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 municipallevel 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.

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

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

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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 Portlands Bureau of Environmental Services BMPs: Best Management Practices CSO: Combined Sewer Overflow CSS: Combined Sewer System CWA: Clean Water Act GCCW: City of Philadelphias 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 Portlands Stormwater Management Plan PWD: Philadelphia Water Department SSMP: City of New Yorks 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 houses 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

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. Philadelphias plan, with its focus on the larger-picture unifying theme of creating a sustainable and resilient city, achieves the highest score while Portlands 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

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

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.

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 Philadelphias Green City, Clean Waters Plan: Adopted in 2009, Philadelphias 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 Plans 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 Departments (PWD) goal is to achieve full regulatory compliance in a cost-

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 Portlands Stormwater Management Plan: The City of Portlands 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 Yorks Sustainable Stormwater Management Plan: New York Citys Sustainable Stormwater Management Plan (SSMP), adopted in 2008, aims to improve public access to the citys tributaries by 42% by 2030, which coincides with PlaNYCs goal to open 90% of its waterways to

recreation (Mayors Office 2008). The plans 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 citys 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 (Mayors 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

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 EPAs recommended goals and policies.

Table 1 : Best Management Practices Scoring Protocol

BMP SCORING PROTOCOL 2 = PRESENT AND REQUIRED 1 = PRESENT AND SUGGESTED 0 = NOT PRESENT

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 EPAs 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.

Table 2: Evaluation Criteria for Best Management Practices

PUBLIC EDUCATION PUBLIC INVOLVEMENT ILLICIT DISCHARGE DETECTION & ELIMINATION CONSTRUCTION POSTCONSTRUCTION POLLUTION PREVENTION / GOOD HOUSEKEEPING Encourage municipal employee training & education Monitor municipal activities Monitor municipal facilities

Develop outreach program Use educational materials and strategies Reach diverse audiences Target homeowners Target businessowners

Conduct public Develop a used oil meetings recycling program

Enforce municipal Establish oversight planning procedures Provide Control illegal Develop erosion stormwaterdumping control strategies Establish siterelated volunteer based mitigation Manage floating trash Develop runoff opportunities measures & debris control strategies Conduct Establish Develop sediment workshops with Prevent septic retention or system failure control strategies volunteer detention educators & controls Control sewage from speakers recreational activities Establish Form citizen watch groups Encourage public reporting infiltration controls

Establish vegetative controls

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).

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 businessowners

Philadelphia Portland NYC

2 2 2

2 2 2

2 0 0

2 0 2

2 0 2

Philadelphias GCCW achieves the highest possible score for the public education BMP. NYCs SSMP fully meets the requirements for each measure except targeting a diverse audience. Portlands 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 citys public outreach efforts is PWDs 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 K12. 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 stormwaterrelated 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

Philadelphias GCCW and NYCs SSMP both score higher than Portlands 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 Philadelphias 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 Kellys jars. Topics discussed during the meeting included GCCWs 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 GCCWs Summary Report and a green infrastructure demonstration (PWD 2009). NYCs 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 Protections 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 visitors 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.

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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).

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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 SSMPs 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 Philadelphias stormwater regulations for new development and redevelopment, a PWD development review meeting is required preconstruction 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

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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 Portlands 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). Philadelphias 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 Citys stormwater regulations for new development and redevelopment focus on minimizing stream bank erosion. Controls such as disconnection of imperious cover, bioretention, green roofs, swales and tree canopy can be applied. If and when a new construction site follows the Citys regulations, it is ensured that the site will not contribute to impairment of a surface waterbody (PWD 2009).

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Philadelphias 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). Philadelphias 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. Portlands 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).

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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 bioretention 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 onsite mitigation measures developers must follow (PWD 2011).

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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 stormonly 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 predevelopment peak rate, with the same standard for 10-year and 25-year postand 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

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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 HOUSEKEEPING Philadelphia Portland NYC Encourage municipal employee training & education 2 0 2 Monitor municipal activities Monitor municipal facilities

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

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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 Citys 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 PWDs 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

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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 POSTCONSTRUCTION POLLUTION PREVENTION / GOOD HOUSEKEEPING 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; Philadelphias scores lie between 5 and 10, NYCs between 3.3 and 7.5 and Portlands 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

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management and its immediate effects. The GCCW and SSMPs 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, Portlands 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 farreaching 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

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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.

