amy liu's masters thesis
TRANSCRIPT
EVALUATING SUSTAINABLE STORMWATER MANAGEMENT PLANS:
AN ASSESSMENT OF BEST MANAGEMENT PRACTICES
A Research Paper
Presented to the Faculty of the Graduate School
of Cornell University
In Partial Fulfillment of the Requirements for the Degree of
Master of Regional Planning
by
Amy Liu
August 2012
© 2012 Amy Liu
ABSTRACT
The purpose of this paper is to assess the extent to which municipal-
level stormwater management plans embrace innovative approaches to
addressing surface water runoff and promote water quality. Municipalities
place great value on stormwater management plans and expect them to serve
as agents to achieve ambitious water quality and community-building goals.
Hence, there is a need to assess how elements in these plans advance
municipalities’ goals to determine the level of progress that can be achieved.
To what extent do stormwater management plans promote the process of
actively involving communities while achieving ecological stewardship goals?
This evaluation of their quality draws initial conclusions about their
effectiveness.
iii
BIOGRAPHICAL SKETCH
Amy is interested in how city planning can solve environmental and social
issues. Growing up in an inner-ring suburb helped her realize that suburbs are
the impetus behind much of the environmental and social injustices
experienced by the rest of Americans. As an environmental studies major at
UC Santa Barbara, she learned that humans must try to rectify the ecological
catastrophes we have created. Now, as a city planner, she has acquired the
tools to help communities try to solve these problems.
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ACKNOWLEDGMENTS
It is my pleasure to recognize the people who made this thesis possible. I
became interested in sustainable stormwater management after attending a
session about the Philadelphia Green City, Clean Waters Plan at the 2011
American Planning Association conference in Boston. I am grateful to Glen
Abrams of the Philadelphia Water Department for his inspiration and positivity.
I would like to thank my thesis committee, Stephan Schmidt and Ann Forsyth,
for their guidance and encouragement. I would also like to thank Tina Nelson,
who helped me throughout the process of my thesis. Finally, I am grateful to
Glen Rosazza, my high school Environmental Science teacher, for helping me
discover my passion in life.
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TABLE OF CONTENTS
BIOGRAPHICAL SKETCH .......................................................................................... iii
ACKNOWLEDGMENTS .............................................................................................. iv
TABLE OF CONTENTS ................................................................................................ v
LIST OF FIGURES ....................................................................................................... vi
LIST OF TABLES ......................................................................................................... vii
LIST OF ABBREVIATIONS ....................................................................................... viii
LIST OF DEFINITIONS ................................................................................................ ix
PART 1: INTRODUCTION AND BACKGROUND .................................................... 1
PART 2: METHOD ......................................................................................................... 5
PART 3: CONCLUSION ............................................................................................. 29
REFERENCES ............................................................................................................. 32
vi
LIST OF FIGURES
Figure 1: The Water Cycle ............................................................................................... 3
Figure 2: Artwork by Bill Kelly ..................................................................................... 14
Figure 3: Artwork by Yishu Wang (left) and Alejandro Vidal (right) ........................... 14
Figure 4: Middle school students learn to measure pervious and impervious surfaces . 15
vii
LIST OF TABLES
Table 1: Best Management Practices Scoring Protocol ................................................... 8
Table 2: Evaluation Criteria for Best Management Practices .......................................... 9
Table 3: Best Management Practice: Public Education ................................................. 13
Table 4: Best Management Practice: Public Involvement ............................................. 17
Table 5: Best Management Practice: Illicit Discharge Detection & Elimination .......... 20
Table 6: Best Management Practice: Construction ........................................................ 22
Table 7: Best Management Practice: Post-construction ................................................. 25
Table 8: Best Management Practice: Pollution Prevention/Good Housekeeping .......... 27
Table 9: Indexed Scores for Promoting Sustainable Stormwater Management Principals
by City ............................................................................................................. 29
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LIST OF ABBREVIATIONS
BES: City of Portland’s Bureau of Environmental Services
BMPs: Best Management Practices
CSO: Combined Sewer Overflow
CSS: Combined Sewer System
CWA: Clean Water Act
GCCW: City of Philadelphia’s Green City, Clean Waters Stormwater Plan
LTCP: Long-Term Control Plan
NPDES: National Pollutant Discharge Elimination System
PADEP: Pennsylvania Department of Environmental Protection
PSMP: City of Portland’s Stormwater Management Plan
PWD: Philadelphia Water Department
SSMP: City of New York’s Sustainable Stormwater Management Plan
SWMM: Portland Stormwater Management Manual
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LIST OF DEFINITIONS
Bioswale: vegetated flow channel that contains water only during storm events.
Catch basin: surface-level inlet to the sewer system that allows runoff from
streets and lawns to enter the CSS.
Earth disturbance: Any human activity which moves or changes the surface of
land.
Evapotranspiration: the sum of evaporation and transpiration, or the loss of
water vapor from plants, from land surface to atmosphere
Infiltration: process by which water on the land surface enters the soil.
Precipitation: rain, sleet, hail or snow falling from the sky.
Rain barrel: storage container that collects rainwater from downspouts
connected to a house’s roof.
Surface runoff: excess water from precipitation flowing over the land.
Urbanization: physical growth of urban areas.
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PART 1: INTRODUCTION AND BACKGROUND
1.1 INTRODUCTION:
Cities have designed integrated stormwater management plans with not
only ecological but also social considerations (Echols and Pennypacker 2007).
