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ACTION STRATEGY
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This Green Infrastructure Action Strategy is the product of collaboration among many
agencies, organizations and individuals. The following organizations are primarily
responsible for coordinating the development of this first iteration of the action strategy:
American Rivers
Association of State and Interstate Water Pollution Control Administrators
National Association of Clean Water Agencies
Natural Resources Defense Council
The Low Impact Development Center
U.S. Environmental Protection Agency
For more information on green infrastructure planning and implementation, and
partnerships, visit the green infrastructure website at:
www.epa.gov/npdes/greeninfrastructure
NACWA
NRDC
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ASIWPCA
American Rivers
Thriving By Nature
January 2008
Front Cover Photos
Top: rain garden; permeable pavers; rain barrel;
planter; tree boxes.
Remainder: Green Street in Portland; Mt. Tabor
rain garden in Portland; Chicago City Hall
green roof; planter inlet in Portland.
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Managing Wet Weather with Green Infrastructure
Action Strategy
2008
Introduction 4
Background 4
What is Green Infrastructure? 5
Green Infrastructure Benefits 5
National Collaboration on Action Strategy Development 6
Purpose of the Action Strategy 7
The Green Infrastructure Action Strategy 9
I. Research 10
II. Outreach and Communication 12
III. Tools 14
IV. Clean Water Act Regulatory Support 17
V. Economic Viability and Funding 20
VI. Demonstrations and Recognition 22
VII. Partnerships 25
Implementation Framework 28
Appendix A: Using Green Infrastructure to Protect Water Quality in Stormwater, CSO,
Nonpoint Source and other Water Programs, March 5, 2007, memo from
Ben Grumbles to EPA Regional Administrators
Appendix B: Green Infrastructure Statement of Intent, April 19, 2007
Appendix C: Stakeholder Statement of Support for Green Infrastructure, open
partnership agreement
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Introduction
Background
Many communities, ranging from highly developed cities to newly developing towns, are
looking for ways to assure that the quality of their rivers, streams, lakes, and estuaries is
protected from the impacts of development and urbanization. Traditional development
practices cover large areas of the ground with impervious surfaces such as roads, driveways,
and buildings. Once such development occurs, rainwater cannot infiltrate into the ground,
but rather runs offsite at levels that are much higher than would naturally occur. The
collective force of such rainwater scours streams, erodes stream banks, and thereby causes
large quantities of sediment and other entrained pollutants to enter the water body each time
it rains.
In addition to the problems caused by stormwater and nonpoint source runoff, many older
cities (including many of the largest cities in the United States), have combined sewage and
stormwater pipes which periodically and in some cases frequently overflow due to
precipitation events. In the late 20l century, most cities that attempted to reduce sewer
overflows did so by separating combined sewers, expanding treatment capacity or storage
within the sewer system, or by replacing broken or decaying pipes. However, these practices
can be enormously expensive and take decades to implement. Moreover, piped stormwater
and combined sewer overflows ("CSOs") may also, in some cases, have the adverse effects
of upsetting the hydrological balance by moving water out of the watershed, thus bypassing
local streams and ground water. Many of these events also have adverse impacts and costs
on source water for municipal drinking water utilities.
A set of techniques, technologies, approaches and practices—collectively referred to as
"green infrastructure"—can be used to eliminate or reduce the amount of water and
pollutants that run off a site and ultimately are discharged into adjacent water bodies. As
cities move towards sustainable infrastructure, green infrastructure can be a valuable
approach.
"Green infrastructure" is a relatively new and flexible term, and it has been used differently
in different contexts. Thus, to date, there is no universally established definition of the term.
For example, Benedict and McMahon, in their book Green Infrastructure (Island Press,
2006), have defined it broadly as "an interconnected network of natural areas and other open
spaces that conserves natural ecosystem values and functions, sustains clean air and water,
and provides a wide array of benefits to people and wildlife." However, for the purposes of
our efforts to implement the Green Infrastructure Statement of Intent (discussed below), we
intend the term "green infrastructure" to generally refer to systems and practices that use or
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mimic natural processes to infiltrate, evapotranspirate (the return of water to the atmosphere
either through evaporation or by plants), or reuse stormwater or runoff on the site where it is
generated.
What is Green Infrastructure?
Green infrastructure is management approaches and technologies that utilize, enhance and/or
mimic the natural hydrologic cycle processes of infiltration, evapotranspiration and reuse.
Green infrastructure approaches currently in use include green roofs, trees and tree boxes,
rain gardens, vegetated swales, pocket wetlands, infiltration planters, porous and permeable
pavements, vegetated median strips, reforestation/revegetation, and protection and
enhancement of riparian buffers and floodplains. Green infrastructure can be used almost
anywhere soil and vegetation can be worked into the urban or suburban landscape. Green
infrastructure also includes decentralized harvesting approaches, such as the use of rain
barrels and cisterns to capture and re-use rainfall for watering plants or flushing toilets.
These approaches can be used to keep rainwater out of the sewer system so that it does not
contribute to a sewer overflow and also to reduce the amount of untreated runoff discharging
to surface waters. Green infrastructure also allows stormwater to be absorbed and cleansed
by soil and vegetation and either re-used or allowed to flow back into groundwater or surface
water resources.
In managing wet weather, green infrastructure practices, like all types of practices, need to be
implemented at multiple scales: site, neighborhood, and regional or watershed. The most
beautifully designed site, even if multiple green infrastructure practices are used, may
actually result in an overall increase in impervious surfaces and thus stormwater discharges,
if new or expanded roads, parking lots and commercial development are needed to serve it.
For that reason, we include approaches such as infill, redevelopment and preserving natural
areas in our suite of green infrastructure approaches. For more information on specific green
infrastructure practices and how they function, visit:
http://www.epa.gov/npdes/greeninfirastructure.
Green Infrastructure Benefits
Green infrastructure has a number of environmental and economic benefits in addition to
reducing the volume of sewer overflows and runoff.
• Cleaner Water - Vegetation, green space and water reuse reduce the volumes of
stormwater runoff and, in combined systems, the volume of combined sewer overflows,
as well as reduce concentrations of pollutants in those discharges.
• Enhanced Water Supplies - Most green infiltration approaches involve allowing
stormwater to percolate through the soil where it recharges the groundwater and the base
flow for streams, thus ensuring adequate water supplies for humans and more stable
aquatic ecosystems. In addition, capturing and using stormwater conserves water
supplies.
• Cleaner Air - Trees and vegetation improve air quality by filtering many airborne
pollutants and can help reduce the amount of respiratory illness. Transportation and
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community planning and design efforts that facilitate shorter commute distances and the
ability to walk to destinations will also reduce vehicle emissions.
• Reduced Urban Temperatures - Summer city temperatures can average 10°F higher than
nearby suburban temperatures. High temperatures are also linked to higher ground level
ozone concentrations. Vegetation creates shade, reduces the amount of heat absorbing
materials and emits water vapor - all of which cool hot air. Limiting impervious surface
and using light colored impervious surfaces (e.g., porous concrete) also mitigate urban
temperatures.
