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Developing Successful Runoff Control Programs For Urbanized Areas

Click HERE for graphic.

 Developing Successful Runoff Control Programs for Urbanized Areas

                           Prepared by:

      Northern Virginia Soil and Water Conservation District
                         Fairfax, Virginia

       in fulfillment of Grant # X-820828-01-0/1/2 from the
                  Nonpoint Source Control Branch,
       Office of Water, U.S. Environmental Protection Agency

                           Final Report
                           July 1, 1994

                         TABLE OF CONTENTS

ACKNOWLEDGEMENTS. . . . . . . . . . . . . . . . . . . . . . . . .ii

EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . 1

     Introduction . . . . . . . . . . . . . . . . . . . . . . . . 4
     Purpose and Intended Audience of this Manual . . . . . . . . 4
     Brief History of Runoff Control. . . . . . . . . . . . . . . 5
     How Urban Runoff Adversely Affects Water Resources . . . . . 7
     The Need for Urban Runoff Management . . . . . . . . . . . . 7
     Retrofitting Developed Areas . . . . . . . . . . . . . . . .10
     Local Governments' Compliance with Federal and State
     Regulations. . . . . . . . . . . . . . . . . . . . . . . . .11
     Summary of Selected Federal Water Quality Programs . . . . .12

     Types of Urban Runoff Retrofit Techniques. . . . . . . . . .14
     Nonstructural Methods to Control Urban Runoff. . . . . . . .15
     Structural Runoff Controls for Highly Urbanized Areas. . . .16

     Important Program Elements . . . . . . . . . . . . . . . . .19
     Building a Strong Institutional Foundation . . . . . . . . .21
     Assessing Institutional Resources
     Setting Priorities/Selecting Management Practices. . . . . .25
     How To Overcome Roadblocks to Implementation . . . . . . . .26
     Funding Options/Alternative Funding Approaches . . . . . . .31
     Elements of Successful Programs/Solutions. . . . . . . . . .34
     Conclusions and Recommendations. . . . . . . . . . . . . . .34

INTRODUCTION TO THE CASE STUDIES. . . . . . . . . . . . . . . . .37
     City of Alexandria, Virginia . . . . . . . . . . . . . . . .38
     Southeastern Massachusetts . . . . . . . . . . . . . . . . .42
     City of Austin, Texas. . . . . . . . . . . . . . . . . . . .51
     City of Orlando, Florida . . . . . . . . . . . . . . . . . .63
     County of Fairfax, Virginia. . . . . . . . . . . . . . . . .71
     Cities of Eugene and Portland, Oregon. . . . . . . . . . . .76

GLOSSARY. . . . . . . . . . . . . . . . . . . . . . . . . . . . .90

BIBLIOGRAPHY. . . . . . . . . . . . . . . . . . . . . . . . . . .92



This report was researched and written by Robert losco, Urban Water
Quality Specialist, Northern Virginia Soil and Water Conservation
District (NVSWCD), Fairfax, Virginia.

The author would particularly like to acknowledge the contributions
of Jean R. Packard, Vice-Chairman and Director, NVSWCD, and Norman
T. Jeffries, former Executive Director, NVSWCD.  They reviewed many
drafts and provided valuable insights.  In addition, the entire
NVSWCD staff deserves thanks for providing the overall assistance
necessary to complete this project.

The project was funded by Grant # X-820828-01-0/1/2 from the
Nonpoint Source Control Branch, Office of Water, U.S. Environmental
Protection Agency, Washington, DC. The EPA Project Officer for this
grant was Rod Frederick, Chief, Urban Sources Section, Nonpoint
Source Control Branch.

The following individuals provided review comments:

          Earl Shaver
          Delaware Department of Natural Resources
          Dover, DE
          Warren Bell
          City Engineer
          City of Alexandria, VA
          Leslie Tull
          Environmental Officer
          City of Austin, TX
          Kevin McCann
          Storm Water Utility Bureau
          City of Orlando, FL
          Dave Janik & Bernadette Taber
          Buzzards Bay Project
          Marion, MA
          Noel Kaplan
          Office of Comprehensive Planning
          Fairfax County, VA

          Jack White
          Department of Environmental Management
          Fairfax County, VA
          William Henry
          Department of Public Works
          Fairfax County, VA
          Deborah Evans
          Department of Public Works
          City of Eugene, OR
          Tom Liptan
          Bureau of Environmental Services
          City of Portland,'OR
          Dale Lehman
          Woodward-Clyde Consultants
          Gaithersburg, MD
          William Tate
          U.S. Environmental Protection Agency
          Washington, DC
          Robert Goo
          U.S. Environmental Protection Agency
          Washington, DC
          Dov Weitman
          U.S. Environmental Protection Agency
          Washington,  DC

Executive Summary

This manual defines the institutional and programmatic issues which
are crucial to the success of runoff control programs in already
urbanized or urbanizing areas.  These nontechnical factors are
often decisive in determining the effectiveness and success of such

The manual describes strategies which local communities can use to
develop the institutional frameworks needed to implement runoff
control programs.  The strategies are described in the program
development section of the manual and in the case studies

Each community will have different urban runoff management needs,
environmental concerns and available resources.  Yet, building an
effective program requires certain common key steps.  This manual
lays out the essential elements, which will also be useful in
preparing the management plans required by various Federal
regulations and programs.  In addition, retrofitting for runoff
control may be necessary in some urban areas to achieve the water
quality improvements necessary under current Federal and state

The Coastal Zone Act Reauthorization Amendments of 1990 (CZARA),
6217, required the development of the Guidance Specifying
Management Measures for Sources of Nonpoint Pollution in Coastal
Waters (USEPA, 1993).  States with coastal zone management programs
are required to develop coastal nonpoint pollution control programs
consistent with these Management Measures.  The "Existing
Development Management Measure" of Chapter Four (Urban Areas)
requires development and implementation of programs to reduce
pollution from existing development.

The National Pollutant Discharge Elimination System (NPDES) Storm
Water Permit Program, established by 402(p) of the Clean Water
Act, requires permits for certain municipal and industrial storm
water discharges.  In addition, this program requires the
development of storm water management plans for the areas covered
by the permit, which usually includes urbanized areas.

Both of these programs could involve the use of retrofits to
achieve water quality improvements.  While program requirements may
differ based on the specific regulatory authority, the goals of
these programs are complementary and many of the same management
practices are applicable and satisfy the requirements of both
programs.  The case studies presented in this manual provide
examples of the innovative ways in which many local governments are
meeting the requirements of multiple programs to improve water
quality.  However, communities need to refer to


applicable state and Federal regulations to assure that they are in
compliance with all regulatory requirements.

The manual describes ways that local governments can approach the
issues surrounding the implementation of urban runoff retrofit
technology even when the control options are limited.  It reviews
appropriate "ultra-urban" technologies for situations where more
conventional, land-intensive control practices are not feasible. 
Specific recommendations are summarized to help program
implementation personnel develop strong institutional frameworks
and create effective urban runoff control programs.  The
recommendations presented are largely based on the program
implementation experiences of the case study communities featured
in the manual.  They include:

Problem Identification

     -    Identify problems clearly at the outset

     -    Define runoff control program objectives, requirements,
          and penalties

Priority & Goal Setting

     -    Consider innovative and cost effective retrofit methods

     -    Prioritize retrofit alternatives and set realistic goals
          to implement

Adequate Funding

     -    Identify stable and/or dedicated funding sources for
          urban runoff management programs

     -    Utilize cost-share approaches among agencies

     -    Utilize economic incentives to reduce amounts of
          stormwater discharges, e.g., utility fee reductions for
          reduced amounts of impervious surface

     -    Identify opportunities for public/private partnerships to
          conduct nonpoint source pollution control activities

     -    Obtain participation and support from private interests
          who will benefit from urban runoff control programs


Multilateral Approaches

     -    Use teams or multi-agency work groups wherever possible

     -    Create effective institutional structures

     -    Identify related Federal, state and local programs and
          assess their storm water control effectiveness and degree
          of interaction

     -    Designate a lead agency to coordinate program development
          and implementation

     -    Designate sufficient agency staff to support
          implementation projects




This manual recommends strategies for communities to use to develop
the institutional frameworks necessary for the successful
implementation of urban runoff control projects, including retrofit
projects in developed areas.  It provides practical information for
local government personnel who wish to develop such programs. 
While each community will have different runoff management needs
and available resources, building an effective program requires
certain common steps.  This manual describes the step-by-step
procedures necessary to develop effective programs to reduce
nonpoint source pollution from urban runoff in developed areas.

Institutional factors have a significant impact on the
effectiveness of urban runoff control programs.  Because the
development of institutional frameworks is vital to effective
program implementation, this manual emphasizes program development,
rather than specifying technical requirements for programs.
(Technical manuals for the implementation of urban runoff controls
are listed in the Bibliography.)  It recommends strategies and
outlines the step-by-step procedures which are necessary to develop
urban nonpoint source pollution control programs.

Finally, in the accompanying case studies, this manual describes
some approaches which local governments have successfully used to
implement urban runoff control programs.

Purpose and Intended Audience of this Manual

This manual provides specific guidance to help local governments
implement urban runoff programs.  It does not track all regulatory
requirements; these will differ by state and locality.  Rather, it
addresses certain elements of urban runoff control programs that
are often problematic for municipalities considering program
implementation.  It is designed to help them through the program
development and implementation process.

A local government wishing to develop an urban runoff control
program for developed areas needs to base its approach on local
conditions.  This manual describes the basic issues in sufficient
depth, with the use of examples, to enable a local government to
design an effective program based on its particular needs.

The audience for this manual includes public agencies such as local
environmental regulatory agencies; regional and local planning
agencies; councils of governments; planning commissions,
departments of public works, soil and water conservation


districts, and other agencies concerned with land use, development,
and urban runoff management.

However, the general public also needs to be included along with
interested environmental groups and elected officials as part of
the process of managing urban runoff problems and issues; this
manual seeks to impart a basic level of knowledge about these
issues to the nonprofessional or nontechnical person.

The purpose of the case studies is to present alternatives for
local governments to consider in formulating solutions to urban
runoff problems.  They have been chosen to provide examples of
innovative and successful alternatives in the field.

Brief History of Runoff Control

Urban runoff has not always been recognized as a major contributor
of pollutants.  Historically, urban nonpoint source pollution has
been overlooked by surface water regulation agencies at the local,
state and federal levels.  Efforts to control surface water quality
degradation concentrated on point sources.  Urban nonpoint source
pollution control focused on street sweeping, used motor oil
recycling, and public education.1  In addition, local governments
have historically been concerned mostly with urban runoff quantity
control.  Water quality concerns have now become equally important
for municipalities because of federal and state mandates.

During the first fifteen years of the national program to abate and
control water pollution, EPA and the states have focused most of
their water pollution control activities on so-called "point
sources," such as discharges through pipes from sewage treatment
plants and industrial facilities.  These point sources have been
regulated by EPA and the states through the National Pollutant
Discharge Elimination System (NPDES) permit program established by
Section 402 of the Clean Water Act.

Congress also amended the Clean Water Act in 1987 to require EPA to
establish phased NPDES requirements for storm water discharges. 
Storm water discharge permits will provide a mechanism for
monitoring the discharge of pollutants to waters of the United
States and for establishing appropriate controls.2

The attempts to control point source pollution have reduced
pollutant loads and

     1Murray, James, "Nonpoint Pollution: First Step in Control,"
in Design of Urban Runoff Quality Controls, Roesner et al, eds. 
American Society of Civil Engineers (New York, 1989), p. 378.

     2USEPA, "Overview of the Storm Water Program," Office of
Wastewater Enforcement and Compliance, Permits Division,
Washington, DC: March, 1993.


considerable progress has been made in restoring and maintaining
water quality.  However, the abatement of point source pollution
did not solve all water quality problems.  Recent studies and
surveys by EPA and by state water quality agencies indicate that
the majority of the remaining water quality impairments in our
nation's rivers, streams, lakes, estuaries, coastal waters, and
wetlands result from nonpoint source pollution and other
nontraditional sources, such as urban storm water discharges and
combined sewer overflows.

Congress amended the Clean Water Act in 1987 to focus greater
national efforts on controlling nonpoint sources.  Section 319 of
the Act was enacted to establish a national program to control
nonpoint sources of water pollution.  In addition, Congress enacted
Section 6217 of the Coastal Zone Act Reauthorization Amendments
(CZARA) in 1990 to address the impact of nonpoint source pollution
on coastal waters.

In recent years EPA introduced the Watershed Protection Approach
(WPA) as a flexible framework for focusing and integrating current
efforts and exploring innovative methods for achieving
environmental objectives.  The WPA focuses on four major elements:
1) identifying specific geographic locations; 2) integrating
available authorities to deal with all pollution sources; 3)
involving all stakeholders in analyzing and creating solutions; and
4) measuring effectiveness against clearly established objectives. 
These key elements are derived from experience gained over the past
few years in many states and other EPA efforts such as the Clean
Lakes and National Estuaries Programs.


How Urban Runoff Adversely Affects Water Resources

Urbanized areas and areas in which development has altered the
natural hydrology and infiltration characteristics of the land
typically experience increased surface runoff.  Land development
alters the natural balance between runoff and natural absorption
areas by replacing them with greater amounts of impervious surface. 
The result is increased rates and volumes of surface runoff.

Click HERE for graphic.

The negative impacts of urbanization on water quality has been
well-documented in a number of sources, including the Nationwide
Urban Runoff Program and the States' reports written in response to
the requirements of 305(b) and 319 of the Clean Water Act.  For
example, the States report that urban runoff and storm sewers are
the second leading source of water quality impairment of lakes and
estuaries, and the third leading source of water quality impairment
of rivers in the United States.

As a consequence of the increased quantity and rate of runoff,
greater amounts of pollutants are carried into receiving waters,
and water quality degradation increases.  Other negative impacts
include the increased susceptibility of eroded land to flooding,
other hydrologic changes, and wildlife and in-stream habitat
degradation.  [See Box 1]

The Need for Urban Runoff Management

Many American cities contain areas in which buildings, parking
facilities and urban streets and walkways cover almost one hundred
percent of the land surface.  This creates runoff conditions but
offers no room for structural urban runoff quality management
facilities such as extended dry detention or wet ponds.  Even when
redevelopment occurs within these areas, high land values usually
require replacement similarly intense land uses in order to provide
economic viability for the project.  Conventional best management
practices (BMPs) are difficult, if not

     3USEPA, The Quality of Our Nation's Water: 1992, office of
Water, EPA Document 841-S-94-002, March 1994, p. 10.


impossible, to implement in this context.

In such situations, innovative BMP applications requiring little or
no above ground coverage are necessary in order to meet
increasingly stringent Federal and state urban runoff pollution
control requirements.  In highly urbanized areas, the use of
innovative urban quality control retrofitting is the primary option
to improve the water quality of surface waters which receive runoff
discharges from older urbanized areas.


Why worry about urban runoff?

What is the problem with urban runoff anyway?

Storm water runoff picks up pollutants and debris as it traverses
developed areas, particularly parking lots and streets.  During
storm events, pollutants are picked up and flushed directly into
local lakes, creeks, and streams, without being filtered by the
soil or natural vegetative cover.  This endangers water quality. 
Better pollution control is needed to reduce the amount of
contamination affecting these water bodies.

Isn't new development the cause of all these problems?

New development, in many localities, has to meet strict regulations
on the quality and quantity of storm water runoff.  However, many
of our current water quality problems are caused by runoff from
older, developed areas.  We can't solve the problem without
retrofitting older stormwater control devices or installing them
where none currently exist.

How can we solve this problem?

As the public becomes aware that there are problems with urban
runoff quality, and begins to take action, the water quality of
area streams and rivers should improve.  As people learn that the
storm drain at the end of the street flows straight to a nearby
stream, they will be more interested in what drains to, or is
dumped in, the street catch basin.  They will also press their
elected officials to incorporate stronger stormwater treatment
standards into both new development and redevelopment projects in
their community.

How urban runoff affects water resources.


Retrofitting Developed Areas

As urbanization occurs, and areas of impervious surface increase,
maintenance of water quality becomes increasingly difficult. 
Retrofit of structural controls is often the only feasible
alternative for improving water quality in developed areas.

Click HERE for graphic.

Ideally, as land is developed best management practices would be
implemented to control present and future urban runoff problems.
However, controlling pollutants in runoff from new development
alone will not solve existing water quality problems.  Therefore,
retrofitting is necessary.  It is also the primary option for
developed areas to improve urban runoff water quality.

Retrofitting is a process that involves the modification of
existing surface @vater runoff control structures or surface water
runoff conveyance systems which were designed to control flooding,
so they will also serve a water quality improvement function.

Retrofitting should also be considered as an opportunity to improve
existing water quality best management practices.  Existing
practices may be inadequate or performing poorly, or they may
simply lack the pollutant removal capability of newer BMP designs. 
The least expensive and most practicable retrofit opportunities
often involve the improvement of existing urban BMPs.  BMP
retrofits are a widely used technique.  The opportunity to improve
existing urban BMPs at modest cost, or to convert older dry storm
water detention ponds, for example, into more efficient wet
extended detention ponds is afforded by a retrofit approach.

