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Runoff Ramblings author David Hirschman, Program Director at the Center, is at it again. This time he asks whether MS4s are taking an unfair share of the regulatory burden through a conversation with "MS-4-lorn"
Carrying A Disproportionate Regulatory Burden?
An (ongoing) Debate Between MS-4-lorn
. .an admission. Prior to joining the
Center, I worked for a moderate-size county that became an MS4 during my tenure
in the Public Works Department. As a
result, I tend to be sympathetic to the plight of local governments struggling
to comply with the permit regulations. The vagaries of local government
operation do not often mesh so neatly with the six minimum measures.
have heard the argument that MS4s are shouldering a disproportionate share of
water quality responsibility compared to other sectors, especially given the
increasing trend to link TMDL waste load allocations to MS4 permits (see Figure
1). On a watershed scale, MS4s only make
up a certain percentage of the land area. What about loads from agriculture, industrial sites, towns, cities, and
counties that are not MS4s (yet)? Do
these sectors have permit obligations commensurate with their contributions to
The ants go
marching. . .why is the MS4
Carrying so much
extra? (photo courtesy: USDA)
general attitude of the overburdened MS4 can be personified as "MS4-lorn." The MS4 alter-ego, "MS4-titude," boldly states that, indeed, it is time for MS4s to
step up to the plate and take care of polluted runoff from municipal streets,
parking lots, lawns, and construction sites. I think I smell a debate brewing.
MS4-lorn: Look, we MS4s make up approximately 2% of the total
land area of the U.S.
(U.S. EPA, 2005), yet we have almost all of the pollutant reduction
responsibility for developed areas. What
gives? Even if we were completely
successful with the task, what about the other 98% of the country?
MS4-titude: Well, we may be 2% of the land area, but we also
represent 70% or more of the population (U.S. EPA, 2005) and probably a whole
lot of the impervious cover. Urban
stormwater is also the primary source of impairment for 13% of rivers, 18% of
lakes, and 32% of estuaries (NRC, 2008). In this regard, we are uniquely responsible
for managing the impacts of urban stormwater.
MS4-lorn: Be that as it may, there are still a lot of other
pollutant sources or sectors (e.g., agriculture, industry, non-MS4 cities and
towns) that don't have the same permit obligations. From a permit standpoint, we are treated just
like a point source, yet our system is so much more complex than a pipe coming
out of a factory. The sources of
pollutant are dispersed across the landscape, and our ability to influence the
quality of the ultimate receiving water is quite limited.
MS4-titude: That means it's time to get with the program and
figure out how to have that type of influence. We have other types of infrastructure - water, wastewater,
transportation, solid waste - where we have to exercise that type of control,
so why not stormwater? The best
management practices (BMPs) are well known, so the real issue is figuring out
implementation. Often, that's a problem
of political will, and not technical know-how.
MS4-lorn: You are absolutely correct about political will, MS4-titude,
and I'll also throw in local budgets. In
the world of our elected officials, stormwater just doesn't rank when stacked
against education, public safety, transportation, and other local concerns. I've tried to talk to them about the permit
responsibilities, but it's a tough sell. If the feds and state want this level of implementation, they should
MS4-titude: Dream away, MS4-lorn. I agree that elected officials are a tough audience, though. In our community, we started with some high
profile stormwater projects at schools, and included hands-on activities and
tours for students, local staff, developers, and site designers. Once the elected officials could see
stormwater in action, it became something they were proud of and understood
better. When discussing these issues
with elected officials and the public, think about using "Water Words That
Work," such as the advice at the following website: http://waterwordsthatwork.com/
MS4-lorn: MS4-titude - your optimism is quite annoying! Well, how about this -- the regulators are now tying TMDLs to MS4
permits. Some of the newer permits
require the retrofit of pre-existing impervious cover (not just new development
and redevelopment). The tough-talkers
are even saying there will be a waste load reduction allocation for existing
development. How can we possibly go into
pre-existing neighborhoods, shopping centers, and commercial areas and mandate
some type of stormwater retrofit? Surely, even you must think that this represents egregious regulatory
Well, MS4-lorn, it's time to stop
whining and think creatively.
MS4-lorn: Oh, give me a break. . .