• Moderate the Impacts of Climate Change - Climate change impacts and effects vary
regionally, but green infrastructure techniques provide adaptation benefits for a wide
array of circumstances, by conserving and reusing water, promoting groundwater
recharge, reducing surface water discharges that could contribute to flooding. In
addition, there are mitigation benefits such as reduced energy demands and carbon
sequestration by vegetation.
• Increased Energy Efficiency - Green space helps lower ambient temperatures and, when
incorporated on and around buildings, helps shade and insulate buildings from wide
temperature swings, decreasing the energy needed for heating and cooling. Further,
diverting stormwater from wastewater collection, conveyance and treatment systems
reduces the amount of energy needed to pump and treat the water. Energy efficiency not
only reduces costs, but also reduces generation of greenhouse gases.
• Source Water Protection - Green infrastructure practices provide pollutant removal
benefits, thereby providing some protection for both ground water and surface water
sources of drinking water. In addition, green infrastructure provides groundwater
recharge benefits.
• Community Benefits - Trees and plants improve urban aesthetics and community
livability by providing recreational and wildlife areas. Studies show that property values
are higher when trees and other vegetation are present.
• Cost Savings - Green infrastructure may save capital costs associated with paving,
creating curbs and gutters, building large collection and conveyance systems, and digging
big tunnels and centralized stormwater ponds; operations and maintenance expenses for
treatment plants, pumping stations, pipes, and other hard infrastructure; energy costs for
pumping water around; cost of treatment during wet weather; and costs of repairing the
damage caused by stormwater, such as streambank restoration.
National Collaboration on Green Infrastructure
On April 19, 2007 the Green Infrastructure Statement of Intent (Appendix B) was entered
into and between: the U.S. Environmental Protection Agency (EPA); National Association of
Clean Water Agencies; Natural Resources Defense Council; the Low Impact Development
Center; and the Association of State and Interstate Water Pollution Control Administrators.
The Statement of Intent also recognized the support of all signatories of the Stakeholder
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Statement of Support for Green Infrastructure (Appendix C), which continues to garner
interest and new signatories.
The objectives of the Statement of Intent are to:
• Affirm the belief by the signatory organizations in the value of green infrastructure as
both a cost effective and an environmentally preferable approach to reduce stormwater
and other excess flows entering combined or separate sewer systems in combination with,
or in lieu of, centralized hard infrastructure solutions;
• Establish a framework for working together to advance an understanding of green
infrastructure as a tool for reducing overflows from sewer systems and stormwater
discharges and to encourage and promote their wider application;
• Identify partnership opportunities between the signatory organizations;
• Develop strategies to promote the use of green infrastructure by cities and utilities as an
effective and feasible means of reducing stormwater pollution and sewer overflows such
as:
• Developing models for all components of green infrastructure and make them
available nationwide.
• Exploring opportunities and incentives for the use of green infrastructure
provisions in municipal separate storm sewer system (MS4) permits and CSO
Long Term Control Plans (LTCPs), including as a component of injunctive relief
provisions of enforcement actions;
• Developing memoranda and guidance materials, including language for the
National Pollutant Discharge Elimination System (NPDES) Permit Writer's
Manual, that would explain how regulatory and enforcement officials should
evaluate and provide appropriate credit for the use of green infrastructure in
meeting Clean Water Act requirements;
• Recognizing the most effective and innovative uses of green infrastructure to
meet Clean Water Act goals through EPA awards or recognition programs;
• Providing technical assistance, training, and outreach to potential users of green
infrastructure, including states, cities, counties, utilities, environmental and public
health agencies, engineers, architects, landscape architects, planners and
nongovernmental organizations;
• Establishing a web-based green infrastructure resource center at EPA to assist
communities in complying with requirements for combined sewer overflows and
municipal stormwater permits and evaluating the multiple environmental benefits
that green infrastructure can provide; and
• Developing tools to assist local green infrastructure programs with outreach,
training, model development and application, planning and design, monitoring,
and plan review.
Purpose of the Action Strategy
The purpose of this action strategy is to set forth a collaborative set of actions among the
signatory organizations to both the Statement of Intent and the Statement of Support in
order to promote the benefits of using green infrastructure in mitigating overflows from
combined and separate sewers and reducing runoff, by encouraging the use of green
infrastructure as prominent components of combined and separate sewer overflow (CSO &
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SSO) plans, municipal stormwater (MS4) programs, and nonpoint source and watershed
planning efforts. This action strategy outlines the efforts that the partners feel are important
in bringing green infrastructure technologies and approaches into mainstream wet weather
management.
This Green Infrastructure Action Strategy also represents one of the key actions that EPA is
undertaking to address projected impacts of climate change. The EPA Office of Water has
developed the draft National Water Program Strategy: Response to Climate Change which
will soon be released for public comment. Green Infrastructure is one strategy that
communities can use to adapt water and wastewater management in the face of changing
hydrologic cycles.
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The Green Infrastructure Action Strategy
This green infrastructure action strategy includes seven major areas for which objectives and
tasks are being developed and implemented:
o Research
o Outreach and Communications
o Tools
o Clean Water Act Regulatory Support
o Economic Viability and Funding
o Demonstrations and Recognition
o Partnerships
Specific project plans for some areas and activities are well defined, and even underway in
some cases. In other areas, tasks and activities are only generally laid out, and additional
effort will be undertaken to develop the project plan and begin implementation. The core
partners group for development of this action strategy preferred this approach, as it made it
possible to begin work immediately on efforts with widespread support, rather than waiting
for development and finalization of this action strategy document.
In fact, this action strategy is a living document. It will be regularly updated as activities and
priorities evolve. In all areas, but especially in areas where action is not well-defined, we
welcome input from anyone or any organization with ideas, energy or resources to develop
specific tasks. This is truly a collaborative effort, and new partners willing to take leadership
in specific areas can only strengthen the outcomes.
The various components of this action strategy have been developed and will be
implemented by different partners or combinations of partners. Many of them are
collaborative. Some are being undertaken by individual organizations, if particular tasks fall
squarely within their provinces. Further, not all tasks will be initiated immediately, but initial
priorities have been identified in this action strategy.
The Steering Committee, the core coordinating group of this green infrastructure effort, is
comprised of representatives from American Rivers, the Association of State and Interstate
Water Pollution Control Administrators (ASIWPCA), the Low Impact Development (LID)
Center, the National Association of Clean Water Agencies (NACWA), the Natural Resources
Defense Council (NRDC) and U.S. EPA.
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I. Research
Because many green infrastructure management practices are relatively new, there is little
quantitative data on performance and effectiveness.
Goal: Ensure that potential adopters of green infrastructure approaches have the necessary
information to make the transitions on multiple fronts, e.g., technically, administratively,
financially.
Objective I.I: Develop protocols to quantify multiple benefits of green infrastructure
practices.
Description: Develop standard protocols/methods for co-assessing benefits from
green infrastructure practices (energy savings, carbon sequestration, urban heat island
reduction, water conservation, air quality, property values, biodiversity) along with
water quality and quantity benefits.
Priority: High
Responsible Entities: Co-leads: EPA, Low Impact Development Center
Timeframe: Underway FY07. Complete TBD.