They have emphasized qualities such as public education and public input
before installing visible public and private green infrastructure. By promoting
community involvement, cities expect residents to use water resources more
responsibly and efficiently. Community-based design also determines public
perception and acceptance of the added value for any extra costs of green
infrastructure (Echols and Pennypacker 2007).
Municipalities place great value on stormwater management plans and
expect them to serve as agents to achieve ambitious water quality and
community-building goals. Hence, there is a need to assess how elements in
these plans advance municipalities’ goals to determine the level of progress
that can be achieved. To what extent do stormwater management plans
promote the process of actively involving communities while achieving
ecological stewardship goals?
The purpose of this paper is to assess the extent to which municipal level
stormwater management plans embrace innovative approaches to addressing
surface water runoff and promote water quality. This paper shall serve as a
quantitative framework to assess the sustainability potential of municipal
stormwater plans from the following cities: Philadelphia, New York and
Portland. The purpose of this assessment is to systemically evaluate, on a
scale of 1 to 10, how closely each plan meets sustainability principles
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suggested by the EPA. It is assumed these principles serve as metrics for a
successful plan.
Using citizen engagement paired with green infrastructure to manage
stormwater is a relatively new concept; it may be too soon to assess outcomes
of the plans. But this evaluation of their quality draws initial conclusions about
their effectiveness.
Findings suggest public involvement in creating and implementing plans
is key in addressing stormwater as a holistic resource. Successful stormwater
management plans should include social capital as an integral part of the
planning process. Philadelphia’s plan, with its focus on the larger-picture
unifying theme of creating a sustainable and resilient city, achieves the highest
score while Portland’s plan, designed to address the requirements of the
National Pollution Discharge Elimination System (NDPES), scores the lowest.
1.2 Background
Urbanization, or the transition in land use and creation of impervious
surfaces to support increasing populations, has directly affected ecological
patterns and processes. In particular, cities have changed the hydrologic cycle.
When allowed to take its natural course, the hydrologic cycle operates in a
closed loop of precipitation, infiltration, surface runoff and evapotranspiration
(Hoyer et al. 2011). However, impervious surfaces hinder this process by
preventing infiltration and ground water recharge as urban pollutants
exacerbate the water quality of nearby rivers, lakes and estuaries (NRC 2009).
The disruption of the hydrologic cycle is visually depicted in Figure 1
below. Urbanization has significantly modified hydrological pathways and the
3
balance of precipitation, evapotranspiration and infiltration has changed.
Instead of infiltrating and replenishing groundwater, surface water leads to
increased runoff rates. Large surface runoff volumes increase opportunities for
the transport of pollutants to nearby streams both directly and through
conventional storm systems (Davis and McCuen 2005).
Figure 1: The Water Cycle
1.3 NPDES REQUIREMENT
The US has established federal regulations such as the Clean Water Act
to restore the drinkability of our water (Davis and McCuen 2005). The Clean
Waters Act created the NPDES, a permit program for controlling discharges
from point sources such as industrial pipes or man-made ditches (Office of
Water 2009). Cities with Municipal Separate Storm Sewer Systems (MS4) are
4
required to obtain a NPDES permit, which requires treatment and removal of
major pollutants before wastewater is discharged, and develop a stormwater
management plan (Office of Water 2009). Municipalities’ stormwater plans, or
Combined Sewer Overflow (CSO) Long-Term Control Plans (LTCP), are
required to meet the guidelines of the National CSO Control Policy (Office of
Water 2002). Phase I, issued in 1990, requires medium and large cities with
populations of 100,000 or more to obtain NPDES permits (Office of Water
2009). Phase II, issued in 1999, requires small urbanized areas to obtain
NPDES permits (Office of Water 2009). All three cities in the sample selection
are Phase I municipalities.
1.4 STORMWATER MANAGEMENT TRENDS
The majority of cities has dealt with surface water runoff through
separate systems for stormwater and sewer. Traditional stormwater
management has focused on collecting, conducting, and disposing of runoff
through structural methods (pipes, culverts, bank stabilization) using centralized
systems that are primarily concerned with providing adequate drainage and
flood control (Davis and McCuen 2005).
Instead of draining stormwater away, innovative best management
practices and low impact development control it closer to the source.
Techniques such as minimizing impervious surface, protecting and restoring
natural drainage channels and vegetative cover and enhancing infiltration using
decentralized systems create multi-functional landscapes (DER 1999). Simple
non-structural systems such as bioswales, rain gardens and permeable
pavement offer the potential to preserve the hydrologic functions of cities.
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PART 2: METHOD
2.1 SAMPLE SELECTION
The case studies shall demonstrate that cities can be centers of
efficiency and sustainability when it comes to implementing innovative
stormwater management techniques. Innovative stormwater mitigation
practices recommended by the respective stormwater management plans bring
the urban water cycle closer to a natural one and create environmental and
social amenities for the people.
The plans were chosen on the basis that they were written between 2005
and 2010 and serve Phase I mid- to large-sized urbanized areas. The period of
time 2005 – 2010 was selected to ensure the plans address presently relevant
environmental issues. Phase I mid- to large-sized cities where chosen because
it is assumed these cities have the financial and human capital to create and
implement assessable green stormwater programs. Three plans from three
cities – Philadelphia, Portland and New York City – comprise of the sample.
2.1.1 City of Philadelphia’s Green City, Clean Waters Plan:
Adopted in 2009, Philadelphia’s Green City, Clean Waters Plan (GCCW)
approaches sustainable stormwater management by reducing runoff as close to
the source as possible and treating water as a resource. The Plan’s goal is to
provide environmental and social benefits beyond reducing combined sewer
overflows. Central to the program is sustainability, open space, waterfront
revitalization, outdoor recreation and quality of life. The Philadelphia Water
Department’s (PWD) goal is to “achieve full regulatory compliance in a cost-
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effective way while regaining the resources in and around stream that have
been lost due to urbanization” (PWD 2009).
