements for Federal agencies pertaining to wet weather. Consider Federal
and local requirements (e.g., D.C. WASA pretreatment requirements associated with the CSO
Nine Minimum Controls).
Prepare storm water management planning guidance document.
Coordinate an urban storm water technological exposition for the region.
D. EDUCATE AND INVOLVE THE PUBLIC. FOSTER VOLUNTEERISM AND COMMUNITY
INVOLVEMENT.
D.1. Research and create a comprehensive wet weather media advertising campaign.
Conduct public survey to:
- Gain public understanding and perception of wet weather problems
- Gain baseline information on current behavior in addressing wet weather pollution
. - Citizen willingness to adopt new ideas and practices to control wet weather pollution
Coordinate existing public education outreach efforts to ensure they are coordinated and
compatible with survey results.
* Design and implement a tailored media advertising campaign.
D.2. Develop a comprehensive approach to increase and enhance volunteerism.
Identify and catalogue existing volunteer groups and current activities.
identify a dedicated group of people/organizations to promote volunteerism and tailor
educational materials.
* Develop presentations for various audiences on conservation and wet weather pollution
prevention and control.
Develop a central repository of outreach materials.
D.3. Create and implement a student wet weather discovery program.
* Form a partnership among local schools, radio and television stations, universities, and
citizen/environmental organizations.
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Conduct neighborhood surveys to assess wet weather pollution control and prevention
opportunities in teams of students and trained adult volunteers.
Identify range of research topics that could be pursued by students for science fairs or university
research opportunities.
D.4. Evaluate practicality of conducting homeowner water management model programs.
Review existing materials (e.g., studies, surveys, case studies, etc.) for information on effective
homeowner water management activities.
Develop a strategy evaluating these activities to develop model programs.
Use results of model program to perform a wide-reaching education and outreach campaign
targeted towards homeowners.
E. ENHANCE DECISION-MAKING THROUGH BETTER MONITORING, DATA COLLECTION, AND
INFORMATION MANAGEMENT
E.1. Develop a comprehensive integrated watershed information management system.
» Develop a collaborative integrated watershed information management system for the Anacostia
and Rock Creek watersheds.
Long-term vision is to develop a web-based application that can access and integrate
geographically-distributed data through an easy-to-use graphical user interface.
Near-term activities include:
- Identify user needs and functional requirements.
- Evaluate existing information management resources.
- Implement a prototype using readily available information.
- Develop a World Wide Web application that will enable data access, online data querying, and
geographic analyses.
Identify and prioritize data needed to support broadly-based watershed management decision
making and public outreach objectives.
E.2. Effectively manage available land resources to enhance water quality.
Evaluate land use goals of the District's master plan and seek opportunities to use land
resources and land planning approaches to minimize wet weather pollution. Coordinate future
land planning activities among all relevant agencies. Focus special attention on:
- Identifying environmentally sensitive and other undeveloped natural areas for preservation,
protection, recreation
- Identifying opportunities for placing additional, or retrofitting existing, storm water controls in
existing and redevelopment areas
- Developing site standards, including land use controls, for new development
E.3. Develop a coordinated, strategic monitoring plan.
* Develop wet weather measures of progress.
* Conduct a monitoring evaluation of existing monitoring programs and future monitoring needs.
Evaluate potential of implementing a biological monitoring program.
- Expand on prior work to define a watershed-based biological monitoring program to provide
reliable indicators of stream quality and an approach for prioritizing areas for action.
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E.4. Create a watershed SSO inventory for the Anacostia River and Rock Creek watersheds.
Identify, to extent practical, locations of sanitary sewer outfalls to the Anacostia River and Rock
Creek watersheds.
Prepare report on dry and wet weather overflows to the Anacostia.
» After identifying extent of SSOs, initiate a program to eliminate them.
F. PURSUE POLLUTION PREVENTION THROUGH SOURCE CONTROLS AS A KEY PART OF
THE SOLUTION.
F.1. Conduct a war on trash.
District of Columbia
- Identify and prioritize high-volume trash sources
- Use a range of trash controls in high-priority areas
- Foster volunteerism and community-wide initiatives
- Solicit selected businesses to participate, focusing on fast food establishments, convenience
stores and grocery stores
Federal Landowners
- Increase trash cans and recycling bins in high use areas
- Regularly service trash cans and recycling bins to prevent overflows
- Study feasibility of expanding use of recycling bins on federally owned public land
Maryland Prince George's and Montgomery County
- Identify tributaries that contribute high volumes of trash
- Pilot test solutions
- Solicit selected businesses to participate, focusing on fast food establishments, convenience
stores and grocery stores
- Continue to support existing efforts to foster volunteerism and community wide initiatives
F.2. Conduct pollution prevention opportunity assessments within Anacostia watershed
businesses.
Target and prioritize businesses.
Conduct pollution prevention opportunity assessments within targeted businesses with assistance
from the Anacostia River Business Coalition.
Encourage businesses to implement strategies that evolve from the assessment.
F.3. Study origins of and better controls for transportation-related contaminants in storm water
runoff, and improve programs to prevent these contaminants.
Discuss storm water impacts from roads and highways during a future meeting of the
Transportation Planning Board.
Conduct a study to determine nationally occurring activities, beginning with a Transportation
Research Board literature survey.
Utilize research and technology transfer program between DPW and Howard University.
- Fill gaps and expand areas of research
- Focus on toxics and thermal pollution
G. SEEK INNOVATIVE APPROACHES OF FINANCE WET WEATHER ACTIONS.
G.1. Financing wet weather pollution prevention and control in DC.
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A. Strengthen Current Wet Weather Controls and
Planning in the District of Columbia.
Background/Justification
In its 1998 Water Quality Report under section 305(b) of the Clean Water Act, the District of
Columbia reports once again that most of its water bodies are not meeting the Federally-approved
water quality standards. The most seriously degraded water body is the Anacostia River; it is also
an area bordered by park land which has great recreational and fishing potential and whose
restoration would provide both environmental and economic enhancement. Continuous
wastewater discharges in the District of Columbia have been brought under control, but pollution
from combined sewers and separate storm sewers is still uncontrolled or inadequately controlled.
The intermittent storm flows carry massive amounts of sewage, trash, sediment and other
materials through the sewers and into the District's waters.
Combined Sewer Overflow (CSO^ Pollution
The most recent Federal wastewater permit for the Blue Plains Wastewater Treatment Plant and
its system of sewers, pumps and other facilities, requires the District (D.C. Water and Sewer
Authority) to: (a) utilize hs existing facilities in a way that achieves maximum feasible reduction of
overflows (the "nine minimum controls"); and (b) undertake long term planning of the additional
facilities (termed the "LTCP") needed to attain virtually complete control of overflows and meet
water quality standards. USEPA has recently provided Federal grant funds for repair of the major
existing CSO facility, the swirl concentrator installed near Robert F. Kennedy Stadium, and to
support CSO facility planning and associated monitoring.
Earlier CSO facility plans conducted by the city projected that the District would have to pay $1
billion to over $2 billion to control CSOs. Obviously, such costs are daunting and revenues on
that scale would be very difficult for the District to raise. However, wet weather pollution control
planning and techniques have been advancing as cities gain experience. Although costly end-of-
pipe CSO storage and control facilities may be needed, many cities are finding that prevention
programs, such as pollution prevention and storm water retention facilities, often offer a more
cost-effective way to reduce CSO pollution significantly. As storm water-related pollution also
flows into District waters from upstream in Maryland, a prevention strategy needs to consider not
only inflows originating in the District but also flows from the upstream State.
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Separate Storm Sewers
The District is required by the Federal Clean Water Act to have a storm water management
program to prevent pollution of its waters from separate storm sewers. Although the District
began developing its plan to meet Federal regulations several years ago, this plan has never been
completed and submitted to USEPA. This must now be done, as the District is in violation of the
regulatory deadlines, and USEPA must subsequently issue a discharge permit to the District
(termed a municipal separate storm sewer system or "MS4" permit).
Not only will developing a Federally-approvable storm water management program enable the
District to satisfy its legal obligations, the timing is unusually favorable as it facilitates
coordination with the CSO LTCP. Integration of the CSO and MS4 strategies allows the District
to take maximum advantage of its wet weather pollution prevention and control planning,
determine the most intelligent and cost-effective use of prevention programs, prioritize costly
monitoring, target problem areas for attention, and investigate areas where storm water retention
facilities might be feasible and most beneficial.
Storm Water Pollution Prevention
The District has a major wet weather pollution prevention program already in operation the
erosion control and storm water management regulatory programs for new construction (DOH
Environmental Health Administration). This program receives Federal grant support and has
recently been reviewed by EPA during the District's environmental reorganization. Prevention is
almost always the best and least costly way to solve pollution problems. This vital program needs
to be strengthened, and its resources expanded especially for inspection and enforcement.
Expected Benefits:
Only through actions to prevent and control wet weather pollution can the District of Columbia
hope to attain its water quality standards and provide its citizens with the full recreational, fishing,
aquatic life protection and area beautification benefits envisioned by these standards. If the
District implements these recommendations swiftly, and receives cooperation from its upstream
neighbors to reduce pollution, trash and excess storm water flow into the District, the residents
and visitors to the District of Columbia should observe noticeable improvement in the Anacostia
River and, to a lesser extent, Rock Creek and other District waters, within five years.
Related Actions:
The importance of dealing with wet weather pollution coming from Maryland has been noted;
thus, success in implementing Recommendation B is important. Also, given the dominant Federal
presence in many sections of the District and in the Anacostia and Rock Creek watersheds, .
implementing Recommendation C is essential.
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A.1 Take near-term actions to optimize control and treatment of D.C.
combined sewer overflows through the use of existing facilities and
programs.
To Whom Recommendation is Addressed:
D.C. Water and Sewer Authority
D.C. Department of Health, Environmental Health Administration
U.S. Environmental Protection Agency
D.C. Department of Public Works
U.S. Army Corps of Engineers
Montgomery and Prince George's Counties
State of Maryland
Geographic Focus: All of the District's CSO sewersheds and receiving waters (priority to the
Anacostia River and Rock Creek); Anacostia River basin'for end-of-pipe solids and floatables
controls.
Recommendation Summary: (1) The D.C. Water and Sewer Authority should expedite repair
of existing CSO control facilities. (2) Implementation of the "nine minimum CSO controls"
(NMC) required by the current USEPA discharge permit needs to be strengthened to ensure
optimum performance is being attained. (3) In addition to carrying out the current trash removal
operations in the Anacostia River, D.C. WASA should give priority to evaluation and installation
of end-of-pipe solids and floatables controls (e.g. trash traps). (4) A simple method needs to be
developed and implemented for measuring the performance of these activities on CSO volume and
pollutant loadings, including reductions in solids and floatables.
Recommendation Strategy:
(1) Repairs in progress to yield near-term CSO pollution control benefits
(a) Complete repairs and upgrading by Fall 1999 of the D.C. Swirl Concentrator as this
facility treats the largest volume of D.C. combined sewer overflows (discharging to the
Anacostia River at Robert F. Kennedy Stadium). Test chemical addition to improve
removal efficiency of the facility. D.C. WASA has received Federal grant funds for this
project, and should continue to take advantage of technical advice from USEPA's Wet
Weather Research Program to optimize performance using innovative approaches to this
technology. A performance evaluation should be conducted after improvements are
completed, with the protocol for this evaluation designed in cooperation with D.C. EHA
and USEPA. (The evaluation report will also contribute to overall technical knowledge in
CSO control.)
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(b) Rehabilitate the Main/O Street and Eastside pump stations on the following schedule:
complete design by 1/2001; start construction by 3/2002 and have new pumps in
operation in 2004.
(c) Complete repair/replacement of the fabridams in the year 2000. After repair, WASA's
operational plan and budget should provide for adequate maintenance.
(2) In addition to the repairs above, complete evaluation of NMC measures by 7/1/99 to optimize
performance of existing facilities (as part of Phase 1, LCTP, ref. Recommendation A.2).
The nine minimum controls:
1. Proper operation and maintenance of the combined sewer system
2. Maximum use of the collection system for storage
3. Review and modification of pretreatment requirements
4. Maximization of flow to the publicly owned treatment works (POTW) for treatment
5. Prohibition of CSOs during dry weather
6. Control of solid and floatable materials in CSOs
7. Pollution prevention
8. Public notification of CSO occurrences and impacts
9. Monitoring of CSO impacts and the effectiveness of CSO controls
(3) (a) Continue trash removal operations in the Anacostia River, coordinated with activities
of the U.S. Army Corps of Engineers to maintain navigation in the main channel.
(b) D.C. WAS A should give priority to evaluation and installation of end-of-pipe solids
and floatables controls. This effort could be supplemented by trash removal activities in
Montgomery and Prince George's Counties and by application of similar technologies on
storm sewers, where appropriate. Evaluate immediate installation of trash traps/netting
. for both CSO and selected storm sewer outfalls in the Anacostia River Basin, with Prince
George's County. Input as to the most appropriate areas and measures for installing
facilities should be sought from local environmental/ boating groups. This activity should
be coordinated with implementation of Recommendation F. 1, War on Trash. The
evaluation should be completed by July 1999 and installation, where applicable, should be
complete in the year 2000.
D.C. WASA is the principal implementing authority for this recommendation.
USEPA will have a major impact on D.C. WASA's implementation of the recommendation. The
requirements to implement the NMC are contained in the NPDES permit for the D.C. water
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pollution control system, issued by USEPA, and USEPA has also provided Federal funds to aid
repair of the D.C. swirl concentrator and a $7+ million planning grant, including support for
evaluation of the effectiveness of the NMC.
The D.C. Environmental Health Administration is responsible for identifying monitoring and other
actions which dischargers need to take to meet the requirements of the D.C. Water Pollution
Control Act, and is responsible for establishing priorities to guide funding of projects in the
District of Columbia under the annual Federal construction grants allocations.
Many of the actions required for wet weather pollution prevention under the NMC, such as street
cleaning and sanitation, are carried out by D.C. agencies such as the Department of Public Works.
Although this recommendation is directed to D.C.'s CSOs, cooperation with Maryland's
Department of the Environment and with Montgomery and Prince George's Counties is essential
to cany out coordinated up and downstream actions to restore the Anacostia River and protect
Rock Creek and other District waters.
Timeframe/Schedule:
Individual action schedules are noted. Note: Target dates have been developed based on
planning and budget processes and are not intended to be viewed as enforceable
commitments.
Financial Considerations:
WASA has included funds in its current and approved capital program for improvements
to the swirl, pump stations, and fabridams.
WASA has programmed funds (supported in part by EPA grant), for NMC evaluation and
LTCP development.
Funds for continuing skimmer boat operation are in WASA's annual operating budget.
WASA has not budgeted funds for installation of trash traps or nets.
Legal Authority/Regulatory Needs:
NPDES permit
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A.2 Carry out required CSO "long-term control planning'1 in a way that
supports an integrated D.C. wet weather (CSO and storm sewer)
pollution prevention and control program.
To Whom Recommendation is Addressed:
D.C. Water and Sewer Authority
U.S. Environmental Protection Agency
D.C. Department of Health, Environmental Health Administration
D.C. Department of Public Works
Maryland Department of the Environment
Montgomery and Prince George's Counties
Federal Agencies Committee, Chesapeake Bay Program.
Geographic Focus: All of the District of Columbia; Rock Creek and Anacostta River watersheds
in Maryland
Recommendation Summary: D.C. WASA should prepare an innovative long-term CSO
control plan (LTCP) that is consistent with the national CSO Control Policy and provides for
attainment of applicable water quality standards. The plan should evaluate CSO control measures
and source control/pollution prevention measures, identifying sources of, and opportunities to
reduce hydraulic loading in the D.C. sewer system. The District of Columbia needs an integrated
wet weather pollution prevention and control strategy covering both CSO and separate storm
sewer discharges - and the LTCP modeling and analysis should be designed to facilitate
development of such an integrated strategy and control program, based on a watershed approach.
Recommendation Strategy: Implement the LTCP to incorporate the elements identified in the
following two phases. Take full advantage of available Federal grant support to perform CSO
planning that contributes to an integrated wet weather strategy (incorporating ways to prevent
and control both CSO and storm water discharges). An integrated strategy will help the District
balance expenditures for wet weather pollution prevention and control in the two types of sewer
systems with the goal of achieving the maximum environmental benefits for the available funding.
In conjunction with initial design of LTCP, reach agreement with D.C. EHA and USEPA on
appropriate monitoring of CSO outfalls. Suggested elements for Phases 1 and 2 of the LTCP are
listed below:
Phase 1 (emphasis on CSO options): Evaluation of: rain leader disconnection in CSO areas;
methods for reducing ground water flows in the sanitary sewer system; street cleaning strategies
which will contribute most effectively to wet weather pollution prevention, including street
cleaning/flushing (Alexandria model) in parts of the CSO area. Planning of: options for
addressing Anacostia CSO sewershed; initial long-term control implementation planning,
including sewer separation in selected areas, increased storage of combined sewage in existing
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facilities such as the Capitol Hill Relief Sewer and the Anacostia Gravity Force Main; storm water
program development/finding options. Evaluation and implementation of: improvements to
implement NMCs (ref. Recommendation A. 1).
Phase 2 (integrated wet weather source control options within combined sewer system):
Evaluation of: storm water "best management practices" (BMPs) addressing erosion, new
construction controls, illegal discharges and roadway runoff, pollution prevention; coordinated
street and catch basin cleaning to enhance wet weather pollution prevention results; alternative
intake designs; sources of hydraulic loading in the D.C. sewer system and opportunities for
reducing this loading. Study of: use of Federal/other open space for off-line storage (e.g.
possibilities for enhanced storm water retention/infiltration facilities on relatively undeveloped
land areas at the upper end of sewersheds such as U.S. Soldiers Home). Planning of: detailed
long-term CSO control plan.
The LTCP will also contribute data and modeling to conduct D.C.'s part of the Anacostia River
"integrated watershed analysis" described in Recommendation B.3. The ultimate level of CSO
control will be determined by the outcome of the water quality assessment, including the
integrated watershed assessment. D.C. WASA must also carry out a public participation program
in connection with the LTCP (ref. Recommendation D).
While it is premature to say exactly how much of the D.C. combined sewer overflows will be
eliminated by the facilities already under construction or planned in Recommendation A. 1, an
early estimate is that these measures especially the new pump stations - could reduce current
overflows to the Anacostia River by as much as 50%. The additional facilities and measures to be
evaluated and planned in Phases 1 and 2 of the LTCP should be capable of achieving an estimated
reduction of 85% of current overflows. The detailed modelling to be carried out in the LTCP will
provide more exact estimates.
Depending on the level of water quality improvement gained and results of the integrated
watershed assessment process, D.C. WASA may be required (by its Federal NPDES permit) to
complete a third phase of CSO long-term planning and implement costly new controls. The results
of the integrated watershed assessment (Recommendation B.3) will be relevant.
D.C. WASA is the principal implementing authority for this recommendation.
USEPA will have a major impact on D.C. WASA's implementation of the recommendation. The
requirements to implement the NMC are contained in the NPDES permit for the D.C. water
pollution control system, issued by USEPA, and USEPA has also provided Federal funds to aid
repair of the D.C. swirl concentrator and a $7+ million planning grant, including support for
evaluation of the effectiveness of the NMC. The completed LTCP will be subject to USEPA
approval.
The D.C. Environmental Health Administration is responsible for identifying monitoring and other
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actions that dischargers need to take to meet the requirements of the D.C. Water Pollution
Control Act, and is responsible for establishing priorities to guide funding of projects in the
District of Columbia under the annual Federal construction grants allocations.
