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The greater Toronto area,
North Americas fourth largest city, has almost 2.2 million
cars and other vehicles. Winter temperatures hover around -5 to
-10° C (14° to 23° F), the range at which road-salt
use is most common. From the first snow in early December, cars
wear a distinctive dull brownish-white coating that salt imparts.
Toronto drivers regularly frequent their local car washes to clean
off the salt and grime; in winter, half of all car washes in southern
Ontario take place at commercial establishments.
Come springtime, the
ritual sponge, bucket, and hose return, and people wash their cars
in driveways everywhere. After lawn watering, summer car washing
produces the second largest demand for peak summer water use. The
City of Toronto developed the Peak Pail program in 1997 to encourage
water conservation while washing the car. For $15, residents get
a bucket, a sponge, a trigger nozzle, and other conservation devices.
Unfortunately, the program failed to recognize that domestic lotlevel
car washing produces unregulated discharges of nonylphenol ethoxylate
(NPE)based detergents, greases and oils, heavy metals, and
salts, most of which flow to storm sewers that discharge to local
rivers and lakes.
In July 2000, after two
years of legal drafting and public consultation, Toronto became
the first North American city to regulate discharges to its sewers
of federally regulated Tier 1 and 2 chemicals, including NPE. Sewer
Use Bylaw 2000-457 is primarily aimed at eliminating persistent
bioaccumulative substances from Torontos sewage sludge or
biosolids to ensure that they meet land application-use standards.
It would also facilitate closure of the Ashbridges Bay sewage incinerator,
the largest in the Great Lakes basin. The bylaw also targets storm-sewer
discharges, making them meet similarly strict discharge limits and
requiring industries violating the bylaw to prepare pollution prevention
plans. The bylaw, however, exempts residential discharges.
Of course the bylaw was
hotly contested, with the coatings industry, specialty chemical
makers, dentists (large generators of mercury), and industry associations
on one side and the World Wildlife Fund, watershed protection groups
including RiverSides, anti-incineration advocates, and land-use
advocates on the other.
As the debate over NPE
limits continued, an unusual partnership began. Deputing in favor
of NPE limits was the Canadian Carwash Association (CCA), which
had already decided to phase out its use of NPE and similar surfactants.
At city hall, the CCA argued that if commercial property runoff
to storm sewers had to comply with the bylaw, then unregulated discharges
of NPE-laden detergents should comply too. The source it had in
mind was domestic car washing in driveways.
Monitoring programs across
North America have identified domestic car-washing discharges as
significant detriments to dry-weather surface-water quality. Fort
Worth, TX; King County and Bellevue, WA; and Calgary, AB, are among
the cities that have identified residential car washing as having
a deleterious impact on local water quality. Calgary has implemented
Sewer Service Bylaw 24M96, which prohibits unregulated discharges
from residential properties. Fort Worth requires mobile spray-wash
businesses to have a discharge permit. Many cities are implementing
runoff impact education programs, the most comprehensive of which
is the City of Ottawas WaterLinks/CommunEAUté program.
(Our vote for best program bus-shelter poster is Bellevues
picture of a guy in wicked shorts washing his car on Puget Sound.)
Despite mounting evidence
of its negative environmental impacts, domestic car washing remains
exempt from the NPDES General Permit for Discharges from Small Municipal
Separate Storm Sewer Systems. In Canada there is no acknowledgement
of the impact of nonpoint-source NPE-laden discharges under the
federal Fisheries Act or CEPA99. RiverSides has recommended that
EPA rescind the car-wash discharge exemption, so far to no avail.
Since August 2000, RiverSides
has been negotiating a partnership with the CCA to establish a program
for CCA member businesses that highlights how communities can meet
surface-water quality and water conservation objectives by encouraging
the use of commercial car washes. RiverSides and its partner, Environmental
Economics International, are preparing a Green Clean Strategy for
the CCA, establishing an industry stewardship commitment to best
management practices and focusing on building business/community
partnerships to support community-based clean-water activities.
To combat unregulated
lot level discharges, watershed protection groups and municipal
decision-makers should view commercial car washes as community partners
that can assist spreading the clean-water message to residents and
community leaders. We strongly encourage clean-water advocates and
municipal decision-makers to recognize the potential benefits of
a partnership with local car-wash businesses and to include them
in clean-water consultations and community initiatives.
Kevin Mercer is executive
director of RiverSides Stewardship Alliance in Toronto, ON. Don
Huff is a partner at Environmental Economics International.
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