Contact: Jenny Molloy, U.S. EPA
Chris Kloss, Low Impact Development Center
Objective 1.2: Assess and quantify multiple benefits of green infrastructure.
Description: Compile existing data. Assess and quantify multiple benefits of green
infrastructure (water quality and quantity along with benefits noted above), with side-
by-side comparisons to gray infrastructure approaches to managing wet weather.
Consider also water quality benefits derived by eliminating or reducing utilization of
collection systems that transport pathogens, etc. to receiving waters.
Priority: High
Responsible Entities: Co-leads: EPA, Low Impact Development Center, and other
interested parties are encouraged to participate
Timeframe: Dependent upon development of protocols for co-assessment.
Contact: Jenny Molloy, U.S. EPA
Chris Kloss, Low Impact Development Center
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Objective 1.3: Identify and fill green infrastructure-related research gaps.
Description: Convene a research forum to identify green infrastructure-related
research gaps, and identify mechanisms for filling those gaps.
Priority: High
Responsible Entities: Co-leads: U.S. EPA, Water Environment Research
Foundation, Low Impact Development Center
Timeframe: Conference in January 2008
Contact: Jenny Molloy, U.S. EPA
Dan Murray, U.S. EPA
Jeff Moeller, Water Environment Research Foundation
Chris Kloss, Low Impact Development Center
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II. Outreach and Communication
As is typical of new technological approaches, implementers often need to understand
available technologies, benefits and performance of these new mechanisms, and how to
design, build, incorporate, implement and maintain new management systems. In addition, it
is sometimes necessary to develop or modify administrative, logistical and institutional
frameworks for doing things in a new way.
Goal: Ensure that potential implementers of green infrastructure approaches have the
necessary information to make the transitions on multiple fronts, e.g., technically,
administratively, financially.
Objective II. 1: Establish a web-based Green Infrastructure resource center. This resource
center will be a clearinghouse for all types of information, e.g., technical, regulatory,
funding, research, tools, case studies.
Description: The Green Infrastructure resource center was established in July 2007.
(www.epa.gov/npdes/greeninfrastructure). This website serves as an informational
clearinghouse for people interested in learning about green infrastructure. The goal is
to create a site for people with varying levels of interest and expertise, and will be
designed so that visitors can quickly access information that is substantive and up-to-
date. The site will be divided into several sub-sections, including:
• General Information (background information about the collaborative effort;
benefits of green infrastructure; basic definitions)
• Case Studies (catalog of green infrastructure initiatives, pilot programs, and
demonstration projects that have been completed or are underway)
• Performance Data (publications, reports and calculators that quantify the
performance capabilities of green infrastructure practices)
• Funding & Incentives (links to sources of funding for green infrastructure
projects; compilation of incentives that cities/municipalities have adopted to
promote green infrastructure)
• Resources (links to other sources of information)Additional components will be
added, and the website will be kept current.
Priority: High
Responsible Entities: Lead: U.S. EPA. Co-lead: National Association of Clean
Water Agencies, Low Impact Development Center, American Rivers.
Timeframe: Underway. Basic framework July 2007; more in-depth information,
and sophisticated tools ongoing.
Contact: Greg Voigt, U. S. EPA, ORISE Fellow
Nathan Gardner-Andrews, National Association of Clean Water
Agencies
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Objective II.2: As noteworthy activities, products or accomplishments, occur, publish a
brief periodical newsletter.
Description: Publish a 1 sheet (2 pages) newsletter on a semi-regular basis, of
noteworthy activities, production of tools and technical guidebooks, new data, and
other accomplishments. The periodical will not be held to a specific publication
schedule, but will be used as a primary means to keep all partners updated on
progress. The periodical will be distributed to all signatories of the Statement of
Support, and placed on the website.
Priority: Medium
Responsible Entities: Lead: U.S. EPA. Associates: all partners who would like to
publicize accomplishments
Timeframe: Underway. Ongoing.
Contact: Jenny Molloy, U.S. EPA, Office of Wastewater Management
Objective II.3: Partner with organizations and conference organizers to include green
infrastructure on the agendas of major national and regional meetings and forums.
Description: Work with national and regional organizations to include various
aspects of green infrastructure on conference agendas.
Priority: High
Responsible Entities: All partners, including American Rivers, Association of State
and Interstate Water Pollution Control Administrators, the Low Impact Development
Center, National Association of Clean Water Agencies, Natural Resources Defense
Council and U.S. EPA
Timeframe: Ongoing.
Contact: Jenny Molloy, U.S. EPA
Neil Weinstein, Low Impact Development Center
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III. Tools
One reason for the slow incorporation of green infrastructure practices into mainstream
management designs is because the tools—including predictive and design models that
would facilitate incorporation into designs, or the protocols for undertaking other analyses—
generally do not include green infrastructure layers or modules. Engineers and others use
well-established standard models and design paradigms, and until those tools can be updated
with standard sets of assumptions and other information, green infrastructure practices are
unlikely to move into the realm of standard approaches to managing wet weather.
Goal: Ensure that potential adopters of green infrastructure approaches have the necessary
tools to make the transitions on multiple fronts, e.g., technically, administratively,
financially.
Objective III.l: Establish models and modeling protocols that quantify discharge volume
and pollutant reductions of green infrastructure practices (in combination with each other and
gray infrastructure practices) at site, sewershed, and system-wide scales.
Description: This initiative will involve developing a technical support document on
integrating green infrastructure technologies into commonly used models and
calculators used to plan and design wet weather controls. This effort will consider
components that incorporate factors for climate change. Another consideration will
be to ensure the availability of the necessary modeling tools for designing green
infrastructure solutions. This initiative will involve compiling information on
existing models that will fill this need and developing model and calculator
components to fill the gaps.
Priority: High
Responsible Entities: Lead: U.S. EPA. Associates: Low Impact Development
Center
Timeframe: Underway. Complete by September 2008.
Contact: Robert Goo, U.S. EPA, Office of Wetlands, Oceans & Watersheds
Chris Kloss, Low Impact Development Center
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Objective III.2: Develop a guidebook for municipalities on implementing green
infrastructure.
Description: Develop a guidebook for municipalities that includes a decision-tree
for selecting/applying green infrastructure approaches for new development,
redevelopment and retrofits (including performance and cost factors), master planning
considerations, site planning and design review specifications, operation and
maintenance needs, model codes and ordinances (including removing obstacles in
current codes and ordinances), incentives and funding, tracking and evaluation
protocols, and marketing. The guidebook will include important aspects of
retrofitting and redeveloping in ultra-urban areas, as well as case studies documenting
how other local governments have rewritten or created new stormwater codes,
regulations or policies to encourage or require the management of stormwater runoff
using controls that infiltrate, reuse and evapotranspirate. The guidebook will provide
lessons learned about barriers, implementation, partnerships and incentives, as well as
data on total build out and quantifiable results
Priority: High
Responsible Entities: Co-leads: U.S. EPA; National Association of Clean Water
Agencies; American Rivers
Timeframe: Complete 2008-2009.
Contact: Abby Hall, U.S. EPA, ORISE Fellow
Objective III.3: Develop design standards and drawings for homeowners and property
owners that can be shared with designers, contractors and builders.