Many of the actions required for wet weather pollution prevention, such as sanitation and street
cleaning, are carried out by D.C. agencies such as the Department of Public Works. Cooperation
with Maryland's Department of the Environment and with Montgomery and Prince George's
Counties is also essential to conduct the evaluation of upstream sources to the D.C. combined
sewershed, and to carry out coordinated up and downstream actions to restore the Anacostia
River and protect Rock Creek and other District waters.
Storm water management actions by Federal facilities in the District of Columbia will have a
major impact on the effectiveness of wet weather pollution prevention and control programs. The
planning process must include close coordination with the Federal workgroup (Recommendation
C.3). USEPA should also investigate how to grant enforcement authority to D.C. WASA to
impose the necessary storm water controls (e.g., volume or pollutant loadings limitations) on
specific Federal facilities, where necessary to meet requirements of the.CSO control program.
Timeframe/schedule:
Completion of the full LTCP in 2001, with preliminary Phase 1 evaluations completed in July
1999.
Financial Considerations:
$7+ million grant, already provided by USEPA.
D.C. WASA has made provisions in its capital program to fund generalized elements of its
CSO program through 2007. There is no assurance, however, that these provisions would
be adequate to satisfy all objectives of the LTCP.
Legal Authority/Regulatory Needs:
Additional legal authority may be needed for WASA to enforce storm water requirements
at Federal facilities. [See Recommendation C.I]
» USEPA should evaluate adding a permit condition in the future NPDES permit requiring
D.C. WASA to establish the necessary controls over storm water flows into its combined
sewers, including associated user fees. '
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A.3 Strengthen the District's storm water management program, in
compliance with Federal requirements.
To Whom the Recommendation is Addressed:
D.C. Government
Geographic Focus: All of the District of Columbia
Recommendation summary: The District of Columbia needs to complete and submit
Immediately to USEPA its storm water management plan (Part II of the application for a Federal
permit for discharges from the municipal separate storm sewer system, "MS4"). Doing this
requires clarifying organizational responsibilities among several agencies. The strategy for storm
water pollution prevention and control would involve integrating the activities of several agencies,
including D.C. WASA, D.C. DOH/Environmental Health Administration, and D.C. Department
of Public Works.
Development and implementation of the program should be coordinated with D.C. WASA's
LTCP for controlling CSO pollution, as many elements of storm water and CSO pollution
prevention and control are similar (e.g. street cleaning). The District can operate its wet weather
pollution prevention and control programs more cost-effectively by integrating its CSO and storm
water management strategies.
U.S. EPA should issue the draft MS4 permit for the District of Columbia in response to a
complete submittal of a storm water management plan by D.C. Assuming submittal of the
complete and approvable District plan by the end of November 1998, EPA could issue the draft
permit by the end of 1998. EPA should consider the District as a model, developing a permit
that: (a) facilitates integration of CSO and storm water management requirements where
applicable; and (b) assures cooperation by Federal agencies which are managing lands and
facilities in the District of Columbia (Recommendation C). EPA should consider the
appropriateness of including formal agreements between D.C. and other jurisdictions such as the
State of Maryland and/or Prince George's and Montgomery Counties as an element of the permit.
Recommendation Strategy: Using the multi-agency task force established by the D.C. Chief
Management Officer in June 1998, complete the storm water management plan required for the
Part n permit application based on available information and comments of USEPA. The plan will
provide a mechanism for integrating storm water/erosion control permitting and other regulatory
responsibilities which encourage source control, with a strategy for managing storm drainage
facilities (including streets as well as storm water intake devices, catch basins and storm sewers).
The program needs to contain a variety of activities, carried out by different city agencies, to meet
the Federal requirements outlined below (see box below; "MEP" means achieve to the maximum
extent practicable).
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U.S. EPA Headquarters Library
Mail code 3201
1200 Pennsylvania Avenue NW
Washington DC 20460
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EXHIBIT 2. REQUIREMENTS FOR THE MUNICIPAL STORM WATER
MANAGEMENT PROGRAM
MINIMUM REQUIREMENTS
A comprehensive pluming process that involve* both public participation and intergovernmental coordination
A description of management practices, control techniques, and system design and engineering methods to
reduce the discharge of pollutants to the MEP
A description of staff and equipment available to set up and assess the storm water management program
ADDITIONAL REQUIREMENTS
Programs to control storm water runoff from commercial and residential areas, construction sites, and
industrial facilities (including waste handling sites)
A description of maintenance activities and a maintenance schedule for structural controls to reduce
pollutants in discharges from MS4s
Identification of structural control measures to be included in these proposed programs, such as detention
controls, infiltration controls, and filtration control* that the municipality plans to apply to the activities
addressed in its management program
Programs to detect and remove illicit discharges, and to control and prevent improper disposal into the MS4
of material* such as used oil or seepage from municipal sanitary sewers
Post-construction controls to reduce pollutants in discharges to MS4s resulting from new development and
significant redevelopment
Practices for maintaining and operating public streets, roads, and highways that will reduce the impact on
receiving waters from storm water runoff discharges
Procedures to assure that the impacts on receiving waters from flood management projects are assessed, and
that existing structural control devices have been evaluated to determine if retrofit controls are feasible
A program to monitor pollutants in runoff from landfills that identifies priorities and procedures for
inspections and establishing and implementing control measures
A program to reduce to the MEP, pollutants in storm water runoff associated with the application of
pesticides, herbicides, and fertilizer
[40 CFR 122.26]
As source prevention activities are often more cost-effective than control measures, particular
attention should be paid to prevention mechanisms. Note: Specific recommendations for
strengthening the most important prevention program, the District's regulatory program for
control of erosion and storm water pollution from new construction, are outlined in
Recommendation A. 4.
Both Prince George's and Montgomery Counties have storm water management programs, the
effectiveness of which is critical for prevention of increased erosion, storm water surges causing
scouring of District streams, and storm water pollution in the District. The D.C. EHA and the
Counties should be able to increase their technical and program competence by working together.
In particular, closer cooperation by the jurisdictions could lead to more successful implementation
of storm water management retrofit projects (measures to address storm water pollution due to
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past development). In addition to sharing experience in implementing conventional best
management practices, D.C. should pay particular attention to the practices for "low impact
development" pioneered in Prince George's County.
While developing a plan that addresses Federal permit requirements, the District should take full
advantage of opportunities to achieve storm water pollution prevention and control while meeting
other city goals (e.g. beautification, improved sanitation, street cleaning/repair, CSO pollution
prevention, CSO LTCP).
Controls for commercial and residential storm water runoff should consider a mix of program
activities, including:
* A shift in focus from just the minimum storm water controls required under local
ordinances and guidelines to programs that encourage the use of functional landscape to
enhance the aesthetic and habitat value at new parking lots and/or new developments;
"Low impact development" practices such as reduced road length and width, use of
infiltration trenches, porous pavements, grassy swales and filter strips where appropriate;
A coordinated catch basin cleaning and street-sweeping strategy that optimizes reduction
of storm water pollutants;
* Coordination with the solid waste program to include leaf collection;
Preventive maintenance inspections for all existing storm water management facilities at
least once a year;
Development and implementation of a rain leader disconnection program;
Development and implementation of a phased approach to storm water public education
which includes collecting pet feces and environmentally-friendly fertilizing and landscaping
techniques;
Modeling of storm water impacts;
Developing a simple method for measuring the performance of these activities; and
Strengthening the erosion control program for new construction [see detailed discussion
under Recommendation A.4].
Detection and elimination of illicit discharges should consider a mix of strategies, including:
Implementation of an illicit connection detection and enforcement program where the
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additional staff will do dry weather flow inspections in target areas;
Visual inspections of targeted areas; and
If necessary, chemical testing immediately after discovery of an illicit discharge, issuance
of fines, tracking and reporting illicit discharges and reporting progress on stopping
targeted illicit discharges.
In developing its financing strategy, the District should consider:
* Allowing fees collected from applicants for construction projects which must comply with
the D.C. storm water management and erosion control program to be used to support
storm water management activities;
* Sources of additional Federal grant funding for construction of BMPs and other storm
water management activities (including Federal highway funds);
Consideration of the creation of a storm water utilitynot a new entity, but a mechanism
supported by storm water fees; and
Additional fees or revenues as necessary to support program implementation activities.
Timeframe/Schedule:
Immediate completion of the Part n permit application is necessary as the District is in violation
of Federal regulations.
Financial Considerations:
This recommendation involves a combination of new and already-funded programs.
The District of Columbia will likely need to allocate additional funds (primarily operating
rather than capital) to meet the requirements of its MS4 permit. No provisions have yet
been made for this funding.
Legal Authority/Regulatory Needs:
Federal authority is contained in the Clean Water Act. The District needs to identify its legal
authorities to implement its storm water management plan in its MS4 permit submittal.
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A.4 Strengthen the District's erosion control and storm water regulatory
program.
To Whom the Recommendation is Addressed:
D.C. Government, in particular the Department of Health, Environmental Health Administration
Geographic Focus: All of the District of Columbia
Recommendation Summary: The District of Columbia needs to revitalize its erosion control
and storm water management regulatory program, taking advantage of the recent environmental
reorganization in the District, the availability of Federal grant funds and program assistance from
USEPA, and the opportunity to seek allocation of storm water management fees collected by the
D.C. government to support administrative costs of the D.C. storm water management program.
Recommendation Strategy: Take advantage of the recent reorganization and review of D.C.
environmental programs by the District government, and of USEPA's grant and technical support,
to strengthen the existing program regulations and staff in the D.C. Environmental Health
Administration and support for enforcement. Specific issues are the following:
(1) The D.C. erosion control and storm water management program, which is intended to prevent
wet weather pollution from new construction, receives grant support from USEPA and has
recently been evaluated by that agency. While basic regulations and staff are in place in the D.C.
Environmental Health Administration, the assessment revealed a number of issues, notably:
(a) Staff shortages;
(b) Need to strengthen technical criteria and procedures for granting waivers and
variances;
(c) Failure to assess fees from developers when requirements are waived raising issues
about comparability and application of the "polluter pays" principle;
(d) Limitations related to timing of decisions, as erosion control and storm water
management plans are not routinely considered with D.C. zoning approvals and related
land use decisions; and
(e) Lack of enforcement strategy and action.
(2) In addressing these issues, priority should be given to:
Expanding inspection of the installation and maintenance of storm water erosion and
sediment control at commercial, residential and road maintenance and development areas,
and integrating a program for evaluating the effectiveness of storm water best
management practices with the broader monitoring strategies discussed in
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Recommendation E. Obtaining information from the Federal facility studies recommended
in Recommendation C should also be a practical strategy for evaluation of practices.
EHA also needs to study the cumulative impacts associated with the issuance of storm
water waivers, issue technical criteria for granting waivers and variances, -and develop a
program to assess fees where waivers are granted.
Immediate improvements should be made in D.C.'s procedures for administering critical
environmental reviews of development projects earlier in the District's zoning and
approval
At a more strategic level, the D.C. Government should incorporate a genera! strategy in
administration of its erosion control and storm water management program to encourage
wider use of "low-impact development" practices routinely in new developments. Where
development is occurring in previously-undeveloped areas of the District (such as the
Rock Creek Basin), the D.C. Government should adopt measures such as tree removal
requirements (ref. Montgomery County's ordinance) and promote project design and
construction practices which leave as much undisturbed area as possible to receive runoff
volume and reduce runoff rates by maximizing infiltration capacity.
(3) As part of implementing the District's environmental reorganization, District financial
authorities are encouraged to allow the Environmental Health Administration to use revenues
received by the City in connection with environmental services (such as review of storm water
management plans) to support environmental program administration. This will not only improve
the programs substantively, but also provide matching funds, allowing EHA to take greater
advantage of available Federal grant support.
(4) Whereas USEPA administers a general storm water pollution prevention and control permit
under Federal law which establishes requirements for new construction projects affecting five or
more acres, there is opportunity for increased work and cost-sharing among USEPA and D.C.
EHA for projects to which both Federal and District regulations apply. USEPA and D.C. EHA
should develop complementary information procedures and mutual inspection/enforcement
programs for such developments.
Timefratne/Schedule:
D.C. EHA should complete its review of actions needed to strengthen its program in connection
with its FY 1999 program grant application to USEPA. USEPA should work with D.C. EHA to
establish a plan and timetable for carrying out needed improvements.
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Financial Considerations:
The District government is urged to consider allowing the revenues generated by reviewing and
approving storm water management plans under the D.C. regulations to be returned to the
Department of Health for environmental program administration.
Legal Authority/Regulatory Needs:
* D.C. Water Pollution Control Act, Erosion Control and Storm Water Management
Regulations
Review of D.C. zoning requirements, especially to protect undeveloped forested areas
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B. Strengthen Institutional Capability to
Implement an Integrated Wet Weather
Pollution Prevention and Control Program,
Based on a Watershed Approach.
Background/Justification
Wet weather pollution is not confined to jurisdictional boundaries; it abides by the natural
boundaries of the watershed through which it flows. As a result, wet weather pollution cannot be
managed effectively on a jurisdiction-by-jurisdiction basis. To prevent and control wet weather
pollution effectively, the approach must also be governed by the natural boundaries of the
watershed. A watershed approach entails inter-jurisdictional coordination and integrating the
efforts, and resources, of ail stakeholders within a watershed. This approach makes management
of wet weather pollution more efficient and complete, and ultimately less expensive.
A watershed may encompass numerous counties and States. These jurisdictions may have
different, or very similar, priorities when it comes to managing water pollution problems.
Differing priorities can lead to information gaps; if no one jurisdiction finds a particular problem
important on the local level, all jurisdictions may ignore the problem. On the other hand, if many
jurisdictions identify one particular problem as a priority, jurisdictions may duplicate efforts to
address this problem. By bringing all stakeholders to the table, a watershed approach provides an
opportunity for collaborative strategic planning and the sharing of information and responsibility.
Within the Anacostia River and Rock Creek watersheds, a watershed approach requires
coordinating the efforts of numerous stakeholders from the District of Columbia and Maryland,
specifically Prince George's County and Montgomery County. Stakeholders represent Federal,
State, and local government, academia, environmental organizations, and citizens.
With the signing of the Anacostia Watershed Restoration Agreement in 1987 and the creation of
the Anacostia Watershed Restoration Committee (AWRC) came the first attempt within the
District and Maryland to coordinate protection and restoration efforts at the watershed level. The
AWRC provides a forum for the multiple stakeholders of the Anacostia River watershed to
collaborate on various water pollution and habitat loss problems. Many of the stakeholders
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involved in the AWRC also play a role in the protection and restoration of Rock Creek; however,
the Anacostia is the primary focus of the AWRC.
To date, the AWRC's restoration program has concentrated on the many localized problems,
rather than attempting to develop a comprehensive, total watershed approach. While many of the
projects initiated by the AWRC will have benefits beyond their immediate area, they are primarily
designed to address local problems. Many of these projects address wet weather pollution, but
AWRC has not brought this issue to the forefront. There is a need for AWRC, as the watershed
coordinating body, to take the lead and begin addressing the issue of wet weather holistically.
With its current membership and current functions, AWRC has the potential to coordinate an
integrated wet weather prevention and control program. To implement such a program
effectively, AWRC needs to ensure that all stakeholders relevant to the wet weather issue within
the District and Maryland have representation. AWRC needs to develop programs and projects
that focus on the issue of wet weather pollution. Public accountability for achieving measurable
goals will also spur the needed investment and accomplishment.
The wet weather challenges faced by Rock Creek, which include streambed scour from erosive
flow and elevated levels of fecal coliform bacteria, also require the attention of both Maryland and
the District. With the pressures of population growth and increased development in Maryland,
the problems faced by Rock Creek are likely to increase in the near future. The Rock Creek
watershed has numerous stakeholders dedicated to its restoration and protection, but no
coordinating body to ensure resources are used effectively and efficiently. This is an institutional
need which should be addressed.
Successful and cost-effective planning for the Anacostia River and Rock Creek watersheds
depends on conducting a comprehensive, integrated watershed assessment. Large-scale
investments, such as CSO and storm water controls, can be costly and should be planned in the
context of overall benefit to the entire watershed. Regulatory activities, such as Total Maximum
Daily Load (TMDL) development and the water quality standards triennial review process, have
information needs similar to wet weather control planning. Disparate efforts to collect this
information will result in duplication of effort and inefficient expenditure of limited resources. An
integrated effort will examine the wet weather pollutant sources throughout the watershed, assess
their collective impact on water quality and determine what can be achieved for various levels of
investment in both CSO and storm water controls. It is increasingly important that the combined
effects of multiple projects be considered in making future restoration plans. As multiple
jurisdictions and agencies are involved, this will require more comprehensive analysis and greater
program coordination and cooperation.
Expected Benefits
Adopting a watershed approach to wet weather pollution control for the Anacostia River and
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Rock Creek watersheds can produce the following benefits:
* Support from organizations and individuals who have the power to "make or break"
restoration and protection efforts;
Shared planning, implementation and funding responsibility;
Decreased gaps in information;
Increased understanding of watershed problems through information sharing; and
Increased awareness of wet weather pollution among watershed communities.
Related Actions
The District of Columbia's programs to strengthen wet weather pollution prevention and control
under Recommendation A will contribute significantly, and be aided by, effective watershed
strategies and actions promoted in this recommendation. It would be impractical to include all
agencies with a stake in the Anacostia program on the AWRC. However, there must be effective
collaboration with the numerous Federal agencies (such as the Navy, NASA, Agriculture) with
substantial land holdings in the watershed. It is important that the Federal facility efforts be
accelerated, as indicated in Recommendation C, and the Federal workgroup (ref.
Recommendation C.3) should assure that the relevant plans and actions are factored into the
AWRC planning process.
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B.I Strengthen the Role of the Anacostia Watershed Restoration
Committee (AWRC).
To Whom Recommendation is Addressed:
Members of AWRC, other stakeholder agencies, and interested observers
Geographic Focus: Anacostia River Basin.
Recommendation Summary: The AWRC is a valuable body already carrying out inter-
jurisdictional coordination to assist water quality and habitat restoration efforts in the Anacostia
River watershed; it should be continued and strengthened. AWRC members should: 1) enhance
committee oversight and decision making; 2) strengthen information resource capabilities; and 3)
strengthen their public education and outreach role.
Recommendation Strategy: The AWRC was formed in 1988 to implement the goals of the
1987 Anacostia Watershed Restoration Agreement and address the rapidly deteriorating water
quality conditions in the Anacostia River. Most of the water quality problems it was created to
address sediment deposition, low dissolved oxygen, excess nutrients, poor habitat and toxic
conditions are associated with wet weather phenomena. They are the result of conditions
throughout the watershed, in both Maryland and the District, and all levels of government, local,
State, and Federal have a critical role in restoration.
Currently, the AWRC members are the District of Columbia, Montgomery and Prince George's
Counties, the State of Maryland, and the U.S. Army Corps of Engineers. The AWRC receives
technical and administrative support from the Metropolitan Washington Council of Governments
(COG) and scientific and outreach support from the Interstate Commission on the Potomac River
Basin (ICPRB). While each member agency retains responsibility for its respective programs, the
AWRC has provided a common vision for the restoration of the Anacostia watershed and has
established a framework for program coordination.
The strategy below for strengthening the AWRC's capabilities and effectiveness is organized to
implement three essential themes:
(1) Enhance the oversight and decision-making processes, while retaining the integrity of
individual agency programs;
(2) Design, centralize, and make readily accessible the information resources that help guide
agencies' restoration efforts and chart the program's progress; and
(3) Design, centralize, and make readily accessible the information resources to enhance public
information and foster informed public commentary.
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Oversight and Decision Making
As the Anacostia program evolves and matures, it is apparent that other agencies have a stake in
the program and that there is a need for closer technical coordination to reflect watershed issues.
Accordingly, there are two specific recommendations.