PWD conducted a triple bottom line cost-benefit analysis to assess the
environmental, social and economic aspects of the program. The TBL analysis
weighs environmental and social costs and benefits in addition to economic
implications for comprehensive results. Accounting for not only the water
quality but also the additional environmental and social benefits generated by
the new infrastructure helps the public see the total benefits of the proposed
actions. The triple bottom line analysis helps to justify the project to taxpayers
by presenting the extensive benefits of green infrastructure.
2.1.2 City of Portland’s Stormwater Management Plan:
The City of Portland’s Stormwater Management Plan (SWMP), prepared
by the Bureau of Environmental Services, was adopted in 2011. The goal of
the SWMP is to “reduce the discharge of pollutants from the MS4 into waters of
the state, protect water quality and satisfy the applicable requirements of the
Clean Water Act” (BES 2011). The stated benefits of pollutant reduction include
increased “recreation, cold water fisheries, municipal and industrial water
supply and navigation” (BES 2011).
2.1.3 City of New York’s Sustainable Stormwater Management Plan:
New York City’s Sustainable Stormwater Management Plan (SSMP),
adopted in 2008, aims to improve public access to the city’s tributaries by 42%
by 2030, which coincides with PlaNYC’s goal to open 90% of its waterways to
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recreation (Mayor’s Office 2008). The plan’s goal is to improve water quality for
recreation through preventing stormwater pollution.
With the highest population density in the country, NYC faces significant
water runoff challenges. Billions of gallons of CSOs are discharged into its
waterbodies each year while excessive levels of runoff from separate sewer
systems cause flooding and sewer backups. SSMP is the city’s first
comprehensive effort to green stormwater management through alternative
methods such as green infrastructure source controls. SSMP has a three-part
strategy: implementing cost-effective and feasible source controls, resolving the
feasibility of promising technologies and exploring funding options for source
controls (Mayor’s Office 2008).
2.2 EVALUATION METHOD
The evaluation metric is based on a set of goals and policies that have
been deemed by the EPA to be effective stormwater management controls.
The plans are quantitatively assessed based on the extent to which they include
these goals and policies (Edwards and Haines 2007). BMPs for the City of
Philadelphia, City of Portland and New York City are scored with a three-step
method. First, policies under each guideline are given a score of 0 if action is
not present, 1 if action is present and suggested and 2 if action is present and
required (Berke and Conroy 2000). Keywords indicating actions are suggested
are “encourage,” “consider,” “intend” and “should” while those indicating actions
are required are “shall,” “will,” “require” and “must” (Berke and Conroy 2000).
Then, the scores under each guideline (i.e. public education, public
involvement, illicit discharge, construction, post-construction and pollution
prevention) are summed up. Lastly, by dividing the sum of the scores by the
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maximum possible score and multiplying by 10, a standardized index is created
(Berke and Conroy 2000). The index assesses the plans’ treatment of
guidelines on scale of 1 to 10, where 10 is the highest score. A higher indexed
score indicates a stronger adherence to EPA’s recommended goals and
policies.
Table 1 : Best Management Practices Scoring Protocol
2.3 EVALUATION CRITERIA
The EPA recommends a management systems approach to solving
urban stormwater issues. Individual principles serve as parts of the sum and
are combined to achieve overall highly effective results (Office of Water 2002).
Six principles have been selected as key elements to sustainable stormwater
management by the EPA. Public education, public involvement, illicit discharge
detention and elimination, construction, post-construct and pollution
prevention/good house-keeping are the minimum measures. BMPs comprise of
the 27 elements listed under the minimum measures.
The BMPs embody EPA’s priority of prevention over treatment (Office of
Water 2002). It is less difficult and expensive to prevent degradation of
waterbodies than to restore them after receiving pollutants (Office of Water
2002). Therefore, BMPs from each minimum measure focus on the prevention
of pollutants from reaching stormwater.
BMP SCORING PROTOCOL
2 = PRESENT AND REQUIRED
1 = PRESENT AND SUGGESTED
0 = NOT PRESENT
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Table 2: Evaluation Criteria for Best Management Practices
PUBLIC
EDUCATION
PUBLIC
INVOLVEMENT
ILLICIT DISCHARGE
DETECTION &
ELIMINATION
CONSTRUCTION POST-
CONSTRUCTION
POLLUTION
PREVENTION /
GOOD HOUSE-
KEEPING
Develop outreach program
Use educational materials and strategies
Reach diverse audiences
Target homeowners
Target business-owners
Conduct public meetings
Provide stormwater-related volunteer opportunities
Conduct workshops with volunteer educators & speakers
Form citizen watch groups
Develop a used oil recycling program
Control illegal dumping
Manage floating trash & debris
Prevent septic system failure
Control sewage from recreational activities
Encourage public reporting
Enforce municipal oversight
Develop erosion control strategies
Develop runoff control strategies
Develop sediment control strategies
Establish planning procedures
Establish site-based mitigation measures
Establish retention or detention controls
Establish infiltration controls
Establish vegetative controls
Encourage municipal employee training & education
Monitor municipal activities
Monitor municipal facilities
Source: US EPA.