Factors such as the presence of existing development, or a
community's financial constraints, may limit runoff management
options; targeting may be necessary to Identify, priority
pollutants and select the most appropriate retrofit methods.  This
is particularly true in highly urbanized areas where land is
limited and the use of conventional pond systems is restricted.

In highly urbanized areas, sand filters or water quality inlets,
with oil grit separators


may be appropriate for retrofits because they do not limit land
usage.  Sand inters, however, may be a better alternative for
treating hydrocarbon runoff from small sites than oil grit
separators because sand is a superior filtering medium.  Recent
research questions the effectiveness of oil grit separators at
removing hydrocarbon pollutants.4

Urban runoff retrofitting for nonpoint source pollution control
includes a broad range of different techniques which attempt to
reduce the adverse impacts of urban runoff on receiving waters. 
The types of retrofit techniques will differ depending upon where
they are placed in the storm drainage network.

Local Government's Compliance with Federal and State Regulations

The current storm water management requirements and drainage needs
in major population centers are significant.  EPA storm water
permit regulations require large (>250,000) and medium (>100,000)
size municipalities to have storm water discharge permits for
discharges from their storm sewer systems under the National
Pollutant Discharge Elimination System (NTDES) storm water permit
program.  Large and medium-size municipalities nationwide are now
applying for these permits which will require implementation of
comprehensive storm water management programs to control storm
water runoff.

Click HERE for graphic.

In addition, Section 6217(g) of the Coastal Zone Act
Reauthorization Amendments (CZARA) of 1990 requires States to
develop coastal nonpoint source pollution control programs,
including a management program to control runoff from existing
development.  The new coastal zone requirements are only
applicable, however, in areas which. are not subject to the NPDES
storm water permitting regulations.

     4Schueler, Thomas R., "Hydrocarbon Hotspots in the Urban
Landscape: Can They Be Controlled?" in Watershed Protection
Techniques. volume l(l), February 1994, p. 3-5.


The increasing stringency of federal, state and local regulations
are all examples of the emphasis being placed on minimizing both
point and nonpoint source pollution from urban runoff.

Summary of Selected Federal Water Quality Programs

Coastal Zone Management Act of 1972 (CZMA)

-    established a program to encourage states to develop
     comprehensive programs to protect and manage coastal resources

Coastal Sone Act Reauthorization jAmendments of 1990 (CZRA) 6217

-    mandated state coastal program affecting coastal water quality
     and required the development if the Guidance Specifying
     Management Measures for Sources of Nonpoint Pollution in
     Coastal Waters which states are to incorporate into their
     coastal nonpoint source programs

National Pollutant Discharge Elimination System (NPDES) Storm Water
Permit Program

-    established by 402(p) of the Clean Water Act; requires
     permits for certain municipal and industrial storm water

Clean Water Act 319: Nonpoint Source Control Program

-    initiated a national program management programs which
     resulted in state nonpoint source management programs to
     control nonpoint sources of water pollution and protect

Clean Water Act  320: National Estuary Program 

-    focused point and nonpoint pollution control on geographically
     targeted, high priority estuarine waters; controls are
     selected and implemented on a watershed basis

EPA's Watershed Protection Approach

-    voluntary effort to align traditional regulatory and
     nonregulatory programs to support watershed protection in an
     integrated, holistic manner


While program requirements may differ based on the specific
regulatory authority,, the goals of these programs are
complementary and many of the same management practices are
applicable and satisfy the requirements of multiple programs.  The
case studies presented in this manual provide examples of the
innovative ways in which many local governments are meeting the
requirements of multiple programs.  This manual will help
communities develop and implement programs to improve water
quality.  However, communities need to refer to applicable state
and Federal regulations to assure that they are in compliance with
all regulatory requirements.

Click HERE for graphic.

For example, some communities are not subject to NPDES permit
requirements but may be subject to requirements under the Coastal
Zone Act Reauthorization Amendments of 1990 ("CZARA"), and vice
versa.  In addition, some states have additional regulatory
programs that may govern the management of storm water or runoff in
the absence of Federal requirements.  Other communities may not be
subject to any regulatory requirements at this time, but the public
is increasingly aware of runoff problems and their causes and some
control of runoff is becoming inevitable.



Types of Urban Runoff Retrofit Techniques5

Retrofit techniques can be differentiated depending upon where they
are placed in the storm drainage network.  Some of these are
described below:

-    Source retrofit: Use of techniques that attenuate runoff
     and/or pollutant generation before it enters a storm drain
     system, e.g., reducing impervious areas, using pollution
     prevention practices

-    Open channel retrofit: These are installed within an open
     channel below a storm drain outfall, e.g., an extended
     detention shallow marsh pond system.

-    Natural channel retrofit: Depending on the size of the channel
     and the area of the floodplain, a natural channel may provide
     several retrofit options

-    Off-line retrofit: Involves the use of a flow-splitter to
     divert the first flush of runoff to a lower open area for
     treatment; used where land is available for off-line treatment

-    Existing BMP retrofit: The retrofit of an existing B.MP to
     improve its pollutant removal efficiency or capacity (ability
     to detain flow) or both.

-    In-line retrofit: Used where there are space constraints that
     prevent the use of diversions to treatment areas.

Urban runoff retrofits involve a broad range of different
techniques intended to reduce the adverse impacts of urban runoff
on receiving waters. [See Box 2] The overall goal should be to
achieve some reasonable degree of hydrologic control and pollutant
removal (in relation to cost-effectiveness) as a result of the
retrofit.  Otherwise, the retrofit is not worth doing.

     5 as identified in MWCOG, Watershed Restoration Source Book,
P. 59.


Click HERE for graphic.

Technical factors affect the site-specific suitability of
particular retrofit technologies.  A checklist of these factors

     -    land use
     -    climate
     -    size of drainage area
     -    soil permeability
     -    slopes
     -    depth to water table
     -    space requirements
     -    type and condition of the water
     -    resource to be protected
     -    depth to bedrock
     -    pollutants to be addressed
     -    maintenance access

Nonstructural Methods to Control Urban Runoff

Land use controls can be a cost effective means to control urban
runoff.  They have a maintenance cost/multiple use advantage over
structural BMPs in many cases, and should be employed in
redevelopment situations where appropriate.  Furthermore, land use
controls may be necessary along with structural measures in order
for a jurisdiction to meet its water quality goals.

Strategies for implementing land use controls may include limits on
impervious surfaces, encouragement for the preservation of open
space, and promotion of cluster development.  The use of
nonstructural and structural best management practices for
controlling urban nonpoint source pollution can also be required as
a condition of development approval.


Zoning is a powerful tool which communities can use to control the
type of development or redevelopment allowed within their
boundaries.  Following are some examples of zoning controls that
can be used to protect water resources:

-    cluster development:  constructing dwellings close together to
     preserve open space

-    down-zoning:  changing an established zone to require a lower

-    conditional zoning:  allowing certain activities only under
     specified conditions that protect water resources


-    overlay zoning: placing additional zoning requirements on an
     area that is already zoned for a specific activity or use;
     through the use of resource overlay zoning, high pollution
     activities can be controlled in sensitive areas

-    open space preservation: protecting open space and buffer
     zones near water bodies, e.g., greenways or riparian corridors

Structural Runoff Controls for Highly Urbanized Areas6

1. Innovative Practices

In areas where impervious materials cover almost one hundred
percent of the surface, conventional BMPs requiring large amounts
of land and good soil conditions are usually not feasible.  These
types of BMPs include dry ponds, wet ponds, constructed wetlands
and various sorts of infiltration devices.

On sites where standard BMPs are not feasible, one should consider
the use of unconventional or innovative BMPs sometimes known as
"ultra-urban" BMPs.  These systems are designed to function by
gravity flow between the components.  They include: 1) sand
filtration systems; 2) underground sand filters consisting of
multiple chambers; 3) surface sand filters such as double-trench
systems; and 4) peat/sand filtration systems.

Each is briefly described below:

Sand filtration systems: The City of Austin, Texas has developed a
BMP which consists of a sedimentation and filtration basin and is
appropriate for use on redevelopment sites where topography, space
limitations and high value land do not allow the use of traditional
BMPs.  These filtration systems are primary water quality control
structures.  In order to ensure the long-term effectiveness of
these systems, it is necessary to protect the filter media from
excessive sediment loading.  A sediment trapping structure is
required to be located prior to the filtration basin.  Austin sand
filter stems are particularly well-suited to regional storm water

Underground sand filters with multiple chambers: This is a system
consisting of a structure containing three chambers, one each for
pre-treatment, filtration and discharge.  The first chamber is a
pre-treatment facility performing the same function as a water
quality inlet, removing floating debris and material such as oil
and grease.

     6 A more detailed description of these controls and their
effectiveness is provided in the Alexandria Supplement to the
Northern Virginia BMP Handbook. [see Bibliography]


The second chamber is a filtration device, while the third is a
clear well discharging directly to the storm sewer system.  The
District of Columbia uses underground sand filters as in-line
facilities for both storm water quality and peak flow attenuation. 
One of the major advantages of the D.C. sand filter is that it does
not take up any space on the surface, allowing full use of high-
value urban land.  This aspect makes it particularly attractive to
land developers.

Surface sand filter systems: This system is usually referred to as
the Delaware sand filter because it was developed for use in
Delaware.  Unlike the other filters described in this section, the
surface sand filter system is intended to be an on-line facility,
processing all runoff leaving the site up to the point where the
overflow limit is reached.  It consists of two parallel concrete
trenches, one for sedimentation, the other for filtration.  A major
advantage of this filter design is that it requires a depth of only
30 inches from the ground surface to the bottom of the paved
trench, making it useful in areas with high water tables.  The
simplicity of the design also facilitates maintenance.

Peat/sand filtration Systems Peat/sand filters are filtration
systems which were first developed as alternative wastewater
systems.  Peat is an excellent natural filter of many types of
effluents and pollutants and is just beginning to be used for urban
runoff quality management.  A peat/sand filter system should be
considered for use on developments of several acres where the
pollutant removal requirement is higher than could be expected to
be achieved through the use of other ultra-urban BMP--;.  In
addition, peat/sand filters require less site area than most
conventional BMPs.  However, it should be noted that, under certain
conditions, peat filters can become net exporters of nutrients.

Use of Public Rights-of-Way

A retrofit technique which has been identified for use in a land-
limited context is the use of public rights-of-way as an
opportunity for runoff controls such as wet ponds, vegetated swales
or meandering vegetated channels.  This would include the use of
land under bridges and overpasses, the median strips of roads and
highways, and the exit ramp rights-of-way off major highways.


2. Retrofit Capability of Selected BMPs7

Extended Detention Ponds: Frequently used in retrofit applications,
particularly within dry storm water management ponds.

Wet Ponds: Occasionally used in retrofit situations, particularly
within dry storm water basins

Constructed Storm Water Wetlands: An effective retrofit technique. 
Can be achieved by adding wetland features to dry storm water

Infiltration Trenches: Limited by soil conditions.

Infiltration Basins: Not recommended for retrofit settings,
especially in the coastal zone.

Porous Pavement: Limited by soils which have been modified in most
urbanized watersheds and are not capable of providing adequate

Sand/Peat Sand Filters: Designed as end-of-pipe retrofits in
several applications.  A double-trench version has been designed
for parking lot retrofits.

Grassed Swales: Although not suitable for ultra-urban areas because
of the difficulty of preventing erosion in highly impervious areas,
retrofit option may involve installing check dams to increase
contact time in existing swales.

Filter Strips: Although the percentage of impervious surface in
highly urbanized areas limits the usefulness of this practice as a
water quality control device in ultra-urban settings, this type of
retrofit is appropriate if enough land is available.

Water Quality Inlets: Although water-quality inlets are often used
in ultra-urban areas, their low pollutant removal capability limits
their usefulness as a retrofit technology.

     7 More detailed information on the retrofit capability of
these practices can be found in A Current Assessment of Urban Best
Management Practices. [see Bibliography]



While the program elements discussed in this section are considered
important to program development and success, they do not
necessarily fulfill all regulatory requirements which may be
applicable to a given municipality.  Planners and program managers
should check on all relevant program requirements when developing
their programs.

Important Program Elements

An urban runoff control and retrofit implementation program
involves both technical and programmatic components and should
include the following elements:

     -    technical capability

     -    use of appropriate technology

     -    implementation authority/enabling legislation

     -    funding mechanism or resource commitment institutional
          support structures

The case studies which are part of t his manual demonstrate that
local motivation is critical to the successful implementation of
urban runoff controls.  Also, successful implementation will not
occur without a strong local commitment of personnel and resources. 
Regulations, ordinances, enabling legislation, design criteria,
construction specifications, inspections and enforcement, and
operations and maintenance procedures should all be clear and
explicit.  Appropriate technology for implementing runoff control
measures must exist and must be at an affordable cost to the
agency.  If the foregoing are not present, implementation or
continued successful program performance may not occur.


              Important Elements for Program Success

     -    Technical Capability

     -    Design Criteria for Selection of Appropriate Technology

     -    Implementation Authority/Enabling Legislation Dedicated
          Funding Mechanism

     -    Staffing/Training/Institutional Support/Operations &

The box above depicts some of the key elements for developing and
conducting a successful urban runoff control program.  All of them
may significantly affect program outcome:

-    technical capability and the choice of an appropriate
     technical solution
-    implementation authority and a dedicated funding mechanism

-    the often-neglected elements of program staffing, proper
     training, strong institutional support, and the proper
     operations and maintenance procedures


Building a Strong Institutional Foundation

Urban runoff management program practitioners strongly support the
view that the success or failure of urban runoff control programs
depends upon effective institutional frameworks.  The following
elements are often cited as crucial to program success:


     -    adequate problem assessment
     -    BMP targeting and selection methodology (e.g., on-site
          vs. regional facilities)
     -    appropriate design criteria adequate staffing and
     -    responsibility for success of total program vested in a
          single agency at an appropriate level of authority


     -    dedicated program funding, such as a storm water utility
     -    ease of operation and maintenance procedures
     -    administrative mechanism to ensure 0 & M is performed

Each of these elements must receive adequate institutional support
if a successful urban runoff control program is to be implemented. 
In order to develop the necessary institutional frameworks, the
local government should focus sustained attention on the
institutional aspects of program development.  There should be a
recognition that developing an institutional framework is essential
to support a successful multi-agency, long-term urban nonpoint
source runoff program.


     How can communities develop a successful program?

Each local government may have different tasks to complete to
create a successful program.  However, certain common threads run
through all the case studies described in this manual and these can
be instructive in helping local governments to put together
effective urban runoff control programs.

     A strong motivation to act is essential.

Frequently the strongest motivation to act is economic.  In the
Southeastern Massachusetts area case study, the closure of
thousands of acres of shellfish beds due to contamination by storm
water runoff resulted in millions of dollars of lost income to
local residents and serious disruption to local economies.

For other communities, such as Austin, TX, protection of drinking
water supplies is a high priority.  Still others, such as Orlando,
FL, are concerned about the water quality of the hundreds of lakes
within its metropolitan region.

     Teamwork is essential to accomplish your goals.

Pick the right people and the right organizations.  The experience
gained from the case studies proves that teamwork is necessary to
achieve the desired results.  The nature of the urban runoff
problem means that any solution will cut across departmental,
bureaucratic and organizational boundaries.  The high cost of storm
water control projects, especially retrofits, makes cost-sharing
among organizations particularly advisable.  So identify the key
players early and make good working relationships a high priority. 
Don't neglect the important role of private organizations and

     The need for adequate staffing and training should be


Click HERE for graphic.

Assessing Institutional Resources

Two initial goals should be considered by a local government
interested in developing an urban runoff control program:

     1)   developing or improving its institutional capacity to
          mitigate the urban runoff water quality problems which it

     2)   ensuring that its institutional capacity matches its
          technical ability to deal with the problem.

Implementation personnel should evaluate the following factors as
part of an initial assessment of institutional structures:

     -    Identify the key agencies and personnel

Determine who the key players are in the relevant agencies. 
Typically, there are four major groups involved in the
institutional water quality decision-making process:

          1)   legislative
          2)   regulatory
          3)   consulting professionals
          4)   "users" such as developers, clients, citizens (also
               includes environmental advocacy groups)

The program manager should be aware that the typical bureaucratic
organization of institutions into branches, divisions, departments,
etc., can hamper the ability of the organization to carry out its
program goals and hinder program effectiveness.  The most
successful programs find ways to break the bureaucratic logjam.

     -    Identify all relevant existing programs and assess their

This may involve looking at an array of water quality programs
scattered across different agencies and departments.  Look for
opportunities to modify these programs to reach the desired goals. 
Make sure that existing governmental structures are capable of
implementing proposed programs.  Finally, identify what new
programs are needed.


Click HERE for graphic.

     -    Determine the motivations and goals of the key agencies

They may be acting in response to a perceived problem such as a
health hazard or to a water use impairments Remember that not all
organizations a subject to the same level of political pressure.

