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Stormwater managers share how they cope with the tremendous amount of data a stormwater program generates. By Carol Brzozowski
When the National Pollutant Discharge Elimination System (NPDES) Phase II rule went into effect, people like David Ladd, the stormwater Phase II coordinator for the State of Maine’s Department of Environmental Protection, discovered that many entities were caught off guard. “Implementation has been especially challenging,” Ladd writes in his reflections on being a permitting authority. He says many municipalities criticized the rule as being an unfunded program. But Ladd had a job to do and he had to find the most efficient and cost-effective way of doing it. He knew that one of the challenges was going to be annual reporting and evaluation. He acknowledges that reporting is the mechanism municipalities use to demonstrate plan implementation, and as a permitting authority, it helps him identify entities needing assistance. Ladd negotiated with DBSP, makers of the Advanced Stormwater Information SysTems (ASIST) software, to put together a software package that would accommodate the state’s five-year stormwater management program. He credits the NPDES software product with helping manage every aspect of a Phase II program. “It even comes with a template stormwater management plan that can be used by municipalities to jump-start their programs,” he says, adding that it also helps entities create annual reports to be submitted electronically. “I have heard some of the NPDES horror stories of how municipalities have spent hundreds of thousands of dollars trying to build database and GIS systems to manage their stormwater programs, and I did not want to see that happening to my municipalities in Maine. The less they spend on management, the more money they will have for addressing some of the real problems that can improve water quality.” It made sense to Ladd that every municipality use the same tool with a standardized program. After ironing out the details, the program was deployed to all 28 regulated small municipal separate storm sewer system (MS4) communities in Maine. Training was provided and a secure Web site was set up for Ladd to distribute information to the municipalities. “This was a win-win solution for my regulated small MS4s and is a good example of how a permitting authority can do more than just regulate,” Ladd says. “Partnering with your municipalities makes your job a lot easier. “The way regulated entities use the software is different from the way I use the software. They generate reports and new data input, and I’m on the receiving end. I’ve got a different way of looking at it, so I don’t know all the ins and outs of what they can do, but seeing all of the different ways they can show their data, it’s pretty good.” Ladd says another challenge for many states is managing volumes of annual reports. “In Maine, I only have 28 Phase II municipalities; some states have hundreds,” he notes. “But I am still a department of one and I need tools that will help me do my job, which is to review all of these reports and make decisions about the quality and effectiveness of each municipal program. When you look at some bigger states that have several hundred, that can really be good paper reduction nationwide.” Saving time is a factor, too. Ladd says with the database system all of the municipalities in the state should be able to produce annual reports within a few hours. “If everything is in top-notch order, there are a couple of them who can generate reports in two or three hours, but the folks doing these paper copies and putting everything in a binder are using several different types of databases that aren’t linking and they’re spending days.” Ladd also is pleased the software enables him to assemble all of the reports into a common database. “I am able to quickly analyze data from our program either for individual municipalities or for the entire state collectively,” he says. “I can generate a report showing how many outfalls have been located statewide, how many were inspected, how many had illicit discharges, and all for a specified period of time.” The system also enables him to analyze information at different geographic levels, including the watershed level, “which could play an important role in our TMDL [total maximum daily load] development or future watershed-based NPDES permitting initiatives.” For the time being, the program is at the level of management before taking it to the next step of sharing among regulated entities. “There have been plans that have been shared, but databases and reports haven’t been shared,” Ladd says. “Once I receive these reports, if any special-interest group or other user group wants to see that information, the Freedom of Information Act allows that.” The regulated entities fall into four distinct clusters, which meet to work on projects together, Ladd says, adding that some projects involve a statewide effort. He meets monthly with representatives from all of the regulated communities. “As far as what is going to be in those reports, neighboring regulated entities are not the least bit surprised,” he says. Building a System
In-House “I did research to check nationwide to see what programs were operating,” he says. “Back then, there weren’t any guidance manuals. I was relieved when the EPA finally put out guidance manuals four years later that we actually did do it right.” In the beginning, the budget was minimal and Shockley was the only one on staff. “It was limited for the first five years,” he says. “But we had our five-year business plan; we knew where we were going and what we needed to do. We finally adopted the drainage utility fee, and once we did that, we were able to implement the program. It was adopted the same year the EPA issued our first stormwater permit.” Now, Oklahoma City submits an annual report of all of its stormwater activities to the Oklahoma Department of Environmental Quality by October 15. The stormwater program has five distinct sections—construction, industrial auditing, environmental, hazardous materials, and pollution investigation—and reports are generated from those sectors on a daily basis and kept for at least three years, Shockley says. Originally, Oklahoma City used ASIST as a fundamental database, but the city is expanding by using a GIS to map its watersheds. “There are an infinite number of details, and that’s why we went to GIS,” he