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.

iv

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.

v

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

viii

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

ix

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.

1

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

2

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.

5

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-

6

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

7

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

8

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

9

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).

10

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

11

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

12

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

14

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

15

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.

16

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

17

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

18

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

19

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

20

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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