(1) Expand AWRC membership. Much of the adverse wet weather impacts and restoration
opportunities occur on park property. In addition, USEPA Region in has a special interest in and
responsibility for the Anacostia program that merits closer coordination with other watershed
partners. Accordingly, it is recommended that the AWRC consider expansion of its membership
to include the Montgomery County and Prince George's County portions of the Maryland-
National Capita] Park and Planning Commission, the National Park Service, and the
Environmental Protection Agency.
(2) Much of the Anacostia restoration effort takes place on a small scale, addressing local streams
in a single jurisdiction. However, there are broader scale problems that impact two or more
jurisdictions and that need more comprehensive technical coordination and oversight.
Accordingly, an Interagency Wet Weather Technical Advisory Group, comprised of AWRC
member staff, should be established by the AWRC to define and coordinate watershed-wide
program priorities including monitoring, modeling, project planning, and tracking of progress.
Information Resources for Agency Use
Program effectiveness, especially from a watershed-wide perspective, depends on access to
timely, relevant information. The following recommendations focus on various aspects of this
need. Each would be implemented with AWRC oversight.
(1) Prepare and maintain a watershed-wide restoration plan that ties together the locally prepared
plans with program elements that transcend jurisdlctional boundaries.
(2) Develop a centralized clearinghouse and database for monitoring data and BMP design,
performance and maintenance information. This could be facilitated by using the combined
resources of the appropriate agencies of the COG member jurisdictions.
(3) Create a centralized comprehensive, integrated wet weather information management system
reflecting regional CSO, SSO, and storm water conditions and impacts. This is intended to assist
watershed-wide wet weather program decision making. Included in this system would be a series
of indicators and targets to measure progress in implementation of the comprehensive plan.
(4) Create a centralized, watershed-wide comprehensive database and associated assessment
program for toxic contaminants.
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Information Resources for Public Access
The AWRC members have long recognized the need for more effective public involvement in the
Anacostia restoration program. There are many community-based organizations and individuals
with a stake in the restoration efforts and concerns about conditions in the watershed. In general,
their involvement with the restoration program and contribution to their community would be
better served if they had ready access to program information and an awareness of what others
are doing.
The effectiveness of the AWRC will be strengthened if the information for public access is greatly
improved. Two specific proposals address this concern.
(1) Create and maintain a centralized information clearinghouse and point of contact for public
education and outreach initiatives. For those with WEB access, this should be a part of the
AWRC home page and include an e-mail address. For those without, there should be a dedicated
telephone number where questions and requests for information can be left. The type of
information provided should include: a summary of and access to restoration program documents;
a calendar of events; referrals to community-based organizations; agency points of contact; and a
guide to the information resources for agency use.
(2) Create a Wet Weather Speaker's Bureau. This would involve development and maintenance
of presentation materials, identification of staff and citizens interested in giving invited
presentations on the Anacostia program, and appropriate training and publicity.
Timeframe/Schedule:
Complete in fiscal year 1999.
Financial Considerations:
The expanded membership will require some additional funding for administrative support.
These requirements should be factored into the FY '00 budget.
Financing from AWRC member contributions, possibly augmented by EPA grant funds.
Legal Authority/Regulatory Needs:
As AWRC is a coordinating mechanism, regulatory needs have not been identified.
Related Actions:
The strengthened AWRC would be a logical organization to lead and coordinate a number of
specific multi-jurisdiction actions outlined in Recommentations D, Educate ami Involve the
Public. Foster Volunteerism and Community Involvement, E, Enhance Decision-Making
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Through Better Monitoring, Data Collection, and Information Management, and F, Pursue
Pollution Prevention Through Source Controls as a Key Part of the Solution.
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B.2 Establish a Rock Creek Watershed Coordinating Committee.
To Whom Recommendation is Addressed:
Maryland Department of the Environment
Maryland Department of Natural Resources
Montgomery County
District of Columbia
U.S. Environmental Protection Agency
National Park Service
U.S. Army Corps of Engineers
Maryland-National Capital Park and Planning Commission
Metropolitan Washington Council of Governments
Community-based organizations located in the Rock Creek watershed
Geographic Focus: Rock Creek watershed
Recommendation Summary: Create a Rock Creek Watershed Coordination Committee to
address physical, biological, chemical, and economic issues specific to the Rock Creek watershed.
Strategy:. A mechanism is needed to coordinate agency actions and program planning for water
quality issues in the Rock Creek watershed, including storm water, sediment, habitat, fish passage,
CSOs, SSOs, and toxics. Better interagency and inter-jurisdictional coordination,
communication, and planning should enable more efficient use to be made of resources allocated
to the Rock Creek watershed and contribute significantly to protecting the natural assets of Rock
Creek Park and surrounding natural areas. Using the Anacostia Watershed Restoration
Committee as a model, a Rock Creek Watershed Coordination Committee (RCWCC) should be
created to address environmental issues specific to Rock Creek. The RCWCC's membership
should be comprised of the agencies listed above, as well as other community-based organizations
located within the Rock Creek watershed (e.g. Audubon Naturalist Society).
Many of the agencies and organizations that participate on the AWRC will also have an interest in
participating as a member of the RCWCC; therefore, initial meetings of the RCWCC should be
coordinated with AWRC meetings. This will facilitate establishment of the RCWCC and be quite
cost-effective.
Although based on the same principle as the AWRC, the RCWCC may differ in organization,
purpose, and function. Through initial informal meetings, the RCWCC membership can
determine how this new committee will operate within the Rock Creek basin. During the first
year, members of .the RCWCC should concentrate on the following activities:
Defining issues;
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Exploring funding options;
* Preparing a multi-year budget and work plan;
* Assessing the need for a formal agreement among involved parties; and
* Assessing the need to initiate an integrated watershed assessment process.
Timeframe/Schedule:
Hold the first meeting to establish the Rock Creek Watershed Coordinating Committee early in
FY 1999.
Financial Considerations:
The cost of initial meetings and administrative support is expected to be modest and
readily absorbed into agency budgets. Ongoing administrative and technical support
would require a budget and funding mechanism. Specific plans should be developed
during FY'99.
Agency contributions and possible EPA grant support.
Legal Authority/Regulatory Needs:
No legal authority or regulatory needs have been identified.
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B.3 Conduct an integrated watershed assessment for the Anacostia River
and tributaries.
To Whom Recommendation is Addressed:
D.C. Department of Health, Environmental Health Administration
D.C. Water and Sewer Authority
Maryland Department of the Environment
Montgomery and Prince George's Counties
Anacostia Watershed Restoration Committee
U.S. Environmental Protection Agency
National Park Service
U.S. Army Corps of Engineers
Chesapeake Bay Program Federal Agencies Committee
Geographic Focus: Anacostia River Basin
Recommendation Summary: The District and Maryland should initiate an integrated watershed
assessment (IWA), to investigate the physical, chemical, biological (including habitat), and
economic factors affecting water quality in the Anacostia River. The IWA should provide the
vision for the future uses and water quality of the Anacostia River and identify the measures
necessary to attain that vision. The IWA process should include the full participation of
stakeholder agencies and a strong public participation effort. It is envisioned that the results of
the IWA would provide a coordinating mechanism for analyses required through other processes,
such as D.C. WASA's CSO long-term control planning, Clean Water Action Plan initiatives, and
watershed TMDL development. The IWA process could also help guide the next D.C. and
Maryland triennial water quality standards review process (2001), and could possibly determine
the need for a formal Use Attainability Analysis.
Strategy: Water quality problems are particularly severe in the Anacostia River basin, and of
long-standing. Current standards will be costly to meet both in the District of Columbia and
upstream in Maryland. Therefore, it is critical to agree on a strategy for identifying the most cost-
effective improvement opportunities, reflecting physical, chemical, biological, and economic
factors. The IWA is intended to facilitate this agreement, and should be initiated as soon as
possible.
A technical work group should be set up to coordinate the IWA's development, implementation,
and funding. Although the technical work group will initially consist of representatives from the
organizations listed above, it should focus on developing a process to incorporate public
participation. One of the first tasks of the technical work group should be the development of a
public participation process within the design and implementation of the IWA. The IWA process
should actively involve the public (by soliciting representatives from community organizations and
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local neighborhoods to serve on the technical work group), and avoid using reactionary
mechanisms (e.g., asking the public to comment on IWA materials developed by the technical
work group).
The technical work group, possibly facilitated by MWCOG, should design the IWA process for
the Anacostia River basin. Immediate attention and agreement should be reached on data needs
and modeling for the IWA, Decisions about data and modeling will facilitate integration of the
IWA process with other processes, such as D.C. WASA's CSO long-term control planning and
joint TMDL development by the District of Columbia and Maryland.
Participants in the technical work group should design the IWA process to be as cost-effective as
possible while producing results suitable for use in other major on-going processes, including:
D.C. WASA's CSO LTCP effort;
Clean Water Action Plan related efforts, such as prioritizing watersheds for restoration
action strategies
TMDL development between the D.C. Environmental Health Administration and the
Maryland Department of the Environment; and
Water quality standards triennial review processes in 2001.
The proposed IWA provides a unique opportunity to both draw on and provide information to the
efforts listed above. Accordingly, a maximum effort should be made to harmonize the water
quality data and modeling requirements for the other processes. The findings of the IWA process,
together with results of the TMDL and CSO long-term planning processes, will provide the
information necessary to make fundamental CSO and storm water program decisions. These
findings may also be used to initiate a formal Use Attainability Analysis (UAA) for setting future
Anacostia River use classifications.
The IWA public participation process developed by the technical work group should provide an
open forum for officials and citizens in the Basin to reach consensus on a vision for the Anacostia
in the light of scientific and economic information about the expected costs and benefits. This
process should coordinate with other public participation processes, such as D.C. WASA's public
participation plan, to provide citizens within the Anacostia River basin consistent information and
avenues for involvement (ref. Recommendations A.2, D. 1 and D.2).
Timeframe/Schedule:
Initiation of IWA development should begin immediately, to coincide with WASA's CSO long-
term planning efforts.
Financial Considerations:
The cost of the IWA will depend on the scope of study and public participation
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mechanisms, to be determined. Note, however, that an effective process should lead to
better analysis and prioritization of pollution control efforts, and thus far more cost-
effective future investments.
* Sources of funding are: (1) USEPA Region m program grant funds to the District's
water quality program, FY 1999 and 2000; possible augmented funding from other Clean
Water sources, including USEPA program grant funds supporting the Maryland water
quality program; (2) Information generated from the D.C. WASA LTCP, already funded
by a facilities planning grant (S7+ million) from USEPA and from D.C. WASA sources;
and (3) State of Maryland [to be determined].
Legal Authority/Regulatory Needs:
Clean Water Act. Existing regulations pertaining to TMDLs and WQS.
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C. Place Strong Emphasis on Federal Agency
Action Because Watershed Restoration Goals
Cannot Be Met Without It.
Background/Justification:
Federal agencies manage significant portions of the Anacostia River and Rock Creek watersheds.
Notably, in the District of Columbia, the Federal Government owns over 40% of the land area and
manages numerous buildings. Federal Government buildings and associated facilities, such as
access roads and parking lots, dominate the Capitol Hill and Federal Triangle areas; these facilities
channel storm water into the District's combined sewer system and thus contribute significantly to
the CSO pollution of the Anacostia River. In the District of Columbia, the Federal Government
owns and manages (through the National Park Service) all of the riparian land along Rock Creek,
and much of the riparian land along the Anacostia River (through several agencies). The Federal
Government also owns and manages lands and facilities in the Maryland portion of the Anacostia
and Rock Creek watersheds; its actions to protect the headwaters are extremely important in
maintaining health ecosystems both upstream and downstream in the District. Finally, Federal
agencies such as the U.S. Army Corps of Engineers and U.S. Environmental Protection Agency
carry out or fund numerous water-related programs; how these programs are administered has
critical implications for the success of local ecosystem restoration and clean water protection
programs.
Combined Sewer Overflow Pollution
Like all water and sewer service users, the Federal Government pays service fees to the D.C.
Water and Sewer Authority. Correction of the District's CSO pollution problems will, however,
require major capital facility construction that is beyond the District's capacity to finance. If the
Federal Government assumes responsibility to eliminate its share of the CSO overflow burden,
efforts to restore water quality and uses of the Anacostia River will be greatly accelerated. Key
elements to carry out this responsibility are to cooperate with D.C. WASA as it carries out the
CSO long term control plan (addressed in Recommendation A.2); to contribute the Federal
Government's fair share for capital financing of major CSO control facilities; and to install storm
water pollution prevention and control measures on Federal lands and buildings.
Storm Water Management
The Federal Government can make a substantial contribution to prevention and control of storm
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water pollution through its land management practices. Open areas on Federal lands throughout
the Anacostia and Rock Creek watersheds provide among the most suitable, cost-effective areas
in the National Capital Region for installing storm water management BMPs, such as landscaping
features that retain storm water flow. These features do not need to detract from the primary
purpose of Federal installations; to the contrary, they can contribute to visual quality, facility
maintenance, erosion control and employee morale.
In addition to owning land and managing buildings and other facilities, Federal agencies provide
regulatory guidance and enforcement, technical expertise, and funding support to state and local
environmental protection and restoration efforts in the watersheds. Because of the strong
presence of Federal agencies in these watersheds, their participation in restoration efforts is
essential to the successful recovery of the watersheds. Restoring the health of the watersheds
requires the effort of all parties who benefit from or use the resources offered by the rivers and
their tributaries.
Many actions have already been taken by Federal agencies to build watershed partnerships,
improve the delivery of Federal programs, implement watershed and ecosystem approaches, and
improve land management and pollution prevention. HoweVer, much more needs to be done,
especially within the District's urban core areas. Priorities need to be established, funding
opportunities need to be identified, a true partnership needs to be established with the District of
Columbia, the State of Maryland and other watershed agencies, and implementation needs to
occur.
Expected Benefits:
Evidence increasingly demonstrates that the most devastating environmental effects may result not
just from the direct effects of a particular action, but from the combination of individual, and often
minor, effects of multiple actions over time. Wet weather pollution and environmental degradation
of the watersheds has been the result of a variety of adverse actions, both point source and
non-point source pollution discharges, throughout each drainage area. As a result, habitat
suitability and water quality improvement will only occur through the implementation of many,
often small, projects, programs, and activities throughout each watershed.
On the positive side, there is increased recognition of the cumulative benefits from incremental
actions for watershed restoration. Because Federal agencies own and manage a significant
percent of each watershed, it is essential to implement measures on these areas. For a complete
watershed restoration approach, the Federal lands need to be part of the solution for watershed
restoration.
Related Actions:
Even though this is a specific recommendation for Federal agencies, many of the other
recommendations from this panel (e.g. Monitoring) apply to Federal agencies and should be
implemented whenever possible.
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C.1 Accelerate wet weather pollution prevention and control on Federal
lands and at Federal buildings and associated facilities.
To Whom Recommendation is Addressed:
All Federal agencies that manage lands or buildings within the drainage areas
D.C. Water and Sewer Authority
D.C. Department of Health, Environmental Health Administration
Montgomery and Prince George's Counties
Anacostia Watershed Restoration Committee
Maryland Department of the Environment
Maryland Department of Natural Resources
Federal Agencies Committee, Chesapeake Bay Program
Geographic Focus: Federal lands and buildings owned and/or operated in both the Anacostia
River and Rock Creek Watersheds (Maryland and District* of Columbia)
Recommendation Summary: To prevent and control wet weather pollution, Federal
landowners and building/facility managers need to improve the management of their property
through the following actions: (1) meeting legal requirements relating to storm water pollution
prevention and control; (2) completing storm water management plans; (3) providing input to
D.C. WASA's long term control plan (LTCP) for combined sewer overflows in the District of
Columbia; and (4) implementing storm water management controls.
Recommendation Strategy: Federal agencies should carry out the following basic steps, to
assure that the Federal Government contributes effectively to wet weather pollution prevention
and control within the Anacostia River and Rock Creek watersheds. Cooperation by the Federal
Government should be commensurate with the dominating role the government plays in the land
use patterns especially of the District of Columbia.
Identity all regulatory requirements and evaluate the status of Federal compliance
The Environmental Protection Agency should lead the effort to identify all compliance
requirements for Federal land managers, including Federal, State and local requirements.
Evaluating the status of compliance is the responsibility of individual Federal agencies; however,
the Federal Wet Weather Workgroup described below should be a forum for information
exchange and provide assistance. Issues of concern include timeliness and complete submittal of
sediment and erosion control plans for construction projects; discharge permit requirements; and
monitoring for compliance.
Many facilities are currently required to develop storm water plans (e.g. in connection with EPA
permit), but these plans typically only address a few issues associated with storm water runoff,
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such as pollution prevention for industrial areas. Federal agencies should develop comprehensive
storm water management plans that address both quantity (e.g. flows, discharge duration and
frequency, and flow rates) and quality issues (e.g. polyaromatic hydrocarbons (PAHs), petroleum
products, trash, and sediment).
The Federal workgroup proposed in Recommendation C.3 could provide technical guidance for
these plans, including the following examples: (1) identify impervious areas, (2) determine what
type of storm water management (both quality and quantity controls) these impervious areas have,
(3) identify techniques to improve storm water management for areas with no existing controls
and areas with limited existing controls, and (4) develop a strategy for implementing the storm
water controls.
*
Priority should be given to those facilities in known problem areas. *
Examples of Federal facilities in known problem areas include: (1) lands and buildings within the
District of Columbia CSO sewershed (i.e. Capitol Hill, Federal Triangle and the U.S. Soldiers
and Airmans Home/McMillan Reservoir), (2) sites that drain into areas .with known stream
degradation (either stream instability or poor water qualify) (i.e. National Arboretum and
Beltsville Agricultural Research Center), and (3) areas where storm water-related pollution and
toxic contamination of sediments have been identified.
These comprehensive storm water management plans could be done agency by agency, building
by building, or done jointly between agencies or building managers for a given area. Existing
authorities could be used to collectively look at a larger geographic area.
Provide input to D.C. WAS A for facility planning and design of CSO controls in the District of
Columbia (Recommendation A), particularly the Long Term Control Plan (LTCPY
The immediate requirement is to assure D.C. WASA has adequate background information (e.g.
metering data, employee population, and size of property) on Federal facility sanitary and storm
water discharges. Work with D.C. WASA as the LTCP is developed to:
Provide recommendations on technologies suitable for Federal facilities, incorporating a
mix of technologies including new and retrofitted storm water facilities, change in the
conveyance system, and potential low-impact development measures.
Identify Federal buildings and associated facilities that contribute to the combined sewer
system and quantify, if possible, their contribution.
Identify opportunities for quantity/quality control from Federal facilities and lands.
Once D.C. WASA has developed the early stages of the LTCP, more specific information
requirements will be requested from the Federal agencies. The Federal workgroup could be, if
needed, an avenue for this information exchange.
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Implement new storm water management controls.
Again, implementation priority should be given to facilities and buildings that are key components
of D.C. WASA's Long Term Control Plan for the combined sewer system, and to measures
needed to carry out other storm water management plans identified as high priority in 2 above.
Successful implementation and management of the priority recommendations will require the
following: (1) identifying project costs and benefits both existing and future; (2) building
support for Federal efforts; and (3) measuring and reporting progress.
Timeframe/Schedule:
Fall 1998- Identify all regulatory requirements, USEPA as the lead.
Fall 1998- Identify Federal land and building owners and/or managers within the Rock Creek and
Anacostia watersheds.
Fall 1998- USEPA should send a letter to Federal agencies identified above, to assure that
existing regulatory requirements are fully understood.
Winter 1998/1999- Identify information required by D.C. WASA to begin LTCP.
Winter 1998/1999- The Federal workgroup, in cooperation with AWRC and FAC- Chesapeake
Bay Program, should identify critical Federal facilities and buildings for improved storm water
management. The workgroup should begin to provide assistance to these agencies while
developing the comprehensive storm water management plans.