says. “We are actually in the process of a full watershed characterization study for the entire city. We are 621 square miles with 203 creeks, four major watersheds, two rivers, and two major watersheds that drain to two other rivers.” When Columbus, OH, set up its program, consultants suggested using GIS to keep track of impervious areas, says Dirk Brown, the city’s stormwater utility manager. Brown says the city put together its own system based on several available databases. “For instance, [the way we handle] complaint processing, flooding complaints, and periodic concerns about water quality that have evolved over time wasn’t something modeled after someone else’s program—it was done in-house,” Brown says. “Some of the information in the database is mirrored from other data structures. When you go to that level of detail, nobody is trying to reinvent the wheel, and if there are other agencies keeping track of certain kinds of data and they do it in a certain format and structure; it’s been copied in some sense.” The city has nine reporting requirements, which are summarized in an annual report to Ohio’s Environmental Protection Agency. The report summarizes what the stormwater management program has accomplished, what areas need improvement, and major findings related to the program for the reporting year. Reports include such information as
Brown believes one of the biggest concerns with regard to NPDES reporting requirements is centralization of data. “Although we have different databases for different things, they are not necessarily accessible to everybody, such as sampling data. Obviously, a fiscal person will not necessarily want to have any access to what is happening with the nitrogen, so they don’t have access to that data,” he explains. “It goes to other agencies within the city, such as the attorney’s office, but the data isn’t necessarily reported and assimilated to everybody unless they ask for it.” As with Columbus, Anne Arundel County in Maryland took GIS and available databases to create a program that met its needs. Mary Searing, watershed management manager for the county’s Office of Environmental and Cultural Resources, says the county developed a watershed management tool to track incoming data, specifically all of the GIS layers that pertain to the environment and the databases associated with those layers. The county has used ESRI GIS and mapping software in its tool. One of the tool’s functions is to store and standardize all data so they are available to all county staff. “There were problems in the past where we were using hard-copy maps and different staff were using different versions of the maps to get the data because there were no standards,” Searing says. “People kept their own maps and they didn’t throw those out, and if there were new ones, they weren’t necessarily always used.” The tool is also an effort to communicate across disciplines so that Searing’s office would be aware of what projects were going on relating to land and environment. “There might be staff from the Department of Public Works who would have capital improvement projects they were working on up against a particular stream and a subdivision coming in for development in that same area. The Office of Planning and Zoning might not even know that there were ongoing projects in the same location.” A third advantage is the ability to access data more readily. Searing’s office has completed many watershed studies in the past, and the data are stored in volumes of binders and used only by particular staff members in the environmental office. “With the development of this tool, we can keep this system live and put the data up for everybody to share,” Searing says, adding that changes to the landscape can be added as they occur. “The plan is to always have the most recent data out there about the watershed.” Based on existing land use, Searing’s office can see particular nutrient loads, the total nitrogen and total phosphorous, nitrates, or metals coming off of the landscape under current conditions. Based on full build-out by the zoning department, she can see what the landscape values or loads would be in the future given current stormwater management, zoning and subdivision regulations, and laws. “We can look at some in-between scenarios and say, ‘What if we took this particular piece of land and, instead of developing it the standard way, maybe do some cluster development on it, do some increased buffers, or try to use a different best management practice that might be more effective and have greater efficiency than other traditional types of stormwater management practices?’” Searing says. The county has been developing the watershed tool for more than three years. It has been applied to one of the county’s 12 watersheds; the aim is for it to be applied to all. Currently, the information goes to the Maryland Department of the Environment yearly. “We are trying to be proactive in meeting some of the future TMDL or NPDES permitting requirements, working with state agencies to show them what we think this system will do for us and accepting suggestions they might have,” Searing says. “We’ve had them onboard throughout the development to provide input to us to make sure that it fulfilled their requirements.” The tool also is a model for other jurisdictions to develop a similar application, she adds. Help From Outside
Mike Madigan is a GIS project coordinator for England, Thims & Miller in Jacksonville, the company that helps handle the city’s NPDES requirements. Those reporting requirements are vast, Madigan notes, with the state’s Department of Environmental Protection interested in a number of factors. The first is illicit discharge reporting. Inspectors walk through ditches looking for telltale signs, such as pipes running from backyards. The inspectors obtain an address either in the field or by GIS or GPS, and a letter is sent to the property owner indicating that activity isn’t allowed under the NPDES permit. On the report Madigan’s firm sends to the city’s NPDES coordinator, a photo accompanies information about the illicit activity and a small map shows the parcel with the illicit discharge highlighted. The NPDES coordinator takes it from there. “Sometimes it’s just a matter of a letter sent to the homeowner, and sometimes it calls for them to go out to the person’s home to see exactly what it is,” Madigan says. “Then action is taken, whether it is removed or they are allowed to have it. It is added to