     -    Determine whether Political support exists

This includes both established and grassroots structures. 
Political support for environmental issues becomes especially
significant in times of resource constraints and competing

     -    Identify appropriate pollution control techniques

Consult a BMP manual, such as those listed in the Bibliography, for
the types of control mechanisms appropriate to a particular site.

     -    Identify funding options

This might include study of the feasibility of a dedicated funding
source such as a storm water utility and development of a fee

     -    Consider the limitations of available technology

The potential for solving a problem may be limited by many factors
over which the implementing authority has no control.  This
includes performance limitations of technology as well as any site-
specific constraints.

     -    Conclusion

The importance of developing institutional structures cannot be
overstated.  Effective urban runoff management is greatly helped by
the presence of strong institutional mechanisms.  Furthermore, the
case studies support the conclusion that where urban runoff quality
control is institutionalized through dedicated funding mechanisms
such as storm water utilities, innovative and comprehensive
programs (including retrofit activity) are the rule.


Setting Priorities/Selecting Management Practices

Urban nonpoint source runoff problems may be numerous in a given
area and the solutions are often complex.  Funding to solve these
problems is usually limited, so it is necessary to set priorities
so that the worst problems can be targeted for attention.

A ranking methodology should be developed for a specific study area
(e.g., a watershed) in order to encourage a phased approach and to
allocate scarce resources optimally.  Once particular waterbodies
and sources have been targeted for action, the local government can
then determine the most cost effective approach to solve the

The following factors should be considered in the ranking process:

     -    waterbody importance
     -    type of use (recreation/aquatic life/drainage)
     -    status of use (impaired or denied uses)
     -    level of use
     -    pollutant loads

The key point to be made about the ranking process is that it
should reflect local issues and concerns.  The ranking factors can
be assigned different degrees of weight based on the degree of
local importance.

In evaluating and selecting appropriate control practices, local
governments should consider:

     -    Does the practice selected meet any applicable regulatory

     -    Is the selected control buildable and effective?

Relying upon structural controls is different from the use of
source controls and regulatory or non-structural controls.  Complex
structural controls pose both construction and future maintenance
challenges that should not be overlooked.

Use the following as a checklist of the tests which the proposed
BMP should pass to be considered for implementation:

     -    Does it meet regulatory requirements?
     -    Is it effective at pollutant removal?
     -    Can it gain public acceptance?
     -    Is it technically implementable/easily maintained?
     -    What are the associated costs?


The process of setting priorities and targeting urban runoff
problems is a complex process consisting of many factors and should
be performed in a systematic manner.

How To Overcome Roadblocks to Implementation

Two of the biggest "roadblocks" to implementation of urban runoff
control retrofit projects are high cost and shortage of funding and
the lack of available land in urbanized areas.  Many participants
in the urban runoff management and planning process describe the
extreme difficulty of implementing urban runoff retrofits because
of the lack of available land at highly urbanized sites and the
lack of funding for these typically expensive projects.  The most
difficult sites are those where land for siting control practices
is severely constrained or non-existent.  The high cost associated
with retrofitting older urban storm drainage systems requires a
careful evaluation of pollutant reduction goals and the targeting
of control practices.

Land Availability

In the urban context, land may be strictly limited and/or its value
may be prohibitive for some uses.  Practices requiring large land
areas are simply not feasible.  The three most used control devices
for storm water quality management, viz., dry ponds, wet ponds, and
infiltration devices, are not always suitable for urban retrofit
situations because of space constraints or underlying soil

On sites where these types of conventional practices are not
feasible, innovative and experimental approaches should be tried. 
Newer ultra-urban technologies that take up little or no above-
ground space should be used.  Performance monitoring should be done
to verify effectiveness.

Cost of Implementation

The extremely high cost of retrofit projects - engineering studies,
land acquisition, and the actual construction costs - raises the
question of how realistic these projects are for many local
governments to achieve.  In addition to initial project cost, there
is also the continuing and long-term cost associated with
operations and maintenance.  Some ways to reduce the high cost of
these projects include:

     -    utilizing state or federal cost-share programs where
          available (e.g. FEMA floodplain "buyout" or EPA nonpoint
          source grants)

     -    encouraging multi-jurisdictional efforts to spread the
          cost and benefits

     -    soliciting volunteers and in-kind contributions to reduce
          project cost


     -    creation of special districts or dedicated funds such as
          storm water utilities

     -    low interest state revolving fund (SRF) loans for
          nonpoint source control projects

The use of high value urban land is the biggest obstacle to
implementing retrofits for many municipalities.  Land which would
ordinarily be generating revenue for the municipality is removed
from the tax rolls.  This is a clear institutional disincentive to
implement retrofits in highly urbanized areas.  If a local
government considers water quality improvement as a goal desired by
the community, then the revenue loss might be viewed differently by
the public, and would be easier to justify politically.

Localities are increasingly turning to methods of returning the
costs of storm water discharges to individual property owners,
through mechanisms such as storm water utility fees or storm
drainage and flood control fees.  The goal of these programs is to
provide economic incentives to property owners to reduce the amount
of storm water discharges from their land by offering credits for
implementation of best management practices, as well as to reduce
the burdensome cost to already fiscally-strained jurisdictions.


Click HERE for graphic.

Increasing Public Awareness

To ensure adequate support for urban runoff control programs, the
public needs to be educated about the nature of urban nonpoint
source pollution and the benefits of controlling urban runoff. 
These issues are not readily understood by large segments of the
public.  The need to heighten public awareness cannot be

Urban runoff control programs must have public backing and
involvement to succeed.  There is broad general support for
environmental concerns and this support can be translated into
political support of urban runoff control programs.  However,
adequate funds must be devoted to public information and education
programs about the nature, causes and solutions of urban runoff and
urban nonpoint source pollution.  The public must recognize the
seriousness of urban runoff pollution, and understand the
importance of local commitment for a successful urban runoff
management or retrofit program.

Click HERE for graphic.

Public education is an essential tool for using public awareness
and generating political support.  Educational efforts typically

     -    program meetings and presentations

     -    program materials such as newsletters, fact sheets,
          brochures, and posters

     -    homeowner education programs

     -    media campaigns

     -    coordination with activist groups for program support


Click HERE for graphic.

Creating a Stable Funding Mechanism

Runoff control programs are usually implemented at the local level. 
Local communities generally have limited budgets and limited
staffing which impedes effective implementation.  Sources of
funding at the Federal and state levels are also limited and
uncertain, and cannot be counted upon to provide total project

One successful institutional response by many municipalities has
been the establishment of storm water utilities.  Some
jurisdictions have used storm water utilities to fund the basic
"hardware" of urban runoff management, while others have included
funding for watershed planning and retrofitting programs.

Special taxing districts, such as a watershed improvement district,
can levy taxes and borrow money to engage in a wide range of
nonpoint source pollution control activities.  A special taxing
district is similar to a school district or a sanitary district and
functions as a special governmental unit in a particular area. 
Real estate within its boundaries is appraised and taxed to fund
program activities.

The purpose of a dedicated funding source such as a storm water
utility or a special taxing district is to provide a stable and
reliable method of financing storm water management programs.  The
development of comprehensive and effective programs requires a
secure funding base.

[More information on funding options is provided below.]


Policies and Procedures vs. Programs and Institutional Frameworks.

Effective prevention and control of urban runoff pollution requires
both defined policies and procedures, and effective programs and
institutional structures. just having policies on paper is no
guarantee of an effective program.  Institutions must be organized
in such a way as to implement the policies and carry out the

Indeed, the implementation phase is just the final step in an often
long process of planning and preparation It must be accompanied by
a real institutional commitment to change ineffective and outmoded
structures, to break through political or bureaucratic impasse, and
to see that programs function effectively.

The question for the local program manager is: Are the local
government's agencies organized to efficiently and effectively
carry out runoff control activities?  Are the various agencies
involved clear about their responsibilities?  Responsibilities of
each involved party can become a major issue when urban nonpoint
source control projects involve multiple agencies, as they almost
always do.

     The responsibility of each agency involved in an urban runoff
     control project should be clearly spelled out.

The complexity of developing and implementing urban runoff control
programs, including the special considerations relative to retrofit
situations, means that the following distinct phases should be
well-known to the program manager:8

     -    planning phase: analyze, evaluate, plan

     -    preparation phase: prepare budget, allocate resources,
          and obtain permits

     -    Pilot project phase: test selected BMPs

     -    full-scale implementation: construct selected BMPs

     -    evaluation/documentation: evaluate program effectiveness

     8  U.S. Environmental Protection Agency, 'Evaluating Nonpoint
Source Control Projects in an Urban Watershed," in Nonpoint Source
Watershed Workshop.  Seminar Publication # EPA/625/4-191/027.


Funding Options/Alternative Funding Approaches

Implementation of urban runoff control programs at the local level
often requires non-Federal funding.  Now that governments at all
levels are facing fiscal constraints, alternative funding sources
are becoming increasingly important.  Following is a discussion of
some of these approaches:

Click HERE for graphic.

Local governments with strong institutional frameworks have led the
way in the development of utilities specifically designed to abate
NPS pollution or targeted at a particular type of NPS pollution:

     -    Local governments are using the utility concept to
          develop institutional approaches incorporating homeowner
          responsibility for some runoff management practices
          (e.g., septic system maintenance, small construction
          grading and landscaping permits requiring best management
          practices to control runoff)

     -    Storm water utilities are spreading all over the country
          as a way of providing a dedicated funding source for
          urban runoff control projects; a storm water utility is
          to storm water what a sewage utility is to sewage and a
          water utility is to drinking water.  It is a dedicated
          funding source or "stand alone" service unit within the
          city government which generates revenues through fees for
          service.  It is responsible for the operation,
          construction and maintenance of storm water management
          devices and for storm water system planning.

State revolving loan funds were very successful in the early years
of point source pollution control and are now being adapted to
nonpoint sources:

     -    State revolving loan funds, originally established for
          states to upgrade sewage treatment facilities through
          construction grants, may also be used to fund a wide
          variety of nonpoint source control projects and best
          management practices (BMPs)


Special fees and taxes are another source of dedicated project
funds for nonpoint source pollution control:

     -    This approach involves the use of user fees/special taxes
          to fund nonpoint source pollution projects and programs,
          such as special taxes and fees on the sale of fertilizers
          and pesticides, waste disposal, and underground storage

Some innovative approaches being used to fund urban nonpoint source
Pollution control programs include:

     -    Special tax districts, such as watershed improvement
          districts, which can be created to protect highly valued
          water bodies.

     -    Check-off on tax forms to fund restoration and
          conservation programs.

     -    Revenue bonds, which are long-term municipal bonds
          guaranteed solely by the dedication of project funds.

     -    Public/private partnerships can be used to pay for
          capital and/or operating expenses.for storm water
          facility projects when neither could fund them alone.

     -    An annual nonpoint source pollution control tax based on
          property size and land use (not on value) is being used
          in Puget Sound, Washington.

     -    The sale of special license plates in Maryland and
          Virginia has raised substantial amounts of money to
          restore the Chesapeake Bay.

Types of Funding Mechanisms Available to Local Governments

     -    General funds

          The use of general funds may require the re-allocation of
          existing revenues.

     -    Long-term borrowing

          Large structural BMPs may require funding through bond


     -    Pro-rata share fees

          These fees are typically based on an assessment of the
          development's potential to contribute to urban runoff

     -    Storm water Utilities

          Utilities typically assess a fee based on the percentage
          of a site's impervious area.

     -    Special assessment districts

          Funds for projects in a district can be raised by
          assessing fees to landowners in the district.


Click HERE for graphic.

Elements of Successful Programs/Solutions

The case studies presented in this manual were selected as examples
of exemplary local government initiatives in the area of urban
runoff control and/or retrofit implementation.  The case studies
included are all "success stories," and they display certain common
elements.  Among these are the following:

     -    strong institutional motivation to act on problem
     -    political and/or grassroots support for action
     -    skilled personnel
     -    knowledge of available technologies dedicated funding
          source, such as a storm water utility fee an environment
          of institutional cooperation and a long-term commitment
          to work together
     -    targeting strategy/process to maximize use of limited

Many communities are recognizing the benefit of preventing
ecological and habitat destruction to avoid the very high costs
associated with the restoration of degraded resources.  The most
successful communities take a pro-active stance with regard to
regulatory requirements, and use proper planning techniques to
prevent degradation of water resources.  They are realizing the
economic, environmental and social benefits of protecting the
existing ecosystem through land use controls, development
restrictions and urban best management practices.

Conclusions and Recommendations

Effective urban runoff control programs are built upon numerous
institutional, economic and technical factors.  The most successful
programs examined in this project displayed a strong institutional
or programmatic focus, in additional to having a strong motivation
(usually economic) to act on a problem.  Furthermore, the case
study communities displayed strong political and/or grassroots
support for community action as well as skilled personnel.

Solutions must be tailored to each communities' particular
circumstances, but the following recommendations may assist the
interested community to more quickly develop an urban runoff
control or retrofit program for developed areas.



-    Identify and obtain stable, if not dedicated, funding sources
     for urban runoff programs, including retrofit programs.

-    Utilize cost-share approaches among agencies to maximize
     resource impact and obtain participation and support from
     private interests benefitting from urban runoff control

-    Use team or multilateral approaches wherever possible; given
     the nature of urban runoff problems, most solutions will need
     to cut across bureaucratic and organizational boundaries.

-    Focus effort initially on building institutional structures to
     support comprehensive urban runoff control programs.

-    Identify water quality problems and prioritize retrofit

-    Identify all existing related programs and assess their
     effectiveness and modify where needed.

-    Consider innovative, cost effective, and environmentally
     responsible ways of retrofitting.

-    Utilize economic incentives (such as tax or fee reductions) to
     motivate property owners to employ runoff control and/or
     retrofit strategies.

-    Make retrofit projects a condition of approval for
     redevelopment projects.

-    Create a single management agency charged with overall
     responsibility to plan and coordinate program implementation
     and conduct and/or monitor operations and maintenance

-    Designate agency staff to support implementation of projects.

-    Do adequate retrofit planning and realistic goal setting.

-    Select knowledgeable contractors or contractors with a good
     track record in water quality and urban runoff control


-    Supervise, even direct if necessary, the construction phase of
     all projects.

-    Educate developers, consultants, contractors, politicians and
     the general public about urban nonpoint source pollution

-    Identify opportunities for public/private partnerships to
     conduct nonpoint source pollution control activities.


                 Introduction to the Case Studies

The following case studies exemplify many of the institutional,
regulatory, planning and implementation issues discussed throughout
this manual.  They describe the experiences of selected local
governments in dealing with the problem of urban runoff management
in developed areas.  Many of the approaches described in the case
studies are highly innovative and will be useful guides for other
localities considering the implementation of urban runoff control
and/or retrofit programs.

This manual utilizes the case studies to illustrate some approaches
which localities are successfully using to manage urban runoff
problems.  It provides examples of jurisdictions where
institutional frameworks have been successfully developed to
support urban runoff management and retrofit programs. 
Institutional issues are given great emphasis in the case studies,
as in the main narrative, because institutional issues, rather than
purely technical ones, are believed to be a common obstacle to the
successful implementation of urban runoff management projects.

The case studies demonstrate the many different ways communities
have developed and implemented urban runoff management programs. 
Each program is unique, based on the magnitude and negative impact
of that community's urban runoff problem, the available resources
and existing pollution control programs, and the existing
regulatory context in which the local government is operating.

                   City of Alexandria, Virginia


Municipalities are being confronted by increasingly stringent
local, state, and Federal environmental regulations.  Complying
with these regulations is a challenge.  The approach taken by the
City of Alexandria, Virginia is a case study which illustrates this

Alexandria is situated on the tidal Potomac River, across and down
river from Washington, DC.  Because of its location, the City must
comply with Virginia's "Chesapeake Bay Preservation Act." The Act's
implementing regulations required the City to designate "Chesapeake
Bay Preservation Areas" within its boundaries.  The City as a whole
was designated to be a preservation area.  This designation means
that development and redevelopment of land in the City must achieve
specified storm water management criteria.  For permitted
development, nonpoint source pollution loads cannot exceed pre-
development loads based on average land cover conditions.  For
redevelopment of land currently served by water quality best
management practices (BMPs), nonpoint source pollution in post-
development runoff cannot exceed the load existing prior to
redevelopment.  For redevelopment of land not currently served by
water quality BMPs, a ten percent reduction in nonpoint source
pollution in runoff must be achieved when compared to the load
existing prior to redevelopment.

Meeting these storm water management criteria in Alexandria has
indeed been a challenge.  Implementing conventional water quality
BMPs to control the quality of storm water discharges is often
either economically impractical or physically impossible because of
a number of factors such as a lack of physical space, extremely
high land values, a high water table, or unsuitable soil
conditions.  The City has met the challenge by adopting and
adapting for local use a class of BMPs dubbed "ultra-urban."

Ultra-urban BMPs are non-conventional BMPs that are particularly
suited for use in highly urbanized areas.  They are based on sand
filter technology and are currently used in other parts of the
United States.  Alexandria has installed four of these ultra-urban
BMPs in intensely developed areas.  In order to facilitate the use
of sand filter technology, the City has published design criteria
for various ultra-urban BMPs in the Alexandria Supplement to the
Northern Virginia BMP Handbook.