FY 1999- FY 2000- Explore traditional and innovative budget and authority opportunities to
implement improved storm water management techniques.
Fall 2000 - Federal agency representatives could sign an implementation agreement to
demonstrate their support for implementing D.C. WASA's Long Term Control Plan
Financial Considerations:
Compliance with regulatory requirements is a responsibility of each Federal agency, in the same
manner as for other regulated pollution sources. Similarly, Federal agencies must pay fees for
water/sewer services received. For activity areas (2) and (4), the Federal storm water workgroup
should explore all traditional and innovative funding opportunities.
Legal Authority/Regulatory Needs:
Exploring all legal authority and regulatory needs for implementing the long-term priority actions
is a priority of the workgroup. The workgroup should explore existing authorities and programs
and make recommendations for creating new authorities and programs.
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C.2 Focus Federal financial support and other assistance on wet weather
pollution prevention and control priorities.
To Whom Recommendation is Addressed:
Federal agencies that provide regulatory guidance and enforcement, technical expertise, and
funding support to state and local environmental protection and restoration efforts in either the
Anacostia River and Rock Creek Watersheds (Maryland and District of Columbia)
Geographic Focus: Anacostia River and Rock Creek Watersheds (Maryland and District of
Columbia)
Recommendation Summary: Federal agencies operating regulatory, financial assistance,
research, and other programs in the District of Columbia and Maryland watersheds that are
pertinent to wet weather pollution prevention and control should examine their current activities
in light of the Panel recommendations, identify how these programs can facilitate their
accomplishment, and take action.
Recommendation Strategy: First, the Federal agencies represented on the D.C. CSO/Storm
Water Panel should review their programs and determine how their activities could be funded and
organized in the future to meet the Panel's recommendations and to enhance wet weather
pollution prevention and control in the Anacostia River and Rock Creek watersheds. Programs
that should receive particular attention include, but are not limited to, the following:
U.S. Environmental Protection Agency
%r
USEPA. Region HI:
Issuance and enforcement of NPDES permits for CSO and storm water pollution
prevention and control in the District of Columbia, and oversight of comparable
parts of the Maryland Department of the Environment's delegated NPDES
program. In particular, EPA should assure that regulated wet weather activities under
the Clean Water Act promote a watershed approach, assure optimum integration of CSO
and storm water-related pollution prevention and control strategies and requirements,
provide for appropriate coordination of requirements pertaining to Federal facilities and
other wet weather dischargers, and are consistent with the Panel's specific
recommendations concerning priority actions. EPA should also consider providing
compliance assistance to Federal facilities in the watersheds.
Assistance, guidance and approval actions for D.C. and Maryland water quality
standards and total maximum daily loads pertaining to wet weather pollution. In
particular, EPA should support as strongly as possible through technical assistance and
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funding the completion of the "integrated watershed assessment" for the Anacostia River
outlined in Recommendation B-3. EPA should assist the District of Columbia and
Maryland to take advantage the newly-created Clean Water Action Plan (CWAP),
especially to assure that the Anacostia River and Rock Creek receive the necessary
attention and priority in the States' Unified Watershed Assessments, which will enable
new funding under the CWAP to be utilized effectively to meet urgent wet weather
pollution control needs, especially in the Anacostia River watershed.
* Water and Chesapeake Bay Program grant support to the environmental protection
programs of the District of Columbia and Maryland, and financial support for
wastewater treatment operations and non-point source control/environmental
restoration projects. In addition to incorporating the Panel's recommendations into its
grant guidance for FY 1999 and future fiscal years, Region HI should encourage Maryland
to give greater priority to the Anacostia River in its State operations until the water
quality and use goals are met. Region III should search for additional sources of grant
flinding, including use of grants and technical assistance available under other EPA
programs (such as RCRA, Superfund-Brownfields, and Supplementary Environmental
projects associated with enforcement actions). It should achieve greater efficiency in using
currently-administered sources of funding through better cross-program coordination and
priority setting. Current plans for developing an integrated "water strategy" for
coordinating grants to the D.C. Department of Health should contribute to cost-
effectiveness, as will continuation of the Region's Anacostia Work Group.
USEPA Headquarters:
Model program funding. Strategies for the National Capital Region may qualify as a
model for urban wet weather pollution prevention and control certainly that is the
Panel's intention. USEPA Office of Water should cooperate with Region JH and the
Federal Workgroup established under recommendation C.3 to identify ways in which
EPA's national wet weather program can support D.C.-Maryland efforts in the
Washington area, and vice versa.
* Wet weather research and development assistance and funding. The EPA ORD Wet-
Weather Research Program has contributed expert information and advice to the Panel,
and has offered to provide technical assistance to D.C. WASA in carrying out its CSO
control program planning and evaluation. USEPA should assess other ORD research
programs for both applicability and support for carrying out the Panel's recommendations.
A particular example would be support for research on appropriate microbiological
indicators for protection of water-based recreation especially related to storm water
pollution.
Technical guidance on storm water "best management practices**. Useful policy and
technical guidance has been provided by USEPA Headquarters to assist agencies to
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U.S. EPA Headquarters Library
Mail code 3201
1200 Pennsylvania Avenue NW
Washington DC 20460
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improve wet weather pollution prevention and control programs. Currently, the Office of
Water is administering a cooperative assistance agreement on "Low Impact Development"
techniques to address storm water runoff. The Panel supports expeditious completion of
the study. These urban runoff management practices, which have been pioneered in Prince
George's County, appear to be cost-effective, attractive for urban landscaping, and
amenable to installation in small areas. The use of these techniques in appropriate retrofit
situations has the potential to reduce the volume of wet weather pollution and pollutant
discharges in both combined and separate storm sewer areas in the District of Columbia.
The Office of Water should also be prepared to provide technical advice regarding other
types of best management practices that could have particular benefits in reducing wet
weather pollution of the Anacostia River and Rock Creek.
Clean Water Action Plan Federal Steering Committee. EPA should encourage this
body, which is made up of senior-level Federal representatives who are working to
achieve the Federal interagency partnership goals of the CWAP, to focus some of its
activities on "the Government's own front yard" - the D.C. metropolitan area. High-level
attention and support will be needed, both from the Administration and the Congress, if
success is to be achieved in restoring the Anacostia River.
Chesapeake Bay Program:
Federal Agencies Ecosystem Management Agreement Revision of this agreement
offers the opportunity to incorporate continued Federal activities to restore the Anacostia
River and to focus additional activity on overall wet weather pollution prevention and
control. The Bay Program's Federal Agencies Committee should continue to support the
D.C. CSO/Storm Water Panel's efforts by providing a "home" for the recommended
Federal Wet Weather Workgroup.
Special Bay Program initiatives such as Riparian Reforestation and "BayScaping"
and project funding. The Bay Program has many programs which have been addressing
storm water management from the standpoint of ecosystem restoration and nutrient
reduction, and overall the Chesapeake Bay Agreement is a focal point for developing and
implementing innovative environmental practices. The Bay Program is urged to examine
the principals and practices of "low impact development" storm water management, and
spur their implementation through its special programs.
Federal Highway Administration fFHWA):
Federal highway funding and implementation of the recently-enacted TEA-21
amendments. About 40% of the District's roads are eligible for Federal highway funding,
and Federal grant funds can support activities such as erosion control during road
construction and installation of storm water management features to prevent and control
pollution associated with highway use. FHWA also has considerable technical expertise in
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highway storm water pollution prevention and control devices. As highway use results in
significant amounts of storm water pollution associated with trash, oil and toxic chemical
runoff, FHWA should cooperate with D.C. WASA in facility planning for CSO pollution
prevention, work with the D.C. and Maryland Highway Departments to assure that
appropriate measures are built into highway construction and reconstruction projects
undertaken with Federal funding, increase its technical assistance and cooperation with the
D.C. Environmental Health Administration and Department of Public Works regarding
storm water pollution prevention and control from road construction and use.
* Special Study. A recommendation for a special regional study of highway-related storm
water pollution is contained in Recommendation F.3. FHWA is urged to cooperate fully
with this study, provide technical expertise and, if possible, provide financial support for
the study and its implementation.
U.S. Navy:
Anacostia River research and design of storm water management for Navy facilities
bordering the Anacostia River. The Navy needs to implement its responsibilities as a
Federal land manager, as addressed in Recommendation C. 1. However, the Navy can
make an additional, and most valuable, contribution to the wet weather pollution
prevention and control by continuing to support research on the Anacostia River, and on
design of cost-effective storm water pollution prevention control, at the Naval Research
Laboratory. The Navy can also provide additional technical expertise resulting from its
environmental restoration projects in other areas.
Leadership within the Department of Defense on environmental matters. The Navy
should promote awareness of the Panel's recommendations and implementation of wet
weather pollution prevention and control in the Anacostia River and Rock Creek
watersheds through its position as Department of Defense Region HI Environmental
Coordinator.
U.S. Army Corps^)f Engineers:
Drift collection/removal in the Anacostia and Potomac Rivers. The Corps should
continue to collect and remove drift materials from waters of the Potomac and Anacostia
Rivers, and coordinate its activities with trash removal performed by D.C. WASA.
Environmental Restoration. Building upon its experience with successful wetland
restoration in Kenilworth Park, the Corps through cooperative efforts, has completed and
continues to implement a series of environmental restoration projects throughout the
Anacostia River watershed in Maryland and the District of Columbia, including 42 acres
of wetlands restoration at Kingman Lake. The Corps and the National Park Service are
encouraged to identify other Anacostia riverbank areas in the District where wetlands
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could be restored. In addition to their habitat value, wetlands are natural filters for
contaminated storm water.
The Corps of Engineers has several authorities under which it can assist state and local
governments (subject to available funding) to carry out habitat restoration projects,
provide flood plain management planning and technical services, and assist in
comprehensive water resources planning. Many projects can provide both wet weather
pollution prevention and control methods and fish and wildlife habitat restoration, while
also being cost-effective. The District of Columbia has not recently been able to take full
advantage of such programs because of limited local matching funds. The Corps should
continue to explore additional partnering opportunities to expand restoration efforts in
both the Anacostia and Rock Creek watersheds.
Completion of Anacostia Federal Facilities Impact Assessment and support for the
Chesapeake Bay Program's biennial Federal Anacostia workplan. The Corps should
continue its current efforts, and extend its assessment services to assist Federal land and
building managers in the urban core of the District of Columbia.
Management of open lands at McMillan Water Treatment Plant The Panel has
identified this area and surrounding properties such as the U.S. Soldiers and Airmans
Home, which are located at the top of the combined sewershed draining to the largest
combined sewer outfall on the Anacostia River, as a place where installing storm water
retention landscaping and other facilities might contribute substantially to reducing CSO
overflow. The Corps is urged to cooperate with D.C. WASA's investigations under the
LTCP, and to develop a storm water retention project plan should the LTCP show that
this would be beneficial.
National Park Service:
* Management of National Park lands. The National Park Service (NFS) manages over
4000 acres of park land within the Anacostia River Watershed and Rock Creek
watersheds. Rock Creek Park extends along the entire riparian area of Rock Creek within
the District of Columbia. Through its management efforts, and subject to available
funding, NFS has a major opportunity to contribute to wet weather pollution prevention
and control. Designing and building CSO and storm water management facilities in the
District of Columbia along the Anacostia River and Rock Creek will almost always require
cooperation with the National Park Service (e.g. for crossing land), and thus NPS
partnership with D.C. WAS A and other District government agencies will be essential. In
addition, NPS lands can be a "living laboratory" for installing and evaluating storm water
management best management practices, such as "low impact development" methods,
which are compatible with the highest standards of natural land management,
beautification and recreation. Demonstration of these methods has national as well as
local value for continuously improving the state of the art in wet weather pollution
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prevention and control.
U.S. Geological Survey:
Stream monitoring and scientific assistance. USGS operates and maintains a number
of stream gage stations and other monitoring data collection points in the Anacostia River
and Rock Creek watersheds. Good hydrologic data are .essential to designing and carrying
out cost-effective CSO planning and wet weather pollution prevention and control overall
all. USGS has contributed expertise to the Panel, and its scientific advice, monitoring
expertise and data will be a key Federal contribution. A USGS scientist should be assigned
along with EPA's Wet-Weather Research Program to provide ongoing advice for D.C.
WASA's short and long-term CSO control program.
General Services Administration:
GSA's National Capital Region will be responsible for carrying out studies and
actions under Recommendation C.1 for Federal buildings it owns or controls. In
addition, the GSA "Green Buildings" program is encouraged to become an active partner
in developing the state-of-the-art for wet weather pollution prevention and control
measures for buildings and associated facilities.
Second, the Federal Agency Pane! Members should communicate with Federal agencies which
were not on the Panel, to let them know of the recommendations and to solicit their active
involvement in carrying them out. Agencies with which contact should be made include, but are
not limited to, the following:
National Capital Planning Commission:
The National Capital Planning Commission (NCPC) coordinates all Federal Planning activities in
the National Capital Region. Established in 1924, the Commission seeks to preserve the unique
beauty of the city and its natural environment while at the same time encouraging orderly growth
and development. The Commission seeks to build on the Capital's unique design and planning
history. NCPC has three main missions:
Setting long-range policies and goals for future Federal development and playing an
important role in the historic preservation, environmental protection and economic
development of the National Capital;
Reviewing $5 to $8 billion in Federal construction investment for the National Capital
Region, including all federal public works projects, to ensure they conform with planning
policies; and
Reviewing every federal development project in the National Capital Region, including
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location and design of all federal buildings, museums, memorials and monuments proposed
in Washington, and reviewing all District of Columbia public projects and proposed
policies, plans and zoning actions. Projects are reviewed for compliance with the
Comprehensive Plan, as well as with federal environmental and historic preservation laws.
Through its missions, NCPC could provide greater overview of wet weather pollution prevention
and controls to prevent the further degradation and long-term improvement of the waterways.
Other agencies whose programs are providing or could provide assistance: NOAA, USFWS,
USDA-NRCS and Forest Service (cross connection: urban reforestation), HUD job training and
urban development, Smithsonian Institution/National Zoo.
Timeframe/Schedute:
Summer 1998- Include implementation of the Panel's recommendations in the revised Federal
Ecosystem Management Agreement for the Chesapeake Bay Program.
Fall 1998- Identify all pertinent Federal programs which can provide funding and technical
support.
Winter 1998/1999- Seek Federal agency agreement and develop an annex to the Federal Biennial
Work Plan, including wet weather pollution prevention and control assistance commitments
for both the Anacostia River and Rock Creek watersheds. Do this in cooperation with
AWRC.
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C.3 Convene a Federal workgroup to facilitate communication and
provide leadership.
To Whom Recommendation is Addressed:
Federal agencies that either manage lands or buildings in or provide regulatory guidance and
enforcement, technical expertise, and funding support to state and local environmental protection
and restoration efforts in either the Anacostia River and Rock Creek Watersheds (Maryland and
District of Columbia)
Geographic Focus: Anacostia River and Rock Creek Watersheds (Maryland and District of
Columbia)
Recommendation Summary: Federal agencies should form a Federal Wet Weather Workgroup
concerned with pollution prevention and control from both combined and separate storm sewers
to accomplish the following: (1) to coordinate and support the implementation of priority storm
water activities for the watersheds, (2) to facilitate communication among Federal agencies and
state, county, and District of Columbia agencies, (3) to provide leadership to Federal agencies,
regarding identification of legal requirements, guidance on storm water management planning, (4)
to provide expertise during the development of the comprehensive storm water management
plans, described above, (5) to assess both conventional and innovative sources of funding for
Federal agency initiatives, to assist individual agencies in obtaining resources for implementing
storm water management, and (6) to develop a strategy to brief agency, the White House, and
Congress on the need for a coordinated Federal interagency planning effort.
The scope of the workgroup's activity should be broad enough to encompass toxics and
contaminated sites associated with storm water pollution. Special attention should be given to the
"Low Impact Development" (LID) applications for Federal buildings and facilities. The
workgroup can be tracked through the updates of the Biennial Federal Workplan for the
Anacostia River Watershed (first issued in 1997).
Recommendation Strategy: A "workgroup" institution should be created to coordinate and
support the implementation of Federal actions and activities in the watersheds. The workgroup
could be formed under the Federal Agencies Committee (FAC) within the Chesapeake Bay
Program. The FAC members will be responsible for identifying key representatives for their
agencies. In addition, other Federal agencies that have a presence in the watersheds but not
specific members of the FAC will need to be included in the workgroup.
Membership would include representatives from applicable landholders, building owners and/or
operators, and agencies that provide regulatory guidance and enforcement, technical expertise,
and funding support to state and local environmental protection and restoration efforts within the
watersheds. In determining what agencies should be represented on the workgroup, all Federal
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lands and buildings in both the Anacostia and Rock Creek watersheds should be identified and
what Federal agency manages the property needs to be determined. As part of this process,
identify what lands and buildings drain to the combined sewer overflow area. Key departments
and agencies comprising the workgroup include the following, though this is not an exclusive list:
General Services Administration-National Capital Region, Architect of the Capital, Smithsonian
Institution, National Park Service, National Capital Planning Commission, U.S. Army Corps of
Engineers, Armed Forces Retirement Home, Department of Defense, Department of Agriculture,
U.S. Postal Service, Bureau of Printing and Engraving, Environmental Protection Agency, and
U.S. Geological Survey. Federal representatives should include facility and building managers
and budget and policy specialists, as applicable.
A main priority of the workgroup is to facilitate communication. There is an increasing need for
coordination and communication among Federal agencies and between Federal agencies and state,
county, and District of Columbia agencies. Through the workgroup, information, including
technical, budget, and project scope and status, could be exchanged between the interested
agencies. It is anticipated that a direct result of increasing the coordination and communication
will be an increased awareness of related activities and lead to partnering opportunities. The
Anacostia Watershed Restoration Committee should be one mechanism that will be used to
facilitate communication.
T
With EPA leadership, the workgroup should perform the specific task of identifying the legal
requirements which the Federal agencies are required to meet, both Federal, state, and local
compliance requirements including storm water permit requirements pretreatment requirements,
approval of sediment and erosion control plans and storm water management plans for new
construction.
The workgroup should provide expertise during the development of the comprehensive storm
water management plans. A more detailed description of the storm water management plans and
technical expertise that should be provided by the workgroup is described above. Also, the
workgroup should assess whether a new version of "Bayscaping" should be promoted, which
incorporates LID with the Chesapeake Bay Program's current Bayscaping guidance.
In addition to the guidance document, the workgroup would work with AWRC to organize an
"Urban Storm Water Technological Exposition" for the National Capital Region. The purpose
would be to educate Federal facility managers about cost-effective state-of-the-art in storm water
management techniques. If feasible, the exposition should be a public-private partnership.
The workgroup should pursue both conventional and innovative sources of funding for Federal
agency initiatives, to assist agencies in obtaining resources for implementing storm water
management. Exploring all funding opportunities for implementing the long-term priority actions
is critical. The workgroup should explore existing authorities and programs and make
recommendations for creating new authorities and programs. Note the possibility (presented in
Recommendation C.2) of collaborating with the Federal Steering Committee of the Clean Water
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Action Plan.
The importance of obtaining top agency support for the Federal contribution to the degradation of
the watershed is critical for the implementation of corrective action. As a result, the workgroup
should develop a strategy to brief agency heads, the White House, and Congress on the need of
implementing storm water controls throughout each watershed and have it be a coordinated
Federal interagency planning effort.
I
Timeframe/Schedule:
Fall 1998- Identify all regulatory requirements, USEPA as the lead.
Fall 1998- Identify Federal land and building owners and/or managers within the Rock Creek and
Anacostia watersheds.
Fall 1998- USEPA should send a letter to Federal agencies identified above, to assure that
existing regulatory requirements are fully understood.