the database so there is a list of all of the ones that have been removed.” Reporting has changed hands over time in Jacksonville, Madigan notes. “When we first got started with NPDES in 1991, England, Thims & Miller was hired to put together the application for the city,” he says. “We developed the whole phase for the illicit reporting. We performed field screening on major outfalls looking for the illicits and also determined drainage areas. We compiled data of priority industries and got that permit going. We got the permit from the EPA and then we helped the city with it.” The firm handled all of the annual reports, giving the EPA, and eventually the state’s Department of Environmental Protection, what was required. In addition, the firm put together a monitoring program and compiled the data, hiring all of the people needed for water-quality testing. “Permits run five years, so every five years we get new permits and file that data at the end of the five years. Then we have that data to build trend analyses if required, and also to assist in TMDLs,” Madigan says. Although Madigan’s firm, experienced in matters relating to NPDES, did the majority of the work in the beginning, the city began to take on more responsibility, he notes. Now, the city’s NPDES coordinator puts together the report and Madigan’s company helps supply the information. “The city has found they are now taking control of the monitoring because they can use their environmental regulatory group,” says Madigan. “Because NPDES can touch on so many different programs, they are incorporating it and working more with other groups in the city, which among cities is rare. They are trying to incorporate it so different funding can go toward meeting all the needs required for NPDES and the other programs that might be related to it.” Jacksonville uses a Microsoft Access database to maintain the data, Madigan says. Since 1996, his company has done an inventory of all of the county’s stormwater systems using field crews and GPS and has collected information on more than 150,000 structures. The information is stored in a GIS. The company uses ESRI products. “The technology continues to change,” Madigan says. “At first, we used an Access database and through SQL [structured query language], we would relate it to our GIS through a unique ID. Now GIS has come to a point where there are geodatabases. They are pretty much like a giant Access database, but you can put multiple tables and different data sets into them.” Madigan’s company is doing that with all of the structures and illicit discharges and their attributes. The company is determining pollutant loadings from all of the major outfalls and storing that information in a geodatabase as well. The city also adds its information. Throughout the year, Madigan’s company sends spreadsheets and databases with information to the city’s NPDES coordinator, whose main focus is environmental issues such as illicit connections and priority industries. The information helps in decisions regarding street maintenance and flooding areas. “The city is working on a more proactive maintenance management system, and the data we have would go to that as well,” Madigan says. Information the company gathers goes to the city and in an annual report to the state’s Department of Environmental Protection, as well as to other entities such as the state’s Department of Transportation. “Everything has changed over time,” Madigan says of the information-gathering process. “We used to develop three or four large binders of information that would be printed out and sent to the DEP, and now the DEP has worked it out so that it’s a matter of several pages of information that is just basically written down or checked off—questions to the NPDES coordinator about what’s been done—and that’s compiled at their end.” Based on the answers, the Department of Environmental Protection can choose to do more investigations in the region. A check-and-balance system is also in place, allowing the state to look at the data and make suggestions for improvement. If the data are found to be satisfactory, the process serves as a double-check after the annual report, Madigan says. Like other cities, Jacksonville is beginning to house all of its NPDES information on the Internet for all interested parties to view. “We’ve been working so that anybody can log in and view the information, which currently shows the drainage basin within the county, all the structures we’ve collected, and all of their attributes,” Madigan says. Photos that are taken of the illicit discharge sites are posted on a Web site. Efforts are underway to include more water-quality information, such as TMDL sites. “When we do the pollutant loading, those drainage areas will be in there and you can get all of that information with the click of the button,” he says. The goal, says Madigan, is to manage all of the information without redundant efforts. “Some of the enormous requirements NPDES has are overwhelming. So we as a GIS group are trying to develop a database model that encompasses everything into one data set. It’s shared and housed in one place so anybody can access it when they need it.” Managing for the Military CBI Systems assisted Earth Tech in developing the software, which Earth Tech installed at each Air Force base on the mainframe computer systems. Earth Tech trained personnel how to use the software. “They basically took a paper plan or no plan at all and with our help developed a computerized document in software,” says Collen Brownlow, an Earth Tech engineer. He adds that the computer software generates the annual report, based on data input. “We assist the base with visually monitoring the stormwater,” Brownlow says. “There also is an annual sampling; stormwater has to be sampled from outfalls and analyzed for such factors as heavy metals.” The reports are submitted by the bases to state regulatory agencies. Brownlow explains that the software is built into a Microsoft Access database, which provides a prompt for input for goals and measures. It also provides reminders of meetings. It helps keep track of such factors as inspection records for permitted construction activities. Permit Options in