The Alexandria Supplement states that the standard types of BMP
facilities such as dry ponds, wet ponds, and infiltration devices
are not suitable for use in large areas of Alexandria because of
space limitations or poor soil conditions.  The planner, developer,
or engineer is therefore urged to consider the use of
unconventional or


innovative BMPs.  It should be noted that infiltration is not the
preferred method in Alexandria and will only be approved where it
can be clearly demonstrated that it will work.  Most areas of
Alexandria do not contain soils that are conducive to the use of
infiltration devices. (Marine clay is the prevalent soil type in
Alexandria and the region.)

To complicate the problem, Alexandria, in common with many older
cities developed in previous centuries, has sections of combined
sanitary and storm sewers.  During heavy or prolonged storm events,
combined sewer overflows (CSOs) may occur, discharging directly
into streams.  Alexandria has applied for an NPDES permit for the
CSOs from the Virginia Department of Environmental Quality.


The development of design criteria to guide local developers,
culminating in the Alexandria Supplement to the Northern Virginia
BMP Handbook, resulted from the City's engineering staff consulting
with jurisdictions across the country where similar ultra-urban
technology is being proposed or has been implemented.

It should be noted that the City's strategy of implementing ultra-
urban BMPs was essentially driven by the lack of available land and
alternatives.  Most other BMP's were fairly easily screened out
because of the severe space constraints.  Available technology
aside, the other principal strategy issue requires that
opportunities be seized as they arise, usually from redevelopment.

The general strategy employed in the implementation of these
retrofits was one of exploiting any available opportunities. 
Cooperation was solicited from developers.  The double trench
Delaware sand filters which were implemented did not take up any
valuable land above-ground and this was a strong selling point for
bottom-line conscious developers.  This allowed them full economic
use of the land.  The focus has been on available sites.  Parking
lots have been the chief sites suitable for the Delaware sand
filters, and implementation has been limited to them.

One advantage of the Delaware sand filter for Alexandria is that it
requires a total depth of 30 inches from the ground surface to the
bottom of the paved trench.  This is critical in portions of the
city where the depth to groundwater is minimal.  In addition, the
simplicity of the system and the ready accessibility of the
chambers for regular maintenance makes the Delaware-type filter
very suitable for site conditions which are typical in Alexandria. 
This type of system is appropriate for up to five acres of 100%
impervious cover.

Two [District of Columbia] underground vault sand filter systems
were installed on a 3-acre townhouse development in the
Winter/Spring of 1994.  The principal advantage of these systems is
that they may be placed under streets, and in cells of


parking garages, allowing full economic use of the surface areas.


The cost of implementing sand filter technology varies due to site-
specific conditions.  Most of the devices already implemented in
Alexandria were prototypes, making accurate cost estimates
difficult.  However, a range based on the characteristic design of
the Delaware, Austin, and District of Columbia designs can be
estimated.  The costs of Austin sand filters, typically suitable
for large-scale sites, range from $13,000 to $19,000 per impervious
acre.  The D.C. sand filter, which is characterized by an
underground vault with sediment and filtration chambers, originally
cost around $35,000 per unit, but through economies such as pre-
cast concrete and standardized design, costs have come down
considerably to the $12,000 to $16,000 range.  It should be borne
in mind that the early models of these systems are essentially
prototypes and that costs are highly variable.  Economies of scale
are likely to come about through routine implementation.  The use
of prefabrication and modular units may further reduce costs in the

Effectiveness of Ultra-Urban BMPs compared with Conventional BMPs

Most of the (Delaware) double-trench sand filters implemented to
date in Alexandria have not been subjected to long-term monitoring
and Delaware does not rate these systems for nutrient removal
efficiency.  Based on long-term monitoring of sand filtration
systems done by Austin, Texas, the Delaware system is rated at 80%
suspended solids removal rate.  Alexandria, however, recognizes a
TP (total phosphorus) removal rate of 40%.10

The Virginia Chesapeake Bay Local Assistance Department has
provided a grant to the City of Alexandria to monitor the
performance of the first two Delaware sand filters constructed in
the city.

Other Institutional Issues

This case study illustrates the benefit of having a committed
public official dedicated to implementation of nonpoint source
pollution control technology.  The City Engineer has implemented
retrofits mostly on his own initiative, having had relatively few
bureaucratic obstacles to overcome.

     9  Warren Bell, A Catalog of Stormwater Quality Best
Management Practices for Ultra-Urban Watersheds.  Presented at the
National Conference on Urban Runoff Management in Chicago, IL on
April 2, 1993.

     10  Ibid.


There are other programs described in case studies in this manual
where institutional support comes from the $'grass roots." It is
vital to have public support for pollution control programs, but
building support for these programs may sometimes require that
public officials take the lead and steer programs past the numerous
bureaucratic obstacles.

For more information...

For more information on the City of Alexandria's program, call the
Transportation and Environmental Services Department at (703) 838-


                    Southeastern Massachusetts

This case study looks at storm water retrofit projects in the
following areas of Cape Cod:

-    Buzzards Bay/Buttermilk Bay:

     1)   Spragues, Cove Storm Water Remediation Project (Town of
     2)   Broad Marsh River Storm Water Remediation Project (Town
          of Wareham)
     3)   Electric Avenue Beach Storm Water Demonstration Project
          (Town of Bourne)
     4)   Hen Cove NPS Pollution Mitigation Project (Town of

-    Town of Yarmouth
-    Town of Orleans

Existing Nonpoint Pollution Problems on Cape Cod

A Cape Cod Section 208 planning study identified the following
pollutants in storm water runoff from urban sources at various
locations on the Cape:

     Organics: Oil and grease (hydrocarbons), benzene, xylene, and
     toluene from auto emissions or atmospheric deposition.  Runoff
     from roads into Buzzards Bay is estimated to contribute 33,000
     lbs. of petroleum hydrocarbons a year to the Bay.

     Inorganics:    Nitrates, phosphates, ammonia, chloride,
     sodium, calcium, potassium, barium, iron, cadmium, chromium,
     copper, lead, and zinc have all been identified in runoff from
     a section of Route 28 near Falmouth.

     Biological:    Bacteriological contaminants (mostly fecal
     coliform) in storm water runoff were strongly implicated in
     the closure of shellfish beds in Buttermilk Bay (Bourne).

I. Case Studies

Buzzards Bay Area

In Buzzards Bay, over 8,000 acres of shellfish beds are believed to
be closed as a


direct result of storm water contamination.  This represents an
estimated economic loss of $24 million to communities in the
Buzzards Bay area.11  The Buzzards Bay Comprehensive Conservation
Management Plan (CCMP) adopted in 1992 calls for the prevention of
new storm water discharges to the Bay, as well as the remediation
of existing discharges that pose a threat to water resources.  The
plan also calls for towns to inventory and prioritize storm water
discharges for remediation.  After towns have evaluated their storm
water needs, they can proceed based on available resources. 
Funding, however, is one of the most significant factors affecting
the ability of Southeastern Massachusetts area towns to deal with
their' urban runoff problems.

The development of the Buzzards Bay CCMP resulted in some
significant accomplishments for the Buzzards Bay region:

     -    it established overlay district protection to limit
          nitrogen inputs to marine waters of Buttermilk Bay (a
          first in the nation)

     -    it resulted in the development of regional strategies,
          approaches and enforceable mechanisms as part of the
          Massachusetts Coastal Zone Management program

1. Electric Avenue Beach

Strategy and Rationale

An existing storm water system was retrofitted at Electric Avenue
Beach in Bourne, Massachusetts as a demonstration project as part
of the Buzzards Bay Project (a joint project of the Massachusetts
Coastal Zone Management Program and the U.S. Environmental
Protection Agency).  The project was undertaken in response to high
fecal coliform bacteria levels found in wet weather storm drain
discharges to Buttermilk Bay, a tidal embayment in the towns of
Bourne and Wareham at the northern end of Buzzards Bay.  The
Buzzards Bay Project funded the implementation of a storm water
infiltration system in order to test the effectiveness of these
systems in removing bacterial and nutrient contamination from the
storm water runoff entering Buttermilk Bay.

The storm water infiltration system was designed to intercept a
one-year design storm from the adjacent watershed and to avoid
direct discharge of the first flush to the Bay.  Instead, the flow
enters a settling tank for removal of solids and floatable waste
and is then discharged to infiltration galleys.  The only flow
which is

     11  Buzzards Bay Project, "Bay Watch," (Newsletter)
Spring/Summer 1993 Vol. 7 (5), p. 1.


discharged from the original outfall is from a one-year storm or
better.  Monitoring provided by the Barnstable County Health
Department has confirmed a reduction in bacterial loading.

There are other points which make this project noteworthy:

     -    the infiltration galleys are preceded by oil/grit
          chambers designed to reduce clogging in the infiltration

     -    because the infiltration devices are very close to the
          beach area, the distance to groundwater is approximately
          two feet - groundwater sampling has not shown any
          contamination, however

     -    a substantial reduction in construction costs was
          achieved by utilizing personnel from the Town of Bourne's
          Department of Public Works

One of the unique aspects of this demonstration project was that
the EPA Region I and Buzzards Bay Project oversight staff utilized
the Department of Public Works personnel from the Town of Bourne
for construction of the storm water infiltration system.  The
significant institutional consideration here is that the experience
gained by Town staff in the design of the demonstration project
could be used for the construction and maintenance of additional
storm water infiltration systems.  This enhances the storm water
quality control expertise of Town personnel and further
institutionalizes the process.


At the Electric Avenue demonstration project site in Bourne,
monitoring indicates that the retrofit structures are removing over
95% of the fecal coliform from storm water runoff.

2. Hen Cove Nonpoint Source Pollution Mitigation Project

Storm water runoff pollution was implicated in the closure of
shellfish beds and a swimming beach in Hen Cove.  The Buzzards Bay
Project assisted the Town of Bourne in retrofitting the adjacent
storm drain systems so that pollutants are not discharged directly
to the Cove.

Strategy and Rationale

The Hen Cove project targeted specific storm drain systems which
currently allow direct discharge of untreated storm water into the
Cove.  The mitigation project incorporated the use of leaching
chambers and the surrounding soil to treat the "first flush."
(During heavier or more severe storms, excessive runoff will
overflow into the


conventional storm drain system.) Several individual leaching
chambers were places under the road surface throughout the
watershed (there are 13 so far).  At each location, runoff from the
road will be diverted into a storm drain with a settling basin to
allow sediments and other solids to settle out.  From the storm
drain inlet, the storm water is then piped under the road surface
into leaching chambers.  The leaching chambers are pre-cast,
perforated concrete structures which are surrounded by crushed
stone.  Storm water is temporarily stored in the chambers and in
the voids between the crushed stone until it seeps into the
surrounding soils.

Groundwater monitoring will determine the success of this approach
by determining the amount and type of pollution attenuation in the
surrounding soils.

3. Spragues, Cove Storm Water Remediation Project

The Buzzards Bay Project is working with the Town of Marion,
Massachusetts, to reduce pollutants associated with storm water
runoff entering Spragues Cove.  Spragues Cove is a small, shallow
embayment on the shore of Sippican Harbor.  Currently its three-
acre area of valuable shellfish beds is closed for shell-fishing
because it exceeds both state and Federal bacteria standards for

The largest storm drain system drains approximately 64 acres of
watershed directly in the Cove.  The mitigation project will
incorporate the use of a constructed wetland system to treat the
"first flush."

Strategy and Rationale

Several treatment alternatives for the storm water draining into
Spragues Cove were considered:

     -    No action.  The drainage system continues to function and
          shellfishing areas remain closed because of high fecal
          coliform counts

     -    Mechanical treatment methods such as chlorination,
          ultraviolet light, ozone and reverse osmosis

     -    Physical methods of treatment such as infiltration,
          settling or constructed wetlands

The Town of Marion reviewed the alternatives and decided that a
constructed wetland system met the objectives of the project.  The
system will include a settling basin, marshland vegetation, and an
open, deep water pool.  The settling basin allows for coarse
sediments and particulates to settle out prior to entering the
wetland treatment system.  In the wetland itself, physical and
biological processes will treat and remove pollutants from the
water.  The restored wetland system will have a hydraulic detention
time of over 14 days.


The wetland system will be constructed where a salt marsh
previously existed.  The site was filled decades earlier with
dredge spoil from nearby Sippican Harbor.  In addition to providing
water quality improvements, the restored wetlands system will
enhance the fish and wildlife habitat in the area.  Currently the
site has little habitat value.


Existing research on using wetlands to treat wastewater for fecal
coliform indicates that at least 95 percent or greater is typically
removed.  Fecal coliform counts associated with storm water from
the Spragues Cove outfall are significantly lower than previously
recorded levels.  The water quality monitoring plan will be part of
the quality assurance/quality control (QA/QC plan required by the
U.S. Environmental Protection Agency.

Costs and Funding

The Town of Marion and the Buzzards Bay Project obtained $25,000
through the Massachusetts Department of Environmental Protection's
319 grant program.  The Town provided an in-kind match valued at
$35,000 to cover the cost of construction, equipment and labor. 
The Town also donated the land on which the wetland system will be
constructed (estimated value of $100,000 per acre).  A total of two
to three acres of land will be utilized for the project at a total
cost of $200,000 to $300,000.  Additionally, the U.S. Fish and
Wildlife Service granted the Town $10,000 for the project under the
Wetland Restoration Program.  Planning and technical assistance
will be provided by an interdisciplinary team from the Soil
Conservation Service (SCS).

4. Broad Marsh River Storm Water Remediation Project

Broad Marsh River is a tributary to the Wareham River estuary.  It
is located in the Town of Wareham in the northern part of Buzzards
Bay.  The entire Broad Marsh River has been closed to shellfishing
and some beaches closed to swimming due to high fecal coliform
concentrations, The most significant source of pathogens and fecal
coliform pollution in the river is associated with storm water
runoff from discharges from adjacent storm drain systems.  Other
potential sources, such as migratory waterfowl and boats, have been
deemed insignificant.

The primary objective of the storm water remediation project is to
reduce the amount of pollution (mostly fecal coliform) from storm
water runoff entering Broad Marsh River.


Strategy and Rationale

Several alternatives were considered for the treatment of storm
water runoff from storm drain systems adjacent to the Broad Marsh

     -    No action.  Fecal coliform pollution would continue
          unabated and result in the continued closure of
          shellfishing beds and many beach closures for swimming.

     -    Extended detention basins, wet ponds or constructed
          wetlands would be used to detain the first flush of
          runoff for at least 24 hours.

     -    Infiltration structures such as infiltration basin at the
          end of each storm drain system, or a series of leaching
          chambers under the existing road surface

The selected alternative was the use of leaching chambers placed
under the road surface.  The rationale for selecting this
alternative is typical in many retrofit situations; detention
basins were rejected because, as an "end-of-pipe" practice, they
require considerable commitment of land to function properly. 
Since there are 16 storm water outfalls to this section of the
Broad Marsh River, there would have to be 16 detention basins and
this would require the acquisition of a large amount of land,
including some dwellings.  This choice was not deemed feasible. 
Infiltration basins located at the end of a pipe have a similar
need for large land commitment.  The leaching chamber option was
chosen because leaching chambers placed under the road surface
would minimize the disruption to the present drainage system and
would not require a large land commitment.


This project is not yet fully established.  However, to demonstrate
the effectiveness of the leaching chambers, the project will
monitor a minimum of three chambers.

Costs and Funding

The Buzzards Bay Project was initially unable to fund the Broad
Marsh River project.  However, the Buzzards Bay Project together
with the Town of Wareham, requested funding under the Massachusetts
Department of Environmental Protection's 319 (Nonpoint Source)
Program and successfully secured funding in the amount of $88,450
to help reduce pollution loadings from storm water runoff.

5. Town of Yarmouth

In 1991, the Town of Yarmouth implemented the retrofit of a
drainage system to


eliminate the direct discharge of storm water runoff containing
high fecal coliform counts to the Bass River.  The drainage system
was retrofitted to direct the flow into a retention basin to allow
storm water to percolate through a gravel bed.  This design also
allowed for evaporation to remove pollutants.  The retrofit
substantially reduced fecal coliform counts from pre-retrofit
levels and improved the water quality in several ways:

     -    it has reduced velocity, encouraging infiltration

     -    it further reduced the velocity through infiltration and

     -    fecal coliform counts are lower even after similar pre-
          retrofit rainfall events


Water quality monitoring performed by the Barnstable County
Department of Health Laboratory both before the retention basin
retrofit and afterward revealed substantially reduced fecal
coliform counts.12

6. Town of Orleans

The Town of Orleans, Massachusetts is a community on Cape Cod which
has extensive coastal waters, including three estuaries.  These
waters contain important commercial shellfishing areas.  In 1988,
several areas within the Town's waters were closed to shellfishing
due to bacterial contamination.  Through sampling of storm drain
outfalls and receiving waters, and from a review of existing water
quality data, the Town identified storm water runoff as a
significant source of contamination from bacteria and other
pollutants to its coastal waters.