MS4-titude: Create a cost-share or tax incentive program for
existing commercial property owners. Explore a pollutant trading program whereby new development (or
redevelopment) offsets some of its pollutant load by paying for high priority
retrofits to existing developed areas. Work with your transportation, parks, and schools departments to build
retrofits into capital improvement projects. Seek "outside-the-box" retrofits such as stream, riparian, and wetland
restoration, residential downspout disconnection programs, stormdrain
stenciling, pollution prevention programs, etc. With a little creativity, we MS4s can make a big difference to our
streams and waterways.
OK, enough bickering. You've both made some interesting points.
take a step back and look at a particular case study. I happen to live in the James River Watershed
in Virginia. It is a large watershed (over 10,000 square
miles) with 17 MS4 communities (11 cities and 6 counties). It also has large expanses of farmland,
forest, and many smaller non-MS4 communities.
to a quick analysis, MS4s comprise approximately one-quarter of the land area
in the watershed, but nearly three-quarters of the population and over 60% of
the impervious cover (see Figure 2). Recent models from the Chesapeake Bay Program indicate that developed
areas contribute approximately 20% of nutrient loads to the Bay (U.S. EPA,
. .are MS4s disproportionately burdened with permits and regulations? Certainly, as MS4-lorn and MS4-titude have
argued adeptly, the answer lies in your perspective. However, MS4s may not have the luxury to
argue interminably about this, especially if the EPA or state auditors show
up. So, some attitude of "getting with
the program" is advisable. This is also
justified from a water quality standpoint, if MS4s comprise a majority of the
populations and a substantial percentage of impervious cover in our watersheds.
the future, "watershed-based permitting," as recommended by the National
Research Council, may make the whole system more rational (NRC, 2008). In the meantime, the base level of stormwater
literacy among MS4s certainly needs to ramp up.
I become a turncoat, and changed my loyalties concerning MS4s? Perhaps so, but I also think this represents
a combination of pragmatism (it is required), idealism (we deserve and can
achieve cleaner water in our municipalities), and impatience (let's stop
arguing and start solving problems).
are your thoughts? Please email us at email@example.com and let us know what you
think about the assertions of MS4-lorn, MS4-titude, or your own musings.
J. Hirschman, Program Director
Note: Municipal separate storm sewer
systems (MS4s) are localities and other institutions that must obtain and
comply with federal and state pollutant discharge permits. Phase 1 MS4s represent larger communities
(roughly greater than 100,000 in population), while Phase 2 MS4s are smaller
communities (roughly greater than 50,000). In essence, MS4s must develop local stormwater programs to address
discharges from the municipal system into receiving waters.
Commonwealth of Virginia. 2005. Chesapeake
Bay Nutrient and Sediment Reduction Tributary Strategy for the James River, Lynnhaven and Poquoson Coastal Basins.
River Association. About
the James webpage.
National Research Council.
2008. Urban Stormwater Management in the United States. The
National Academies Press.
U.S. Census Bureau. State
and County QuickFacts.
U.S. Environmental Protection Agency. 2009. Chesapeake
Bay TMDL Resource Library, Slide: N and P
values from the 2008 Scenario of Phase 5.2 Watershed Model. http://www.epa.gov/reg3wapd/tmdl/ChesapeakeBay/ResourceLibrary.html#keydocs
U.S. Environmental Protection Agency. 2005. Storm Water Phase II Final Rule. Urbanized Areas: Definition and
Description. EPA 833-F-00-004, Fact
Sheet 2.2. December 1999 (revised December 2005).
Is Watershed Planning the
key to fixing MS4 Permits?
The Municipal Separate Storm Sewer System (MS4) Permit
Program has been in existence for over 15 years. While the program has resulted
in the construction of thousands of management practices and the protection of
thousands of acres of sensitive lands, local state and federal regulators as
well as the environmental community give the MS4 Program low marks regarding
its overall success in meeting the goals of the Clean Water Act (CWA). To their
credit, EPA is planning to initiate national rulemaking for establishing a
comprehensive program which would not only reduce stormwater discharges from
new and redevelopment but also significantly enhance the MS4 Program.