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Berke, Philip R., and Maria Manta Conroy. 2000. Are We Planning for Sustainable Development?, Journal of the American Planning Association 66, no.1: 21-33. Davis, Allen P., and Richard H. McCuen. 2005. Stormwater Management for Smart Growth. New York: Springer Science. Department of Environmental Resources. 1999. Low-Impact Development Design Strategies: An Integrated Design Approach. Prince Georges County. Echols, Stuart P., and Eliza Pennypacker. 2008. Learning from Artful Rainwater Design. Landscape Architecture 98, no.8: 28-39. Edwards, Mary M., and Anna Haines. 2007. Evaluating Smart Growth: Implications for Small Communities, Journal of Planning Education and Research 27, no.1: 49-64. Erosion and Sediment Control Manual. 2008. City of Portland. Fairmount Water Works Interpretive Center. 2008. Bill Kelly: Interpreting the Green Cities, Clean Waters Vision. http://planphilly.com/sites/planphilly.com/files/FINAL%20BillKellyFinalFlyer. pdf (accessed December 10, 2011). Farr, Douglas. 2008. Sustainable Urbanism: Urban Design with Nature. Hoboken, N.J.: Wiley. Hoyer, Jacqueline, Wolfgang Dickhaut, Lukas Kronawitter, and Bjorn Weber. 2011. Water Sensitive Urban Design. Berlin: Jovis. National Research Council of the National Academics. 2009. Urban Stormwater Management in the United States. Washington, D.C.: National Academies Press. Office of Water. 2002. Combined Sewer Overflows: Elements of a Long-Term Control Plan. U.S. Environmental Protection Agency. http://cfpub.epa.gov/npdes/cso/ltplan.cfm (accessed December 1, 2011). Office of Water. 2009. National Pollutant Discharge Elimination System. U.S. Environmental Protection Agency. http://cfpub.epa.gov/npdes/ (accessed December 1, 2011).

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Office of Water. 2005. Stormwater Phase II Final Rule Fact Sheet 2.3: Public Education and Outreach Minimum Control Measure. U.S. Environmental Protection Agency. Office of Water. 2005. Stormwater Phase II Final Rule Fact Sheet 2.4: Public Participation/Involvement Minimum Control Measure. U.S. Environmental Protection Agency. Office of Water. 2005. Stormwater Phase II Final Rule Fact Sheet 2.5: Illicit Discharge Detection and Elimination Minimum Control Measure. U.S. Environmental Protection Agency. Office of Water. 2005. Stormwater Phase II Final Rule Fact Sheet 2.6: Construction Site Runoff Control Minimum Control Measure. U.S. Environmental Protection Agency. Office of Water. 2005. Stormwater Phase II Final Rule Fact Sheet 2.7: PostConstruction Runoff Control Minimum Control Measure. U.S. Environmental Protection Agency. Office of Water. 2005. Stormwater Phase II Final Rule Fact Sheet 2.8: Pollution Prevention/Good Housekeeping Minimum Control Measure. U.S. Environmental Protection Agency. Mayors Office of Long-Term Planning and Sustainability. 2008. PlaNYC Sustainable Stormwater Plan. City of New York. Philadelphia Water Department. 2012. Green City, Clean Waters Art Contest. http://www.phillywatersheds.org/green-city-clean-waters-art-contest-openphilly-students (accessed January 30, 2012). Philadelphia Water Department. 2009. Green City, Clean Waters: The City of Philadelphias Program for Combined Sewer Overflow Control. City of Philadelphia. Philadelphia Water Department. 2006. Checklist B: Technical Submittal Guide, Post-Construction Stormwater Management Plan. http://www.phillyriverinfo.org/WICLibrary/ChecklistB.pdf (accessed December 1, 2011). Philadelphia Water Department. 2011. Stormwater Management Guidance Manual, Version 2.0. City of Philadelphia. Philadelphia Water Department. 2006. Stormwater Regulations. http://www.phillyriverinfo.org/WICLibrary/StormwaterRegulations.pdf (accessed December 1, 2011).

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Portland Bureau of Environmental Services. 2011 Clean Rivers Education Program. City of Portland. http://www.portlandonline.com/bes/index.cfm?c=41186 (accessed February 10, 2012). Portland Bureau of Environmental Services. 2011. Stormwater Management Plan. City of Portland. Steiner, Frederick R., and Kent Butler. 2007. Planning and Urban Design Standards. Hoboken, N.J.: Wiley. Urbonas, Ben, and Peter Stahre. 1993. Stormwater: Best Management Practices and Detention for Water Quality, Drainage, and CSO Management. Englewood Cliffs, N.J.: PTR Prentice Hall.

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