2.3.1 Public education & outreach
Individual behavior and practice change are essential to control
stormwater pollution; the public needs to be aware of the significance of its
actions in relation to stormwater to prompt the desired behavioral shift. The
EPA suggests that municipalities develop outreach programs with a multi-tiered
approach. Municipalities should generate awareness of stormwater pollution,
educate citizens with substantive information and try to change behavior to
prevent pollution. To ensure inclusive participation, municipalities should
engage citizens from diverse socio-economic groups. Homeowners along with
business-owners should be targeted for comprehensive public education (Office
of Water 2005, 2.3).
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2.3.2 Public involvement
Municipalities should include the public in each step of a stormwater
management plan: developing, implementing, updating and reviewing. Public
involvement is key to successful stormwater management. If given the
opportunity to provide input during public meetings and assistance through
volunteer and workshop events, the public can serve as active stakeholders in
creating and implementing stormwater programs. A community can be a
valuable intellectual and creative resource. Moreover, when citizens help
develop or make decisions about the program, they feel a sense of attachment;
their involvement engenders broader public support. Citizens may even decide
to form citizen watch groups for self-monitoring. Fewer legal challenges may
arise when citizens work alongside their civil counterparts. With fewer legal
obstacles and more citizens at work, municipalities can expect shorter
implementation periods (Office of Water 2005, 2.4).
2.3.3 Illicit Discharge Detection & Elimination
Illicit discharge, or non-stormwater waste, cannot be accepted or
processed by a MS4. When illicit discharge enters the MS4 directly (i.e.
wastewater piping illegally connected to storm drains) or indirectly (i.e. spills or
used oil entering drains), it pollutes receiving waterbodies (Office of Water
2005, 2.5). Pollutant levels may become high enough to significantly degrade
water quality, threatening aquatic and human health.
Because used motor oil contains heavy metals and contaminants that
are toxic to humans and wildlife, it should be disposed of at a recycling or
disposal facility. Illegal dumping into stream banks, off-road areas or into storm
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drains can impair water quality and should be stopped. Floating trash and
debris can significantly affect the aesthetics and health of waterbodies,
specifically as choking hazards to wildlife, and should be managed accordingly.
Furthermore, a septic system inspection and maintenance program can identify
sources of illicit discharge and prevent septic failure. Sewage resulting from
recreational activities should be controlled. A program to publicize and facilitate
public reporting of illicit discharges should be created (Office of Water 2005,
2.5).
2.3.4 Construction
Stormwater runoff from construction sites can significantly affect the
quality of receiving waterbodies. Site plan review of new development and
redevelopment projects should consider potential water quality impacts.
Procedures for site inspection and enforcement of control measures, along with
sanctions for failure to comply, should be enacted. Municipalities are
recommended to oversee that developers implement regulatory erosion, runoff
and sediment control measures on new development or redevelopment
projects. (Office of Water 2005, 2.6).
2.3.5 Post-construction
The issues associated with increased impervious surfaces due to
development will exacerbate the rate and level of runoff. To mitigate
stormwater water impact from new development, developers can treat, store
and infiltrate runoff onsite before it can flow downstream. The EPA
recommends using site-based infiltration, detention, retention and vegetative
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controls that follow a planning-based process to mitigate post-construction
stormwater issues. Cities should develop regulatory ordinances to require that
developers implement post-construction runoff controls (Office of Water 2005,
2.7).
2.3.6 Pollution Prevention/Good Housekeeping
Various municipal activities may threaten water quality. Winter road
maintenance, infrastructure repairs, upkeep of fleet and landscaping are
examples of practices that may produce pollutants that eventually wash into the
MS4 (Office of Water 2005, 2.8). Potential pollutants are sediment, nutrients,
trash, metals, oil, pesticides, organics and oxygen-demanding substances
(Office of Water 2005, 2.8).
EPA recommends municipal employees be educated to identify potential
sources of stormwater contamination and how to minimize these sources’
impact on water quality. Training programs should entail information such as
pollution prevention, good housekeeping and spill prevention and response.
Cities should train staff to track and report illicit discharges from municipal
activities or on municipal facilities (Office of Water 2005, 2.8).
2.4 RESULTS
Each minimum measure – public education, public involvement, illicit
discharge and elimination, construction, post-construction and pollution
prevention/good house-keeping – and to what extent it meets EPA
recommendations are discussed in the following sub-sections. Goals and
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actions from the municipal plans in each measure are highlighted to illustrate
adherence to the recommendations.
2.4.1 Public education & outreach
Table 3: Best Management Practice: Public Education
PUBLIC
EDUCATION
Develop
outreach
program
Use educational
materials &
strategies
Reach diverse
audiences
Target
homeowners
Target business-
owners
Philadelphia
Portland
NYC
2
2
2
2
2
2
2
0
0
2
0
2
2
0
2
Philadelphia’s GCCW achieves the highest possible score for the public
education BMP. NYC’s SSMP fully meets the requirements for each measure
except targeting a diverse audience. Portland’s PSMP scores the lowest, failing
to address a diverse audience, homeowners and business-owners.
Philadelphia has dedicated approximately $2 million dollars annually to public
outreach and education programs related to stormwater awareness. Central to
the city’s public outreach efforts is PWD’s Model Neighborhoods Initiative,
launched to showcase new green infrastructure in self-selected neighborhoods
(PWD 2009).
The City has also explored alternative approaches to public outreach
with art. PWD hosted an art exhibit with local artist Billy Kelly, who incorporated
elements of the Plan into his work (Fairmount Water Works, 2008). Kelly
created “jar art” – jars filled with water, plants and urban vignettes – to explore
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the human relationship with water. PWD and Partnership for the Delaware
Estuary organized an art competition open to Philadelphia students in grades K-
12. Students are encouraged to illustrate ways to protect waterways through a
drawing or video to win art supplies and other prizes (PWD 2012).