After holding several listening sessions to solicit
stakeholder input and publishing a request for written comments in the Federal
Register, EPA is particularly interested in comments on Best Management
Practice performance and costs, post construction runoff control criteria and
guidance on retrofitting. Their hope is
to provide greater consistency and standardization among Phase I and II
The Center for Watershed Protection lauds EPA for this
effort and appreciates the need to focus on these specific areas. However,
there should be as much effort spent on program integration as on improving
individual programs. The program-centric approach to the MS4 permits is one of
its chief failings and has resulted in inconsistent standards of success. For instance, MS4 permits might require a
municipality to develop watershed
restoration plans and maintain a program for controlling post construction
runoff from development. However there
is no requirement to integrate these programs. Therefore, the impacts from new development are not accounted for in
watershed restoration plans, making it almost impossible for the permit to
achieve a water quality-based outcome.
We suggest that EPA consider a comprehensive watershed
planning approach as the framework for the MS4 Program. The planning goal should be tied to attaining
water quality standards (e.g., TMDLs). However, the singular focus of traditional TMDL is overly simplistic and contrary to what is
needed to restore ecosystems which is the goal of the CWA.
and local governments are adopting a more comprehensive, decentralized approach
to managing stormwater by integrating site development and low impact
development techniques. Care must be taken not to view site level solutions as
the panacea for managing our urban watersheds. Site-level solutions cannot
solve system-wide problems. What is needed is a wider planning view that
encompasses the ecosystem at the watershed scale. The cost of urban BMPs is
exorbitant and it will be almost impossible to justify their widespread
implementation unless their benefits are broadened to include more
comprehensive societal benefits. This will require a reconciliation of natural
and built ecosystem goals, which is one of the basic tenets of the
A "sustainable" watershed plan first must identify sensitive
ecosystem features within a watershed and protect and or restore these elements.
These areas must become sacrosanct features of the landscape that planners must
learn to incorporate into their building envelopes and transportation
infrastructure with the greatest care. Here is where flexibility is the key,
using an adaptive management process to find the best mix of mitigation and
restoration measures to meet ecosystem goals. Tools within this tool-box include
intra- basin "trading" and offsetting, environmental site design, and
Finding new and improved technologies is an essential part
of this strategy, and science plays a key role in determining which practices
work best and their collective benefit at the ecosystem-watershed scale. Both the
public and key decision-makers have historically viewed science as the enemy of
(BMP) implementation because of the time and resources associated with quantifying
benefits. However, this view is the
enemy of innovation as an iterative science-based process is essential to
determine the most optimal path to reach our restoration goals.
We are at a critical juncture in the history of the MS4
Program. The Program has failed to meet its goals because of its
program-centric approach and lack of a common yardstick for measuring success.
We feel strongly that the program must adopt a watershed planning approach that
focuses on ecosystem endpoints. The ecosystem must include the natural as well
as the built environment and the value of restoration must be integrated to
recognize broader societal benefits. Watershed
management plans are not static and must continually seek-out new solutions
that are validated by scientific process.
-- Bill Stack, Deputy Director of Programs
The schedule of webcasts for 2010 can be found here at www.cwp.org/Webcasts.
The next webcast is entitled "The Watershed Treatment Model, a TMDL and MS4 Tracking Tool." This webcast is highly recommended for communities seeking ways to track their progress on TMDLs. Check out our Webcast website for the newest topics, information on CEUs,
details about speakers, and to register to attend. To register by mail and
review a brochure for the 2009 Webcasts, click here.
And remember, you can save on webcast costs by becoming a members of AWSPs.
Where We're Speaking
Nonpoint Source Pollution Conference May 17-19, 2010. Plymouth, MA
Drescher will speak about our Coastal Stormwater
Battiata will speak about
Runoff Reduction Method for stormwater management.
River Rally 2010 May 21-24, 2010. Snowbird, UT. Organized by River Network.
will speak about stormwater retrofitting practices.
Seipp will speak about
Urban Watershed Forestry.
Coastal States Society's 22nd International Conference, Shifting Shorelines: Adapting to the Future June 13-16, 2010. Wilmington, NC
Drescher will speak about our Coastal Stormwater
2010 Ohio Stormwater Conference June 10-11, 2010. Sandusky, OH
Dave Hirschman will be the keynote speaker
for this conference!