Description: Individuals and organizations choosing to implement green
infrastructure technologies often have difficulty conveying the purpose and
possibilities for designing site features to manage stormwater runoff. Outreach
materials would include simple drawings and images alongside design specifications
for managing certain volumes per square feet of imperviousness. Materials should be
printed in English and Spanish.
Priority: Medium
Responsible Entities: Co-leads: EPA, and other interested parties are encouraged to
participate
Timeframe: Begin in FY08.
Contact: Jamal Kadri, U.S. EPA
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Objective in.4: Develop bid specification language for green infrastructure practices, to
make it easier for projects to accurately bid construction activities utilizing green
infrastructure technologies.
Description: Individuals and organizations choosing to implement green
infrastructure technologies often have difficulty accurately bidding the project
because of their inexperience with the technology. Model bid specifications will
articulate specific provisions, outcomes, etc.
Priority: High
Responsible Entities: Co-leads: EPA; and other interested parties are encouraged to
participate
Timeframe: Begin in FY08.
Contact: Greg Voigt, U. S. EPA, ORISE Fellow
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IV. Clean Water Act Regulatory Support
There is a misperception by many that regulatory programs do not allow the use of green
infrastructure. In actuality, regulatory programs generally allow the use of management
practices that will meet the necessary water quality/environmental outcome(s). In practice,
regulatory programs often facilitate the proliferation of standard gray infrastructure simply
because that is the technology with which the regulated community and the regulators are
familiar.
Goal: Clarify for regulators and the regulated community how Clean Water Act provisions
can facilitate implementation of green infrastructure approaches. Make specific efforts to use
NPDES-related mechanisms to facilitate near-term implementation.
Objective I V.I: Clarify for regions and states that there is nothing in regulations or statutes
precluding the use of green infrastructure solutions in various regulatory programs, and
provide direction to promote utilization of green infrastructure approaches in lieu of, or in
combination with, gray infrastructure approaches.
Description: Issue joint memo from Water Permits Division and Water Enforcement
Division, to regional and state NPDES permit and enforcement program managers
clarifying that green infrastructure approaches are acceptable controls for CSOs,
stormwater and other discharges within the Clean Water Act frameworks, subject to
the same frameworks and requirements.
Priority: High
Responsible Entities: EPA Water Permits Division and Water Enforcement
Division
Timeframe: Completed. Memo issued August 16, 2007.
Contact: Gary Hudiburgh, U.S. EPA
Objective IV.2: Develop model permit language for MS4 permits that will specifically
incorporate green infrastructure management practices into municipal stormwater programs.
Conduct pilot tests of the model language in permits, as appropriate.
Description: Draft language that can be incorporated into MS4 permits to focus
stormwater management on processes of infiltration, reuse and evapotranspiration,
and simultaneously consider both site design and community design/regional issues.
Develop accompanying justification for permit fact sheets and accompanying
guidance for permittees. Conduct pilots with select states and regions, including
providing direct permit writing technical assistance, as necessary.
Priority: High
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Responsible Entities: U.S EPA and relevant states as pilots are initiated.
Timeframe: Underway. Pilots with West Virginia and Tennessee 2007 and 2008.
Contact: Jenny Molloy, U.S. EPA
Lynn Richards, U.S. EPA
Robert Goo, U.S. EPA
Objective IV.3: Develop a guidebook for state and regional NPDES programs (permitting
and enforcement) on facilitating the use of green infrastructure via regulatory programs.
Description: This guidebook will discuss considerations for evaluating green
infrastructure approaches as part of a regulatory program. The guidebook will
provide information about how to incorporate green infrastructure approaches for wet
weather programs in permits, long term control plans (LTCP), and settlements
(Supplemental Environmental Programs (SEPs) and injunctive relief). The
guidebook will describe the elements of these documents and provide examples of
existing permits, LTCPs and settlements with relevant provisions. The guidebook
will articulate review criteria to help ensure that the feasibility of green infrastructure
approaches is always considered during design and review stages.
Priority: High
Responsible Entities: U.S. EPA, NACWA, NRDC, ASIWPCA, LID Center,
American Rivers
Timeframe: Complete by summer 2008.
Contact: Gary Hudiburgh, U. S. EPA
Objective IV.4: Provide guidance on green infrastructure stormwater technologies and the
interface with underground injection control (UIC) regulations for class V wells.
Description: Clarify which infiltration measures are classified as class V wells, and
therefore subject to underground injection control requirements to protect
groundwater quality. Provide guidance to EPA and state regulatory programs.
Provide guidance to adopters of infiltration techniques regarding their regulatory
obligations, where appropriate.
Priority: High
Responsible Entities: US EPA
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Timeframe: Spring 2008.
Contact: Jeff Jollie, U.S. EPA
Greg Voigt, U.S. EPA, ORISE Fellow
Objective IV.5: Continue training to municipal officials and others who operate MS4s,
combined sewers and other wet weather programs.
Description: A one-day training on using green infrastructure to help manage wet
weather regulatory programs was piloted in northern Kentucky in September 2007 for
about 100 people. The training program included technology and policy components.
This training will be provided in other municipalities as requested.
Priority: High
Responsible Entities: U.S. EPA, Low Impact Development Center
Timeframe: Ongoing.
Contact: Gary Hudiburgh, U.S. EPA
Chris Kloss, Low Impact Development Center
Objective IV.6: Collaborate on development of a CSO long term control plan (LTCP).
Description: There are currently several communities in the process of developing
LTCPs that may be good candidates for a model 'green' plan. Identify one or two
good candidates and provide tools and assistance necessary to incorporate green
infrastructure controls into the LTCP.
Priority: High
Responsible Entities: U.S. EPA, and interested state NPDES programs and
municipal operators are encouraged to participate
Timeframe: Commence FY08.
Contact: Gary Hudiburgh, U. S. EPA
19
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V. Economic Viability and Funding
Practitioners are often reticent to adopt new approaches without adequate documentation that
these approaches are economically viable and demonstration of the economic advantages of
employing approaches that provide multiple benefits. In addition, municipalities and other
entities interested in green infrastructure are often dissuaded from pursuing projects because
of lack of available funds. This can be particularly true for smaller communities that are
already struggling with a lack of resources to meet ever increasing municipal demands.
Goal: Document and/or quantify the multiple benefits of using green infrastructure. Ease
the financial burden on municipalities that are interested in implementing green infrastructure
practices and technology but lack the necessary financial resources
Objective V.I: Document capital expenditures, administrative and life cycle costs; compare
to traditional gray-infrastructure costs. Consider new construction versus retrofits. Consider
regional averages and ranges. Consider individual practices as well as combinations of
practices.
Description: Develop protocols for making standard cost evaluations of green
infrastructure practices. Compile information on capital and life cycle costs and
include cost savings derived from reducing curb, gutter, paving materials, O&M,
dredging, channel restoration, drinking water treatment costs, etc.
Priority: High
Responsible Entities: U.S. EPA and interested parties are encouraged to participate
Timeframe: Begin FY08
Contact: Robert Goo, U.S. EPA
Objective V.2: Document types of incentives and financing mechanisms that communities
can use through a review of strategies used by municipalities with well-established green
infrastructure policies.