Strategy and Rationale

Three drainage areas were targeted as having significant adverse
impacts on water quality in sensitive areas and in need of
remediation.  The Town's strategy was to: 1) identify the three
high priority areas for development and implementation of pollution
control measures; 2) establish a storm water management committee;
3) screen BMP alternatives to choose best available means to remove
bacteria and solids; and 4) appropriate funds for study of
conceptual approaches and engineering designs and for construction
of the BMPs at the three high priority sites.

     12  Town of Yarmouth, "Effects of Route 6 Storm Drainage
Improvements on Water Quality in Bass River,' November 11, 1992.


Prior to undertaking the projects, which are scheduled for
completion in May, 1993, the Town acted on the consultant's
recommendations and took the following actions:

     -    scoped potential solutions
     -    focus on BMPs for control of bacteria and solids
     -    prior to choosing BMPs, Town conducted field
          investigations, which included the following steps:

          -    mapping drainage systems
          -    analyzing pollution treatment alternatives
          -    sizing treatment facilities
          -    designing O & M programs

The BMP selection process identified the most feasible and cost
effective practices for use in the three drainage systems which
were to be retrofitted.  In addition, the Town of Orleans Storm
Water Quality Task Force was set up to insure the project's
technical quality and to address local concerns.

A range of BMPs were considered for control of bacteria and solids
and their associated nutrients.  The following BMPs were considered
for this project, because they are targeted for the control of
solids and bacteria:

     -    extended detention ponds
     -    retention basins
     -    infiltration trenches (subsurface leaching gallies)
     -    filtration beds

A system of sub-surface leaching gallies was used at three sites
because of limited land but suitable soil conditions; one site
consisted of a detention basin upstream of a filter bed structure
because soil conditions were too poor to permit infiltration.

Institutional Issues

The Town's principal institutional motivation for implementing the
retrofit projects was the adverse economic impact of closed
shellfish beds.  Abating and controlling the bacterial
contamination from storm water runoff was directly tied to economic
concerns and this was a very strong motivation for the Town to
organize a task force and to act on the problem.  The Town
appropriated funds to develop conceptual approaches and engineering
designs, as well as for the construction of the necessary BMPs.

II.  Regional Cooperation: Role of the Cage Cod Commission

The  Cape Cod Commission works with towns on Cape Cod on various


including local transportation projects.  In Barnstable County,
shellfish bed closures were the principal motivation for the
Commission to become involved with storm water issues.  The
Commission tries to de-politicize issues and use all "levers"
available, including state environmental review processes, such as
coastal zone management consistency review, to affect outcomes.


The strategy employed by the Cape Cod Commission utilizes several
different components to maximize the leverage which the Commission
can employ to facilitate implementation of storm water retrofit
projects on Cape Cod.  They try to use all the "levers" available,
such as coastal zone management consistency review and the
implementation of the Buzzards Bay Management Plan as part of the
National Estuary Program (EPA).  The Cape Cod Commission works as a
coordinator [much like MWCOG in Anacostia watershed restorations]
with the Massachusetts Department of Public Works (Mass DPW) and
local governments on storm water remediation and retrofitting as
part of local transportation projects.

The Cape Cod Commission (through the Cape Cod Marine Water Quality
Task Force) has developed a process for prioritizing storm water
drainage mitigation projects.  This process includes the
development of a numerical index to rank proposed projects.  The
Worksheet is keyed to the concerns of Barnstable County, viz., the
safety and harvestability of shellfish beds, as well as the safety
of areas used for swimming and recreation.

For more information...

For more information about the Buzzards Bay Project and other
programs in Southeastern Massachusetts, call the Buzzards Bay
program office at (503) 748-3600.


                       City of Austin, Texas


The City of Austin, Texas, stretches from the Texas hill country of
the Edwards Plateau, eastward to the Blackland Prairie and the Gulf
Coastal Plain.  A unique environment results from this rapid
geologic and ecologic transition.

The Colorado River flows directly through the City.  Three riverine
lakes - Lake Travis, Lake Austin and Town Lake - are the three most
downstream reservoirs of a chain of reservoirs on the Colorado
River known as the Highland Lakes.  These reservoirs are the City's
main water supply, as well as being tourism and recreational

Another key water resource in the area is the Edwards Aquifer, a
limestone aquifer on the western side of the City.  The aquifer is
the sole source of water supply to several communities south of

These water resources are potentially threatened by water pollution
resulting from storm water runoff and other sources of nonpoint
pollution.  In response to this threat, the City has developed one
of the best watershed protection programs in the country.  The
keystone of this program is the Comprehensive Watersheds Ordinance.

Development of the Comprehensive Watersheds Ordinance

In order to protect water resources from degradation due to urban
nonpoint source pollution, the City enacted several watershed
protection ordinances in 1988.  These ordinances were combined into
a single code which applies to the entire city and to its
extraterritorial jurisdiction.  The City of Austin Land Development
Code and the Environmental Criteria Manual provide guidance for
water quality management.  The 1988 regulations became the basic
building blocks of the Austin storm water management and BMP
implementation and retrofit program.

The original catalyst for the consolidation of the existing
watershed protection ordinances was the comprehensive planning
effort known as "Austin Tomorrow." This plan identified nonpoint
source pollution as a potential threat to Austin's environmental
and economic well-being.

Monitoring of Austin's creeks and lakes followed this study and in
1978 the Lake Austin Watershed Ordinance became the first water
quality related ordinance and nonpoint source pollution control
ordinance to be adopted in the region.

In 1981, the City of Austin joined the EPA-sponsored Nationwide
Urban Runoff


Program (NURP) study and began monitoring its storm water
structural controls in 1982.  Subsequent watershed protection
ordinances were passed from 1980-1984 to cover additional
environmentally-sensitive areas.

By 1986, the City of Austin had had eight years of experience with
watershed protection ordinances and appointed the Comprehensive
Watersheds Ordinance Task Force to develop the consolidated
ordinance and provide final review and recommendations for
implementing the consolidation of the numerous existing ordinances.

Overview of the Comprehensive Watersheds Ordinance

The Comprehensive Watersheds Ordinance (CWO) was directed at
preventing urban runoff pollution by placing requirements on
proposed new development with Austin and its extraterritorial
jurisdiction.  Although the Comprehensive Watersheds Ordinance
originally existed as a stand-alone document, it has since been
incorporated into the City's Land Development Code.  In addition,
there have been several amendments to it since 1986 and more are
anticipated in the future to better protect various sensitive
areas.  Nevertheless, knowledge of the evolution of the Ordinance
is helpful to understanding Austin's strategy for urban nonpoint
source pollution control.

Specific pollutants were not addressed in the Comprehensive
Watersheds Ordinance.  Control of specific pollutants was
instituted only for the sensitive Barton Springs Zone, which
recharges the Edwards Aquifer.  Several ordinances for the
protection of this sensitive area have been put in place over the
last several years.

The Ordinance required a range of widely accepted and proven
structural and nonstructural nonpoint source pollution controls to
be included in new development projects.  These controls included
best management practices (BMPs) such as impervious cover
limitations, water quality buffer zones, protection of critical
environmental features, limitations on disturbance of the natural
stream, erosion control practices, sedimentation and filtration
basins, and wastewater disposal requirements.  One significant
aspect of the ordinance was the use of nonstructural controls to
prevent and mitigate nonpoint pollution associated with
development.  The rationale behind this approach was that
impervious cover limitations and buffer zone requirements have been
proven to maintain the basic hydrologic balance.

Protection of non-drinking water supply watersheds in the eastern
side of Austin were not given high priority.  Downstream of Town
Lake the Colorado River is not used for drinking water supply. 
Furthermore, clay soils dominate on the eastern side of the City;
therefore, maintaining infiltration and recharge is not a critical
goal in these watersheds.


Effectiveness of the Ordinance

The City of Austin standard sand filter design requires the first
half inch of runoff from a site to be diverted into a sedimentation
basin and then filtered through sand.  This design is based on
eight years of monitoring filter ponds of different designs.13 
The demonstrated removal efficiency of the sedimentation/filtration
ponds for total suspended solids is 75% to 97%.

An important consideration learned from the Austin experience
regarding effectiveness is that maintenance is critical to ensure
BMP effectiveness, yet timely maintenance is problematic at both a
local and nationwide level.  Another is that the best protection
for water resources is believed to be afforded by a combination of
structural and non-structural controls as provided for in the
Comprehensive Watersheds Ordinance.  Structural controls alone are
not always effective, nor can they prevent an increase in
pollutants from high intensity developments.

Austin's non-degradation strategy for contributing watersheds is to
limit the percent of impervious cover in new developments and to
reduce post-development pollutant loads through a menu of storm
water control practices, and a program of retrofitting storm water
treatment measures in developed areas.  Austin has incorporated
this strategy into the framework of the City of Austin Land
Development Code through a mechanism known as an "impervious cover
cap." The impervious cover cap is established by setting a Maximum
Sustainable Removal Rate for storm water treatment measures at 90%:
beyond this point, storm water control measures cannot be relied
upon to reduce the pollutant loads associated with additional
impervious cover down to the pre-development level.

This strategy aims to reduce excessive reliance on storm water
treatment measures because of their inherent limitations and risk
of failure due to lack of maintenance and their need for
replacement.  Impervious cover levels, on the other hand, do not
change over time, do not require maintenance, and their life span
is infinite provided their nature is unchanged.

However, the Austin program recognizes that modification of the
City's development regulations would provide only a partial
solution to the problem of water quality degradation.  It sees
retrofitting of structural storm water controls as the only way to
reduce pollutant loads from existing development and development
projected but not

     13  Parrish, John H. and Stephen Stecher, "Nonpoint Source
Pollution Control in the City of Austin." City of Austin,
Environmental and Conservation Services Department, March 1991, p.


yet built.14

The Austin program has recognized that, in light of the growing
trend toward limiting building density and/or impervious cover as a
means of nonpoint source control in residential areas, there is a
need to establish a clear linkage between development density or
impervious cover and pollutant loadings.  In addition, the city
recognized that more study is needed on the effects of types of
land use on the quality of storm water runoff.

The City's Storm Water Monitoring Program has provided the city an
opportunity to evaluate the effectiveness of its varied array of
storm water quality controls, and also to assess whether they are
over- or under-designed relative to site conditions.

First Flush of Runoff and its Effects on Storm Water Control
Structure Design15

Austin's Environmental Resource Management Division published a
report (1990) showing that the first 1/2 inch of runoff did not
necessarily carry the bulk of the storm load.  This was contrary to
the prevailing assumption that the first 1/2 inch of runoff in a
storm washes off 90% of pollutants from the impervious cover.  The
report suggested that for a development with 90% impervious cover,
only 40% of the total storm load would be washed off in the first
1/2 inch of runoff.

The implication of the report for control structure design was that
a control structure designed to capture and treat only the first
1/2 inch of runoff would only remove about 40% of the total annual
load.  The bypass or untreated annual load could be substantial. 
The report did not suggest an alternative structural control
design; it merely raised the issue of a substantial amount of
pollutant load in excess flow from a structure designed to capture
and treat the first 1/2 inch.  Changes to the City's Land
Development Code in December 1993 resulted in the treatment volume
increasing with the amount of impervious area on the site, starting
at .50 inch plus .10 inch per 10% increase in impervious cover over
20% of the site.

However, urbanized watersheds should be targeted for priority
control based on other findings.  Another Austin study confirms
that storm water runoff pollutant loads increase with watershed
imperviousness, and that loading rates of urbanized

     14  Ibid., p. 15

     15   City of Austin, Environmental Resource Management
Division, "The First Flush of Runoff and Its Effects on Control
Structure Design." June, 1990.


creek watersheds were significantly higher than those from small
Suburban sites.16


The City of Austin has developed a sand filtration best management
practice for use in storm water quality management.  The sand
filtration systems are the primary water quality control

The City had previously implemented a storm water monitoring
program in 1984.  This study was conducted to determine annual
removal efficiencies of six storm water quality control structures,
including three filtration basins, one wet pond, one sedimentation
(dry) pond, and one retention/filtration basin system.  The
structures were monitored between 1984 and 1989, and comparative
measurements of inflows and outflows were taken to determine
concentrations of pollutants.

Effectiveness of removal for the following parameters was measured:

     -    Fecal coliform
     -    Total suspended solids USS)
     -    BOD/COD
     -    Nitrogen
     -    Phosphorus
     -    Heavy metals

The study17 concluded that the sand filtration basin is an
effective structural control measure for most of the described
pollutant parameters.  Sand filtration is a demonstrated success in
Austin, although officials concede that maintenance is sometimes
inadequate and sporadic.18  There have also been some isolated
technical and/or design failures, such as slope erosion and
construction failures which have resulted in inadequately
performing BMPs.

     16  City of Austin, Environmental Resource Management
Division, "Stormwater Pollutant Loading Characteristics for Various
Land Uses in the Austin Area." March, 1990.

     17  City of Austin, Environmental Resource Management
Division, "Removal Efficiencies of Stormwater Control Structures."
Final Report, May 1990, p. 16.

     18  Personal communication with Les Tull, Engineer, City of
Austin, Texas, May 25, 1993.



The Austin sand filter program was implemented in response to
regulatory requirements, viz., the consolidation and enactment of
several watershed protection ordinances in 1988.  In addition,
political pressure to act came from citizens demanding action to
protect water quality.  The City of Austin's Land Development Code
and Environmental Criteria Manual provide documentation and
guidelines for the City's water quality management efforts.

Prior to enactment of the watershed protection ordinances, the City
implemented a storm water monitoring program in 1984 to evaluate
storm water control measures and to develop a database to quantify
the effects of impervious cover and land use on water quality and
also to evaluate the effectiveness of various structural storm
water control measures already in use.

The basic strategy and philosophy guiding the Austin program has
been to make new development and redevelopment pay the costs
attributable to its impact and to mitigate all impacts of new
development.  While this has been the strategy, it has not been
possible to accomplish this for all aspects of the development
process, such as permits and review.  In addition, the City assumes
responsibility for maintaining water quality controls for single-
family development.  This approach includes a provision for payment
of a fee in lieu of constructing BMPs so as not to restrict
development.  Fee in lieu of funds are used for retrofit projects
for existing development, but only within the most highly urbanized
and developed Watersheds classified as "urban" in the Land
Development Code.19

There are many components to the Austin storm water management and
urban nonpoint pollution control program.  These include retrofit
watershed master planning, source control of pollutants, and public
education.  A current emphasis is on the public education
component, which includes videos and posters with the theme of
abating urban nonpoint source pollution.

Austin's strategy sees the key to a successful nonpoint source
control program as the targeting of critical areas to achieve high
pay-off returns.  The City's focus is on potential deterioration of
local water supplies, viz., Lake Travis, Lake Austin, Town Lake and
the Edwards Aquifer.  The Comprehensive Watersheds Ordinance
requires the strongest nonpoint source controls in those
developments in watersheds which contribute to the drinking water

Targeting new development is seen as a cost effective method of
preventing future nonpoint source problems.  Required controls
which are prescribed in the Ordinance

     19  Ibid.


can be included in the initial land planning.  Since the primary
controls set forth in the Ordinance are non-structural, raw land
cost is the main cost for new development associated with nonpoint
source controls.  However, structural controls are also used and
these have a cost to the developer.  Since impervious cover
limitations are the most important non-structural control specified
in the Ordinance, retrofitting existing development has proven to
be difficult.  Retrofitting structural controls has also been
difficult, due to limited location and high land costs.

The City's retrofit program uses public education as its main tool
to build and keep the necessary public support for storm water
management programs through the use of videos, posters, and other
media.  In addition, Austin has initiated a process of storm water
retrofit master planning as a way of maximizing the scarce public
resources available for this purpose.

Developing a strategy for controlling nonpoint source pollution
from urbanized watersheds is particularly difficult, and much more
complex than preventing nonpoint source pollution from developing
watersheds.  Retrofitting BMPs in urban areas is still a
"pioneering" activity and involves considerable experimentation and
cost.  While there are an increasing number of localities pursuing
retrofit strategies, there is no broad national experience with
retrofit implementation.

BMP selection in retrofit situations is also problematic; for
example, wet ponds are an excellent BMP for controlling nutrients,
yet they are often very difficult to site under retrofit

Non-degradation Strategy20

Austin has developed a non-degradation strategy for a particularly
sensitive and important area known as the Barton Springs Zone,
which covers several watersheds.  The strategy is "design-based"
rather than being entirely a technology- or performance-based
approach.  The design-based approach requires that compliance be
designed into a project before it is built based upon best
available scientific and engineering principles.  This strategy
includes a City-funded program for retrofitting storm water

Other elements of the non-degradation strategy include:

     -    strengthening existing regulations by limiting exemptions

     -    limiting impervious cover to levels at which generated
          pollutants can be

     20  Parrish/Stecher, "Nonpoint Source Pollution Control in
,City of Austin," march 1991., p. 12


          reduced to background levels by an array of storm water
          control practices

Importance of Non-structural Controls in Austin's Program

One of the distinctive features of Austin's storm water management
strategy is the emphasis given to the use of non-structural
controls.  The basic assumptions of this approach are the

     -    structural controls alone cannot prevent an increase -in
          pollutants from high intensity development

     -    maintenance requirements are high for structural controls
          compared to the maintenance needed for impervious cover
          limitations and buffer zones

     -    sole dependence on structural controls is not wise for
          protecting the City's water resources; a combination of
          structural and non-structural controls is the best

Institutional Issues

Austin created a city department of environmental conservation, the
Environmental and Conservation Services Department, in 1987.  Its
central focus is resource conservation and environmental
protection, as distinct from public works.  This department is co-
equal with other City departments.  It oversees the work of public
and private agencies under its jurisdiction.  This institutional
arrangement is clearly intended to provide support for effective
environmental and regulatory (enforcement) action.