2010 StormCon August 1 -5, 2010. San Antonio, TX
Hirschman will speak about Adopting Stormwater BMPs for Tropical
Watersheds; and Implementing Runoff Reduction Through State
Lilly will speak about
an Impervious Cover TMDL project in Connecticut.
Schneider will speak about
the remaking of our Better Site Design guidance for
|Conferences and Abstracts|
July 15-16, 2010. Three national experts in bioretention research are joining forces to
present the "Bioretention Research & Design Summit: Ask the Researchers." Drs. Allen Davis (University of Maryland),
William (Bill) Hunt (North Carolina State University),
and Robert Traver (Villanova
University) have a
combined over 30 years of bioretention research among them. A Summit
will take place in Raleigh, North
Carolina on June 29-30, 2010 and again in Annapolis, Maryland
on. A third Summit is being planned for Philadelphia, Pennsylvania
either later this year or in 2011. For more information click here.
18-21 July 2010. The 65th SWCS Annual Conference and Call for Presentations and Symposia: Ecosystem Services: Applications for Conservation Science, Policy, and Practice. All
conservation professionals are encouraged to submit abstracts for oral and
poster presentations as well as symposia descriptions for the 2010 Soil and
Water Conservation Society Annual Conference to be held in St. Louis, Missouri.
Abstracts are due by December 17, 2009.
23-27 August 2010. 2010 Watershed Management Conference: Innovations in Watershed Management Under Land Use and Climate Change will be held in Madison, Wisconsin. This conference will highlight innovative approaches for
water resources under climate and land use change. Relevant topics
hydrologic measurement and modeling, integrated and/or adaptive water
management, aquatic ecosystem restoration, risk-based design, and the
regional predictions of climate change. Call for Papers deadline is April 21, 2010.
Nov 1-4, 2010 AWRA Annual Water Resources Conference which will
be held at the Loews Philadelphia Hotel,
Philadelphia, Pennsylvania. Call for Abstracts deadline is May 14, 2010.
2010 Partners in Community Forestry National Conference, November 9-11, at the Loews
"Cool Links" provides information on some new or new-found resources that are helpful to watershed managers and stormwater professionals.
1) The wonderful features of these websites are that they use a
wiki approach to information on watersheds. For the techno-impaired, a wiki
approach allows multiple people to edit/ add information with the
goal of achieving more accuracy, depth, and breadth of information. The result can be a spectacular array of information on streams and rivers. The more widely
used the sites are, the more in-depth the information can be and the more
positive the implications for those collecting data in the areas that they
work. Here are two that we thought were worth checking out.
2) Get your popcorn ready for 15-20 minutes of video on
Stormwater Retrofitting. With some help from professional filmmakers, the
Center for Watershed Protection has developed three videos. Narrated by our own
Greg Hoffmann, the videos include staff Kelly Collins and Chris Swann. Here are the links. Let us know what you
Stormwater Retrofitting, Video 1
Stormwater Retrofitting, Video 2
Stormwater Retrofitting, Video 3
See a nice case study of a Stormwater Pond in the Turkey Branch of Montgomery County. Featuring Bob Hoyt of Montgomery County Maryland's
Department of the Environment, it gives some nice information about how
retrofits are used to treat runoff.
3) Free Webcast Available at EPA
May is American Wetlands Month and EPA is celebrating by
providing interested registrants to a free EPA Watershed Academy Webcast
entitled, "Tools for Protecting Coastal Wetlands" on Tuesday, May 4th
from 1-3pm Eastern time. To register, go to their website www.epa.gov/watershedwebcasts.
4) New Book- Up River by George Ivey
This novel about saving the Awaknee
River in the Southern
Appalachian mountains was recently published by George Ivey. Link
to the website for more information and links to the first few pages of the
novel and reviews.
5) The Chesapeake Stormwater Network has a TECHNICAL BULLETIN No.
8 entitled "The Clipping Point: Turf Cover
Estimates for the Chesapeake Bay Watershed and Management Implications." Check out this article and others here.
6) The California state water resources control board has some great new
ads and posters focused on pet waste and litter that can be downloaded and
Runoff Rundown Team: Hye Yeong Kwon, Karen Cappiella, and contributions from Center staff.