Description: Compile information on the types of incentives that communities are
and can use to facilitate and encourage the use of green infrastructure approaches.
Compile case studies from institutionalized green infrastructure programs, including
examples of stormwater fee structures, taxes, interagency contributions, etc.
Priority: High
Responsible Entities: Co-leads: U.S. EPA, American Rivers, Environmental
Finance Center
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Timeframe: Underway. Complete FY08.
Contact: Abby Hall, U.S. EPA , ORISE Fellow
Objective V.3: Clarify those existing grant and loan programs that local governments and
other entities can use to help fund green infrastructure projects. Work to make green
infrastructure a priority.
Description: Create a list of those existing grant programs that could be used to fund
green infrastructure projects and work with those programs to make green
infrastructure projects a high priority for funding. Work especially to enhance use of
State Revolving Fund (SRF) funds for green infrastructure solutions to wet weather
problems.
Priority: Medium
Responsible Entities: U.S. EPA (Lead) and other partners as grant opportunities
become known
Timeframe: Begin Summer 2007 and ongoing
Contact: Greg Voigt, U. S. EPA, ORISE Fellow
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VI. Demonstrations and Recognition
Publicizing projects, robust data, experiences, and lessons learned and other information will
begin to help familiarize potential adopters with green infrastructure practices that have
successful track records. Recognizing exceptional and successful projects will provide an
incentive for adopters to use more green infrastructure. Existing and new projects provide
great opportunities to gather additional data and information for demonstration and
recognition projects.
Goal: Use existing projects and develop several new green infrastructure pilot projects to
carefully design studies to answer many of the questions outlined in this action strategy (e.g.,
documenting costs, quantifying other benefits, developing models, gathering performance
data).
Objective VI. 1: Develop a catalog of green infrastructure case studies.
Description: This web-based catalog will build on the Natural Resources Defense
Council's Rooftops to Rivers (June 2006,
http://www.nrdc.org/water/pollution/rooftops/rooftops.pdf) and include documented
costs (capital and operation and maintenance), benefits/performance and other
relevant information. This catalog will be broken out by regional, neighborhood, and
site-specific scales and may include examples from Leadership in Energy and
Environmental Design (LEED) for Neighborhood Development and municipalities
included in the policy development handbook. A Stormwater on Brownfields fact
sheet may also elicit case studies of green infrastructure on brownfield sites and in
ultra-urban settings.
Priority: Medium
Responsible Entities: Co-leads: U.S. EPA, Low Impact Development Center,
Natural Resources Defense Council
Timeframe: Begin developing case studies during FY07 and continue in FY08.
Contact: Greg Voigt, U. S. EPA, ORISE Fellow
Objective VI.2: Expand the Washington, D.C., green build-out model to include other green
infrastructure practices, and make publicly available.
Description: Expand the model to include use of pervious or permeable pavement,
rain gardens and other vegetated solutions for volume and pollution reduction
estimates, specifically those practices that infiltrate, reuse and evapotranspirate
Stormwater. This work involves research, method development and application.
Methodology will be transferable.
22
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Priority: High
Responsible Entities: U.S. EPA; District of Columbia Washington Area Sewer and
Water Authority (WASA); Limno-Tech
Timeframe: Commence August 2007. Complete spring 2008.
Contact: Jenny Molloy, U.S. EPA
Objective VI.3: Using the expanded Washington, D.C., green build-out model, reconvene
the advisory team to develop an implementation strategy.
Description: Reconvene the D.C. Green Build-Out Advisory Team to develop a
strategy for implementing a full-scale demonstration in a pilot sewershed.
Priority: Medium
Responsible Entities: D.C. Washington Area Sewer and Water Authority, D.C.
Department of Environment
Timeframe: Following completion of Objective V.2
Contact: Nancy Stoner, Natural Resources Defense Council
Objective VI.4: Recognize innovative green infrastructure through awards or recognition
programs.
Description: Develop a framework for a national recognition program for quality
green infrastructure efforts. The development of this framework will be based on
existing recognition programs.
Priority: Medium
Responsible Entities: Lead: American Rivers, and other interested parties are
encouraged to participate
Timeframe: Begin 2008; ongoing
Contact: Gary Belan, American Rivers
Jenny Molloy, U.S. EPA
Objective VI.5: Seek green infrastructure projects in the early stages to create opportunities
for documenting costs, performance and other data.
23
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Description: Identify green infrastructure projects in the concept or planning stages.
Depending on the type of project, partner in order to gather information, influence
design, and other objectives outlined in this action strategy.
Priority: High
Responsible Entities: All partners, including American Rivers, Association of State
and Interstate Water Pollution Control Administrators, the Low Impact Development
Center, National Association of Clean Water Agencies, Natural Resources Defense
Council and U.S. EPA
Timeframe: Ongoing
Contact: Jenny Molloy, U.S. EPA
Nathan Gardner-Andrews, National Association of Clean Water
Agencies
24
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VII. Partnerships
A broad and intensive effort to expand the partnership and promote green infrastructure
approaches is needed to expedite efforts and gain more widespread acceptance.
Goal: Expand the partnership via the Statement of Support and other mechanisms. Use a
variety of venues and approaches to promote the use of green infrastructure, and disseminate
data, tools, guidance and other useful information.
Objective VII. 1: Work with large retailers to develop agreement on implementing green
infrastructure at retail and warehousing establishments
Description: Collaborate with EPA programs already promoting "green" practices
with large ("big box") retailers to include a green infrastructure wet weather
management component. This initiative will focus on promoting standards and
specifications for new and redeveloped facilities, as well as operation and
management practices. The second phase of this effort will involve expanding to
malls and strip malls.
Priority: High
Responsible Entities: U.S. EPA, Low Impact Development Center, and interested
commercial partners are encouraged to participate
Timeframe: Underway.
Contact: Jenny Biddle, U.S. EPA, ORISE Fellow
Katherine Telleen, U.S. EPA, ORISE Fellow
Neil Weinstein, Low Impact Development Center
Objective VII.2: Leverage existing EPA and federal government wide efforts to lead by
example in green infrastructure.
Description: Participate in EPA's Green Building Working Group, EPA's
Innovation Action Council's Green Building Program, the Interagency Sustainability
Working Group, U.S. General Services Administration and U.S. Department of
Defense to increase emphasis on use of green infrastructure/stormwater management
issues. Work with the EPA's Office of Administration and Resources Management
to add green infrastructure requirements to their facility specifications and complete
demonstration retrofit projects and new projects.
Priority: High
Responsible Entities: U.S. EPA
25
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Timeframe: Ongoing.
Contact: Robert Goo, U.S. EPA
Objective VII.3: Promote existing, and develop new green infrastructure training and
certification for green infrastructure installers.
Description: Individuals and organizations choosing to implement green
infrastructure technologies often have difficulty finding qualified installers. This
effort will promote training and certification programs that already exist (e.g., porous
concrete, green roofs). Where gaps are identified, we will work with relevant
industries to develop training and certification criteria/programs. Specific priority
areas will be determined.
