What You Don't Know About 

Georgia's New 6th Edition Green Book

 

BACKGROUND

by T. Luke Owen, PG

 

After years of rigorous testing and analysis of best management practices (BMPs) through a reputable 3rd party testing facility, funding from the United States Environmental Protection Agency (USEPA), and program oversight by the Georgia Soil and Water Conservation Commission (GSWCC) and Technical Advisory Committee (TAC), the new 6th Edition Erosion and Sediment Control (GA E&SC) Manual became official on January 1, 2014. 

The TAC was chaired by nationally recognized expert Dr. Britt Faucette, Ph.D., CPESC, LEED AP and is composed of a carefully selected group of Certified Professionals in Erosion and Sediment Control (CPESC), Professional Engineers (PE), and representatives from the Georgia Department of Transportation (GDOT), GSWCC, US Department of Agriculture Natural Resource Conservation Service (USDA-NRCE), and the Georgia 

Environmental Protection Division (GAEPD).  The 6th Edition E&SC Manual replaced the older 5th Edition E&SC Manual, published in 2000. 

On February 21, 2014, due to a few stakeholder comments presented after the close of the official public comment period, the GSWCC State Board voted to reopen the 6th Edition E&SC 

Manual and testing procedures for public comment. 

 

On July 30th, 2014 a Georgia State Representative (Stakeholder Member) wrote a letter to the GSWCC requesting that they disregard the 6th Edition GA E&SC Manual and return to the 5th Edition.  On August 2, 2014, Dr. Faucette responded to Stakeholder Member with the following Letter of Concern.

 

 

LETTER OF CONCERN

by Dr. Britt Faucette, Ph.D., CPESC, LEED AP

 Hello Stakeholder Member,

In an email sent by you on July 30, you requested the Georgia Soil and Water Conservation Commission (GSWCC) to disregard the 6th Edition of the Georgia Erosion and Sediment Control Manual (GA E&SC) and return to the 5th Edition.

 

As part of the 6th Edition, the GSWCC obtained scientific data through research conducted by a reputable 3rd party, funded by the US Environmental Protection Agency (US EPA), that showed the difference in performance between the highest performing sediment control barriers and the lowest performing sediment control barriers, allowed in the 5th edition, equates to a difference of nearly 1 ton per acre of sediment discharged from land disturbing activities. Considering the number of acres of land disturbance in the state of Georgia (GA) in a given year,

under the Construction General Permit and required under NPDES Phase 2 of the US Clean Water Act, this can equate to the allowance of thousands of tons of sediment released into GA Waters annually. Given the mandate of the GSWCC to protect and improve the quality of state waters in GA, the Stakeholder Member is explicitly requesting the GSWCC to ignore its own mandate and knowingly allow the contribution and potential release of thousands of tons of sediment into GA water bodies, annually, by ignoring this information and returning to the 5th Edition of GA E&SC Manual. It should be noted that the 6th Edition will help to prevent this from occurring and will help to recognize the use of better performing sediment control practices and technologies, which include silt fences. Of the 13 sediment control barriers that were scientifically researched for their performance in sediment removal, the top 4 performing products/practices were silt fence products. It is important to note the 6th Edition continues to support and promote the use of silt fence products. Simultaneously, it also allows a pathway for other, non-silt fence products and innovative technologies to be used. I believe all interested parties would agree that competition in the market place is a good thing and should be encouraged.

These sediment control barriers include a variety of technologies and best management practices already approved by the US EPA National Pollutant Discharge Elimination System (NPDES) National List of Best Management Practices (BMPs), (it should be noted that the State of Georgia has just renewed its NPDES Permit from the US EPA) as well as by the USDA Natural Resource Conservation Service (NRCS), the US Army Corp of Engineers, and AASHTO. As an example, see links below for US EPA and NRCS approvals for compost filter sock and check dam BMPs. In addition, this class of sediment control barriers (often referred to in the industry as sediment retention fiber rolls) are manufactured by most of the largest E&SC product manufactures in the US, are recognized by the largest industry organization in the US, the International Erosion Control Association (IECA), and have already been approved by nearly every other state environmental regulatory agency in the country. 

http://water.epa.gov/polwaste/npdes/swbmp/Compost-Filter-Socks.cfm

http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb1048852.pdf

http://water.epa.gov/polwaste/npdes/swbmp/Check-Dams.cfm

The implementation of performance testing and standards for BMPs is a practice that is actively supported by leading industry organizations, including the IECA, the Erosion Control Technology Council (ECTC), the American Association of State Highway Transportation Officials (AASHTO) National Transportation Product Evaluation Program, and the Water Environment Federation (WEF), as well as a growing number of state agencies. Providing standardized performance testing and benchmarks also allows the engineering and design community to know which BMPs perform well and which do not, thereby helping them make informed decisions to reduce overall risk on their projects and help safe guard land owners from non-compliance with the Federal Clean Water Act. 

 

The P Factor (Support Practice Factor), is part of both the Universal Soil Loss Equation (USLE) and Revised Universal Soil Loss Equation (RUSLE), which were developed by the USDA to predict and determine soil erosion on land disturbing activities. This method has been used for over 50 years. The test

method used in the 6th Edition is modeled after the USDA methodology that was used to create and develop the USLE and all 5 factors used in the USLE, including the P Factor, which is simply the sediment control performance of a device or practice in comparison to a bare soil. This method and similar test methods have been used by the erosion control industry, engineers & designers, and the agricultural industry successfully for many years.

After decades of pressure from all parties with an interest in protecting and improving the quality of state waters in GA, including the E&SC industry, engineers, developers, and environmental organizations, the GSWCC has finally developed a fair, equitable, and scientific way to evaluate and promote practices and products that will help significantly in the effort to protect and improve the state waters of GA, something all of GA's citizens and industries have a profound interest in supporting.

 

Best Regards,

 

Dr. Britt Faucette, Ph.D., CPESC, LEED AP

Director of Research & Technical Services

Filtrexx International

244 Third Ave

Decatur, GA 30030

 

Global Corporate Headquarters:

Filtrexx International

35481 Grafton Eastern Rd

Grafton, OH 44044