The Environmental and Conservation Services Department and the
Department of Public Works "share" a drainage utility (storm water
utility).  Drainage projects are funded with fees from the drainage
utility.  "Storm water" is not separately identified on the utility
bill, nor described as such officially.

Costs and Financing

Most storm water programs are funded by the drainage utility. or
drainage fee.  Public works drainage projects in the Capital
Improvements Program are paid for with bond sales which are repaid
with tax (general fund) revenues at this time.

     21  Parrish/Stecher, "Nonpoint Source Pollution Control in
City of Austin," p.6


Development is expected to "pay for itself," that is, development
must pay for the cost of controls associated with that development. 
However, in reality, development fees pay for approximately 30% of
the land development review and permit programs.  Nevertheless, the
program's emphasis on non-structural controls means that the cost
for the City is considerably lower (because of less monitoring and
inspection) than if structural controls were the sole means of

The Austin program also takes the view that preventing adverse
water quality is less expensive than trying to restore  its from 
nonpoint source pollution is much less expensive than trying to
restore water quality after it has been degraded.  One of the
stated goals of the Comprehensive Watersheds Ordinance is to avoid
the cost of retrofitting existing development.

There are significant costs throughout the institutional structure
related to control of nonpoint source pollution.  Preventing NPS
pollution can avoid or reduce other costs such as wastewater
treatment, the need for dredging lakes and waterways, and health
risks associated with toxics pollution.  The Austin view is that
the cost of restoration, retrofitting, dredging, advanced types of
water treatment, development of new water supplies, and lost
recreational and economic values can easily dwarf the cost of

Other NPS Control Programs

The City of Austin has also initiated non-structural and low-
structural development controls to limit impervious surface areas
for storm water management purposes.  They have established a
critical zone in which no construction is allowed, as well as a
transition zone where development is limited or not allowed in
order to preserve riparian areas.

Other programs which the City has instituted to control urban
nonpoint source pollution include the following pollution
prevention and source control programs:

     -    household hazardous waste collection: provides for safe
          disposal of hazardous materials

     -    street cleaning and litter collection program

     -    xeriscape and integrated pest management (IPM) programs:
          minimizes inputs to the environment from fertilizers and
          pesticides; both approaches stress the minimal use of the
          least harmful substances to control pests and weeds; IPM
          is encouraged in municipal operations

     22  Parrish/Stecher, "Nonpoint Source Pollution Control in
the City of Austin," p.7


BMP Siting Considerations

There is a diversity of opinion as to whether it is better to
construct large regional BMPs or numerous smaller BMPs closer to
pollutant sources.  The preferred approach in Austin is to
construct numerous smaller BMPs and capture water as close to the
source as possible for the following reasons:

     1)   need to capture less water to achieve the pollutant
          removal desired

     2)   capital and maintenance costs are less if the BMPs are

     3)   maintaining the natural hydrology is easier with smaller
          BMPs - in addition, the need for groundwater recharge is
          addressed, whereas if channeling water further down the
          watershed was done, groundwater recharge would not occur
          (or recharge of polluted water could occur before the
          runoff reached the treatment device)

     4)   protection of smaller waterways from pollution and
          channel erosion

Summary and Conclusion

Austin has attempted to come to terms with its nonpoint source
pollution problems through implementation of the Comprehensive
Watersheds Ordinance and other ordinances since 1986.  The City
recognizes the actual and potential costs of nonpoint source
pollution as it relates to safeguarding of drinking and groundwater
supplies, maintaining tourism and recreational opportunities, and
protecting wildlife habitat, to name a few.

Austin is "ahead of the curve" in terms of meeting EPA and state
water quality goals.  These efforts will continue to pay benefits
into the future.  The development and implementation of the
Comprehensive Watersheds Ordinance could be a model for other local
governments in their efforts to control nonpoint source pollution.

Relevance of Austin's Watershed Approach for Other Jurisdictions

Austin's Comprehensive Watersheds Ordinance is easily transferable
to other jurisdictions and to other hydrogeologic conditions.  The
Texas Water Commission cited Austin's Ordinance as-an example of
the kinds of controls which local governments in Texas could
implement as part of the Nonpoint Source Management Plan which the
state submitted to the U.S. Environmental Protection Agency.


Because the Ordinance is based on BMPS instead of on design or
performance standards, it is widely applicable to other situations
and does not require specialized staffs for its implementation. 
The Ordinance is accompanied by a technical manual which specifies
the technical aspects of the controls which it requires.

Numerous other jurisdictions in Texas have adopted watershed
protection ordinances based on the same framework as Austins. 
Governmental entities across the country have requested copies of
the Comprehensive Watersheds Ordinance for guidance on how to
protect their water resources and control nonpoint source


                   Austin's Program at a Glance

Steps to Implementation

     1)   Comprehensive Planning Process: "Austin Tomorrow"

     2)   Appointed Watershed Ordinance Task Force

     3)   Consolidation of Watershed Protection Ordinances

     4)   Passed Comprehensive Watershed Ordinance

     5)   Targeting of Critical Areas: Austin's strategy uses
          targeting of critical areas to achieve cost effective

          -    Controls for New Development
          -    Identify Candidate Retrofit Sites

Retrofit Program

A strategy for controlling nonpoint source pollution from urbanized
watersheds involves considerable coordination, experimentation and

     1)   Use Public Education to Build Support

     2)   Use Retrofit Master Planning to Maximize Scarce Resources

For more information...

For more information about the City of Austin's program, call the
Environmental and Conservation Services Department at (512) 499-


                     City of Orlando, Florida


The City of Orlando, Florida has taken a pioneering role in trying
to solve its water quality problems related to urban storm water
runoff.  Protection of its numerous lakes and wetlands has been a
primary motivation for action.  Within the corporate limits of
Orlando there are some 83 named lakes, which lie within five major
drainage basins.  The City has the distinction of having been
designated a "National Storm Water City of the Year" by the U.S.
Environmental Protection Agency.  It earned this distinction
because of its aggressive storm water management and retrofit

Some of the innovative storm water treatment systems and retrofit
methods used in Orlando include storm water wetlands, alum
injection, exfiltration, lake aeration, sediment control devices,
trash screens and shoreline and littoral zone vegetation.

Some of the other approaches being used in Orlando are:

     -    storm drain retrofits and water quality enhancements when
          performing corrective maintenance (e.g., vertical volume
          recovery unit for drainage to Lake Lawsona)

     -    exfiltration basin retrofits to existing city storm

     -    littoral zone enhancement and revegetation with native
          aquatic plants

     -    creation of storm water wetlands for pre-treatment of
          runoff entering lakes (e.g., Lake Lorna Doone)

     -    depressional landscaping to encourage runoff infiltration
          (e.g., Lake Ivanhoe)

One of the many major retrofit projects in the Orlando area is the
Lake Greenwood urban wetlands which is a wetland and storm water
management system in an urban environment close to downtown


Evolution of the Florida Storm Water Program/Major Regulatory

The major components of Florida's storm water program are three
pieces of legislation: the 1982 storm water permit requirements for
new development; the 1987 Surface Water Improvement and Management
Act (SWIM), which provided a framework for watershed planning; and
the 1989 storm water legislation, which established program goals
and extended program coverage to existing agricultural and forestry

The Surface Water Protection and Management section of the 1989
storm water legislation provides the regulatory framework for the
Florida storm water management program, particularly the watershed
approach.  This program was enacted by the Florida legislature to
restore the state's degraded water bodies and to protect those
still in good condition.

The landmark 1989 storm water legislation was intended to integrate
the various existing storm water laws and programs into a
comprehensive watershed management program.  Most importantly, the
1989 law emphasized the watershed approach to correcting existing
storm water deficiencies and it gave a regulatory impetus to
retrofitting.  The 1989 law also established the State Storm Water
Demonstration Grant Program which provides matching grants for.
storm water treatment projects undertaken by local governments
which have implemented storm water utilities.  The grant program is
clearly an inducement to Florida municipalities to set up storm
water utilities.

Lessons Learned in Florida's Storm Water Program

The Florida storm water program has been successful at minimizing
storm water problems associated with new growth, but it has been
much less successful in restoring water bodies degraded by storm
water discharges.  The piecemeal approach cannot address one of the
state's largest problems, however, the problem of retrofitting
drainage systems, which includes:

     -    retrofitting of existing storm water drainage systems to
          reduce pollutant discharges to state waters

     -    correcting storm water infrastructure deficiencies
          related to the state's rapid growth

Livingston stresses that the solution is comprehensive and
coordinated work


throughout the watershed.23  He emphasizes the need to address
land use, water resources, and infrastructure planning within a
watershed context. He also states that a dedicated funding source,
such as a storm water utility is also important for maintaining an
effective program.

Lessons Learned in Orlando

The Orlando experience suggests that one of the requirements for
successful urban runoff control and retrofit projects is the
importance of control of the project and the need to write very
good specifications so that water quality goals are met.  Engineers
and consultants may have an economic incentive to design BMPs which
may not be commensurate with the implementing authority's water
quality goals.

Experience reveals that engineers and consultants may sometimes
have a mechanistic approach to problem solving and therefore
advocate a hydraulic solution rather than water quality one in some
instances.  They know how to get the water off-site as quickly as
possible, but this is not necessarily commensurate with a water
quality solution.

The best way for the implementing authority to ensure success is to
be in control of the project, to know the solution that is
necessary, and then see that it is done correctly.

Greenwood Urban Wetland

The Greenwood Urban Wetland in Orlando is a constructed urban
wetland located within a 522-acre drainage basin.  Storm water
runoff collected within the 522-acre sub-basin flows into Lake
Greenwood, which lies at the lowest point in a 4.5 square mile
urbanized area.  The artificial wetland was built to alleviate
flooding, to pretreat storm water runoff prior to discharge into
drainage wells (which discharge water to the upper Floridan
aquifer), and to re-use the stored water to irrigate an adjacent
cemetery and park.  City-owned land which was previously vacant was
excavated to form a series of ponds and a bypass stream leading to
five drainage wells.

The storm water quality enhancement component of the wetland plan
came about as a result of the City's concern for protecting its
groundwater supply.  Proximity to groundwater is a prime concern in
most of Florida.

     23  Livingston, Eric H., "Lessons Learned from a Decade of
Stormwater Treatment in Florida." Bureau of Surface Water
Management, Florida Department of Environmental Regulation,


The storm water "treatment train" concept was incorporated into the
Lake Greenwood urban wetland.  The BMPs included in this treatment
train are: a sediment and trash screening device; a littoral zone
with vegetation; and aerators to increase microbiological activity.

Effectiveness of the Greenwood Urban Wetland

Water quality monitoring of Lake Greenwood was begun in 1987 - one
year prior to the beginning of construction of the wetland.  This
was done to obtain a baseline profile and to ascertain the trophic
state of the lake.  Both before and immediately after construction,
the lake exhibited eutrophic to hyper-eutrophic conditions.  After
completion of the project, the lake's trophic state indices were in
the mesotrophic range.

Prior to construction, the water quality of Lake Greenwood was not
in compliance with Florida Class III (recreation and wildlife
propagation) water-quality standards.  Since construction, there
have been no water quality standards violations of any parameters
tested, including EPA-listed pesticides.  Further monitoring of the
storm water treatment system is being planned for wet weather
pollutant. removal efficiencies and further hydraulic analysis.  An
ongoing storm water monitoring program was begun in 1991.

Based on the preliminary sampling data, it is clear that the Lake
Greenwood urban wetland storm water management system has enhanced
water quality within the lake and also the quality of the water
discharged to the drainage wells (which discharge to a major

Development of Orlando's Storm Water Utili!y

Storm water projects in Orlando have traditionally been financed
out of general fund revenues, as is common in most municipalities. 
In addition, Orlando has used revenue from a state gasoline tax for
projects which also have a road/transportation component. 
Depending upon general fund revenues, however, often results in
projects being deferred to pay for more critical governmental
functions such as police and fire.  The City has adopted an
aggressive program of storm water system repair and replacement,
pollution control, and lake enhancement.  This problem has been
funded in the past through the City's general property tax budget,
but this source is no longer adequate for the scope of the problem
today, particularly in view of increasingly stringent state and
Federal water pollution control requirements.

To provide for the effective management and financing of a storm
water system within the City of Orlando, the City established a
storm water utility.  The storm


water utility generates its revenue through user fees.  A storm
water service charge levied on every parcel of land in the City. 
The fee is based on the amount of storm water which a particular
parcel passes on to the storm water drainage system.

The storm water utility is responsible for the operation,
construction and maintenance of storm water management devices, for
storm water system planning and lake management.

Packed Bed Storm Water Filter Artificial Wetland24

One innovative project which was proposed by the City and
implemented through a consultant was the "packed bed filter." This
experimental storm water BMP will be used (just coming on line in
July 1993) to treat a small but highly urbanized portion of the
drainage basin which flows into Clear Lake.  The project was
initially proposed in response to concerns about the lake's water

The drainage basin for Clear Lake consists of over three square
miles of highly developed urban area.  This retrofit technique
became necessary because best management practices (BMPs) for new
development are not appropriate in the highly urbanized and
completely built-out Clear Lake basin.  This innovative method of
storm water treatment was selected both for its presumed pollutant
removal efficiency, as well as the necessity of using a BMP which
could function within a limited area where land utilization
constraints exist.

The packed bed filter is an example of technology transfer - a
common wastewater treatment technique which has application to
urban storm water pollution treatment.  The filter utilizes a
treatment train of two components, one of which is a packed bed
filter system planted with wetland macrophytes for nutrient uptake. 
Put more simply, the system is a packed-bed filter (similar to a
trickling filter) with hydroponically-growing aquatic plants. 
During dry weather or low flow conditions, the device will treat
water from Clear Lake using the continuous flow to maintain the
planted beds.

The device has a limited storage volume, so a decision was made
that in order to maximize the removal of the most pollutants, the
goal would be to capture less than the first one-half inch of
runoff from a larger acreage than a greater amount from a smaller
acreage.  It is hoped that this will result in the treatment of a
dirtier waste stream and reduce the amount of pollutants reaching
the receiving waters of Clear Lake.

     24  Dyer, Riddle, Mills & Precourt, Preliminary Engineering
Report: Packed Bed Filter.  Prepared for the City of Orlando, FL,
April, 1991, p. 4-3.


Pollutant Removal Efficiency Considerations for Packed Bed Filters

Although the packed bed filter implemented by the City of Orlando
has only recently been brought on line July 19931, there are
certain operational considerations for packed bed filters as they
relate to treating urban storm water runoff.  Packed bed systems
intended to treat storm water do not have to meet the strict
effluent quality criteria that would be required for wastewater. 
Indeed, the concentration of pollutants in storm water most closely
resembles tertiary treated wastewater with the exception of solids
concentrations.  This is one reason why the packed bed storm water
treatment system was designed to treat a larger flow with lesser
removal efficiency than a higher removal rate from a smaller flow.

The packed bed filter employs the concept of a "treatment train."
The concept of a treatment train of BMPs involves a series of unit
operations designed to remove the largest amount of contaminants
from runoff, typically greater than the pollutant removal
achievable through individual unit operations.

The packed bed filter system is a new technology and a transfer of
technology from wastewater treatment systems to storm water
management systems.  As an experimental practice for storm water
treatment, many elements need to be monitored for their relation to
long-term effectiveness:

     -    hydraulic residence time
     -    bed media
     -    plant materials for the packed beds
     -    depth
     -    travel length
     -    velocity
     -    liners

Use of Alum for Treatment of Storm Water Runoff

One technology showing promise is the use of alum to treat storm
water runoff.  Two lakes in Orlando, Lakes Dot and Lucerne, and one
in suburban Winter Park, Lake Osceola, are having their storm water
inputs from large urbanized drainage basins pre-treated with alum. 
The alum treatment concept was initially tested on Lake Ella in

Alum treatment of storm water runoff was selected after an analysis
of the pollution abatement alternatives.  Conventional storm water
management techniques such as retention, detention, or exfiltration
were deemed not feasible due to space limitations, or because of
the poor infiltration capacities of watershed soils.  The alum is
injected and mixes with the storm water in the storm sewer lines. 
Floc accumulation begins


immediately and the floc settles on the lake bottom.