Priority: Medium
Responsible Entities: Lead: EPA, and other interested parties are encouraged to
participate
Timeframe: Underway. Existing programs identified and recognized on the web,
summer 2007.
Contact: Greg Voigt, U. S. EPA, ORISE Fellow
Objective VII.4: Continue to expand the partnership through the Statement of Support for
Green Infrastructure.
Description: Continue to solicit and accept new partners through the Statement of
Support for Green Infrastructure. Add an electronic component to the Green
Infrastructure website for organizations to electronically add their organizations as
signatories to the Statement of Support.
Priority: High
Responsible Entities: Co-leads: National Association of Clean Water Agencies,
National Resources Defense Council; Associates: U.S. EPA (e-signatory feature on
the website)
Timeframe: Ongoing. Website feature completed.
Contact: Nathan Gardner-Andrews, National Association of Clean Water
Agencies
Nancy Stoner, Natural Resources Defense Council
26
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Objective VII.5: Develop targeted partnerships for pivotal areas of implementation—for
example, with the U.S. Department of Transportation, U.S. Green Building Council,
American Society of Landscape Architects and American Institute of Architects.
Description: Other agencies and organizations have missions and resources that are
relevant to the goals of this action strategy. On a case-by-case basis, partnerships will
be developed to help further mutual goals.
Priority: High
Responsible Entities: All partners, including American Rivers, Association of State
and Interstate Water Pollution Control Administrators, the Low Impact Development
Center, National Association of Clean Water Agencies, Natural Resources Defense
Council and U.S. EPA
Timeframe: Case-by-case
Objective VII.6: Work with other federal agencies to build partnerships and implementation
opportunities around green infrastructure.
Description: Explore possibilities for including relevant green infrastructure-related
technologies and approaches in all federal activities.
Priority: High
Responsible Entities: U.S. EPA, Federal Highway Administration, U.S. Forest
Service, U.S. Department of Agriculture, and other interested parties are encouraged
to participate.
Timeframe: Begin FY08
Contact: Robert Goo, U.S. EPA
27
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Implementation Framework
Coordination and Communication
To date, representatives from the six organizations that signed the Statement of Intent,
including American Rivers, Association of State and Interstate Water Pollution Control
Administrators, the Low Impact Development Center, National Association of Clean Water
Agencies, Natural Resources Defense Council and U.S. EPA, have served as a Steering
Committee for this green infrastructure effort. Coordination and communication among the
partners on specific topics has been relatively frequent, largely via conference calls and e-
mails. Conference calls and e-mails are likely going to continue to be the primary means of
communication for the Steering Committee, as well as the signatories of the Statement of
Support, but a more formal coordination framework is currently being developed to ensure
that everyone who is interested can participate.
Current plans include maintaining the existing steering committee as the core coordinating
group, perhaps with a few membership additions. However, formalizing our networks to
communicate with other parties is very important. To that end, U.S. EPA is developing a
network of contacts for each of its D.C. and regional offices; these contacts are being
included on the green infrastructure website contacts page as they are identified. These
individuals will be responsible for communicating relevant information within their offices,
and bringing important information to the attention of the green infrastructure collaborative.
U.S. EPA is also appointing a green infrastructure coordinator to track efforts and facilitate
ongoing activity.
At the same time, the partners are discussing development of an electronic means of
communication among the larger partnership (all signatories to the Statement of Support),
which continues to grow. In addition, discussions are underway about whether
communication tools will include an e-mail distribution list, a listserve, or some other
mechanism. The website will also be used to keep interested parties informed about ongoing
activities.
Project-specific teams will manage their own efforts and create project-specific
communication networks. Participation in any effort or discussion will be open to the extent
legal restrictions (e.g., enforcement negotiations) do not preclude it.
28
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Determining Success
The success of individual projects and tasks will depend on the objectives of each project. In
some cases producing stipulated projects within reasonable timeframes will accomplish
relevant objectives. However, there are several major milestones that will indicate that green
infrastructure is attaining status as a mainstream approach to managing wet weather:
o Notable numbers of MS4 permits, injunctive relief portions of enforcement
settlements, and long-term control plans (enforceable documents) include provisions
that facilitate or require green infrastructure approaches.
o EPA regional offices will set and annually evaluate goals for incorporating green
infrastructure in the MS4 and CSO permitting and enforcement programs.
o Increasing numbers of communities embrace green infrastructure as a key component
of ongoing upgrades to their critical water infrastructure, as evidenced by adoption of
progressive ordinances, and implementation of cutting-edge projects.
o Increasing implementation of green infrastructure technologies as tracked by relevant
industries and commercial vendors (e.g., acres of pervious pavement, square feet of
green roofs, numbers of rain barrels and cisterns in use).
o Research data indicate positive outcomes in terms of technology performance on
multiple fronts and water quality improvements.
o Increasing number of SRF applications proposing to utilize green infrastructure
approaches.
The steering committee agrees to develop a tracking system to compile this information, and
will also refine measures of success as more useful data become obtainable.
Keeping the Action Strategy Updated and Efforts Underway
The steering committee will convene on a regular basis (e.g., quarterly) to discuss progress,
projects, and needs. Where new action is deemed necessary, decisions will be made about
who will be involved and how and when the action will be implemented.
U.S. EPA commits to keeping the website and the action strategy document up to date, as
those are important communication tools for this effort. U.S. EPA also commits to
convening steering committee forums, compiling activities and accomplishments reported to
or through the committee, and communicating other important information to the larger
partnership as long as those efforts are within the purview of the agency.
29
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% UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
\ X?fl7Z j WASHINGTON, D.C. 20460
MAR 5 2007
OFFICE OF
WATER
MEMORANDUM
SUBJECT: Using Green Infrastructure to Protect Water Quality in Stormwater,
CSO, Nonpoint Source and other Water Programs
FROM: Benjamin H. Grumbles
Assistant Administrator
TO: EPA Regional Administrators
Green infrastructure can be both a cost effective and an environmentally preferable
approach to reduce stormwater and other excess flows entering combined or separate sewer
systems in combination with, or in lieu of, centralized hard infrastructure solutions. EPA Water
Programs are in a pivotal position to exert leadership in the consistent and reliable
implementation of green infrastructure approaches. This memo is to highlight opportunities for
the Regions, States, and Headquarters efforts to increase the development and use of green
infrastructure in water program implementation.
Several cities, searching for alternatives to traditional hardscape solutions to wet weather
discharge problems, have initiated some green infrastructure approaches. The Natural Resources
Defense Council (NRDC) has recently published a document with information and case studies
on these efforts. I strongly support the use of green infrastructure approaches described in the
NRDC report and I suggest you share the report with States and promote other tools for green
infrastructure. Rooftops to Rivers: Green strategies for controlling stormwater and combined
sewer overflows (NRDC, June 2006) is available at:
http://www.nrdc.org/water/pollution/rooftops/contents.asp
Green infrastructure approaches essentially infiltrate, evapotranspirate or reuse
stormwater, with significant utilization of soils and vegetation rather than traditional hardscape
collection, conveyance and storage structures. Common green infrastructure approaches include
green roofs, trees and free boxes, rain gardens, vegetated swales, pocket wetlands, infiltration
planters, vegetated median strips, reforestation, and protection and enhancement of riparian
buffers and floodplains. Green infrastructure can be used where soil and vegetation can be
worked into the landscape. It is most effective when supplemented with other decentralized
storage and infiltration approaches, such as the use of permeable pavement, and rain barrels and
cisterns to capture and re-use rainfall for watering plants or flushing toilets. These approaches
can be used to keep rainwater out of the sewer system to reduce sewer overflows and to reduce
the amount of untreated stormwater discharging to surface waters. Green infrastructure
Internet Address (URL) • httpY/www.epa gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
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facilitates or mimics natural processes that also recharge groundwater, preserve baseflows,
moderate temperature impacts, and protect hydrologic and hydraulic stability.