Figure 2: Artwork by Bill Kelly. Source: Philadelphia Water Department.
Figure 3: Artwork by Yishu Wang (left) and Alejandro Vidal (right). Source: Philadelphia Water Department.
As part of the Philadelphia Model Neighborhoods Initiative, educational
materials and programs have been developed. Free guided Model
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Neighborhood walks (“Tree Walk on Your Blocks”) and free summer education
programs (“H2O & You,” “Trees are Terrific” and “Steppin into Nature”) have
reached thousands of adults and children. A number of fact sheets, handouts
and photo simulations regarding green infrastructure projects have been
circulated (PWD 2009).
The Portland Bureau of Planning and Sustainability (BPS) offers
education and outreach programs to encourage waste reduction and recycling.
Free water quality science education programs are provided for students in
grades K-college in Portland through the Clean Rivers Education Program. In
the classroom and in the field, students learn about watershed health, urban
ecology, water pollution (BES 2012). Teachers are offered workshops,
curriculum resources and community service projects. Portland has set a goal
to provide educational programs to 15,500 K-college students annually (PSMP
2011).
Figure 4: middle school students learn to measure pervious and impervious surfaces. Source: Portland Bureau of Environmental Services.
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The Portland Community Stewardship Grants Program awards up to
$10,000 per project to citizens or organizations to promote watershed citizen
involvement in watershed stewardship in Portland. Since 1995, the program
has awarded over $948,000 to 198 projects. With the adoption of the PSMP,
Portland plans to award at least $50,000 in stewardship grants each year
(PSMP 2011).
The Regional Coalition for Clean Rivers and Streams comprises of
agencies and municipalities in the Portland/Vancouver metropolitan that
promote public awareness of stormwater runoff. Annual region-wide campaigns
to educate residents reach more than 1.4 million people (PSMP 2011).
The Portland Bureau of Environmental Services (BES) distributes
stormwater-related educational materials such as water bill inserts, posters, fact
sheets, maps for self-guided tours of demonstration projects. BES has also
created informational signage for eco-roof installations, swales and stormwater
demonstration projects. The BES will continue to develop and distribute
educational materials (PSMP 2011).
Public education for homeowners is recognized as key in the GCCW to
increasing participation in residential stormwater measures. Public workshops
on installation of rain barrels to collect runoff have already been realized as a
successful pilot program. The Plan also recommends further steps such as
encouraging homeowners to disconnect downspouts to direct runoff to pervious
and use site slopes to direct stormwater runoff to rain gardens (PWD 2009).
PWD identifies participation of diverse partners as key to implementing
the plan. A Public Participation Program Team was formed to educate and
involve the public on the Plan. The team, consisting of PWD staff and
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consultants, developed strategies, materials and events to reach diverse
populations (PWD 2009).
NYC will develop a public outreach and education program to promote
water pollution awareness and prevention techniques. A design and
construction manual will be published. The manual can be used by developers,
homeowners and public agencies (SSMP 2008).
2.4.2 Public involvement
Table 4: Best Management Practice: Public Involvement
PUBLIC
INVOLVEMENT
Conduct public
meetings
Provide stormwater-
related volunteer
opportunities
Conduct workshops with
volunteer educators &
speakers
Form citizen watch groups
Philadelphia
Portland
NYC
2
0
2
2
2
2
2
2
2
0
0
0
Philadelphia’s GCCW and NYC’s SSMP both score higher than Portland’s
PSMP. While both the GCCW and SSMP indicate a series of public meetings
relating to the conceiving of their respective plans were held, the PSMP fails to
mention any public meetings that may or may not have been conducted. None
of the plans mention any effort to encourage citizen watch groups.
A four-series of thirteen total public meetings were held in Philadelphia
during the development of the GCCW to involve residents by providing
opportunities for mutual learning. Notifications of the meetings were dispersed in
local newspapers, radio stations, watershed partnership listservs and popular
neighborhood locations. Meetings were located at different locations, such as
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schools, libraries and communities centers, to maximize overall citizen
accessibility and attendance (PWD 2009).
The first series of public meetings used informational displays to teach
residents about the current status of Philadelphia’s waterways and stormwater
infrastructure as well as the anticipated green infrastructure approach. The
second series of meetings showcased the Green City, Clean Waters Exhibit, an
informational art exhibit, to target new audiences. The informational component
comprised of CSO- and watershed-related posters. The artwork displayed was
Bill Kelly’s jars. Topics discussed during the meeting included GCCW’s vision,
examples of gray and green infrastructure and integrated partnerships (PWD
2009).
During the third series of public meetings, Philadelphia residents took the
“CSO-Control Approach Survey.” The results of the survey reflected that
residents overwhelmingly favored green over gray infrastructure. Subsequently,
CSO-related options, alternatives and approaches were discussed at the
meetings. The forth series concluded this round of public meetings with the
introduction to of the GCCW’s Summary Report and a green infrastructure
demonstration (PWD 2009).
NYC’s Interagency BMP Task Force has held five public meetings to
engage residents. The result was working groups to discuss solutions, possible
source controls for the SSMP and an interagency online platform for sharing
design solutions. The SSMP incorporates many suggestions offered by
members of the public (SSMP 2008).
Several volunteer events to promote environmentally responsible
stormwater and watershed activities have already taken place in Philadelphia.