Winter 1998/1999- The Federal workgroup, in cooperation with AWRC and FAC- Chesapeake
Bay Program, should identify critical Federal facilities and buildings for improved storm water
management. The workgroup should begin to provide assistance to these agencies while
developing the comprehensive storm water management plans.
FY 1999- FY12000- Explore traditional and innovative budget and authority opportunities to
implement'improved storm water management techniques.
Financial Considerations:
Participation of Federal agencies on this workgroup will be funded through internal mechanisms
of each agency. The Federal Agencies Committee staff within the Chesapeake Bay Program will
provide staff support to the workgroup. USEPA should contribute information from its Wet
Weather Research and other programs for identification of appropriate technologies, and seek
financial support and possible private partners for an "Exposition" to inform Federal agencies of
technical options.
Legal Authority/Regulatory Needs:
No additional authority needs have been identified.
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D. Educate and Involve the Public.
Foster Volunteerism and Community
Involvement.
s.
Background/Justification
Wet weather pollution is "everyone's business11 and so is its prevention and control. An educated
and involved watershed community is one of the most important resources needed to prevent and
control wet weather pollution. The collective impact of individuals who live, work, and play
within a watershed can significantly affect the quality and quantity of wet weather runoff.
Education can increase the public's awareness of the positive and negative impacts associated
with their actions, and inspire community involvement and foster volunteerism. A successful
watershed approach to wet weather pollution prevention and control depends on the support and
involvement of an informed community.
Within the Anacostia River and Rock Creek watersheds, individual decisions are a large
contributing factor to current wet weather pollution problems. For example, the choice to throw
trash into a public trash can or on the ground makes a difference. Between 1992 and 1998, the
District removed approximately 2,625 tons of trash and 20,000 tires from the Anacostia River.
Not all activities have such obvious impacts on the Anacostia River or Rock Creek.
Transportation contributes to wet weather pollution by producing air emissions that eventually
end up in the water as atmospheric deposition. Irresponsible pet owners increase the level of fecal
bacteria that drains into the sewer system. Through better decision-making, individuals have an
opportunity to become part of the solution.
Numerous opportunities exist to increase awareness and involvement within the Anacostia River
and Rock Creek watersheds. As part of their Federal storm water permit requirements, the
District, Prince George's and Montgomery counties must develop a public participation program
that will inform residents about the sources of wet weather pollution. These programs must also
provide a mechanism for community members to become involved in storm water management.
The District Water and Sewer Authority must develop a similar program through its CSO Long
Term Control Planning process. Watershed-based environmental organizations, such as the
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Alliance for the Chesapeake Bay and the Anacostia Watershed Society; conservation
organizations such as Audubon Naturalist Society and the Maryland Native Plant Society; and
many local and sub-watershed organizations in the D.C. Metropolitan area, voluntarily lead
initiatives to keep community members informed and involved. They publish newsletters, develop
educational curricula, sponsor educational programs, lead field trips, coordinate volunteer
monitoring, and much more.
Given the numerous ongoing education and participation efforts within the District and Maryland,
there is a need for coordination among these various organizations and activities. It is difficult to
say how often organizations "reinvent the wheel" when another organization's programs or
materials already address a particular topic or audience. Without coordination, overlaps in
information are likely to occur, as well as gaps. Organizations need to ensure that all watershed
issues, including wet weather, are addressed. In addition to addressing a wide range of issues,
programs and materials need to target the diverse audiences within the watershed. To facilitate
this holistic approach, each organization needs to be aware of what other organizations are doing.
Ultimately, this information needs to reach watershed residents.
In addition to coordination, organizations within the Anacostia River and Rock Creek watersheds
need to identify opportunities for partnerships in education and volunteerism. Other cities have
taken advantage of a range of skills and interests within the watershed to address the issue of wet
weather pollution. For example, Louisville and Jefferson County, Kentucky, developed a wet
weather educational program that coordinated the efforts of high school students, teacher and
university student volunteers, and city employees. A limited number of partnerships exist to
address wet weather pollution, including a collaborative effort between Howard University and
the District government, but more can be done.
Expected Benefits:
Education and volunteerism are two important mechanisms for achieving behavioral change,
which may ultimately lead to more responsible social actions. After a day participating in a trash
clean-up along the Anacostia River, an individual may be less likely to throw trash from a car
window. Learning about the negative impacts of cars on water quality may inspire someone to
ride their bike to work. Responsible actions prevent wet weather pollution. The ultimate benefit
of prevention is a decreased need for expensive control and restoration.
Additional benefits can accrue as a result of coordinated educational outreach and community
involvement. Many educational efforts and volunteer programs are funded through grants. Such
funding can be limited, difficult to obtain, and unreliable. Taking a watershed approach to
outreach and involvement integrates the efforts of many, resulting in an efficient and strategic use
of resources. The ultimate benefit of a coordinated approach is the ability for a watershed to
educate the various audiences within its boundaries on a broad range of issues related to
protection, restoration, and conservation.
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Related Actions:
Efforts to meet public participation requirements associated with D.C. WASA's CSO LTCP (ref.
Recommendation A.2) and other D.C. and Maryland programs should contribute to meeting the
public participation goals of this recommendation. D.C. WASA's LTCP and the D.C.
Government's storm water management plan (to be completed under its MS4 Federal permit)
could establish goals for volunteer efforts such as reduction of waste oil and trash, as well as
detection and removal of illicit connections to storm and combined sewers.
This recommendation also provides substance which should be considered for implementation by
AWRC as it implements Recommendation B.I. Federal agencies' public participation programs
should also offer support for this effort.
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D.I Research and create a comprehensive wet weather media advertising
campaign.
To Whom Recommendation is Addressed:
Anacostia Watershed Restoration Committee
Interstate Commission on the Potomac River Basin
District of Columbia Government, including D.C. WASA
Montgomery County
Prince George's County
Geographic Focus: Anacostia River and Rock Creek Watersheds
Recommendation Summary: Conduct a public survey to accomplish the following: assess
public understanding and perception of wet weather problems; gain baseline information on
current behavior in addressing wet weather pollution; and determine citizen willingness to adopt
new ideas and practices to control wet weather pollution. Using the survey results, craft a media
advertising campaign. This campaign will provide watershed residents, businesses and tourists
simple, but informative, messages on how to reduce their contributions to wet weather pollution.
Recommendation Strategy: A watershed-wide multi-media advertising campaign would be a
large-scale effort to spread the word about water pollution and conservation. The educational
messages provided through this campaign should be tailored to three audience groups: 1)
residents, including property owners and water and sewer rate payers; 2) businesses; and 3)
tourists. Campaign strategy and content would be determined through a baseline measurement of
wet weather awareness within the watershed. This baseline measurement of awareness would
also assist in determining which communication tools (e.g. radio, television, print, computer-
based) would be most effective.
A key goal of this campaign is to use the results to foster additional volunteerism and citizen
involvement for household activities like low impact landscaping, rain gardens, rain barrels,
downspout disconnection and pollution prevention. The activities described below are
components of the campaign research and design process.
Conduct a Baseline Survey of Wet Weather Awareness.
Assemble existing public survey information and identify current surveying activities. Use these
as a basis to develop additional survey questions that will fill gaps and identify important types of
information e.g. questions that will identify early adopters; questions that will identify baseline
behavior. Use a variety of survey techniques (e.g. phone interviews, focus groups and others) to
address current knowledge about water pollution and conservation and determine what activities
consumers would undertake to prevent further pollution.
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Assess Compatibility of Existing Outreach with Survey Results.
AWRC should coordinate existing public outreach efforts among D.C. and Maryland agencies,
and with Federal agencies (i.e. through cooperation with the Federal Wet Weather Workgroup) to
ensure that their efforts are not only integrated, but also compatible with the results of the survey.
Use the public education and outreach initiatives clearinghouse described in B. 1 as a starting point
for assessing the compatibility of existing efforts with survey results. AWRC can suggest various
modifications to existing education and outreach materials/programs that would address survey
results.
Design and Implement a Tailored Media Advertising Campaign.
The information collected through the survey will determine how the media advertising campaign
is designed and implemented. The advertising campaign may consist of an overarching theme or
slogan, possibly using a character that would be recognized as a symbol of wet weather
awareness. The campaign slogan would tie together ads and public service announcements on
various wet weather related topics, such as pet waste, dumping in storm drains, and trash. A
variety of media could be used to communicate these public service announcements. It is
important to identify and seek out similar programs that have been done elsewhere in the
watershed(s) and/or nationally to build on and use the appropriate aspects of these campaigns.
Timeframe/Schedule:
AWRC should organize a planning team to discuss the scope of this activity further in Winter
1998/1999.
Financial Considerations:
A comprehensive campaign can cost as much as $300,000.
Sources of funding to be addressed by the planning team include: WASA funding to
complete the public participation plan component of the CSO LTCP; funding
. opportunities associated with the development of the D.C. municiple NPDES storm water
permit; Anacostia Business Coalition; Public Relations Society of America (National
Capita] Region); local public television stations.
Legal Authority/Regulatory Needs:
* Applicable requirements of the Clean Water Act
No legal/regulatory needs identified.
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D.2 Develop a comprehensive approach to increase and enhance
volunteerism.
To Whom Recommendation is Addressed:
Anacostia Watershed Restoration Committee
Existing volunteer groups
Geographic Focus: Anacostia and Rock Creek Watersheds
Recommendation Summary: Build upon the strengthened role of the AWRC and existing
efforts of volunteer groups within the Anacostia and Rock Creek watersheds to increase and
enhance volunteerism. The approach should include identification and cataloguing of existing
volunteer groups and activities; coordination of a group dedicated to promoting volunteerism
while conducting education and outreach; development of education and outreach materials
targeted to various audiences; and creation of a central repository of outreach materials.
Recommendation Strategy: Through its strengthened role, proposed in Recommendation B. 1,
the AWRC should serve as the coordinating body to develop a comprehensive approach for
increasing and enhancing volunteerism. The actions described below will facilitate the
development of a comprehensive approach.
Determine the Range of Volunteer Activities.
Many volunteer opportunities exist within the Anacostia River and Rock Creek watersheds. To
focus the realm of activities, AWRC should determine what types of volunteer activities should be
promoted to residents within and around the watersheds. Survey results discussed in
Recommendation D.I could assist in determining which activities would be of most interest, or
best educate, residents. The range of activities could include water quality monitoring, trash
collection, teaching environmental education courses, and storm drain stenciling.
Identify and Catalogue Existing Volunteer Groups and Current Activities.
Using the list, AWRC should then identify local volunteer groups that sponsor these types of
activities. As AWRC identifies these groups, they should also devise a system (i.e., a database)
that will catalogue the groups and their activities. The cataloguing system could include the
following information: name of the group; location within the Anacostia River or Rock Creek
watersheds; characteristics of membership (e.g. youth, families, binding enthusiasts, political
activists, etc.); current activities; point of contact information for each activity; educational
materials available through the group (e.g. brochures, newsletters, posters, educational curricula,
etc.); funding sources; and partnerships with other volunteer groups and/or agencies (e.g.
USEPA, local businesses, local charitable foundations, etc.).
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Create a Corq Education and Volunteerism Team.
Maintenance of the cataloguing system, as well as other activities, will require a dedicated group
of people and/or organizations. AWRC's Wet Weather Speakers Bureau, discussed in
Recommendation B. 1, may initially take on this role until a core education and volunteerism team
is selected. The core team will need to take on the following activities: 1) provide outreach and
education to watershed residents; 2) promote volunteerism by advertising opportunities, in
coordination with the advertising campaign discussed in Recommendation D.I; and 3) update and
tailor existing educational materials based on survey results from Recommendation D. 1.
Develop Targeted Educational Materials.
The development of presentations appropriate to different audiences (e.g. homeowners, business
owners, decision makers, and tourists) is included in Recommendation B.I as a function of the
AWRC's Wet Weather Speakers Bureau. This activity will eventually become the responsibility
of the core education and volunteerism team. Educational and outreach materials should stress
the variety of benefits that can be achieved by increased water pollution control and conservation.
Materials targeted to decision makers should involve them in public participation processes and
build public support.
Create a Central Clearinghouse of Outreach Materials.
Based on the cataloguing system, develop a central repository of outreach materials. This
repository should link to the AWRC's centralized information clearinghouse discussed in
Recommendation B.I. This information will be available on the AWRC home page and will
provide links to the Chesapeake Bay Program page. For those without Internet access, there
should be a dedicated telephone number where questions and requests for information can be left.
Note: This is a low-cost effort with multiple benefits. According to other cities -with a similar
educational program, help in identifying areas for downspout disconnection efforts
significantly reduced inflow into the system. In addition, students can supplement an over-
burdened inspection and operations and management staff by identifying key areas for action.
Students also are able to enhance their learning by taking classroom learning into a "hands-
on" environment
Timeframe/Schedule:
Planning for this low-cost, and potentially cost-saving initiative should be initiated by AWRC in
Fall/Winter 1998.
Financial Considerations: to be determined by the planning process.
Legal Authority/Regulatory Needs: no needs identified.
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D.3 Create and implement a student wet weather discovery program.
To Whom Recommendation is Addressed:
District of Columbia Government, including D.C. WASA
Local TV news station weather forecasters
District and Maryland public school systems
District and Maryland universities
Washington Suburban Sanitation Commission (WSSC)
Chesapeake Bay Foundation
Anacostia Watershed Society and other non-profit organizations
Montgomery and Prince George's Counties
Geographic Focus: Anacostia River and Rock Creek Watersheds
Recommendation Summary: This recommendation encourages community involvement in
addressing wet weather pollution problems through increasing the awareness of students within
the watershed. Through a partnership among schools and local radio and television stations,
students would have the opportunity to investigate wet weather problems within their
neighborhoods and report their findings through a collaborative project.
Recommendation Strategy: The strategy focuses on the perceived need for the District of
Columbia to strengthen significantly its environmental awareness programs. There are existing,
and excellent, programs in certain Maryland suburban school districts; these should receive
continuing support where they exist and be extended to other school districts as needed.
Create a Student Wet Weather Discovery Program.
Such a program would allow students, ranging from grades K-12, to become wet weather "watch
dogs" as part of their environmental science learning experience. This program could also be
extended as a summer internship or summer school experience. The program will build on existing
efforts, and be initiated in cooperation with District schools and local TV stations. As a first step
it is important to approach local TV weather forecasters to seek input on how best to develop and
implement a wide ranging program involving students. Secondly, adult volunteers should be
trained to work with students through this program. Partnering with local universities may
provide a channel for program volunteers.
Through this program, students will learn about wet weather and their watershed, including
impacts associated with combined sewer overflows, sanitary sewer overflows, and storm water
runoff. Working with the trained adult volunteers, students could survey neighborhoods with the
intent to achieve the following goals:
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Identify and survey outfall locations;
Help track need for operation and maintenance activities;
Identify locations where downspouts are connected to the sewer systems; and
* Identify areas where illegal dumping is occurring.
Information collected through the program .could be tracked and managed by the schools and
shared with the District of Columbia Departments of Health and Public Works and D.C. WASA.
At the end of the investigative portion of the program, students will design and develop a project
to present the information they have collected. The program could seek to create partnerships
with local radio broadcasters and television networks involved in the public education and
outreach campaign. Through these partnerships, students could receive sponsorships and
technical assistance to design and implement their wet weather projects. Student, projects could
include developing a brief wet weather documentary to be aired on a local television access
channel; capturing images of wet weather pollution for use in television and printed public service
announcements; preparing articles on wet weather related issues for publication in local
newspapers; and creating public awareness exhibits that could travel around the watershed for
display at local events (e.g. Earth Day activities in Anacostia Park).
A second way to involve students is through science fair projects. Using expertise from the panel,
a list of potential projects appropriate to meeting panel objectives should be developed and
distributed. These topics could provide the basis for science fair projects and environmental or
science club activities. Consider evaluating the District's Environmentors program as a model for
how this collaborative effort could work.
University students involved in the Student Wet Weather Discovery Program as volunteers could
also use the information collected through the program for master's projects or a thesis. Local
universities within the District are currently working with the District government to conduct wet
weather projects. Building on existing partnerships between the District government and local
universities, and cooperating with comparable Maryland efforts, could provide additional research
and data collection through this program.
Take advantage of the double benefits of student activities
This is a low cost effort with multiple benefits. A good deal of field investigation and "detective"
work is required to implement effective wet weather pollution prevention and control programs.
Local government agencies have staff constraints and must target field actions carefully. Students
can supplement over-burdened inspection and operations and management staff by identifying key
areas for action, and conducting follow-up communication in neighborhoods. Students also are
able to enhance their learning by taking classroom learning into a "hands-on" environment.
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Timeframe/Schedule:
Exploratory assessment in the District of Columbia should begin in Fall 1998, in order to
determine how such a program might fit into pollution prevention objectives associated with D.C.
WAS A's LTCP (Recommendation A.2) and the District's storm water management program
under the Federal MS4 permit (Recommendation A.3). Possible initiation of the program in
school year beginning September 1999.
Financial Considerations: To be determined, based on experience in other jurisdictions.
In addition to local funding, support may be available from EPA Office of Research and
Development grant program for university research and local charitable foundations.
Legal Authority/Regulatory Needs: Should be implementable within existing authorities.
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D.4 Evaluate practicality of conducting homeowner water management
model programs.
To Whom Recommendation is Addressed:
D.C. Water and Sewer Authority
D.C. Department of Health, Environmental Health Administration
D.C. Department of Public Works
Montgomery and Prince George's Counties
Anacostia Watershed Restoration Committee
Volunteer groups
Landscaping contractors
Building contractors
Geographic Focus: Anacostia River and Rock Creek Watersheds
Recommendation Summary: Options for homeowners to reduce runoff into combined and
storm sewers (e.g. landscaping techniques, downspout disconnections, rain gardens and rain
barrels) should be evaluated, to determine the practicality of implementing homeowner water
management model programs. Based on the practicality evaluation, implement model programs
and use the results to conduct homeowner education and outreach.
Recommendation Strategy: Regional agencies, local governments and community-based
organizations around the country promote and implement homeowner programs to reduce runoff
into storm sewers. Many of these programs could be adapted for residents in the Anacostia River
and Rock Creek watersheds. The activities described below are components of the research,
design, and implementation of homeowner water management model programs.
Review Existing Materials.
To determine what options may succeed in these watersheds, the District and Maryland should
review existing materials on various homeowner storm water programs. Materials should include
effectiveness studies conducted by regional agencies and case studies from other cities. The
review should produce a list of possible homeowner activities, such as landscaping techniques,
rain gardens, and downspout disconnection, to be further evaluated.
Develop and Implement an Evaluation Strategy.
Develop an evaluation strategy to determine if the each activity on the list would be practical to
implement. During the evaluation, investigate the following considerations:
» What is the extent of the problem and the potential program costs;
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1200 Pennsylvania Avenue NW
Washington DC 20460
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What are the associated potential reductions in water quantity;
What are other environmental and cost benefits associated with this type of public
education and involvement program; and
* What is the legality of implementing such a program given existing codes and ordinances.
The evaluation strategy should then be implemented to determine which homeowner storm water
activities could be used in a model program. The survey discussed in Recommendation D.I will
provide additional insight as to what activities residents .within the Anacostia River and Rock
Creek watersheds may be willing to undertake. This is also an important consideration when
determining the practicality of conducting a homeowner program.
Create and ImplerngjrtaJSp"ieowner Water Management Model Program.
Use information from other cities and regions to help design and implement homeowner water
management model programs. The programs could target various neighborhoods within each
watershed and focus on the use of a different water management activity. The model programs
should contain an education and outreach component that instructs residents how to properly
participate in an activity, and provides information on the environmental and economic benefits of
the activity.
Use Results in Education and Outreach Campaign.