Green infrastructure has a number of benefits:
• Cleaner Water - Vegetation and green space reduce the amount of stormwater runoff and, in
combined systems, the volume of combined sewer overflows.
• Enhanced Water Supplies - Most green infiltration approaches result in stormwater
percolation through the soil to recharge the groundwater and the base flow for streams.
• Cleaner Air - Trees and vegetation improve air quality by filtering many airborne pollutants
and can help reduce the amount of respiratory illness.
• Reduced Urban Temperatures - Summer city temperatures can average 10°F higher than
nearby suburban temperatures. High temperatures are linked to higher ground level ozone
concentrations. Vegetation creates shade, reduces the amount of heat absorbing materials
and emits water vapor - all of which cool hot air.
• Increased Energy Efficiency - Green space helps lower ambient temperatures and helps
shade and insulate buildings, decreasing energy needed for heating and cooling.
• Community Benefits - Trees and plants improve urban aesthetics and community livability by
providing recreational and wildlife areas and can raise property values.
• Cost Savings - Green infrastructure may save capital costs on digging big tunnels and
stormwater ponds, operations and maintenance expenses for treatment plants, pipes, and
other hard infrastructure; energy costs for pumping water; and costs of wet weather treatment
and of repairing stormwater and sewage pollution impacts, such as streambank restoration.
The Office of Water is working with a coalition of organizations, including the Natural
Resources Defense Council, the National Association of Clean Water Agencies, and the Low
Impact Development Center, to develop additional strategies for green infrastructure approaches
to water quality challenges. As those strategies take shape, we will send you additional tools and
information on implementing green infrastructure in our water programs.
I am pleased that EPA Regions and States are looking for opportunities to incorporate
green infrastructure. We would be very interested in hearing about your efforts, and to the extent
they can be applied elsewhere, assist in disseminating information and tools. If you have any
questions, please contact me or have your staff call Jenny Molloy at (202) 564-1939 with any
questions, comments, ideas or information on green infrastructure approaches.
cc: Water Division Directors
OW Office Directors
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Green Infrastructure
Statement of Intent
U.S. Environmental Protection Agency (EPA)
and
National Association of Clean Water Agencies (NACWA)
Natural Resources Defense Council (NRDC)
Low Impact Development Center (LID)
Association of State and Interstate Water Pollution Control Administrators
(ASIWPCA)
April 19, 2007
Introduction
This Statement of Intent is entered into and between the U.S. Environmental Protection
Agency (EPA) and the following organizations in recognition of the Statement of Support
for Green Infrastructure (attached) and the efforts of all supporting organizations thereto:
National Association of Clean Water Agencies, Washington, DC; Natural Resources
Defense Council, Washington, DC; the Low Impact Development Center, Beltsville,
MD; and the Association of State and Interstate Water Pollution Control Administrators,
Washington, DC.
Purpose
The purpose of this Statement is to formalize a collaborative effort among the signatory
organizations in order to promote the benefits of using green infrastructure in protecting
drinking water supplies and public health, mitigating overflows from combined and
separate sewers and reducing stormwater pollution, and to encourage the use of green
infrastructure by cities and wastewater treatment plants as a prominent component of
their Combined and Separate Sewer Overflow (CSO & SSO) and municipal stormwater
(MS4) programs. The Statement is intended to describe and facilitate cooperation,
collaboration, coordination, and effective communication among the signatory
organizations. We encourage other organizations that support green infrastructure to join
us in this initiative.
Background
Many communities in the United States are looking for ways to reduce overflows from
sewer systems and stormwater discharges. Overflows occur when separate sewage
and/or combined sewage and stormwater pipes overflow due to rainfall, other wet
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weather events, or system deterioration. In the late 20th century, most cities that
attempted to reduce sewer overflows did so by separating combined sewers, expanding
treatment capacity or storage within the sewer system, or by replacing broken or decaying
pipes. More recently, a number of cities and utilities have recognized that sewer
overflows can also be reduced effectively by diverting stormwater from the sewer system
and directing it to areas where it can be infiltrated, evapotranspirated or re-used. These
approaches are often referred to as "green infrastructure" because soil and vegetation are
used instead of, or in addition to, pipes, pumps, storage tunnels, and other "hard
infrastructure" that is traditionally used to store and treat the combined sewage and
stormwater. Green infrastructure can also be used to reduce stormwater discharges and
help to restore the natural hydrology, water quality and habitat of urban and suburban
watersheds.
Green infrastructure approaches currently in use include green roofs, trees and tree boxes,
rain gardens, vegetated swales, pocket wetlands, infiltration planters, vegetated median
strips, reforestation, and protection and enhancement of riparian buffers and floodplains.
Green infrastructure can be used almost anywhere where soil and vegetation can be
worked into the urban or suburban landscape. Green infrastructure is most effective
when supplemented with other decentralized storage and infiltration approaches, such as
the use of permeable pavement and rain barrels and cisterns to capture and re-use rainfall
for watering plants or flushing toilets. These approaches can be used to keep rainwater
out of the sewer system so that it does not contribute to a sewer overflow and also to
reduce the amount of untreated stormwater discharging to surface waters. Green
infrastructure also allows stormwater to be absorbed and cleansed by soil and vegetation
and either re-used or allowed to flow back into groundwater or surface water resources.
Objectives
The objectives of this Statement are to:
• Affirm the belief by the signatory organizations in the value of green infrastructure as
both a cost effective and an environmentally preferable approach to reduce
stormwater and other excess flows entering combined or separate sewer systems in
combination with, or in lieu of, centralized hard infrastructure solutions;
• Establish a framework for working together to advance an understanding of green
infrastructure as a tool for reducing overflows from sewer systems and stormwater
discharges and to encourage and promote their wider application;
• Identify partnership opportunities between the signatory organizations; and
• Develop strategies to promote the use of green infrastructure by cities and utilities as
an effective and feasible means of reducing stormwater pollution and sewer
overflows such as:
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o Developing models for all components of green infrastructure and make them
available nationwide.
o Exploring opportunities and incentives for the use of green infrastructure
provisions in MS4 permits and CSO Long Term Control Plans (LTCPs),
including as a component of injunctive relief provisions of enforcement
actions;
o Developing memoranda and guidance materials, including language for the
NPDES permit writer's manual, that would explain how regulatory and
enforcement officials should evaluate and provide appropriate credit for the
use of green infrastructure in meeting Clean Water Act requirements;
o Recognizing the most effective and innovative uses of green infrastructure to
meet Clean Water Act goals through EPA awards or recognition programs;
o Providing technical assistance, training, and outreach to potential users of
green infrastructure, including states, cities, counties, utilities, environmental
and public health agencies, engineers, architects, landscape architects,
planners and nongovernmental organizations;
o Establishing a web-based green infrastructure resource center at EPA to assist
communities in complying with requirements for combined sewer overflows
and municipal stormwater permits and evaluating the multiple environmental
benefits that green infrastructure can provide; and
o Developing tools to assist local green infrastructure programs with outreach,
training, model development and application, planning and design,
monitoring, and plan review.
