ensuring clean water through stormwater rulemaking

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Ensuring Clean Water through EPA’s National Stormwater Rulemaking Issues and Opportunities Katie Rousseau, American Rivers Healing Our Waters Great Lakes Restoration Conference October 13, 2011

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Ensuring Clean Water through EPA’s National Stormwater Rulemaking

Issues and Opportunities

Katie Rousseau, American RiversHealing Our Waters Great Lakes Restoration Conference

October 13, 2011

Runoff: a growing problem

Development rates outpace population growth

Development = Imperviousness = Impaired Waters

Source: California Water and Land Use Partnership

Regulatory responses not keeping pace with impacts, or emergence of LID

- Increasing trend toward embrace of decentralized, “green infrastructure” management approaches

- Regulatory structures often at odds with green infrastructure principles

- Tension between permitting and community and water quality needs

Inconsistency frustrates successful resolution of these problems

Permits without objective, retention standards

Post-construction requirements limited to MS4s

DC NJ

DE NY

FL OH

MD RI

MN VT

NC  

AL AR AZ

CO CT DC

FL GA IA

ID IL IN

KS KY LA

ME MI MN

MO MS NC

ND NE NM

OH RI SD

UT VA WY

Inconsistency frustrates successful resolution of these problems

Inequitable distribution of local responsibility…

…contributes to national problems.

A National Stormwater Rule

Possible options include : Post Construction Performance Standards for New

Development and Redevelopment Projects Additional Dischargers Brought into Regulatory Program Retrofit Program to Address Existing Imperviousness

Other issues at play : Public participation in municipal stormwater management

programs, state designation of standards, etc. Links to impaired waters Industrial stormwater, Combined Sewer Overflows

Post-Construction & On-site Management

Not an LID or green infrastructure requirement, as some state permit programs are attempting

Performance standard requiring on-site precipitation management: EISA guidance (95th % storm) as model ?

Possible relaxation for redevelopment, urban infill, and brownfields

Compliance flexibility where infeasible

Filling Holes in Stormwater Program

More complete universe of sources subject to the Clean Water Act brought under regulation

EPA proposing alterations to MS4 definition: “urbanized cluster” replacing “urbanized area” ? out to sub-watershed boundary ?

Uncertainty about other needs – direct dischargers, areas of planned future growth

Retrofit Planning & Implementation

Lots of movement in this field, despite perception of high costs Costs may be less than

feared. Other benefits may offset these costs

EPA proposing long term planning process to be implemented incrementally and tied to MS4 permits

Is this enough?

Where this all leads…

Broader embrace of green infrastructure drives lower costs, improved efficiencies

Increased demand drives evolution in professional communities

Changing attitudes drive integrated water management

Continued local leadership

A National Stormwater Rule

When ?? !! Proposed Rule : December 15, 2011 Public Comment Period: through February 2012 Final Rule : November 2012

Katie RousseauAmerican Rivers

[email protected]

419.936.3759

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