Upon completion of the model programs, the results should be incorporated into a wide reaching
education and outreach campaign that targets homeowners throughout the watersheds. The
campaign should be designed using the results of the public survey in Recommendation D. 1, as
well as the model programs.
Timeframe/Schedule:
Carry out this evaluation in conjunction with preparation of D.C. WASA's CSO LTCP
(Recommendation A.2) and of the District's storm water management plan
(Recommendation A.3).
During FY 1999, Montgomery and Prince George's Counties should also evaluate
coverage and sufficiency of their homeowner-directed guidance.
Financial Considerations:
Funding for D.C. WASA's LTCP, including $7+ million USEPA grant, and District
funding of its storm water management plan development.
Legal Authority/Regulatory Needs: to be determined.
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£. Enhance Decision-Making Through Better
Monitoring, Data Collection, and Information
Management.
Background/Justification
Effective wet weather pollution prevention and control depends on accessible, reliable, accurate,
comprehensive, and up-to-date information. Quality information is essential to effective program
planning, responsible policy development, and informed comment. The identification of water
quality problems, the prioritization of solutions, and the tracking of progress also depend on good
information management.
Many agencies in the Washington region collect, store, and analyze water quality data for the
Potomac River and its tributaries. Under the current information management framework,
environmental data are maintained in different locations, by different people, using different
approaches - it is often a time-consuming and frustrating challenge to identify, obtain, and
integrate these data. The value of this information has been enhanced by its concentration in a
centralized database, but this is only a first step.
The Metropolitan Washington Council of Governments (COG) serves as the coordinator for the
Potomac Regional Monitoring Program. Since 1982, COG has compiled water quality data on
the Potomac River and its tributaries for storage in the Regional Potomac Database. The
compilation of Anacostia River data into the Regional Anacostia Database began in 1985.
Over the years, COG has worked with its partners to continually improve this effort. In 1992, the
Regional Monitoring Subcommittee (RMS) was formed to coordinate the monitoring and data
management activities. All the available information has been merged into an Oracle database
management system. Eleven Federal, State, and local agencies participate in this cooperative
program. The number of monitoring sites has grown to more than 200.
There is a clear need for a comprehensive watershed information system for the Anacostia and
Rock Creek watersheds. While COG's regional database can provide the nucleus for this system,
an evaluation of needs should precede any system development. The needs of all stakeholders,
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from community-based organizations to research institutions to governmental agencies should be
systematically assessed before proceeding. The anticipated result will be a comprehensive system
that provides for coordinated monitoring and for effective information management. It will
provide much needed support for public outreach and watershed planning and management.
Expected Benefits
All stakeholders will benefit from this system. Community-based and environmental organizations
will have ready access to the condition of their local streams and other water bodies they depend
on as an integral part of their quality of life. Agencies responsible for environmental stewardship
will be better able to identify water quality and habitat problems, define solutions, and track
progress. By designing an integrated system, it can make the most efficient use of staff,
monitoring equipment, and computer resources.
Related Actions
An effective water quality information management system is a common theread through most of
the other recommendations. Those that involve key decisions need good information to ensure
informed decisions and effective outcomes. Recommendation A, Strengthen Current Wet
Weather Controls and Planning in the District of Columbia, depends on good information to
support cost-effective solutions. Good information is essential to Recommendation B.3, requiring
an integrated watershed assessment for the Anacostia River and its tributaries. The Federal
agency actions envisioned in Recommendation C depend on good information. High quality,
readily accessible water quality information is indispensable to those aspects of Recommendation
D aimed at educating and involving the public.
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£.1 Develop a Comprehensive Integrated Watershed Information
Management System.
To Whom Recommendation Is Addressed:
Anacostia Watershed Restoration Committee
Citizen Monitoring Programs
D.C. Department of Health, Environmental Health Administration
B.C. Department of Public Works
D.C. Water and Sewer Authority
Federal Agencies
Interstate Commission on the Potomac River Basin
Maryland Department of Environment
Metropolitan Washington Council of Governments
Montgomery County Department of Environmental Protection
Prince George's County Department of Environmental Resources
Geographic Focus: Anacostia River and Rock Creek Watersheds
Recommendation Summary: A collaborative integrated watershed information management
system for the Anacostia River and Rock Creek watersheds should be developed, drawing on
both governmental and community-based resources. The long-term vision is for a Web-based
application that can access and integrate geographically-distributed data. To encourage and
facilitate wide-ranging user access, an easy-to-use graphical user interface (GUI) will be an
integral part of the system. Interim milestones will provide early access to information that can be
made readily available.
Recommendation Strategy: Initially, this will focus on the Anacostia River watershed.
Ultimately it will be expanded to include the Rock Creek watershed. The AWRC will serve as the
initial oversight and coordinating body for this project, supplemented by its Rock Creek
counterpart as appropriate. (See Recommendations B. 1 and B.2, Strengthen the role of the
Anacostia Watershed Restoration Committee and Create a Rock Creek Watershed Coordination
Committee).
The existing regional water quality database, maintained by COG, will serve as the nucleus of this
project. Some key components of this system, including a regional GIS capability, already exist
and will provide an integral part of the recommended system. This will facilitate system design
and implementation.
The near-term system will be designed to support completion of several upcoming environmental
analyses (e.g., TMDL development, integrated watershed assessments). It will also be designed
to facilitate evolution to the long-term vision.
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The long-term vision for the system is a World Wide Web-based application that enables access to
and integration of watershed data that are distributed geographically (e.g., locally at each data
collecting agency) and linked using Web-based GIS and other querying tools. The system will be
designed to provide direct access to data bases that are being maintained on an ongoing schedule
by all participating data gathering organizations.
Some of the key activities involved in this project are outlined in Boxes E. 1-1 and E. 1-2. The
technical team responsible for implementation will develop a detailed work plan outlining the
specific approach. Box £.1-1 includes the steps to define both the long-term vision and the near-
term implementation steps.
Box E.l-1. Near-Term Implementation Activities
1. Identify user needs and functional requirements. Survey watershed partners and all
stakeholders, from the general public to technical organizations, to provide the foundation for the
system.
2. Evaluate existing information management resources: The integrated information management
system will build on existing efforts. This evaluation will identify, review, and document existing
sources and managers of watershed data, current management approaches, and hardware/software
preferences.
3. Implement a prototype system using readily available information. Information that is readily
available, i.e., can be used with a minimal amount of reformatting and other manipulations, will be
incorporated in a prototype system as quickly as possible. Information, which should be in a
format compatible with popular GIS software, can include local, state, Federal, and other sources
so long as they meet pre-determined quality assurance criteria.
4. Develop World Wide Web application that will enable data access, online data querying, and
geographic analyses, including a user-friendly graphical user interface (GUI). From its
earliest stages, the system will be web-based. The GUI will provide access to the data and enable
users to perform a wide-range of queries. While initially the GUI may not have the full
functionality to be found in the long-term system, it will be designed to have a consistent look and
feel as the system develops. A wide-range of stakeholders will be involved in reviewing the system
as it is develops to ensure it meets the range of needs identified in the user needs and functional
requirements analysis.
In planning for the system, strong consideration should be given to adopting the approach being
advocated by EPA's Chesapeake Bay Program (CBP) and outlined in the Strategy for Increasing
Basin-Wide Public Access to Chesapeake Bay Information (1996) of which the District of
Columbia, federal agencies, and Maryland were signatories. Many tools and guidelines are being
developed to implement the Strategy and will facilitate these data integration efforts by providing
detailed guidance on how to report data (i.e., data dictionary), document data (i.e., metadata), and
establish an effective integrated data server.
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Box E.I-2 identifies some of data management tasks necessary to develop the comprehensive,
Web-based, distributed information management system.
Boi E.l-2. Key Data Management Implementation Activities
1. Develop data standards. All data managers in the Anacostia and Rock Creek watersheds should
work together to develop a common data dictionary. By clearly defining the way data elements
should be reported, a data dictionary helps to ensure consistent reporting, nomenclature, and
definitions among disparate data providers.
2. Develop metadata standards and recommend/distribute metadata entry tool. Clearly
maintained metadata provides the foundation for an effective distributed information network. It is
crucial to develop metadata standards and tools to implement consistent metadata reporting.
Consider adopting the Chesapeake Bay Program's Metadata Reporting Guidelines and metadata
entry tool. Implement immediately for all new data and developed a phased approach for updating
existing data.
3. Prepare data base design, data transfer, and QA/QC protocols. Work to develop consistent
approaches among all data managers to facilitate implementation of a distributed network.
Identify and Prioritize Data Needed to Support Brqadly-based Watershed Management Decision-
Making and Publjc Qutreach Objectives
A hierarchy of data needs will be defined to effectively address key watershed management and
public outreach objectives. There are two main information categories containing multiple data
types:
(1) Those needed to understand and prioritize pollution sources; and
(2) Those needed to identify and prioritize opportunities to prevent and/or control sources of
pollution that are critical to effectively addressing wet weather pollution.
Within these, a hierarchy will be defined to ensure the necessary data exists to make informed
policies and management decisions. Over time, additional objectives may be defined to expand
the hierarchy and refine the data requirements. This aspect of the program complements the user
needs and functional requirements task identified above. It will provide information on immediate
additional data requirements and sets the stage for future system enhancements. Box E.l-3 is
illustrative of the information hierarchy that is envisioned.
When added to the outcome of the user needs task, this will provide a comprehensive list of data
and information to be included in the watershed information management system. A broad
stakeholder group will be used to develop the hierarchy of data needs. Once this hierarchy is
established, the technical implementation team will acquire and review the most essential data
sets, write or update the accompanying metadata files, and prioritize them for incorporation or
linkage to the system. This process will also be used to identify incomplete data sets and those
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that need to be created and/or converted to GIS coverages.
Box E.l-3. Priority Information Categories (Preliminary)
Understanding and priofjtjzinp sources of degraded water quality
- Location, nature, and extent of water and related environmental degradation (physical,
chemical, and biological) in Rock Creek and Anacostia River watersheds
- Monitoring data representing a watershed-wide understanding of water quality degradation,
including:
-r Key contributors of trash and debris
Areas contributing high levels of storm water-induced degradation
Location and monitoring data of permitted dischargers (e.g., industrial dischargers, CSO
outfalls)
Information supporting and building on the recommendations of the Anacostia River
toxics management plan to characterize the extent of toxics problems in the Anacostia
Identifying and prioritizing opportunities to prevent and/or control sources of pollution
- Effectively manage available land resources to enhance water quality (see Recommendation
£.2 for more information)
Environmentally significant and/or sensitive areas for restoration and protection
Additional storm water controls and retrofit opportunities in existing and redevelopment
areas
Opportunities to implement innovative approaches and site standards for new
development
- Evaluate and target sediment control priorities for the following areas:
Construction sites
Storm water pond maintenance
Location of stream bank erosion
Opportunities for new technology
- Focus operation and maintenance activities (e.g., street sweeping, catch basin cleaning,
outfall inspections, public education and outreach) on locations causing the greatest wet
weather pollution problems
- Building on prior work by AWRC members, develop list of mitigation projects and list of
opportunities for mitigation within the Anacostia River and Rock Creek basins. This list of
projects should be based on addressing the highest priority problems areas first
Timeframe/schedule:
AWRC should initiate an interagency planning process early in FY 1999, in coordination with the
Federal workgroup (ref. Recommendation C.3).
Financial Considerations: to be determined.
Legal Authority/Regulatory Needs: implementable within existing authorities.
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E.2 Effectively Manage Available Land Resources to Enhance Water
Quality.
To Whom Recommendation Is Addressed:
District of Columbia Government, including planning and zoning authorities
National Capital Planning Commission
Maryland National Capital Parks and Planning Commission
Montgomery and Prince George's Counties
Geographic Focus: Anacostia River and Rock Creek Watersheds
Recommendation Summary: A coordinated land use planning evaluation should be conducted
among the District of Columbia and its adjacent Maryland Counties. Each jurisdiction (i.e.,
District of Columbia, Prince George's County, and Montgomery County) would conduct its own
evaluation, but would work in conjunction with the other jurisdictions to ensure that mutual goals
and objectives were identified and pursued. The Panel recommends that the District government
work with the District planning and zoning authorities, the National Capital Planning Commission,
the Federal workgroup (ref. Recommendation C.3) and other relevant organizations to evaluate
land use goals of the District's master plan and coordinate future land use planning efforts. A
parallel effort should occur in the adjacent Maryland Counties. The purpose of these evaluations
is to identify opportunities to use land resources and land use planning approaches to minimize
wet weather pollution and improve overall watershed protection.
Special emphasis should be placed on:
Identifying environmentally-sensitive and other undeveloped natural areas for preservation
and/or restoration
Identifying opportunities for retrofitting or placing additional storm water controls in
existing and redevelopment areas
.. Developing site standards for new development and redevelopment.
It is important that the District, Prince George's, and Montgomery Counties work together to
identify collaborative approaches that will cross jurisdictiona! lines and achieve mutual goals.
Recommendation Strategy: The lead planning agency in the District of Columbia, Montgomery I
County, and Prince George's County should each convene immediately a Task Force to conduct a
comprehensive evaluation of their jurisdiction's master plan and other land use planning efforts,
focusing on the three areas outlined below. These Task Forces should be balanced and
representative of stakeholders affected by, or affecting, land use planning decisions, including
local planning boards, NCPC, MNCPPC, local developers, City Council, Board of Supervisors,
environmental regulatory agencies and organizations, and other stakeholders, as appropriate.
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Each jurisdictional Task Force should appoint representatives to an Interjurisdictional Task Force
that will oversee and coordinate the land use planning evaluations. The Interjurisdictional Task
Force will work to identify mutual goals and objectives and seek to promote planning approaches
that are compatible between all of the jurisdictions.
Identify Environmentally Sensitive and Other Undeveloped Natural Areas for Preservation,
Protection. And/or Restoration.
Evaluate Master Plan
When evaluating the land use goals of each master plan, identify and expand components of the
plans that will preserve existing environmentally-sensitive and other undeveloped natural areas
that may be designated for development. Strive to:
Identify and protect environmentally sensitive areas (e.g., highly erosive soils, steep or
unstable slopes, stream valleys and flood plains, tidal and nontidal wetlands, riparian areas,
upland forest resources, wildlife corridors, and headwater areas);
Preserve the remaining natural features of the District and the Anacostia River and Rock
Creek watersheds of Montgomery and Prince George's Counties to contain storm water
while simultaneously using the same features to provide for the various needs of the
community (e.g., vegetative buffer zone which controls erosion and attenuates pollutants
can also act as passive sitting/walking paths); and
Identify opportunities to restore damaged areas along the water courses, including
conducting an assessment to determine if riparian areas may be restored along the
Anacostia River in locations now occupied by industries and/or shoreline engineering
structures.
Modify and/or Add Zoning Ordinances
Evaluating and updating the master plan and other land use planning efforts will be the starting
point to change existing zoning ordinances or to impose revised and/or new zoning ordinances
that are more protective of water quality and associated natural amenities. Options to consider
include: (1) protection areas; (2) impervious surface requirements; and (3) setbacks; (4) growth
management and regulations to control the location and type of development; among others. The
jurisdictions may want to consider creating a new zoning designation (or strengthen existing
designations) to protect sensitive areas and encourage restoration in key locations. The
jurisdictions also should evaluate existing environmental ordinances to ensure they are compatible
with proposed changes to the master plan and/or zoning regulations.
The information obtained from this overall evaluation should be incorporated into a
comprehensive, integrated watershed information management system (Recommendation E.1) and
be used to evaluate the sufficiency of local erosion control and storm water management
programs. In particular, coordinate with Recommendation A.4, Strengthen the District's erosion
control and storm water regulatory program.
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Develop a Greenway Plan
After updating existing master plans, the jurisdictions should work in cooperation with regional
planning committees to develop a Greenway Plan for the District and adjoining watershed
jurisdictions. The Greenway Plan would identify targeted areas of contiguous open space,
adjacent to water bodies, that should be managed to enhance water quality, wildlife habitat and
human recreation. In addition to providing maps of existing and proposed Greenways and other
public open space, the Plan should include a prioritized set of Greenway management actions,
such as reforestation, park acquisition, trail development and maintenance, and signage
recommended for these areas. Once the Greenway Plan is approved, Greenway jurisdictions
would be required to incorporate these management actions into their master planning activities.
Identify Opportunities for Placing Additional, or Retrofitting Existing, Storm Water Controls in
Existing and Redevelopment Areas
The jurisdictions, especially the District of Columbia, should conduct a watershed-wide analysis
using GIS and "best-professional judgement" of publicly- and privately-owned open space1 that
may be suitable for storm water retrofit opportunities. Consider any opportunities, but place
emphasis on innovative, low impact approaches to storm water control (see Recommendations
A.3 and C. 1, Strengthen the District's storm water management program, in compliance with
Federal requirements and What Federal Agencies should do, respectively).
The first step in the analysis is to identify the locations of publicly* and privately-owned open
spaces that are located down gradient from urbanized land uses. This can be accomplished using
land use, topographic, and property ownership information, coupled with on-site inspections and
interviews with local residents and other "experts". Once these public- and private-open spaces
are identified, the next step is to determine if the upgradient urban land use is served adequately
by storm water best management practices (BMPs). This may be accomplished using GIS
information or general knowledge of age of existing developments. The resultant maps would
provide the basis for a decision-making process between federal, state and local land owners to
determine priority sites for storm water retrofits.
A further benefit of conducting a watershed-wide GIS analysis of publicly- and privately-owned
open space that may be suitable for storm water retrofit opportunities is that it presents an
opportunity to create incentives for retrofitting. For example, the District could approach
negligent landowners to clean up and use an abandoned site or the District would place a lien on it
for potential use as a storm water retrofit project (i.e., in conjunction with enforcement of "clean
it or lien it" requirements).
Publicly- and privately-owned land that is not actively used by people for recreation and is not occupied
by loads or other human-made structures, and does not quality as an environmentally-sensitive or natural area
slated for preservation/restoration. The prime example of open space in the context of this recommendation is
abandoned or vacant lots, and illegal dumping sites.
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Develop Site Standards. Including Land IJsejControls, for NewJJevelopment.
The individual Task Forces, working with the Interjurisdictional Task Force, also should evaluate
the abundance of emerging information on low impact, environmentally-sensitive development
and prepare site standards and guidelines for new development and redevelopment efforts in the
District. Building from existing information, such as recommendations outlined by the national
Site Planning Round Table in its model development principles and approaches used by Prince
George's and Montgomery Counties, the District's standards and guidelines should reflect the
most current and innovative thinking on approaches to minimize wet weather pollution. Prince
George's and Montgomery Counties also may update standards to reflect the latest thinking.
Timeframe/schedule:
Brief District and Maryland County officials in Fall 1998, with objective of obtaining
commitment to undertaking project by mid-1999.
USEPA should evaluate relationship to the District of Columbia's MS4 permit
requirements.
Financial Considerations: to be determined.
Task Force evaluations could be part of planning agency budgets.
Sources of grant support for further development of initiatives need to be assessed.
Legal Authority/Regulatory Needs:
Task Forces would identify new authority needs, if any.
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£.3 Develop a coordinated, strategic monitoring plan.
To Whom Recommendation Is Addressed:
Anacostia Watershed Restoration Committee
Citizen Monitoring Programs
B.C. Department of Health, Environmental Health Administration
D.C. Department of Public Works
D.C. Water and Sewer Authority
Federal Agencies Committee, Chesapeake Bay Program
Interstate Commission on the Potomac River Basin ,
Maryland Department of Environment
Metropolitan Washington Council of Governments
Montgomery County Department of Environmental Protection
Prince George's County Department of Environmental Resources
Geographic Focus: Anacostia River and Rock Creek Watersheds
Recommendation Summary: Many of the agencies involved in improving water quality
conditions in the Anacostia River and Rock Creek watersheds collect or at least make use of
monitoring information. Such information helps guide their programs and charts their progress.
