HOW BAD (OR GOOD) IS OUR STORMWATER REALLY? · PDF fileHOW BAD (OR GOOD) IS OUR STORMWATER REALLY? Scott R. Smith July 10, 2015. Click to edit Master title style ... Industrial Areas;

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HOW BAD (OR GOOD) IS OUR STORMWATER REALLY?Scott R. Smith July 10, 2015


STORMWATER QUALITY IS HIGHLY VARIABLE

© Copyright 2014 Smith Management Group May 8, 2013 • 2


Questions to ask yourself:• Am I budgeting appropriately? The

sources that impact stormwater are variable.

• Am I focusing on the correct controls and enforcement mechanisms?

• What resources can I use to ensure that taxpayers are getting the most for their investment into the MS4 program?

• Will projects I undertake actually improve water quality?

STORMWATER QUALITY IS HIGHLY VARIABLEOverview of Today’s Discussion

October 1, 2015 • 3© Copyright 2015 Smith Management Group


Stormwater Reality• Urban stormwater is one of several sources that

can impact waterways

municipal discharges

runoff from rural areas

• Stormwater is generated from numerous sources

Residential Areas;

Commercial Sources;

Industrial Areas;

Roads;

Highways;

Bridges.




Beware of Stormwater Sales Pieces! • According to EPA, waterways and receiving

waters near urban & suburban areas are often adversely affected by urban stormwater runoff.

The degree & type of impact varies from location to location.

Urban stormwater runoff (can) affect water quality, water quantity, habitat and biological resources.

While water quality impacts are often unobserved by the general public…other impacts are more visible.




PAST EMPHASIS FOR THE MS4 PERMITTING PROGRAMS

© Copyright 2015 Smith Management Group October 1, 2015 • 6


Two of the six minimum control measures focus on

construction

PAST EMPHASIS OF THE MS4 PERMITTING PROGRAMContent of the Permit

May 8, 2013 • 7© Copyright 2015 Smith Management Group


5 of the 22 pages of the Kentucky Phase II MS4 permit contain requirements for the construction industry –that’s

almost 25%!

An MS4 program to reduce runoff from construction sites includes developing:

• An ordinance,

• Requirements to implement erosion and sediment control best management practices (BMPs),

• Requirements to control other waste at the construction site,

• Procedures for reviewing construction site plans,

• Procedures to receive and consider information submitted by the public, and

• Procedures for inspections and enforcement of stormwater requirements at construction sites.

In addition to the stormwater requirements that Phase II MS4s place on construction sites, construction operators must also apply for NPDES permit coverage if their project disturbs at least one acre and discharges to a waterbody.

PAST EMPHASIS OF THE MS4 PERMITTING PROGRAMContent of the Permit


Click to edit Master title stylePAST EMPHASIS OF THE MS4 PERMITTING PROGRAMEPA’s Guidance


“Sediment runoff rates from construction sites are typically 10 to 20 times greater than those from agricultural lands, and 1,000 to 2,000 times greater than those of forest lands. During a short period of time, construction activity can contribute more sediment to streams than can be deposited over several decades, causing physical and biological harm to our Nation’s waters.”


WHAT ARE THE CURRENT PROBLEMS?


Click to edit Master title styleWHAT ARE THE CURRENT PROBLEMS?EPA says there is still a problem…

“In many parts of the country, permitting agencies have issued several rounds of stormwater permits. Notwithstanding these developments, stormwater discharges remain a significant cause of water quality impairment in many places, highlighting a continuing need for more meaningful WLAs and more clear, specific, and measurable NPDES permit provisions to help restore impaired waters to their beneficial uses.”

From EPA Nov. 26, 2014 memo Revisions to the November 22, 200 Memorandum “Establishing Total Maximum Daily Load (TMDL) Wasteload Allocations (WLAs) for Storm Water Sources and NPDES Permit Requirements Based on Those WLAs


Click to edit Master title styleWHAT ARE THE CURRENT PROBLEMS?What does the data show?


Agriculture23%

Unknown22%

Municipal Discharges/Sewage15%

Habitat Alterations (Not Directly Related To Hydromodification)

12%

Resource Extraction10%

Hydromodification9%

KY Probable Sources Contributing to Impairments for Reporting Year 2012

Agriculture Unknown

Municipal Discharges/Sewage Habitat Alterations (Not Directly Related To Hydromodification)

Resource Extraction Hydromodification

Industrial Silviculture (Forestry)

Construction Other

Spills/Dumping Recreation And Tourism (Non-Boating)

Land Application/Waste Sites/Tanks Natural/Wildlife

Atmospheric Deposition

Click to edit Master title styleWHAT ARE THE CURRENT PROBLEMS?What does the data show?



Conclusions from the data:

• The sources are not directly related to construction & development or agriculture.

• The primary problems relate to pathogens, nutrients, and sewage.

• There are issues with point sources.

• Impacts from sewage issues should be identified.

• Agriculture impacts should be realistically assessed.

WHAT ARE THE CURRENT PROBLEMS?What does the data show?



WHAT SHOULD YOU DO MOVING FORWARD?



Look At Your Stormwater With Your Eyes Wide Open

• Know your stormwater system.

• Observe during wet and dry weather conditions.

• Identify all sources with potential impacts.

WHAT SHOULD YOU DO MOVING FORWARD?Overview



Examine “Habitat”• Look for indicators of a “healthy stream”

Obvious areas that are polluted;

Good habitat for “critter” reproduction;

Observed fish and/or “bugs” (macroinvertebrates)

Plenty of dissolved oxygen;

Healthy food web.

• Assess stream buffers.

• Can stream areas habitat be improved?

WHAT SHOULD YOU DO MOVING FORWARD?Specific Considerations



Permit Considerations

• Look for information on streams in or adjacent to your permit (KDOW).

• To adequately address stormwaterissues, waivers to stormwater permits should be available.

• Stormwater permits and requirements should be consistent with EPA regulations. Some cities may choose to do more.




Benchmarking

• Look at information from other cities –including cities in other states and parts of the country.

• Attend conferences to talk with peers.

• Compare your data with neighboring MS4s.




Data collection

• Don’t be afraid to invest early in somestormwater system data.

– Chemistry

– Bugs

– Fish

• Remember Frank Lloyd Wright – “Form follows function”.




Work with sources as partners• Address point source issues

• Develop plans to address sewage impacts

• Work with agriculture

• Help ensure Agriculture Water Quality Plans are in effect

• Prioritize impacts

• Help secure funding




Take monitoring seriously

Analyze data

Consider expenditures of time and money

Work to ensure that enforcement/control efforts provide a ROI

Identify sources of grants or other funding

Build in accountability

WHAT SHOULD YOU DO MOVING FORWARD?Final Checklist


Click to edit Master title styleCONTACT INFORMATION

Scott R. Smith

Smith Management Group

Senior Consultant

[email protected]

(859) 231-8936 ext. 116


mailto:[email protected]


THANK YOUfrom Smith Management Group


LEXINGTON859-231-8936

LOUISVILLE502-587-6482

www.smithmanage.com

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HOW BAD (OR GOOD) IS OUR STORMWATER REALLY? · PDF fileHOW BAD (OR GOOD) IS OUR STORMWATER REALLY? Scott R. Smith July 10, 2015. Click to edit Master title style ... Industrial Areas;