Storm Water Integrated Strategy
When rainwater and snow-melt flows over construction and industrial site surfaces, the precipitation runoff can pick up pollutants such as sediment, bacteria, hydrocarbons, metals, debris, pesticides, fertilizers, solvents, acids, oil and grease and transport them to our rivers, lakes, and coastal waters without treatment. This can kill fish and other wildlife, destroy aquatic habitats, and cause stream bank erosion. Urban Storm water runoff have become a major cause of impaired water quality nationwide, contributing to 13% of impaired rivers and streams, 18% of impaired lakes, 55% of impaired ocean shorelines, and 32% of impaired estuaries according to EPA’s National Water Quality Inventory: 2000 Report. Thus, EPA's Federal Facilities Enforcement Program embarked upon a compliance strategy in October of 2005 to ensure that the Federal government was complying with Federal storm water requirements under the Clean Water Act. Below you will find information on EPA Region 2's efforts to minimize the impact of storm water discharges within the Federal community in New York, New Jersey and the Caribbean.
In the Spotlight...
New storm water runoff requirements for Federal development projects
The Energy Independence and Security Act of 2007 requires, among other things, that the sponsor of any development or redevelopment project involving a Federal facility with a footprint that exceeds 5,000 square feet shall use site planning, design, construction, and maintenance strategies for the property to maintain or restore, to the maximum extent technically feasible, the predevelopment hydrology of the property with regard to the temperature, rate, volume, and duration of flow. In others words, Federal facility construction projects which disturb more than 5,000 square feet must use low impact development techniques.
As part of EPA's ongoing efforts to help the Federal community understand and comply with the federal requirements regarding storm water, EPA's Federal Facilities Program sponsored a storm water and low impact development webinar on June 23, 2009. The presentations and transcript from this webinar can be downloaded from FedCenter, the Federal Government's home for comprehensive environmental stewardship and compliance assistance information.
Also, on FedCenter, is a Storm Water Webpage which provides a summary of the federal and state storm water requirements as well as contruction related storm water issues.
In addition , a new industrial storm water permit guide has been created by the Printer's National Environmental Assistance Network and since many of the storm water compliance problems being found on Federal lands are associated with construction activities, Region 2 encourages the Federal community to visit The Construction Industry Compliance Assistance Center as well.
Moreover, EPA's Office of Water have created a Low Impact Development Website to encourage land development (or re-development) that works with nature to manage stormwater as close to its source as possible. Low Impact Development employs principles such as preserving and recreating natural landscape features, minimizing effective imperviousness to create functional and appealing site drainage that treat stormwater as a resource rather than a waste product.
Finally, EPA and the U.S. Botanic Garden produced a 9-minute on-line video, “Reduce Runoff: Slow It Down, Spread It Out, Soak It In,” that highlights green techniques such as rain gardens, green roofs and rain barrels to help manage stormwater runoff. The goal is to mimic the natural way water moves through an area before development by using design techniques that infiltrate, evaporate, and reuse runoff close to its source.
Since October of 2005 , EPA Region 2 has conducted 31 storm water inspections at Federal facilities in New York, New Jersey, and Puerto Rico and found a compliance rate among federally regulated facilities of 32%. Issues of concern noted in the inspection reports include:
- No permit for vehicle/aircraft/ship maintenance activities;
- Not implementing all best management practices (BMP) in stormwater pollution prevention (SWP2) plans;
- SWP2 plans not site-specific;
- No documentation of required SWP2 plan inspections;
- Illicit connections of non-stormwater discharges to storm sewers;
- Appropriate erosion and sediment BMPs not implemented at construction sites;
- No installation/repair/maintenance of required storm water controls at construction sites;
- Not conducting required weekly inspections of construction sites;
- Deficiencies noted in weekly inspections of construction sites not addressed;
- Notice of intent for general stormwater construction permit not submitted; and
- Notice of intent for general stormwater construction permit and a brief description of the construction project not posted in a prominent place for public viewing.
Given the extremely low compliance rate among the Federal community in regards to Federal storm water regulations, EPA Region 2 encourages Federal Agencies to conduct self-audits of construction sites and vehicle maintenance activities and to voluntarily disclose any storm water violations to EPA under EPA's Voluntary Audit Policy. By doing so, one may be able to eliminate or substantially reduce the civil penalties for those violations that would normally have been assessed provided, of course, that certain conditions are met. To help businesses and organizations conduct these audits, EPA, in 2005, developed a Protocol for Conducting Environmental Compliance Audits under the Stormwater Program.