While these agencies have coordinated many of their efforts, this has not been done on a
systematic basis, nor with an eye toward a comprehensive watershed approach. One of the key
recommendations of the Panel (Recommendation B.3, Conduct an Integrated Watershed
Assessment for the Anacostia River and tributaries') is for the preparation of an integrated
watershed assessment (IWA) for the Anacostia River and its tributaries. To accomplish the IWA
and to ensure that the District's programs to monitor and control water quality in the Anacostia
River are effective, they must be coordinated with Maryland-based monitoring and control
actions. Accordingly, there is a need to build on prior work to jointly evaluate and integrate the
District's and Maryland's respective approaches to monitoring. The ultimate goal is to develop a
comprehensive, watershed-based environmental monitoring program.
The following components comprise this recommendation:
Develop wet weather measures of progress based on existing vision and goal(s) statements
to serve as one basis for identifying key monitoring needs
Conduct a monitoring evaluation of existing monitoring programs and future monitoring
needs, to be done in coordination with the user needs assessment and the priority
information tasks described in Recommendation E. 1, Develop a comprehensive integrated
watershed information management system.
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Expand on prior work in Maryland and the District to define a watershed-based a
biological monitoring program, to provide reliable indicators of stream quality and an
approach for prioritizing areas for action.
Recommendation Strategy:
Develop jyet Weather Measures of Progress.
To measure progress in meeting water quality goals, an appropriate set of wet weather indicators
should be developed. This effort should be initiated in the Anacostia watershed, and expanded to
the Rock Creek basin as appropriate. Such indicators could be defined to track development and
land planning processes; pollution prevention activities; habitat restoration and conservation
efforts; status in implementing storm water and CSO regulatory requirements; surface water
quality; and community involvement.
Indicators can track progress in either programmatic activities (e.g., the number of storm water
permits issued to facilities in the watershed annually) or environmental health (e.g., annual
loadings of sediment or total amount of submerged aquatic vegetation). Ideally, indicators in each
category will be based on quantifiable data.
Indicators should reflect agreed-to goals, such as those embodied in the AWRC's Six Point
Action Plan to Restore the Anacostia River or the Chesapeake Bay Program's Bay Partner
Communities' benchmarks.
The key steps in developing the indicators is outlined in Box E.3-1.
Box E.3-1. Key Steps to Developing Watershed-Based Wet Weather Indicators
Define responsibilities with the AWRC as an oversight body.
Review and refine as needed goals and objectives, building from existing efforts.
Identify indicators that support the goals and objectives.
Identify data sets to support indicators.
Identify data gaps.
Define monitoring requirements.
Conduct a Monitoring Evaluation.
It is important to develop an integrated approach to monitoring that will meet a wide range of wet
weather and water quality assessment objectives. Working collaboratively, under the oversight of
appropriate members of the Regional Monitoring Committee, the local, state, federal, and other
entities involved with monitoring should conduct a thorough evaluation of existing monitoring
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programs. Some of the objectives of such an evaluation are identified in Box E.3-2.
Box £.3-2. Guiding Objectives for a Monitoring Evaluation
Identify existing and future monitoring needs
- requirements of the IWA (see recommendation B-3)
existing sources of data on watershed conditions
- potential areas of duplication, irrelevancy, and/or gaps
- opportunities to exchange existing NPDES end-of-pipe monitoring for watershed-wide
ambient monitoring, where appropriate
Determine if regulatory requirements are being fulfilled
Assess if IWA can be completed
Ensure the monitoring network provides a watershed-wide understanding
Improve operational linkages among the variety of monitoring programs
Improve the value and cost-effectiveness of monitoring efforts
Assess the performance of wet weather control measures (e.g., BMP effectiveness)
Explore opportunities to incorporate new monitoring technologies.
The overall goal should be to develop a comprehensive framework, building upon the existing
monitoring programs, for a watershed-wide, coordinated, and integrated monitoring program that
eliminates inefficiencies, fills gaps in the knowledge base, and provides information that will
target, support, and guide wet weather pollution control efforts and the larger goal of restoration
and protection. This effort should consider biological, chemical, and physical monitoring and
ensure that sufficient data are being collected to understand sources of pollution and receiving
water impacts; identify priority areas for action; and establish the efficacy of control and
prevention measures.
Evaluate Potential of Implementing a Biological Monitoring Program.
Biological monitoring information can provide indicators of water quality and environmental
health that are suitable for tracking, interpreting, and explaining to the general public and
decision-makers. Although the District currently collects extensive biological information, it does
not use these data as part of a consistent program to evaluate and report on stream water quality.
The District should assess the practicality of implementing a coordinated biological monitoring
program, using fish and benthic macroinvertebrates as key indicators, to evaluate stream
conditions, establish protection goals, and identify priority areas for action. The assessment.
should reflect both the needs of small streams wholly within the District and larger streams that
are partly in Maryland. Accordingly, the program should mesh with comparable programs in
Maryland.
Existing biological monitoring programs should be reviewed. The Montgomery County, County-
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wide Stream Protection Strategy could be a starting point for this evaluation. Ultimately, the
District should develop its own coordinated biological monitoring program, starting in the
Anacostia River watershed and expanding to Rock Creek.
Timeframe/schedule:
Establish process to conduct review in Winter 1998/1999, as part of USEPA grant
funding for D.C. and Maryland water quality programs.
Include on FY 1999 of Federal Agencies Committee, Chesapeake Bay Program.
Financial Considerations: to be determined.
* Implementation of this recommendation could occur within existing funding for
monitoring programs.
Legal Authority/Regulatory Needs:
Implementable within existing authorities.
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£.4 Create a watershed SSO inventory for the Anacostia River and Rock
Creek watersheds.
To Whom Recommendation is Addressed:
Anacostia Watershed Restoration Committee
D.C. Water and Sewer Authority
Washington Suburban Sanitary Commission
D.C. Department of Health,. Environmental Health Administration
Geographic Focus: Anacostia River and Rock Creek Watersheds
Recommendation Summary: Compile a sanitary sewer overflow (SSO) inventory for the
Anacostia River and Rock Creek watersheds that identifies exact locations of the overflows.
Draft a report on dry weather and wet weather overflows, and initiate a program to eliminate
SSOs.
Recommendation Strategy: WSSC, working cooperatively with D.C. WASA, should develop a
more vigorous program to identify the locations of SSOs within the Anacostia River and Rock
Creek watersheds with the goal of developing a comprehensive SSO inventory. The results of the
inventory should be incorporated into a geographic information system (CIS) that will allow
WSSC to track reports of SSO-related pollutants and identify possible sources withing the sewer
system. This inventory and CIS effort should be integrated with WASA's efforts to include the
location and documentation of CSO overflows (frequency, location, antecedent-rainfall
conditions).
As part of its efforts to develop a SSO inventory, WSSC should prepare a report on dry weather
and wet weather overflows to the Anacostia, including historical data. This report should include
information on the frequency and duration of power outages at pump stations.
After compiling the SSO inventory for the Anacostia River and Rock Creek watersheds, WSSC
should initiate a program to eliminate SSOs to fully comply with NPDES permit requirements.
WSSC also should develop and document a regular, ongoing inspection program that will help
identify maintenance needs.
Timeframe/Schedule: Immediate, building upon existing inventory efforts.
Financial Considerations: WSSC and D.C. WASA sources.
Legal Authority/Regulatory Needs: No additional authority needed.
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F. Pursue Pollution Prevention Through
Source Controls as a Key Part of the Solution.
BackgrpundUustification
Pollution prevention is the effort or ability to control pollution at its source before it becomes a
problem. Storm water becomes polluted as it travels over the land, picking up contaminants, such
as sediment, organic matter, trash and toxics. Therefore, preventing wet weather pollution
requires controlling sources of pollution on the land. In the Anacostia River and Rock Creek
watersheds, pollutants generate from a range of sources including Federal facilities, local
businesses, watershed residents, and tourists. Activities that generate pollutants include littering,
manufacturing, and transportation. Effective pollution prevention requires an understanding of
pollution sources and a proactive approach to reduce or abate pollutants at those sources.
The Anacostia River and Rock Creek watersheds are impacted by various wet weather pollutants.
Each year a very large volume of trash and debris is delivered to the Anacostia River and Rock
Creek from their tributaries and CSOs. This is an exceptionally significant problem in the
Anacostia River which receives the bulk of CSO discharges and has high contributions from
upstream reaches. Trash and debris are highly visible, significantly degrading the aesthetics and
useability of the river for local residents and others. Local government departments, Federal
facilities and environmental organizations within the District and Maryland attempt to address the
trash problem. Despite these efforts, trash removal from the Anacostia River is a constant battle
requiring further attention and resources.
There are other wet weather pollutants, most not as obvious as trash, that also require
preventative measures. The Anacostia River watershed contains thousands of businesses,
including commercial and industrial facilities and real estate development, that have the potential
to contribute sediments, trash and toxics via wet weather runoff. Highways and railways that
wind through both watersheds within the DC metropolitan area are heavily travelled. Numerous
wet weather problems can be associated with transportation, such as air emissions leading to
polluted atmospheric deposition, trash from road users, and toxic pollutant runoff (e.g., PAHs).
Although evidence exists that transportation-related pollutants affect water quality and sediments,
information regarding transportation impacts and remedial actions needs to be developed further.
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Controlling wet weather pollution related to combined sewer overflows and storm water is an
expensive and time-consuming endeavor. Approximately $35 million has gone into CSO capital
projects in the District of Columbia since the early 1980's. Another $7 million has been invested in
the Anacostia Floatable Debris Control program since 1992. These program expenditures will not
decrease until there is a reduction in the wet weather problem sources they target. The cost of
additional programs to control other pollutants, such as toxics, are not yet known because the
extent of the problem is not fully understood.
Expected Benefits:
Pollution prevention can generate multiple benefits throughout the Anacostia River and Rock
Creek watersheds. The primary benefits of pollution prevention are improved water quality for
less money. Significant cost savings will result from pollution prevention on alt levels, including
Federal, state, and local government, as well as businesses and households. Preventing pollution
will reduce the amount of resources needed to implement and comply with pollution control
programs. As rate-payers, households and businesses will benefit from these cost-savings, as well
as through installation of water conservation measures at the user end, including retrofit of low-
flow toilets and water-conserving shower fixtures.
Related Actions:
Pollution prevention studies and requirements need to be incorporated into D.C. WASA's LTCP
(Recommendation A.2) and the District's storm water management program (Recommendation
A.3), in order to meet Federal permit requirements. Prevention programs will also be enhanced
by public participation and volunteerism, as addressed in Recommendation D.
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F.I Conduct a "War on Trash".
To Whom the Recommendation Is Addressed:
AMTRAK, Conrail and CSX
Anacostia River Business Coalition &f°f)
Anacostia Watershed Restoration Committee, Trash work group
D.C. Business Improvement Districts
Citizen's groups, neighborhood associations, and similar organizations
D.C. Water and Sewer Authority
D.C. Department of Public Works
Local fast food restaurants and convenience stores
Local residents and commuters
Maryland Department of Environment
Maryland National Capital Parks and Planning Commission
Montgomery and Prince George's County agencies addressing trash and debris
National Park Service and other Federal Agencies
Geographic Focus: Anacostia River and Rock Creek Watersheds
Recommendation Summary: A very large volume of trash and debris are delivered to the
Anacostia River and Rock Creek each year from their tributaries, storm sewer overflows and
CSOs -this is an exceptionally significant problem in the Anacostia River which receives the bulk
of CSO discharges and has high contributions from upstream reaches. Trash and debris are one of
the Anacostia River's most obvious and challenging sources of impairment. It is a high visibility
problem that significantly degrades the aesthetics and useability of the river for local residents and
other users.
This recommendation promotes a targeted approach to trash control throughout the District of
Columbia, including Federal lands and facilities that are located in the Anacostia and Rock Creek
basins, placing priority on problems confronting the Anacostia River. The recommendation also
proposes actions, including pilot projects, for the Maryland Counties that are included in the
Anacostia watershed. The following elements comprise the complete "war on trash"
recommendation:
District of Columbia
- Identify and prioritize high volume trash sources
Employ a range of trash controls in high priority areas
- Foster volunteerism and community-wide initiatives to encourage citizen involvement
in trash and debris control
Solicit selected businesses to participate in the war on trash. Focus on fast food
establishments, convenience stores and grocery stores.
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Federal landowners, where applicable
- Increase the number of trash cans and recycling bins in high use areas
- Ensure trash cans and recycling bins are regularly serviced based on level of use to
ensure they do not overflow.
- Study the feasibility of expanding the use of recycling bins on federally owned public
land
Maryland - Prince George's and Montgomery Counties
- Identify tributaries that contribute high volumes of trash
- Pilot test solutions.
- Solicit selected businesses to participate in the war on trash. Focus on fast food
establishments, convenience stores and grocery stores.
- Continue to support existing efforts to foster volunteerism and community wide
initiatives
Recommendation Strategy:
District of Columbia
The District's Department of Public Works (DPW) is the lead agency addressing trash and debris
in the District, although the Federal land holders and agencies are responsible for their own lands,
buildings, and activities. The D.C. Water and Sewer Authority (D.C. WASA) also plays a role in
addressing trash and debris that flows into District waterbodies from the sewer systems.
Residents of the District are another major player and can contribute a significant role by
improving stewardship in their local environment.
and Prioritize Fpgfy Volume Trash Sources.
The District should identify and prioritize high volume trash sources and concentrate efforts in
those areas as needed to effectively address the problem. Developing a system that pinpoints
problem areas is especially important in order to provide the most cost-effective service.
DPW is currently developing a data base call "DPW-SERVES" that provides a starting
point for identifying locations where chronic sanitation problems occur. It should be
expanded to provide access for more individuals inside and outside of DPW, including
District residents.
DPW should coordinate with AWRC and COG efforts to identify sources of trash to the
Anacostia (e.g. geographic areas such as sub-basins, and land use types such as shopping
centers) and incorporate the results into DPW SERVES.
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DPW SERVES should be linked to a geographic information system to develop a "trash
targeting information system" for identifying high priority areas for action. DPW should
work with other agencies and organizations that collect information about trash (e.g. D.C.
WASA, COG, Anacostia Watershed Society) to ensure that the most up-to-date and
comprehensive information about trash is included in the data base and that efforts are not
duplicated.
Employ a Range of Trash Controls in High Priority Areas.
In areas of the city where trash is known to be a problem (either identified through the "trash
targeting information system" or through "best professional judgement") employ a range of
actions to reduce the impacts of trash. Some of these actions, especially increasing the number of
trash cans and recycling bins, should be pursued immediately to show short-term action. Specific
actions include:
Develop a citizen/business hotline where citizens can report through DPW SERVES on
sanitation violations. Develop a quick response approach for addressing problems and
ensure that the problems are incorporated into the DPW-SERVES system.
Increase the number of trash cans and recycling bins in commercial and other high use
areas. Strive for a long term goal of at least one trash receptacle at every bus stop.
Ensure that regularly scheduled servicing is conducted based on level of use. Collect and
remove trash on the same day that high use public events occur.
- Conduct a study to evaluate the feasibility of placing recycling bins in public locations
owned by the District
- Expand opportunities to partner with the business community to support DPW in trash
collection and removal efforts by having the business provide and maintain additional
trash receptacles and recycling bins nriar their location.
Reinstate city-wide residential recycling collection. In addition, DPW should expand its
outreach and education and enforcement efforts to local businesses to encourage
. recycling.
Provide opportunities to recycle and/or properly dispose of household hazardous wastes.
Identify and enforce existing regulations regarding trash, placing special emphasis on
illegal dumping. Also, conduct a general educational outreach campaign on littering and
its impacts to water quality. Inform citizens and businesses of their responsibilities using a
public outreach campaign, again implementing in a phased approach to target high priority
areas first.
- Catch basin stenciling to educate citizens about the harmrulness of dumping materials
into the sewer system
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Public education efforts on a range of pollution prevention topics such as
environmentally-friendly landscaping, and the importance of properly disposing of pet
litter.
The panel supports DPW's recent efforts to expand its sanitation inspection team to 29
inspectors and its efforts to team with the District Police Department to expand the
environmental crimes unit and crack down on illegal dumping.
DPW should target operation and maintenance activities such as street sweeping, catch
basin cleaning, enforcement, citizen outreach and education, and other efforts to areas that
contribute the most to wet weather pollution of the District's waters. When identifying
these areas, wet weather pollution to both combined sewers and separate storm sewers
should be considered. Some of the activities that should be considered include:
- Street sweeping (using mechanical means, supplemented with manual street sweepers
in the highest priority areas)
- Step up alley cleaning
- Evaluate the efficacy of reinstating the flushing program, evaluating the latest
techniques on vacuuming, sweeping, and flushing. Examine local models such as
the City of Alexandria's approach to vacuuming and flushing during dry weather.
DPW and WASA should work together to conduct this evaluation.
Leaf pickup, brush removal, and Christmas tree pickup
* Expand the use of business improvement districts beyond downtown and Dupont Circle
to other high source areas for trash throughout the city. DPW should work with existing
business improvement districts to accomplish two goals: (1) educate the business
improvement districts about how their efforts can help DPW initiatives (e.g., enlist them as
unofficial support staff to monitor for illegal dumping, overflowing receptacles; educate
residents about their responsibilities; and 'routinely collecting errant trash), and (2) develop
an approach to expand the scope and influence of business improvement districts, or
similar programs (e.g., teaming with civic groups, neighborhood volunteers), throughout
the District. Consider innovative ways to expand the business improvement district fleet
of workers at a low cost, such as teaming with homeless shelters, and other agencies/
organizations working with welfare recipients (e.g., as part of welfare to work program).
Foster Volunteerism and Community-Wide Initiatives.
Involve citizens and/or businesses in cleaning up their streets. Institute two programs:
- "Adopt a Street Program" that includes trash pick up, storm drain stenciling, catch
basin cleaning, and alerting the District government if operation and maintenance
activities need to occur. Use DPWs Helping Hand Program to promote and support
this program.
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- A neighborhood, block, or Ward clean up and award program. Some jurisdictions in
other areas have instituted "Tidy Neighborhood" contests with good success. Such a
program would provide guidelines for success (e.g., tree planting, street cleaning) and
opportunities for residents to obtain technical assistance and/or tools on loan from the
District government. This program would involve an annual judging and award. The
award could be recognition by local and regional newspapers and/or some sort of
financial incentives (e.g., small tax credit or cash award for participating residents).
DPW, working with neighborhood organizations and citizen groups, should develop a
program like this for the District. DP Ws Helping Hand Program could serve as a
starting point for this effort and would administrate and support this program.
Both of these efforts could build upon and learn from the pilot program called the Small Habitat
Improvement Program (SHIP) that was established in 1990 by the AWRC and piloted in Watts
Branch over a nine-month period. The goals of SHIP included restoring the Anacostia watershed
stream systems, educating citizens, and reclaiming streams for local neighborhoods. SHIP also
spawned an "Adopt-a-Neighborhood" program in Watts Branch that involved identifying the
geographic boundaries of the neighborhood, conducting storm drain stenciling, removing trash
and cleaning neighborhood streets, and planting trees as part of a riparian reforestation project.
Solicit selected businesses to participate in the war on trash. Focus on fast food
establishments, convenience stores and grocery stores. Engage these businesses in
supporting a public anti-litter campaign. Work cooperatively with these businesses to
implement voluntary waste minimization programs, including recycling efforts. Ensure the
businesses provide adequate trash receptacles and servicing (so that overflow conditions
are not reached).
Federal Landowner's Responsibilities
Adopt the recommendations presented for the District in the following areas, where applicable:
Increase the number of trash cans and recycling bins in high use areas.