Currently, PWD and Water Quality Council sponsor a yearly Earth Day volunteer
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event to encourage community members to install storm drain curb markers, or
stencils. Around 10,000 stencils are installed each year. A volunteer stream
cleanup day took place on April 19, 2008 at Wall Park. 12 adults and 3 children
participated and collected 28 bags of trash. Another volunteer work day took
place at Tacony Creek Park, where 4 adults and 4 teens removed invasive
species and trash. PWD currently contributes $370,000 annually to fund public
education and volunteer programs to each of three watersheds –
Tookany/Tacony-Frankford, Cobbs Creek and Delaware. In addition to current
funding, PWD will contribute an added $150,000-200,000 to each watershed
(PWD 2009).
Philadelphia has conducted a number of workshops to education the
public about stormwater stewardship. PWD has established a program to give
rain barrels to residents for free, given they attend a training workshop to learn
about the benefits of and instructions on using rain barrels. Over 1,200 rain
barrels have been given away so far. Another free workshop, “Thinking Like a
Watershed,” informed teachers of grades four through eight on how to enhance
water-related features of urban systems. Nine teachers attended. Three
conservation plan workshops took place in 2008 to facilitate discussion on
sustainable urbanism ideas. A total of 106 attendees discussed revitalizing
Pulaski Pier, exploring parking solutions and implementing complete streets
(PWD 2009).
The NYC Parks Department engages community groups, homeowners
and friends of parks in the care of Greenstreets installations. The Parks
Department GreenThumb urban gardening program helps 700 neighborhood
groups create and maintain community gardens. The New York Restoration
Project engages community organizations and volunteers to plant and care for
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new trees. Local school and college students serve as volunteers for the
Department of Environmental Protection’s Adopt-A-Bluebelt and Staten Island
Bluebelt programs (SSMP 2008).
A Public Outreach and Education Marketing Manager coordinates
outreach at fairs, festivals and concerts in NYC. A new visitor’s center at the
Newtown Creek Wastewater Treatment Plant will serve as an education forum
with tours, workshops and special events. DEP runs a rain barrel giveaway
program to educate homeowners on stormwater management. The program
was designed to gather data on effectiveness of outreach methods (SSMP
2008).
2.4.3 Illicit discharge detection & elimination
Table 5: Best Management Practice: Illicit Discharge Detection & Elimination
ILLICIT
DISCHARGE
DETECTION &
ELIMINATION
Develop a
used oil
recycling
program
Control
illegal
dumping
Manage
floating trash
& debris
Prevent septic
system failure
Control
sewage
from
recreational
activities
Encourage
public
reporting
Philadelphia
Portland
NYC
0
0
0
1
2
2
2
2
2
2
0
1
0
0
0
1
0
0
Philadelphia scores highest while Portland scores the lowest. The
PSMP does not mention any efforts to prevent septic system failure. The
PSMP and SSMP do not indicate public reporting is encouraged. All three
cities fail to include the developing of an oil recycling program and the
controlling of sewage from recreational activities in their plans.
21
The BPS manages solid waste and recycling programs to prevent illegal
dumping of solids. Preventative programs include curbside recycling, yard
debris collection and bulky waste collection. BPS also offers educational
programs such as the Master Recycler Program to encourage recycling (PSMP
2011).
To manage floating trash and debris, PWD has purchased a pontoon
vessel to retrieve floating trash and debris from a total of 34.1 miles in the
Delaware River and Upper and Lower Schuylkill. Employees use nets to catch
trash and debris while standing on the vessel deck (PWD 2009). Similarly,
Portland has made efforts to research and pilot test controls to reduce floating
trash and debris. Staff will be trained on floating trash- and debris-related
issues (PSMP 2011).
Septic system management plans are required of all Pennsylvania
municipalities to prevent septic failure. Provisions related to operation and
maintenance of sewage systems are kept to control the release of bacteria and
nutrients within the watershed (PWD 2009).
PWD encourages that the public report CSO overflows to the
department. Brochures and other educational materials highlight the effects of
overflows and request that the public report overflows have been distributed
(PWD 2009).
22
2.4.4. Construction
Table 6: Best Management Practice: Construction
CONSTRUCTION Enforce
municipal
oversight
Develop
erosion control
strategies
Develop
runoff control
strategies
Develop sediment control
strategies
Philadelphia
Portland
NYC
2
2
1
2
2
0
2
2
1
2
2
1
The GCCW and PSMP both attain the highest possible score while the
SSMP achieves less than half the points. The SSMP’s construction BMP lacks
specifics; the plan mentions that agencies have coordinated performance
standards for new construction to be adopted by its sewer regulations, details
such as municipal oversight, runoff and sediment control strategies are not
mentioned.
Based on Philadelphia’s stormwater regulations for new development
and redevelopment, a PWD development review meeting is required pre-
construction to enforce municipal oversight. The developer is required to
prepare a conceptual plan, an Existing Resources and Site Analysis worksheet
and map and photographs of the project. PWD reviews the documents and
meet with the developer to discuss water, sewer and stormwater utilities. This
procedure is to ensure compliance with stormwater regulations and address
issues early in the approval process (PWD 2009).
Following the requirements of the Portland Erosion Control Manual, the
city controls erosion, sediment and pollutant discharges from active
construction sites as part of its municipal oversight (BES 2011). Visible and
23
measurable sediment or pollutants shall not exit the construction site, enter the
public right-of-way or flow into any waterbody or drainage system. Washing soil
into a waterbody or drainage system is prohibited. An Erosion, Sediment and
Pollutant Control Plan, a description of where and how activities will be used to
control erosion, sediment and pollutants on a construction site, is required for
earth disturbances that exceed 500 square feet and requires a building, public
works or development permit. Additionally, an Erosion, Sediment and Pollutant
Control Plan may be required for sites on steep slopes, in environmentally
sensitive areas or in response to a violation of Portland’s erosion control
requirements. A pre-construction meeting with the developer may be needed to
review the Erosion, Sediment and Pollutant Control Plan requirements.