Recognition: The signatory organizations intend to develop strategies to identify,
encourage, and recognize innovative and effective use of green infrastructure.
Communication: The signatory organizations intend to communicate widely about this
Statement with their constituencies and encourage them to focus increased attention to
green infrastructure development.
Note: All actions that EPA may take in furtherance of this statement are subject to the availability
of appropriated funds and the parties to this agreement will not submit a claim to EPA for
compensation solely on the basis of this agreement. In signing this statement, none of the
organizations listed above, including EPA, are obligating funds nor making any commitment to
provide funding to any organization or individuals in the future. Further, EPA cannot endorse the
sale or purchase of products or services developed by the participating organizations. This
Statement does not create any right or benefit, substantive or procedural, enforceable by law or in
equity against the other Signatory organizations or EPA, their officers or employees, or any other
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person. This Statement does not apply to any person outside of the other Signatory
Organizations and EPA. Nothing in this Statement of Intent creates an exception to EPA policies
on competition for assistance agreements or procurement contracts.
STEPHEN L. JOHNSON Date
Administrator
U.S. Environmental Protection Agency
DICK CHAMPION Date
National Association of Clean Water Agencies
NANCY SIGNER Date
Natural Resources Defense Council
NEIL WEINSTEIN Date
Low Impact Development Center
DANA AUNKST Date
Association of State and Interstate
Water Pollution Control Administrators
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Stakeholder Statement of Support for Green Infrastructure
Purpose
To bring together organizations that recognize the benefits of using green infrastructure
in mitigating overflows from combined and separate sewers and reducing stormwater
pollution and to encourage the use of green infrastructure by cities and wastewater
treatment plants as a prominent component of their Combined and Separate Sewer
Overflow (CSO & SSO) and municipal stormwater (MS4) programs.
Goals
Green infrastructure can be both a cost effective and an environmentally preferable
approach to reduce stormwater and other excess flows entering combined or separate
sewer systems in combination with, or in lieu of, centralized hard infrastructure solutions.
The undersigned organizations support:
• Use of green infrastructure by cities and utilities where it is an effective and feasible
means of reducing stormwater pollution and sewer overflows;
• Development of models to quantify stormwater detention, retention, and filtration
potential of green infrastructure to better identify opportunities to successfully use
green infrastructure in CSO, SSO, MS4 and nonpoint source programs;
• Monitoring to verify the amount of CSO, SSO, and stormwater discharge reduction
that cities obtain through using green infrastructure;
• Measurement of economic and environmental benefits realized from the use of green
infrastructure in sewer systems and quantification of its life-cycle costs;
• Increased federal, state, and local funding for green infrastructure initiatives;
• Elimination of barriers to the incorporation of green infrastructure in stormwater and
sewer system programs;
• Development and funding of a plan to identify research needs to further green
infrastructure;
• Preparation of guidance documents to assist cities and wastewater treatment plants in
developing green infrastructure initiatives in their CSO, SSO, and MS4 programs;
and
• Development of model provisions to incorporate green infrastructure into CSO and
MS4 permits; SSO capacity, management, operations, and maintenance plans; and
consent decrees and other enforcement vehicles.
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Background
Many communities in the United States are looking for ways to reduce overflows from
sewer systems and stormwater discharges. Overflows occur when combined sewage and
stormwater pipes overflow due to rainfall or other wet weather events. In the late 20th
century, most cities that attempted to reduce sewer overflows did so by separating
combined sewers, expanding treatment capacity or storage within the sewer system, or by
replacing broken or decaying pipes. More recently, a number of cities and utilities have
recognized that sewer overflows can also be reduced effectively by diverting stormwater
from the sewer system and directing it to areas where it can be infiltrated,
evapotranspirated or re-used. These approaches are often referred to as "green
infrastructure" because soil and vegetation are used instead of, or in addition to, pipes,
pumps, storage tunnels, and other "hard infrastructure" that is traditionally used to store
and treat the combined sewage and stormwater. Green infrastructure can also be used to
reduce stormwater discharges and help to restore the natural hydrology, water quality and
habitat of urban and suburban watersheds.
Green Infrastructure Benefits
Green infrastructure approaches currently in use include green roofs, trees and tree boxes,
rain gardens, vegetated swales, pocket wetlands, infiltration planters, vegetated median
strips, reforestation, and protection and enhancement of riparian buffers and floodplains.
Green infrastructure can be used almost anywhere where soil and vegetation can be
worked into the urban or suburban landscape. Green infrastructure is most effective
when supplemented with other decentralized storage and infiltration approaches, such as
the use of permeable pavement and rain barrels and cisterns to capture and re-use rainfall
for watering plants or flushing toilets. These approaches can be used to keep rainwater
out of the sewer system so that it does not contribute to a sewer overflow and also to
reduce the amount of untreated stormwater discharging to surface waters. Green
infrastructure also allows stormwater to be absorbed and cleansed by soil and vegetation
and either re-used or allowed to flow back into groundwater or surface water resources.
Green infrastructure has a number of other environmental and economic benefits in
addition to reducing the volume of sewer overflows and stormwater discharges.
• Cleaner Water - Vegetation and green space reduce the amount of stormwater runoff
and, in combined systems, the volume of combined sewer overflows.
• Enhanced Water Supplies - Most green infiltration approaches involve allowing
stormwater to percolate through the soil where it recharges the groundwater and the
base flow for streams, thus ensuring adequate water supplies for humans and more
stable aquatic ecosystems.
• Cleaner Air - Trees and vegetation improve air quality by filtering many airborne
pollutants and can help reduce the amount of respiratory illness.
• Reduced Urban Temperatures - Summer city temperatures can average 10°F higher
than nearby suburban temperatures. High temperatures are linked to higher ground
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level ozone concentrations. Vegetation creates shade, reduces the amount of heat
absorbing materials and emits water vapor - all of which cool hot air.
• Increased Energy Efficiency - Green space helps lower ambient temperatures and,
when incorporated on and around buildings, helps shade and insulate buildings from
wide temperature swings, decreasing the energy needed for heating and cooling.
• Community Benefits - Trees and plants improve urban aesthetics and community
livability by providing recreational and wildlife areas. Studies show that property
values are higher when trees and other vegetation are present.
• Cost Savings - Green infrastructure may save capital costs associated with digging
big tunnels and centralized stormwater ponds, operations and maintenance expenses
for treatment plants, pumping stations, pipes, and other hard infrastructure; energy
costs for pumping water around; cost of treatment during wet weather; and costs of
repairing the damage caused by stormwater and sewage pollution, such as streambank
restoration.
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