Ensure trash cans and recycling bins are regularly serviced based on level of use to ensure
they do not overflow.
Study the feasibility of expanding the use of recycling bins on federally owned public land.
Initiate and enforce regulations to control pet waste.
Maryland Responsibilities
A significant volume of trash is delivered to the Anacostia River each year from upstream sources
outside of the jurisdictional boundaries of the District of Columbia. Although there is currently
debate on the volumes of trash entering the Anacostia River from the Maryland portions of the
watershed, there is agreement that these upstream reaches are a significant source of the problem.
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This recommendation is comprised of two pans designed to identify high priority sources of the
problems and pilot test solutions.
The first part of this recommendation calls for identifying a small working group comprised of
Maryland and District representatives to evaluate information concerning sources and volumes of
trash originating from Maryland tributaries. This working group could be formed from the
already existing MWCOG AWRC trash workgroup, or developed to supplement these ongoing
efforts. This group would be charged with identifying, collecting, and evaluating information on
trash sources and prioritizing high priority areas for action in Maryland.
After identifying high priority areas, this working group would evaluate the suitability of installing
trash traps or other technologies in the upper part of the watershed to relieve downstream
loading. Different technologies should be tried - one in Prince George's County and the other in
Montgomery County as appropriate for local conditions. When developing these options, it is
essential that an operations and maintenance plan be developed and agreed upon by participating
entities. It is essential that these trash traps be inspected often (daily, weekly?) and that debris be
collected and disposed of on an as needed basis. Maintenance responsibility must be identified a
priori. It is possible that MDE or the county governments could partner with citizen's or
environmental groups to assist with the inspections.
Solicit selected businesses to participate in the war on trash. Focus on fast food
establishments, convenience stores and grocery stores.
Direct the Maryland National Capital Parks and Planning Commission to:
- Increase the number of trash cans and recycling bins in high use areas.
- Ensure trash cans and recycling bins are regularly serviced based on level of use to
ensure they do not overflow.
- Study the feasibility of expanding the use of recycling bins on MNCPPC owned public
land.
Initiate and enforce regulations to control pet waste.
Educate Maryland commuters using D.C. streets about the importance of reducing road
liner (Good Driver/Good Neighbor), and inform citizens about how this litter contributes
to pollution of District waters.
Timeframe/schedule:
Immediate assessment of needed improvements in the District's trash prevention and
control programs should be incorporated in the District's management improvement
efforts. "War on Trash" activities normally produce "double benefits" from metropolitan
area trash and sanitation programs.
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Include immediately in scope of evaluation for D.C. WAS A LTCP and District storm
water management plans.
* AWRC should incorporate inter-jurisdictional planning into its Trash work group program
in FY 1999.
Financial Considerations: to be determined.
Legal Authority/Regulatory Needs: to be assessed; existing authorities may be sufficient, with
increased enforcement.
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F.2 Conduct pollution prevention opportunity assessments within
Anacostia watershed businesses.
To Whom Recommendation is Addressed:
Anacostia Watershed Restoration Committee
Anacostia River Business Coalition
D.C. Department of Health, Environmental Health Administration
D.C. Water and Sewer Authority
Montgomery County Department of Environmental Protection
Prince George's County Department of Environmental Resources
Geographic Focus: Anacostia River Basin
Recommendation Summary: Identify businesses within the Anacostia River watershed that are
likely to contribute to wet weather pollution. Working with the Anacostia River Business
Coalition, conduct pollution prevention opportunity assessments at targeted businesses and
encourage businesses to implement strategies that evolve from the assessment.
Recommendation Strategy: Within the Anacostia watershed, there are thousands of businesses,
including commercial and industrial facilities and real estate development, that could potentially
contribute pollutants (e.g. sediments, toxics) to the Anacostia River. These pollutant loadings
may be reduced through pollution prevention activities, such as good housekeeping practices and
preventative maintenance. Pollution prevention opportunity assessments, an inspection of a
facility and its practices, would help identify where pollutant loadings may be reduced through the
use of pollution prevention activities.
The newly formed Anacostia River Business Coalition (ARBC) is working to achieve the goals of
the Anacostia Watershed Restoration Committee's Anacostia River Toxics Management Action
Plan. The ARBC intends to achieve these goals through the use of pollution prevention. To date,
the members of the ARBC include:
Washington Gas
Washington Metropolitan Area Transit Authority
Potomac Electric Power Company
The Washington Post
ST Services
Lucy Drayton's Amoco Stations
Waste Management Inc.
Parker's Exxon Station
The Greater Washington Board of Trade
District of Columbia Chamber of Commerce
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Given the ARBC's mission, and its relationship with the Anacostia Watershed Restoration
Committee, this organization would be a prime candidate for promoting wet weather pollution
prevention to businesses within the Anacostia watershed. This effort could begin with sponsoring
local business pollution prevention opportunity assessments, and encouraging local businesses to
participate.
To narrow the universe of facilities within the Anacostia watershed, the District government
would need to target and prioritize facilities most likely to contribute pollutants associated with
wet weather water quality impacts, such as sediment and oil and grease. Facility targeting could
be accomplished using industrial data bases (e.g., Dunn and Bradstreet's Facility and Company
Tracking System) and/or industrial storm water permit applicationsa Notice of Intent (NOI)
form-to identify facilities within specific industrial sectors (e.g., chemical manufacturing, auto
repair, industrial machinery and equipment, etc.). The location of these facilities, which is
available through industrial data bases and NOIs, could then be overlayed with water quality
impairment information using a GIS tool. These data layers would facilitate targeting and
prioritizing facilities for pollution prevention opportunity assessments.
Pollution prevention opportunity assessments systematically identify ways to reduce or eliminate
pollutants. The assessment may include review of a facility's operation and waste streams, and
specific locations within the facility (e.g. outdoor storage areas, delivery stations, equipment
storage facilities, etc.) that may contribute pollutant loadings. Through the assessment, a number
of options with the potential to minimize or eliminate pollutants are developed. Facilities then
have tangible, customized pollution prevention measures they can implement.
The actual assessments may be conducted by the District government, by trained members of the
Anacostia River Business Coalition, or by members of industry trade associations. In situations
where a trained entity is not available to conduct a pollution prevention opportunity assessment,
facility staff can be trained to conduct an assessment within their own business. Organizations
dedicated to pollution prevention, such as the Anacostia River Business Coalition, often host
pollution prevention workshops and may be willing to incorporate pollution prevention
opportunity assessment training.
In addition, providing facilities accessibility to pollution prevention opportunity assessments may
assist them in meeting their NPDES industrial storm water permit requirements. Under the
NPDES storm water permit regulations, industrial facilities within certain Standard Industrial
Classification (SIC) codes are required to obtain a storm water permit, which includes the
development of a storm water pollution prevention plan. These plans are often difficult for small
"mom and pop" facilities to develop and implement; therefore, assistance through a pollution
prevention opportunity assessment may lessen the burden and result in an effective pollution
prevention plan.
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Timeframe/Schedule:
Incorporate in FY 1999 programs.
Financial Considerations:
* Evaluation should be part of normal local environmental regulatory agency functions, and
supported in part by USEPA grant program funds.
D.C. WASA pretreatment program
Business assistance from Anacostia River Business Coalition and other organizations, with
possible grant support for special initiatives available from USEPA (competitive pollution
prevention grants)
Legal Authority/Regulatory Needs: to be assessed.
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F.3 Study origins of and better controls for transportation-related
contaminants in storm water runoff, and improve programs to
prevent these contaminants.
To Whom Recommendation is Addressed:
National Capital Regional Transportation Planning Board
in cooperation with:
Anacostia Watershed Restoration Committee
Metropolitan Washington Council of Governments
Chesapeake Bay Program, especially the Modeling and Air Subcommittees
D.C. Department of Public Works
Federal Highway Administration
Howard University
Metropolitan Washington Council of Governments
U.S. Environmental Protection Agency, Region III and Office of Mobile Sources
Geographic Focus: Anacostia River and Rock Creek Watersheds
Recommendation Summary: Considering evidence that transportation-related pollutants (e.g.
PAHs) are polluting Hickey Run and are contaminating Anacostia River sediments, as well as the
contribution of highway users to trash accumulation in water bodies, AWRC should work with
COG's transportation committee on a joint study of: (1) the role and contribution of
transportation (in general) and highways in wet weather pollution in D.C.'s portions of the
Anacostia River and Rock Creek, and tributary waters; (2) available information on cost-effective
best management practices and preventive measures; and (3) cost-effective options for prevention
and control of transportation-related storm water pollutants in the District of Columbia and I
Maryland tributary areas. |
Recommendation Strategy: The strategy for studying the origins of and better controls for
transportation-related contaminants in storm water runoff, and improving programs to prevent
these contaminants, consists of the following four actions:
Action 1: Place on agenda for future meeting of the Transportation Planning Board, discussion of
stormwater impacts from roads and highways and programs that could help control them. Include
in this briefing a discussion of the opportunities presented by. new legislation, Section 1108 of T-
21. Make sure to include in this effort the following organizations: FHA, MDoT, WMATA, MD
Transit Authority, AMTRAK, Conrail, DPW
Action 2: Conduct a study to determine activities that are occurring nationally (e.g. pollutant
studies, BMP effectiveness studies). Start this effort by conducting a Transportation Research
Board literature survey.
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Action 3: Take advantage of the research and technology transfer program that DPW is
conducting with Howard University. Use this program to fill gaps and expand areas of research
not identified in Actions 1 and 2. Focus on toxic and thermal sources of pollution from the
transportation sector.
Action 4: Develop an action plan for retrofits and new design for transportation projects to
minimize their contributions to wet weather pollution. Create milestones for the action plan.
Timeframe/Schedule:
Availability of significantly increased highway funding, and consequent highway development and
renovation, makes initiation of project planning urgent. Fall 1998: USEPA Region III
incorporate project in interagency discussions with FHWA concerning TEA-21 funding.
Financial Considerations:
Potential sources of funding include the Transportation Research Board; FHA (use existing DPW
funding that they receive for research and technology transfer); EPA (joint EPA/ORD project;
Great Water's program); TEA-21. Seek FHA approval for grant eligibility of water pollution
control facilities as part of bridge and roadway rehabilitation and reconstruction projects.
Legal Authority/Regulatory Needs: Implementable within existing authorities.
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G. Seek Innovative Approaches to Finance Wet
Weather Pollution Prevention and Control
Facilities and Activities
Background/Justification
Meeting water quality and use goals in the Anacostia River and Rock Creek watersheds requires a
wide variety of wet weather pollution prevention and control actions. Because this type of
pollution results from many different types of activities, controlling it entails many different types
of prevention measures, pollution control and storm water retention facilities, operation and
management activities such as street and sewer cleaning.
It takes money to build and maintain facilities. What the Panel wishes to emphasize is that a
variety of innovative funding means can and should be employed, involving private as well as
public financing.The most expensive way to address solve wet weather pollution problems is
through a conventional public works strategy which relies on end-of-pipe treatment, as if they are
"the city's cleanup problem".
To the greatest extent possible, wet weather pollution prevention and control needs to begin "at
home" in order to be environmentally and cost-effective - to be built into construction projects
and maintenance of government, business and residential areas, and into street and highway and
parking lot construction and maintenance. The new techniques of "low impact development" are
particularly appropriate for small-scale application, of thousands of individual units which
otherwise look like formal landscaping, or backyard gardens, or green strips in parking lots.
These techniques turn grounds maintenance staff into wet weather pollution prevention and
control officers. Some of the most knowledgeable people in the Nation about these methods are
located in the Washington metropolitan area, and are available to work (often on a non-profit
basis) with local agencies and businesses to design appropriate facilities.
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To Whom Recommendation is Addressed:
All Federal, State and local agencies with wet weather pollution prevention and control
responsibilities in the D.C. Metropolitan area, and funding authorities
Geographic Focus:
All watersheds within the District of Columbia, and their Maryland tributaries
Recommendation Summary: (1) The D.C. government should follow a varied financing
strategy to prevent and control wet weather-related pollution, involving both public and private
funding, and leveraging other public and private investments as much as possible. (2) In
developing and implementing the strategy, D.C. agencies should coordinate with Maryland
authorities, especially considering that (a) stronger measures against upstream pollution
discharges and trash are necessary, and (b) it may be more cost-effective in some cases to
consider storm water retention facilities upstream than downstream, especially to control storm
surges and bank/stream bed erosion. (3) Additional Federal funding will be essential.
Recommendation Strategy:
(1) D.C. strategy for financing prevention and control of wet weather-related pollution
(a) D.C. WAS A, which was created in 1996, has established a publicly-accountable
financial planning system for the Blue Plains Wastewater Treatment Plant and system.
The Panel supports the Authority's efforts to solve management and water/sewer billing
problems and to assure an adequate revenue stream for carrying out all needed functions.
D.C. WAS A acknowledges that the current capital construction plan does not include
financing for all of the improvements that will be required to implement the CSO LTCP.
The Panel recognizes that it is premature to identify all of the CSO-related capital
spending needs today, but urges that a preliminary investment plan be outlined as soon as
possible, so that it can be considered during D.C. WASA's required CSO public
participation process. It can be updated as necessary to reflect the results of the LTCP.
.The "integrated watershed assessment" (Recommendation B.3) for the Anacostia River
will provide a cooperative D.C.- Maryland forum for studying wet weather pollution
sources and assessing the most cost-effective ways to achieve water quality/use goals.
(b) Effective administration of the regulatory requirements associated with the D.C.
erosion control and storm water management regulations is a key leveraging mechanism
for financing wet weather pollution prevention and control (Prince George's and
Montgomery Counties also have such programs). In Recommendation A.4, the Panel
addressed the need to strengthen the District's program for plan review and approval and
for enforcement of associated construction and building requirements. Noted in that
recommendation were program-support opportunities which the District should
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implement, including increasing its fees, dedicating fee revenues to program support, and
taking advantage of cooperative inspection and enforcement opportunities with USEPA
where Federal jurisdiction applies. A cooperative technical training program with the two
Maryland countries and the City of Alexandria might also be considered.
(c) It is appropriate for D.C. WASA's current system of water/sewer rates to cover the
system's CSO-related expenditures; however, the District's separate storm sewers are not
part of the Blue Plains system and other financing mechanisms must be found for
implementing the District's storm water management program under the legally-mandated
Federal MS4 permit (Recommendation A3). The Panel reviewed information from
several cities concerning alternative financing mechanisms (such as property fees based on
extent of impervious surface).
Although the Panel did not make a detailed study of such mechanisms and is not in a
position to recommend adoption of a particular system, it has several suggestions and
observations:
- in determining public financing needs, account should be taken of all opportunities for
public-private partnerships, especially where storm water management practices
enhance property aesthetic and other values;
- also in determining public financing needs, every effort should be made to take
advantage of existing public programs, such as street repair and implementation of city
sanitation programs using technical advice (for instance, from the USEPA Wet
Weather Research Program and from experience of other cities) concerning how such
activities can be carried out in a way that achieves wet weather pollution prevention
and control goals;
- strategies for CSO pollution prevention and control have much in common with
separate storm sewer pollution prevention and control. As covered in
Recommendation A.2, maximum advantage should be taken of the knowledge that will
be developed for D.C. WASA's CSO LTCP, and "dual benefit" programs identified
where possible;
- considerably more attention is needed regarding the contribution of road construction
and use in the watersheds on wet weather pollution; an in-depth study should be
undertaken of both sources and prevention/control options (Recommendation F.4).
New Federal funding authorities specifically include reference to eligibility for Federal
funding of measures needed to correct past environmental damages associated with
highways;
- in line with the above, the Panel noted that the D.C. Department of Public Works has
not been able to take full advantage of opportunities for Federal highway funding to
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install storm water pollution controls on the estimated 40% of District roads which are
part of the national highway system; the new Federal funding under the recent TEA-21
Federal highway legislation offers an exceptional opportunity to work out the
-historical issues and put-new priority on prevention and control of road-generated wet
weather pollution (also, the District of Columbia could be a good area for testing and
demonstrating new technologies);
- carrying out a vigorous public participation program (see Recommendation D) will be
an essential element in developing support for storm water management funding.
From the Panel's review, it is apparent that there are environmental and public interest
groups which are willing and able to assist the District of Columbia in building an
information base, assessing options and communicating with D.C. citizens.
(d) The District of Columbia needs to improve its capacity to find local matching funds to
take advantage of the financing available from the Federal government for storm water
management and related projects, such as ecosystem restoration and fish and wildlife
habitat improvement. While local public financing needs to be increased, opportunities for
leveraging private funding sources and charitable foundation support should also be
vigorously assessed.
(e) As in other highly developed urban areas, the District's existing infrastructure makes
restoration of natural storm water retention and pollution prevention mechanisms
expensive - and some say, impossible. However, the District has extensive areas of
already-developed government, business and residential development which is undergoing
rehabilitation and redevelopment. After reviewing programs in other cities and
considering new storm water management techniques, the Panel believes it is neither
technically nor economically infeasible to make substantial retrofit improvements in the
District's wet weather pollution prevention and control system.
Examples of areas where retrofit opportunities should be actively sought are noted below:
- every parking lot in the city, because these are prime sources of automobile-related
toxic pollutants in storm water runoff and often exacerbate CSOs by channelling and
accelerating storm runoff into combined sewers; retrofit technologies are abundant and
those which rely on landscaping techniques add aesthetic and possible air quality
benefits to otherwise barren urban areas;
- renovated and redeveloped buildings in D.C. Redevelopment Zones and potential
"Brownfields" areas; cost-effective storm water retrofit installations should be
encouraged as part of these developments which are often beyond the jurisdiction of
the D.C. erosion control and storm water management program for new construction;
- open lands (to be assessed as part of D.C. WASA's CSO LTCP and noted in
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Recommendation E), especially for storm water retention in the CSO sewersheds;
- private-public partnerships to clean up downtown shopping areas and other areas
where trash generation from business, commuting and recreational areas is greatest.
(2) Coordination with Maryland authorities, to take advantage of cost-effective wet weather
pollution prevention and control actions in upper watershed areas in Maryland.
(3) Federal funding assistance
(a) Organization of the Panel by USEPA and the Chesapeake Bay Program's Federal
Agencies Committee is a reflection of the awareness that Washington, D.C. is uniquely
dominated by the Federal government's functions. Thus the Federal government needs to
do its fair share to finance city infrastructure and operations for wet weather pollution and
control, and to practice wet weather pollution source prevention. The Panel believes the
abundance of Federal facilities and programs located in the District of Columbia, and in
Maryland's portions of the watersheds which drain into the District, can and should be a
laboratory for the best urban wet weather pollution management in the Nation.
(b) Recommendation C.I details actions which the Federal government needs to take and
finance in order to comply with wet weather pollution generated by its own buildings and
facilities. These requirements apply to individual components of the Federal government,
but it may be more timely and cost-effective to fund assessment and coordinate faclity
planning through a central mechanism, such as the Corps of Engineers. The Panel
suggests immediate exploration of ways to utilize the current Corps of Engineers
authorities and programs to facilitate implementation of the Federal pollution prevention
and control actions envisioned by Recommendation C. 1. In addition, the Federal
government may need to provide up-front capital funding for the Federally-generated
share of CSO overflows to enable D.C. WAS A to meet Federal environmental
requirements.
(c) Recommendation C.2 outlined a number of Federal assistance actions which are
-. needed to accelerate wet weather pollution prevention and control in the D.C. watersheds.
These are based on taking advantage of existing Federal programs - some of which have
already been identified through the Federal agencies participating on the Panel and some
of which need to be investigated. In addition, matching requirements for applicable
Federal programs might be reexamined in light of the District of Columbia's limited
capacity to raise local financing for capital programs, despite taking advantage of
innovative financing opportunities.
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U.S. EPA Headquarters Library
Mail code 3201
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