Alum injection is wastewater treatment technology being adapted to
storm water quality control.  There is still some question whether
it can be considered a retrofit technology, but its use as a
pollution abatement alternative involves many of the hallmarks of a
retrofit situation:

     -    infeasibility of conventional storm water management
          techniques such as retention/detention

     -    infeasibility of using exfiltration systems due to
          limitations of available space and poor infiltration
          capacities of watershed soils

                   Another Case Study in Florida

Lake Jackson Regional Storm Water Management System

Rapidly urbanizing areas in the Megginnis Arm watershed were
causing water quality degradation in Lake Jackson in Leon County
near Tallahassee.  A regional storm water detention system was
designed and constructed through a cooperative effort of the
Florida Department of Environmental Regulation, the Northwest
Florida Water Management District, and with funding from EPA's
Clean Lakes Program and the State of Florida.  The facility
consists of a wet detention pond with a heavy sediment basin at the
inflow, a sand filter system designed to filter particular
pollutants from storm water, and a three-cell constructed wetland
designed to remove dissolved pollutants such as nutrients.

Construction of the system was completed in 1983 at a cost
$2,664,389.  Maintenance operations, which consist of sediment and
clay removal from the top of the filter fabric do not exceed
$30,000 per year.

Effectiveness of the Lake Jackson

Florida State University researchers conducted a long-term storm
water sampling program of the facility and its individual
components.  Overall, the facility has performed up to design
specifications within the constraints of space and the technical
level of the equipment used.  However, the increasing urbanization
of the watershed has resulted in larger volumes of storm water
draining into the facility, well beyond its design capacity.  To
overcome these deficiencies, the facility was enlarged to provide
longer detention of more storm water, allowing the facility to


detain larger storms and limiting the discharge of untreated storm
water into Lake Jackson.

Lessons learned from Lake Jackson experience

Some of the lessons learned in the construction of the Lake Jackson
regional storm water management system include the following design

     -    storage volume and the amount of water bypassing the
          system are critical design elements; the system should be
          designed based on maximum anticipated build-out in the

     -    adequate funding must be provided to operate and maintain
          the system

     -    wetlands systems require some maintenance such as
          dredging to remove accumulated sediments and organic
          matter; they will not work indefinitely without

For more information:

For more information about the City of Orlando's program, call the
Storm Water Utility Bureau at (407) 246-2370.


                    County of Fairfax, Virginia

Regulatory Context

Fairfax County, Virginia is subject to the following Federal and
State legislation and programs:

     -    Amendments to the 1987 Clean Water Act requiring NPDES
          permits for storm water discharges

     -    Virginia storm water management regulations (at local

     -    Erosion and Sediment Control Law

     -    Chesapeake Bay Preservation Act

     -    Section 404 of the Clean Water Act (wetlands protection)

     -    Water quality requirements under the Reauthorization of
          the Clean Water Act pending Congressional consideration
          in 1994

The County may also be subject to some requirements related to
recent coastal zone legislation to which Virginia as a coastal
state would be subject.  States must develop a coastal nonpoint
source pollution control program as a requirement of the Coastal
Zone Act Reauthorization Amendments of 1990 (CZARA).  The State
programs must be approved by EPA and NOAA by 1995.


Fairfax County has been involved in storm water control for more
than 30 years.  During the 1950s and 1960s, the emphasis was on
storm water conveyance and channelization, which included
delineation of flood plains and implementation of flood control
projects.  Beginning in 1972, on-site storm water detention was
required for all new development.  In the 1980s, water quality BMPs
were required for new development in the southern areas of the
County draining to the Occoquan reservoir, the major source of
drinking water for Fairfax County.

In addition to the Master Drainage Plans which were prepared for
all watersheds in

     25  County of Fairfax, Virginia.  Draft.  National Pollutant
Discharge Elimination system.  Municipal Storm Water Discharge
Permit Application, Part 2. November 1992.


the County during the 1970s, a supplemental Regional Storm Water
Management Plan was prepared in 1988.  This plan provides for
regional storm water control ponds to control both quantity and
quality.  Wherever opportunities exist, the County intends to
expand the implementation of regional storm water management ponds
from the current pilot project involving seven watersheds. 
Implementation of the planned storm water control facilities over
the past 20 years has resulted in
expenditures of approximately $60 million, financed primarily
through storm bonds.

There are presently over 1,500 storm water management facilities
located in the County.  In addition, there are 30 major lakes and
over 100 smaller lakes and ponds which function as BMPs and provide
water quality benefits in Fairfax County.

In 1989, the Fairfax County Board of Supervisors adopted the
"Regional Storm Water Management Plan." The adoption of this plan
marked a shift in philosophy on implementing storm water management
from reliance on on-site controls to what are viewed as more
effective regional controls.

Current Activities

The Fairfax County Department of Public Works is currently in the
process of obtaining various permits or implementing programs
designed to provide water quality improvements.  These activities

     -    obtaining an NPDES permit from the Virginia Department of
          Environmental Quality; part 2 of the application has been
          submitted and the County is awaiting approval from the

     -    implementing on-site best management practice (BMP)
          requirements for new developments in Chesapeake Bay
          Preservation Areas to protect water quality

     -    implementing a regional storm water management program to
          provide water quality improvements for both existing and
          new development, and to protect downstream wetlands and

     -    implementation of stream channel erosion protection

     -    adopted a Water Supply Protection Overlay District
          requiring BMPs in the watershed of the County's water
          supply reservoir

     -    re-zoned much of the Occoquan watershed [water supply
          reservoir] to Residential/Conservation District (R-C)
          with 5 acre minimum lots

     -    adoption of an Environmental Quality Corridor Policy to
          protect land


          and surface water resources

Ongoing Activities

As part of the County program to comply with NPDES requirements,
there is a 5-year monitoring program of selected storm water
outfalls.  The outfalls were selected based on different land uses
and, based on the final monitoring results, typical pollutant
loadings for each land use will be extrapolated.

There are approximately 44 regional storm water management
facilities in the Difficult Run watershed alone.  The County
currently spends approximately $1 to $2 million per year on capital
construction for storm water control facilities.  However, prior to
the recent downturn in the economy, typical drainage facility
expenditures totalled $2 million to $4 million per year.  Due to
current economic conditions, the Fiscal Year 1994 appropriation has
been reduced to $341,000.

To pay for these costs out of declining general fund revenues is
becoming difficult for the County and this has led to discussion
about establishing a storm water utility as a dedicated source of
funding for storm water management and control.  A storm water
utility feasibility study is currently in progress.

Role of the Chesapeake Bay Preservation Act

In Virginia, the Chesapeake Bay Preservation Act (CBPA) is a
significant storm water management program through its BMP
requirements and use of buffers such as the environmentally
sensitive Resource Protection Areas (RPA).  The regulatory
requirements of this program need to be considered by developers
and local governments such as Fairfax County, in addition to other
storm water management regulations.

Proposed Management Program

The County's proposed management program consists of the following

     -    continuation of ongoing requirements and programs such as
          implementation of the Chesapeake Bay ordinance which
          requires structural BMPs on all new development

     -    implementation of suitable water quality control

     -    providing inspection and maintenance of storm water
          management facilities


     -    increased public awareness of the importance of clean
          storm water

The County recognizes that the proposed management program will
require additional County funds and is currently evaluating the
feasibility of establishing a storm water utility to provide a
dedicated funding source for storm water management.

The County will look for opportunities to retrofit storm water
devices and to implement additional regional ponds in all the
County's watersheds in existing developed areas that are now
without water quality controls.  The County's Comprehensive Land
Use Plan also encourages the retrofitting of existing storm water
management ponds to become more effective BMPs.

Regional Storm Water Management Plan

In 1989, the County Board of Supervisors adopted a "Regional Storm
Water Management Plan" which proposed 134 regional ponds in the
most rapidly developing watersheds in the County.  The adoption of
this plan marked a shift in Fairfax County's approach to
implementing storm water management from onsite controls to
regional controls.  This shift was based on the belief that
regional controls are more effective.  Concerning the retrofit of
existing facilities, proposed development plans are reviewed by the
Department of Public Works for opportunities to implement region@l
storm water management to supplement the pilot Regional Storm Water
Management Plan for developing watersheds.  In addition, the
feasibility of retrofitting existing or proposed flood management
projects to include water quality is evaluated.

Non-structural BMPs: Environmental Quality Corridors

Environmental Quality Corridors (EQCs) are the primary non-
structural best management practice used by the County to protect
water resources.  Although the core of the EQC system will be the
County's stream valleys, lands may be included within the EW system
if they achieve any of the following:

     -    habitat quality
     -    corridor-like quality
     -    aesthetic quality
     -    pollution reduction capability

The stream valley component of the EQC system includes the

     -    100-year flood plains and flood plain soils
     -    soils with development constraints adjacent to wetlands,
          streams, and steep slopes


     -    additional areas where above-described buffers are
          insufficient to protect water resources

Current Funding/Future Funding of Water Quality Programs26

There are ongoing County water quality programs which are supported
out of the General Fund.  These programs are:

     -    monitoring programs
     -    emergency response
     -    public awareness
     -    public facilities maintenance

The County's NPDES permit application clearly states the necessity
of developing new funding sources for implementation of capital
improvement projects for water quality.

The following point illustrates the tenuousness of funding water
quality improvement projects out of general or bond funds: The
currently approved bond referendum funds have almost been expended,
and the latest storm bond referendum was defeated by voters in
1990.  Neither the general or storm bond funds can be relied upon
to provide stable funding for future.storm water quality capital
improvement needs.

Yet the County estimates that $11.79 million per year will be
required to implement regional storm water management over the next
decade, and to provide for maintenance of these facilities.  County
staff are determining the feasibility of establishing a storm water
utility to provide long term capital as well as maintenance funds
for the County's storm water control facilities.

In the interim, two methods to fund capital construction of water
quality control improvements are being pursued.  These are: use of
storm drainage pro rata share program funds; and proffer agreements
with developers.  Both of these sources are relatively
insignificant at the present time, due to the downturn in economic

For more information...

For more information about Fairfax County's program, call the Storm
Water Management Branch at (703) 324-5800.

     26  Ibid.


               Cities of Eugene and Portland, Oregon

City of Eugene


The City of Eugene developed its Comprehensive Storm Water
Management Plan (CSWMP) in response to Clean Water Act regulations
requiring medium-size cities and counties to improve and manage the
quality of their storm water.  The plan is a model of a rational
and comprehensive approach to dealing with the problem of runoff
from urbanized areas.  From its beginning as a conventional program
emphasizing flood control and rapid conveyance of storm water
runoff off-site, the City has developed a plan which does not
merely conform with, but exceeds, the evolving Federal mandates for
water quality management.

The principal motivation for initiating development of the
Comprehensive Storm Water Management Plan in 1991 was the imminent
promulgation of a Federal mandate (NPDES) requiring jurisdictions
of medium size (between 100,000 and 250,000 population), to reduce
discharges of pollutants to receiving waters from storm water

The Comprehensive Storm Water Management Plan

The City's storm water management program goes further than meeting
Federal and state water quality requirements.  It has taken the
problem of meeting its legal requirements and turned it into
an.opportunity to offer a broad-based solution through a multiple
objective approach to protecting, enhancing and restoring the
City's water quality.

The multiple objective approach of the Eugene plan includes storm
water management.  Wetlands adjacent to Amazon Creek and other
drainage channels are considered to be hydrologically connected to
the City's storm water conveyance system.  The plan recognizes the
central role that wetlands play in storm water management.

According to the plan, the five-year start-up phase of the storm
water management program includes major program activities such as
planning and administration, capital projects (including
retrofitting), operations and maintenance, enforcement and
inspections, and public communications and outreach.  The City has
already developed a storm water utility and user fee structure.

The City, however, did not have the necessary organizational
structure and programmatic resources in place to address the many
issues involved in managing


storm water quality.  It determined that the proper way to address
the whole range of storm water issues was within a coordinated,
comprehensive framework.  Among the factors which influenced its
decision to develop a comprehensive strategy were the following:

     -    commitments already made to implement the recently
          approved West Eugene Wetlands Plan (see below), as well
          as how the new mandates could be incorporated into this

     -    a new proposed plan, the Natural Resources Functional
          Plan, aimed at protecting the city's riparian and
          waterways corridors; this plan calls for the City's urban
          runoff management plan to address the relationship
          between riparian habitat, water quality and flood

     -    implementation of other goals and policies contained in
          the city's general land use plan

The CSWMP encourages this multiple objectives approach to storm
water management, including flood control, water quality treatment,
and natural resources protection.  In addition, it strengthens the
existing ordinances and implementation activities already in place.

Relation of the Wetlands Plan to Storm Water Plan

Amazon Creek is the central drainage feature of Eugene.  The
channelization of Amazon Creek (completed in 1959) significantly
altered the hydrologic and hydraulic conditions of the area. 
Although flood control benefitted the community and allowed
agriculture, commercial, and residential development to spread
westward in the city, it also had the unfortunate effect of
hydrologically isolating surrounding wetlands.  This isolation and
the subsequent draining of wetlands resulted in environmental

Consequently, wetland restoration is a high priority for the City
of Eugene.  It proposes to begin this process through a
demonstration project called the Lower Amazon Creek Restoration
Project which aims to restore the hydrologic interchange with
surrounding wetlands, and restore fish and wildlife,habitat and
other associated water resource values.  This will be accomplished
through the removal of levees, in whole or in part: through
modifying culverts; and through breaching levees at selected

In addition to restoration of historic wetlands, the city is
developing a program to use constructed wetlands for storm water
quality treatment.  The City is interested in using these
constructed wetlands to control (pre-treat) pollutants in urban


which enters a natural wetland system in West Eugene.

This idea grew out of the preparation and planning to develop the
West Eugene Wetlands Plan (WEWP), with the goal being the
preservation of the natural system through the pre-treatment of
runoff from areas of the City.  Without such treatment, the
degradation of the remaining existing natural wetlands would be a
virtual certainty.  Storm water management is seen as critical to
the success of the WEWP, and to the survival of the wetlands

The use of constructed wetlands as a treatment process for urban
runoff is emerging as an alternative to conventional processes. 
Some of the advantages to using constructed wetlands to temporarily
store or treat storm water include:

     -    water quality improvement
     -    flood, erosion and storm damage reduction
     -    replenishing surface and ground water supply
     -    provision of fish and wildlife habitat
     -    aesthetic or amenity benefit27

Regulatory Issues

There are numerous Federal laws and regulations, executive orders;
as well as comparable state and local regulations and ordinances
which regulate activity in wetlands or potential wetland areas. 
Current Federal policy forbids the use or modification of natural
wetlands to treat storm water.

Nevertheless, the following points should be borne in mind:

     -    wetlands are functionally part of many municipal separate
          storm sewers

     -    wetlands in urban areas may be dependent on storm water
          for their very existence

Therefore, the strict application of regulations which forbid the
degradation of wetlands can have unintended consequences in
watershed and wetland planning.  The City of Eugene experience
suggests that flexibility should be allowed when determining the
level of appropriate protection for wetlands and that this- can be
accomplished through a planning process which involves the local
community as well as Federal and state agencies which regulate
these resources.

     27  City of Eugene, OR.  Conceptual Engineering Design for
Water Quality Workshop.  Final Report.  Department of Public Works,
City of Eugene, OR, undated.


Eugene's Existing Storm Water Program

The City's current storm water system has historically been focused
on providing flood control services.  With its emphasis on storm
water conveyance and flood control, the existing program was in
conflict with Federal mandates for water quality management.  Since
the natural water quality treatment systems, such as riparian
areas, waterway corridors and wetlands have been extensively
replaced with conventional, structural conveyance facilities, ways
need to be found to not only stem the removal of natural systems,
but seek opportunities to preserve them.  The CSWMP recognizes this
goal and integrates it into the plan.

The City is faced with significant and complex issues as it seeks
to transform its existing storm water management program to meet
the challenge of complying with Federal mandates and heightened
citizens' expectations.  The framework of the CSWMP will allow it
to do this within a comprehensive planning context.

The City already has a dedicated revenue source to fund general and
storm sewer capital projects, the storm water utility user fee.  It
is the major revenue source for the existing program, and is
expected to be the principal revenue source for the new, expanded
program.  The City has reviewed and analyzed current policy in
light of evolving Federal water quality mandates, and has refined
its policy to include the following:

     -    that all users of the storm water system contribute to
          the financing of the program

     -    that property owners be encouraged to incorporate
          practices beyond the minimum required through the use of
          financial incentives such as fee reductions, etc.

Retrofitting and Eugene's Storm Water Management Plan

Eugene's CSWMP contains a specific capital facilities best
management practice (BMP) for retrofitting existing-facilities,
where feasible and appropriate, to achieve water quality goals. 
These retrofits may include the installation of in-line sediment
traps, detention/infiltration facilities, wetlands or riparian re-
vegetation, or simply, the modification of flood control facilities
(i.e., storm drain inlets, retention basins, or drainage channels)
to function as water quality facilities.

Additionally, the capital facility BMP directly addresses the
NPIDES requirement that the City assess the existing drainage and
flood control facilities in order to determine if retrofitting them
would improve water quality.


The capital facilities program includes retrofitting as one of the
major activities scheduled during the five-year start-up phase of
the City's comprehensive storm water management program, with
retrofit implementation commencing around 1996.