Approval criteria include effort to minimize area of disturbance, use of a
combination of BMPs and description of site inspection and maintenance of all
BMPs after any storm event (ECM 2008).
Philadelphia’s stormwater regulations for new development and
redevelopment require that any earth disturbance comply with the Pennsylvania
Department of Environmental Protection (PWD 2006). All earth disturbances
greater than or equal to 15,000 square feet and less than one acre must be
approved by the PWD with the issuance of an Erosion and Sediment Control
Plan, which conforms to the regulations of the PADEP. The City’s stormwater
regulations for new development and redevelopment focus on minimizing
stream bank erosion. Controls such as disconnection of imperious cover, bio-
retention, green roofs, swales and tree canopy can be applied. If and when a
new construction site follows the City’s regulations, it is ensured that the site will
not contribute to impairment of a surface waterbody (PWD 2009).
24
Philadelphia’s stormwater regulations for new development and
redevelopment focus on restoring the balance between runoff and infiltration,
reducing pollution levels and minimizing runoff rates (PWD 2009).
Philadelphia’s stormwater regulations for new development and redevelopment
require that any earth disturbance comply with the Pennsylvania Department of
Environmental Protection (PWD 2006). All earth disturbances greater than or
equal to 15,000 square feet and less than one acre must be approved by the
PWD with the issuance of an Erosion and Sediment Control Plan, which
conforms to the regulations of the Department of Environmental Protection.
Portland’s Erosion, Sediment and Pollutant Control Plan outlines several
erosion prevention BMPs developers can follow. For approval, an Erosion,
Sediment and Pollutant Control Plan needs to include at least one type of BMP
to prevent or reduce each of the following: erosion control, stormwater runoff
and sediment control. Erosion prevention recommendations include surface
roughening, vegetative cover, mulch, erosion control blankets and plastic sheet
covering. Stormwater runoff controls may include using hay bales, triangular
silt dikes, plastic dams and rock sack berms. Sediment control
recommendations include sidewalk subgrade barriers, silt fences, filtration
bags, vegetated buffers and drain inlet protection (ECM 2008).
25
2.4.5 Post-construction
Table 7: Best Management Practice: Post-construction
POST -
CONSTRUCTION
Establish
planning
procedures
Establish
site-based
mitigation
measures
Establish
retention or
detention
controls
Establish
infiltration
controls
Establish
vegetative controls
Philadelphia
Portland
NYC
2
2
1
2
2
1
2
2
1
2
0
1
2
0
1
The GCCW achieves the highest possible score while NYC scores the
lowest. The SSMP mentions that vegetated and infiltration controls fall under
the responsibility of the Parks Department, but fails to expand on to what extent
such controls are enforced. Post-construction site-based mitigation and
retention are alluded to by the SSMP. The PSMP achieves a full score on all
elements except for establishing infiltration and vegetative controls, which are
not present in the plan.
Established planning procedures require the submission and approval of
a post-construction stormwater management checklist by developers in
Philadelphia. By requiring the developer to identify onsite details such as bio-
retention methods and infiltration calculations, the checklist ensures all
necessary elements of post-construction stormwater management are met.
Approval of a Post-Construction Stormwater Plan is contingent upon the
approval of other municipal permits such as the NPDES II Permit for
Construction Activities. The Post-Construction Stormwater Plan delineates on-
site mitigation measures developers must follow (PWD 2011).
26
In Portland, the planning and permitting process for new construction
ESPCP approval provides the opportunity to incorporate post-construction
stormwater management designs. Portland City Code chapter 17.38 gives the
city authority to limit the volume and rate of stormwater runoff from new
development (ECM 2008).
The PSMP refers to the Portland Stormwater Management Manual,
which was adopted in 2008 set standards for site-based mitigation measures for
development and redevelopment projects. The Stormwater Management
Manual requires that post-development peak flows leaving the site do not
exceed the capacity of the receiving facility of waterbody, do not increase the
potential for stream bank and channel erosion, do no increase flooding
problems and do not increase the occurrence of CS4 overflows (SWMM 2008).
The Philadelphia Post-Construction Stormwater Plan requires that
developers use bio-retention controls to prevent or reduce runoff (PWD 2006,
1). Bio-retention system details, dimensions and plant types must be
documented (PWD 2006, 1).
No detention requirements apply to direct discharge to rivers or storm-
only piping systems in Portland (SWMM 2008, 1-19). When discharging to any
overland drainage system, peak runoff rate for two-year post-development must
equal half of the two-year pre-development peak rate (SWMM 2008, 1-19).
Five-year post-development peak rate must equal the five-year pre-
development peak rate, with the same standard for 10-year and 25-year post-
and pre-development (SWMM 2008, 1-19). Onsite retention to the maximum
extent feasible is required (SWMM 2008, 1-19).
Developers are required to implement post-development infiltration
controls in Philadelphia. Location of infiltration tests, soil borings and fill areas
27
associated with the Geotechnical/Infiltration Report must be reported (Checklist
2011).