The activities conducted as part of the retrofitting component of
the Plan, include:

     -    preparing a master list of existing facilities with
          relevant retrofit considerations for each type

     -    conducting an inventory of existing flood control
          facilities that will provide information necessary to
          determine whether retrofits of these facilities are
          feasible or not

     -    reviewing inventory results to select sites and
          facilities where retrofits would be most appropriate

     -    developing a preliminary plan for retrofitting, with a
          schedule and estimated costs

     -    developing funding plans for retrofits

Eugene's Public Outreach Effort

An important feature in the evolution of the City's program are the
numerous methods for disseminating information about the
development of the storm water management program.  These methods
range from neighborhood newspapers such as the Eugene Storm Water
Connections, with general information about the City's storm water
management program, to more targeted information sheets, brochures,
and stickers, to community workshops to introduce citizens to storm
water pollution issues.


              Important Elements in Eugene's Program

The importance of the West Eugene wetlands to the overall
stormwater management plan.

     -    the integration of natural resource elements into the
          overall stormwater management framework and looking at
          the watershed and how it functions as an integrated unit

The significance of the multiple objective planning approach and
why it could be a model.

     -    opportunity to address urban runoff issues from a
          comprehensive perspective, including wildlife habitat,
          recreation, resource conservation education, etc.

The high level and quality of citizen involvement and how this
reduces conflict.

     -    widespread citizen involvement with two-way communication
          and feedback mechanisms facilitates consensus decision-


For more Information-For more information about the City of
Eugene's storm water program, contact the Storm Water Program
Coordinator at (503) 683-6839.


City of Portland


The City of Portland, Oregon, has developed innovative and
comprehensive urban runoff control strategies to meet the water
quality requirements of Federal and state legislation.  Its program
encompasses a wide range of activities for controlling both point
and nonpoint source pollution.  The range of activities alone -
from transportation improvements to improved pesticides
management - serves to illustrate the diffuse nature of nonpoint
source pollution.

Portland's storm water management program has been designed to be a
constantly evolving program which implements the management
practices that succeed, modifies or eliminates those that do not,
and seeks to develop the most efficient and productive practices
throughout the program's life.  Based on a balanced economic and
environmental approach, its goal is to develop and implement the
most successful municipal storm water permit program in the Pacific

Storm Water Permit Program- (NPDES) Activities

The City of Portland, whose total population is roughly 450,000,
has been classified as a medium-size municipality for the purposes
of the NPDES storm water permitting program because less than
250,000 people are served by its municipal separate storm sewer
system.  A significant portion of the city is served by combined
storm and sanitary sewers, which are subject to other Clean Water
Act regulations.

Under Oregon state-wide land use planning law, each city must
define an urban growth boundary (UGB) within which urban
development is confined.  Once approved, they have the force of
law.  Within Portland's urban growth boundary, six other agencies
operate "municipal-like" separate storm water conveyance systems. 
Together with the City, the six have become co-applicants for the
Portland NPDES storm water permit application.  The co-applicants
include Multnomah County, Multnomah Drainage District #1, Peninsula
Drainage Districts #1 and #2, the Port of Portland, and the Oregon
Department of Transportation.

Although the pen-nit has not yet been issued, the seven co-
applicants are currently conducting a number of programs and
practices that directly or indirectly improve the quality of storm
water.  While the NPDES permit application is a joint effort of all
the co-applicants, each co-applicant has responsibility for
implementation of their individual storm water management plan.

Significantly, from an institutional point of view, the City's
NPDES program implementation schedule has been developed to
coincide with the majority of the co-


applicants' fiscal year budget schedules.  The goal of this action
is ease of implementation, but it also represents a concrete and
very sensible method for facilitating institutional cooperation.

NPIDES Program Implementation Strategy

Portland's NPIDES program strategy is to build on a foundation of
existing urban runoff control practices.  The City developed
existing management program (EMP) fact sheets corresponding to each
regulatory requirement.  Portland's proposed NPIDES management
program emphasizes and builds upon existing storm water controls
and management practices.  The program intends to limit the
introduction of new practices as much as possible, but where
appropriate it will phase in new practices during the life of the

However, BMPs were developed to meet NPIDES requirements not
covered by existing programs.  The co-applicants have grouped.BMPs
into implementation categories:

     -    public education and involvement
     -    operations and maintenance procedures
     -    industrial and commercial controls
     -    illicit discharge controls
     -    new development standards
     -    structural controls
     -    planning/system preservation and development

Nonpoint Source Program Activities - Some projects

1.   Used Oil Recycling Program

The City has a comprehensive solid waste and recycling program,
which includes used oil curbside pickup that properly recycles used
oil.  Although many jurisdictions maintain used oil recycling
programs, few offer pickup of used motor oil as in Portland. (The
City also provides yard debris, cardboard, paper, newspaper, and
metals residential curbside pickup.)

2.   "Skinny Streets" Program

The City Office of Transportation has implemented new design
standards for certain street categories in an attempt to reduce
environmental impacts, such as minimizing the impervious area of
new streets and preserving existing vegetation.


3.   Snow and Ice Control

Sand and gravel materials are used at varying levels and picked up
as soon as possible after a storm has passed, which may take a few
days or several weeks.  By comparison, many jurisdictions remove
these materials only after the winter has passed, if they collect
them at all.

4.   Pesticide/Herbicide Application

All applicators participate in an Integrated Pest Management (IPM)
training program.  In addition, the City Planning Bureau has
landscape requirements which reduce the need for pesticides,
herbicides, and fertilizer through the use of native plantings. 
They are also developing an environmental seed mix.

Approach to Institutional Issues

The process by which the Portland NPDES permit co-applicants put
together their storm water permit application reveals some of the
institutional issues which impact upon the ability of a
jurisdiction to carry out effective storm water management.  The
seven jurisdictions have different institutional motivations and
agendas and degrees or political accountability and these factors
affect how they approach and deal with the problem of urban runoff
management and control.

For example, the Oregon Department of Transportation (ODOT), one of
the seven co-applicants in the permit process, has as its mission
the building of roads, not managing storm water.  Nevertheless, the
ODOT maintains hundreds of miles of storm sewer pipes that collect
and transport storm water surface runoff, in addition to open
ditches and dry wells.  It also has responsibility for 14 major
storm sewer outfalls in Portland.

The ODOT, however, is not subject to the same direct political
pressures to pursue its storm water management goals as, for
instance, the City of Portland.  The same holds for the special
drainage districts, the Port of Portland and other co-applicants. 
This presents the potential for different outcomes.  Such a
divergence of institutional interests and objectives could
potentially limit the effectiveness of the storm water management

However, the Portland experience illustrates how potentially
problematic institutional issues can be dealt with early in the
program planning process and the result is likely to be a more
effective urban runoff control program.  In the process of
developing the storm water management plan, the City's consultants
worked with all the co-applicants to define and clarify issues
related to their proposed BMPs.  As part of this process they


     -    the department or division within the agency which would
          be affected by or involved with the implementation of the

     -    the agency's existing conditions related to the BMP, and
          the tasks necessary to implement it;

     -    the degree to which the implementation of the BMP is
          likely to affect existing staff and/or resources

The fact that the process used in Portland considers these
sometimes subtle but important institutional concerns increases the
probability of a successful outcome. it also points up the
importance of "issue scoping" and framework development to ensure
program effectiveness.

Program Funding

The City finances its storm water management activities through the
levy of a drainage fee which is based on the amount of runoff
allowed to flow into the storm sewer system.  In 1992, the City
initiated a storm water drainage discount program.  Discounts in
the drainage fee are given to property owners who limit the
quantity of storm water discharged from their property.  The
discount may be as high as one hundred percent.

Discounts for water quality are not currently included in this
program, but the City code permits the imposition of such a fee and
discount program in the future.  The existing discount program is
directed at sites with on-site disposal systems.


BMP Selection and Screening Factors used in Portland's Planning

     -    Life Cycle Costs - The approximate cost of initial
          implementation and future operation.

     -    Regulatory Requirements - Does it meet existing and
          anticipated Federal, state and local regulations?

     -    Pollutants Does it offer reasonable control of the target

     -    Implementability - Is it likely to be accepted and funded
          by the various public agencies, city departments, and the
          general public?

     -    Reliability - Does the BMP function predictably and is it
          effective over time?

     -    Environmental Impact - Consider the environmental impacts
          and benefits of the BMP.

     -    Equitability - How are the costs and benefits of the BMP


Portland's proposed NPDES stormwater management plan is innovative
and has the following components:

     -    It emphasizes non-structural source controls including
          education and maintenance programs.

     -    It builds upon existing programs such as curbside
          recycling, household hazardous waste collection, etc.

     -    It encourages regional efforts and programs.

     -    It emphasizes. cooperation among its NPDES co-applicants
          to Improve water quality.

     -    It phases in management plans to allow for budgetary and
          resource constraints.

Portland's NPDES program highlights


                 Portland's Compliance Strategies

     -    Consider urban runoff issues as permanent issues which
          require a long-term planning approach.

     -    Share information and ideas and look for opportunities to
          cooperate on projects, or share costs with other
          jurisdictions, etc.

     -    Work closely with regulatory personnel throughout permit
          period to discern their objectives, priorities and

     -    Be creative and proactive in complying with permit and
          regulatory requirements.

For more information...

For more information about Portland's urban runoff management
program, please call the Bureau of Environmental Services at (503)


Click HERE for graphic.


Best Management Practice (BMP): A practice or combination of
practices that are determined to be the most effective and
practical (including technological, economic, and institutional
considerations) means of controlling point and nonpoint pollutant
levels compatible with environmental quality goals.

Constructed urban runoff wetlands:  Those wetlands that are
intentionally created on sites that are not wetlands for the
primary purpose of wastewater or urban runoff treatment and are
managed as such.  Constructed wetlands are normally considered as
part of the urban runoff collection and treatment system.

Drainage Basin: A geographic and hydrologic sub-unit of a

End of Pipe Control: Water quality control technologies suited for
the control of existing, urban storm water at the point of storm
sewer discharge to a stream Due to typical space constraints, these
technologies are usually designed to provide water quality control
rather than quantity control.

First Flush: The delivery of a disproportionately large load of
pollutants during the early part of storms due to rapid runoff of
accumulated pollutants.  The first flush of runoff has been defined
several ways (e.g., one-half inch per impervious acre).

Impervious cover cap: A mechanism which establishes a Maximum
Sustainable Removal Rate for storm water control measures at 90%. 
The City of Austin, Texas has incorporated this concept into its
Land Development Code.  It is designed to avoid over-reliance on
storm water control measures and recognizes their inherent
limitations and risk of failure due to lack of maintenance.

Impervious surface: A hard surface area that either prevents or
retards the entry of water into the soil mantle as under natural
conditions prior to development and/or a hard surface area that
causes water to run off the surface in greater quantities or at an
increased rate of flow from the flow present under natural
conditions prior to development.  Common impervious surfaces
include walkways, driveways, parking lots, concrete or asphalt
paving, etc.


Municipal separate storm sewer systems: Any conveyance or system of
conveyances (including roads with drainage systems, municipal
streets, catch basins, curbs, gutters, ditches, manmade channels,
or storm drains) that is owned or operated by the State or local
government entity, is used for collecting or conveying storm water,
and is not, part of a publicly-owned treatment works (POTW).

NPDES:  National Pollutant Discharge Elimination System, created by
Section 402 of the Clean Water Act.

Post-development peak runoff: Maximum instantaneous rate of flow
during a storm, after development is complete.

Retrofit: The creation or modification of an urban runoff
management system in a previously developed area.  This may include
wet ponds, infiltration systems, wetland plantings and other BMP
techniques for improving water quality.  A retrofit can consist of
the construction of a new BMP in a developed area, the enhancement
of an older urban runoff management structure, or a combination of
improvement and new construction.

Ultra-urban:   Non-conventional BMFs that are particularly suited
for use in highly urbanized areas; Uaseu on sanU HIMT It:LIUIUIV6Y

Urban runoff: That portion of precipitation that does not naturally
percolate into the ground or evaporate, but flows via overland

Watershed:  A drainage area or basin in which all land and water
areas drain or flow toward a central collector such as a stream,
river, or lake at a lower elevation.  The land area that drains
into a receiving waterbody.



Anacostia Watershed Restoration Committee, The State of the
Anacostia - 1989 Status Report.  Metropolitan Washington Council of
Governments, 1989.

City of Alexandria, VA.  Alexandria Supplement to the Northern
Virginia BMP Handbook, Prepared by the Department of Transportation
and Environmental Services.  Adopted February, 1992.

City of Austin, TX.  "The First Flush of Runoff and Its Effects on
Control Structure Design." Environmental Resource Management
Division, June 1990.

City of Austin, TX.  "Storm Water Pollutant Loading Characteristics
for Various Land Uses in the Austin Area." Environmental Resource
Management Division, March 1990.

City of Austin, TX.  "Removal Efficiencies of Storm Water Control
Structures.  Final Report." Environmental Resource Management
Division, May 1990.

City of Eugene, OR.  Conceptual Engineering Design for Water
Quality Workshop. Final Report. (Undated)

Dav, Gary E., and C. Scott Crafton, Site and Community Design
Guidelines for Storm Water Treatment.  Virginia Polytechnic
Institute and State University, Blacksburg, VA, 1978.

Bell, Warren, "A Catalog of Storm Water Quality Best Management
Practices for Ultra-Urban Watersheds." Presented at the National
Conference on Urban Runoff Management in Chicago, IL on April

Buzzards Bay Project, "Bay Watch" (Newsletter), Spring/Summer 1993
Volume 7(5).

Dyer, Riddle, Mills & Precourt, Preliminary Engineering Report:
Packed Bed Filter.  Prepared for the City of Orlando, FL.  April

County of Fairfax, VA.  Draft.  National Pollutant Discharge
Elimination System. Municipal Storm Water Discharge Permit
Application Part 2. November 1992.

County of Fairfax, VA.  Policy Plan: The Countywide Policy Element
of the Comprehensive Plan for Fairfax County, Virginia. 1990
Edition.  Adopted by the Board of Supervisors, August 6, 1990.

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for urban


storm water pollution," in Water Pollution Control Federation
Journal.  Volume 54k7), July 1982.

Livingston, Eric H., "Lessons Learned from a Decade of Storm Water
Treatment in Florida." Bureau of Surface Water Management, Florida
Division of Environmental Regulation, Tallahassee, FL

Lower Colorado River Authority, LCRA Lake Travis Nonpoint Source
Pollution Control Ordinance - Technical Manual, January 1991.

Metcalf & Eddy, "Storm Water Quality Controls in the Merrimack
River Basin." Report submitted to EPA, Region 1, Boston, MA,
September 30, 1992.

Murray, James, "Nonpoint Pollution: First Step in Control," in
Design of Urban Runoff Quality Controls, Roesner et al, eds. 
American Society of Civil Engineers (New York: 1989)

MWCOG, 1992.  Watershed Restoration Source Book.  Metropolitan
Washington Council of Governments, Department of Environmental
Programs, Washington, DC

MWCOG, 1992.  A Current Assessment of Urban Best Management
Practices: Techniques for Reducing Nonpoint Source Pollution in the
Coastal Zone.  Metropolitan Washington Council of Governments,
Washington, DC

NOAA/USEPA, Coastal Nonpoint Pollution Control Program: Program
Development and Approval Guidance.  National Oceanic and
Atmospheric Administration/U.S. Environmental Protection Agency,
January 1993.

Novotny, Vladimir, and Gordon Chesters, Handbook of Nonpoint
Pollution: Sources and Management. (New York: Van Nostrand Reinhold
Company, 1981)

Parrish, John H. and Stephen Stecher, "Nonpoint Source Pollution
Control in the City of Austin." City of Austin, TX, Environmental
and Conservation Services Department, March 1991.

Schueler, Thomas R., Controlling Urban Runoff: A Practical Manual
for Planning and Designing Urban BMPs.  Metropolitan Washington
Council of Governments, 1987.

Schueler, Thomas R., et al, "Developing Effective BMP Systems for
Urban Watersheds," in Watershed Restoration Source Book. 
Metropolitan Washington Council of Governments, 1992.

Schueler, Thomas R., "Hydrocarbon Hotspots in the Urban Landscape:
Can They Be Controlled?" in Watershed Protection Techniques. 
Volume I(1), February 1994.


Shaver, Earl, "Sand Filter Design for Water Quality Treatment."
Delaware Department of Natural Resources, Dover, DE. (Undated)

Shaver, Earl and Frank Piorko, "The Role of Education and Training
in the Development of Delaware's Sediment and Storm Water
Management Program." Delaware Department of Natural Resources,
Dover, DE. 1991.

Thompson, S.A., "Reduction of Urban Runoff through Economic
Incentives: Boulder, CO," in Water Resources Bulletin, Volume
18(l), February 1982

USEPA, Handbook: Urban Runoff Pollution Prevention and Control
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Permit Application for Discharges from Municipal Separate Storm
Sewer Systems. 1992. (EPA Document No. 833-B-92-002)

USEPA, Urban Targeting and BMP Selection: An Information and
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