2.4.6 Pollution prevention & Good House-keeping
Table 8: Best Management Practice: Pollution Prevention/Good Housekeeping
POLLUTION
PREVENTION /
GOOD HOUSE-
KEEPING
Encourage municipal
employee training &
education
Monitor municipal
activities
Monitor municipal facilities
Philadelphia
Portland
NYC
2
0
2
1
0
0
1
0
0
The three plans do not document pollution prevention and good
housekeeping measures in detail. Philadelphia meets all three measures while
NYC only meets one measure and Portland meets none.
Employee training programs have been established to educate
employees about the GCCW (PWD 2009, 6-12). Training programs focus on
potential sources of contamination, BMPs, safety hazards, discharge prevention
and accident response (PWD 2009, 6-12).
NYC encourages maintaining and creating green jobs by providing
training to the green collar workforce. Current green job training related to
stormwater management include tree pruning, urban forestry, environmental
remediation and riverbank restoration. To create more green jobs, NYC
Economic Development Corporation is conducting a study to understand the
emerging green sector and support high priority segments. The goal of the
28
study is to identify and overcome barriers to growth in these high priority
segments and craft initiatives to stimulate job growth (SSMP 2008).
The Industrial Waste Unit within the Philadelphia Local Emergency
Planning Committee manages the PWD-related harmful spills that may
discharge into the MS4 and threaten the City’s water supply. Industrial Waste
Unit employees are able to respond to oil and chemical spills 24 hours a day,
seven days a week to protect PWD’s structures and treatment processes (PWD
2009).
Sediment and pollutants generated during daily use and repair of roads
and bridges impact water quality by emitting heavy metals, hydrocarbons and
debris. Additionally, the salting and de-icing of roadways contaminate
groundwater and impair aquatic ecosystems. PWD recommends proper
storage and application of materials to roadways (PWD 2009).
Automotive maintenance shops are stormwater “hot spots,” generating
significant levels of pollutants that affect the quality of stormwater. Proper
storing of fluids and thorough clean-ups can reduce the effects of automotive
maintenance practices on local water supply. Automobile recycling facilities are
point sources for oil, antifreeze and pesticides. PWD recommends increased
enforcement to prevent pollution when owners fail to follow requirements (PWD
2009).
2.6 DISCUSSION
Each minimum measure – public education, public involvement, illicit
discharge and elimination, construction, post-construction and pollution
29
prevention/good house-keeping – and to what extent it meets EPA
recommendations has been discussed in the above section. Goals and actions
from the municipal plans in each measure have been highlighted to illustrate
adherence to the recommendations.
PART 3: CONCLUSION
Table 9: Indexed Scores for Promoting Sustainable Stormwater Management Principals by City
PUBLIC
EDUCATION
PUBLIC
INVOLVEMENT
ILLICIT
DISCHARGE
DETECTION &
ELIMINATION
CONSTRUCTION POST-
CONSTRUCTION
POLLUTION
PREVENTION /
GOOD HOUSE-
KEEPING
TOTAL
(60 pts)
Phila
Portland
NYC
dddd
10
4
8
7.5
5
7.5
5
3.3
4.2
10
10
3.75
10
6
5
6.7
0
3.3
49.2
28.3
31.75
3.1 PRELIMINARY FINDINGS
Table 9 presents the scores for each stormwater BMP principle by city.
Philadelphia scores the highest comparative number of indexed points at 44.7
out of 60 possible points. NYC received 31.75 indexed points while Portland
received 28.3 indexed points out of 60 possible points. Plans exhibit a wide
range of scores; Philadelphia’s scores lie between 5 and 10, NYC’s between
3.3 and 7.5 and Portland’s between 0 and 10.
3.2 POLICY IMPLICATIONS
These findings suggest the GCCW, and to a lesser extent the SSMP,
integrate broader social, environmental and economic goals beyond stormwater
30
management and its immediate effects. The GCCW and SSMP’s BMPs focus
on the unifying theme of creating sustainable and resilient cities. In addition to
improving municipal water quality, future objectives of the GCCW and SSMP
are to provide benefits to the community beyond water quality such as
increased recreation, community involvement, aesthetics, and home values.
In contrast, Portland’s SWMP, the lowest-scoring plan, was mainly
intended to address the requirements of the municipal stormwater permit (BES
2011, 1). External benefits such as recreation, fishing and navigation are also
mentioned, but as a side note. The actions required or recommended by BMPs
in the PSMP are piecemeal and cater to specific practices.
Is the GCCW the most effective plan because it has integrated far-
reaching goals and is promoted as a way to green the city? Do more
comprehensive BMPs that closely meet minimum control measures qualify as
more effective or ambitious? Can more sources of collaboration and funding be
obtained by a plan with more detailed goals? The GCCW is the longest plan at
719 pages while the PSMP is the shortest at 62 pages. How does length impact
effectiveness of a plan?
3.3 NEED FOR FUTURE RESEARCH
It can be speculated but not concluded that a longer and more detailed
plan is more effective in addressing stormwater management goals. To reach a
fact-based and empirical conclusion, one needs to conduct future research.
The plans can be assessed over time.
During and after implementation, one can observe if plans with stronger
mandates have a greater effect on management. Eventually, a conclusion
31
about whether a higher-scoring plan as it relates to EPA BMP
recommendations is more effective in promoting stormwater stewardship can
be drawn. Municipalities outside the sample selection can benefit from such
research; they will be equipped with what elements, actions and keywords to
use for their own plans.
Additionally, the sample size can be increased to 5, 10 or 30 plans. A
larger sample size can lead to increased precision and a more reliable
conclusion. As more cities begin to craft innovative stormwater management
plans, larger studies can be conducted to achieve more conclusive findings.
32
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