Michigan The department does annual reporting for its five-year permit. In setting up Wayne County’s initial recordkeeping for NPDES, Kelly Cave, director of the Watershed Management Division for the county’s environmental department, says her county, which is the eighth largest in the country, inventoried what records each department had. “We have a variety of different departments in the county that do things that impact our stormwater permitting requirements, so we looked at what databases different people had already for tracking things and tried to get a system where they could submit a written report to me to compile for the county’s overall report,” she explains. She says Wayne County hasn’t quite arrived at the point where there is a comprehensive countywide system for tracking information but that the systems that are in place were developed either in-house or by a consultant. Cave interacts with other county agencies, such as those that do permitting, in an effort to pull together the data needed for the NPDES report. “We work with them on information gathering, letting them know what the policies are and the kind of things they need to do so that when it is time for us to put together our report, we can do that,” Powell says. “They are responsible for capturing the necessary information and having it available to us so we can actually do the reports.” That information may include incident reports about illegal dumping into water bodies as well as details of projects, storm bank restoration efforts, and public education. Each watershed-based stormwater permit has a list of activities taken from watershed plans that are embodied in a document called the Stormwater Pollution Prevention Initiative, and that becomes the permit’s permanent requirement, Cave says. Most of those requirements involve numbers: “If you said you were going to distribute brochures, how many did you distribute during a year and to whom? How many miles of streets did you sweep? How many projects did you review for compliance with your stormwater ordinance?” The county’s annual report is substantial and is divided into four sections. One involves illicit discharge and elimination efforts, such as an inventory of outfalls. Sewage disposal systems must also be addressed, so information is needed on how many permits were issued for new systems, how many inspections were performed on existing systems, and how many are failing. Another section deals with public education and involvement efforts. “The other two parts of the report are general pollution preventions. That’s where things like reviewing for compliance with stormwater ordinances are counted,” Cave notes. Once gathered, data are sent to the state, which acts as the delegated NPDES authority. “One of the complications of reporting is that you have overlapping jurisdictions in a given area for stormwater management,” Cave says. “We’re a county, but all of the communities in our county also have permits, so some of the things we do are logged in as a government count—they don’t need to do it again.” For example, Wayne County has a countywide onsite sewer disposal ordinance requiring periodic inspection, so the municipalities within the county can count it on their permits. “With the overlapping of jurisdictions, one of the challenges is the sharing of information so that the dollars are spent most effectively and people aren’t reinventing the wheel,” Cave says. To avoid this problem, the report is posted on the county’s Web site and distributed via e-mail to all of its communities’ stormwater managers. TMDLs, Construction
Permits, and Other Specialized Reporting Requirements In southeast Michigan, Wayne County also has TMDLs in its jurisdiction. “In Michigan, they are letting us do the reporting on our permit compliance; because it is a watershed-based permit, we can submit the one report,” Cave says. The Maine stormwater community is dealing with TMDLs as well. “Roughly half of our known non-attainment streams in Maine fall within these urbanized areas,” Ladd says. “We are trying to pay special attention to these types of regulated resources and are working with the state’s TMDL coordinator to come up with plans so we can add a suite of BMPs to try to get those loads down to an acceptable level.” Many entities are performing an inventory of stormwater structures as part of their NPDES permit, such as Anne Arundel County’s Department of Public Works. Maine’s municipalities have mapped their infrastructures, including catch basins and pipes. “I’m going out there and spot checking these structures, but I haven’t checked out all of these other BMP types of stormwater treatments in the communities,” Ladd says. Inspection records for permitting construction activities is another reporting requirement. In Oklahoma City, four full-time erosion control construction inspectors with a supervisor oversee construction projects. Shockley’s office has been incorporated into the permitting system and reviews plans to ensure there are appropriate completion prevention measures. A plan sheet is required, detailing where prevention measures will be located on the project and any other details. “With that in mind, we can no longer have a contractor say, ‘I don’t know anything about it,’ because it is in all the blueprints,” Shockley notes. There are usually 800 to 1,200 active programs or construction projects underway year-round, and the erosion control inspectors check them every two weeks to ensure compliance. “They did more than 8,000 inspections last year. They have to fill out an inspection form in detail—it’s a checklist of things that are required. If there is any deficiency it’s noted,” Shockley says, adding that the permittee has to sign off on every inspection sheet. “Frequently there would be a project or someone just grading a lot and you could have a lot of damage just over a small area,” Shockley says. “We don’t have a lower limit—we’ve never had the 5-acre or 1-acre limit. If you are disturbing soil in Oklahoma City, you have to have a permit.” The only exemptions, he notes, are minor activities such as gardening and repairing service lines to homes. Maine has a general construction permit and has its own regulations in addition to federal regulations. “We look at large projects for stormwater quality and quantity, and we look at smaller projects,” says Ladd—including those with as little as 20,000 feet of impervious area depending where it is in the watershed. “We also look at anything that disturbs less than an acre.” Ladd has instructed the municipalities that they can develop, implement, and enforce through ordinance or other regulatory mechanisms or rely on Maine’s construction general permit. Those who choose the latter have forms to use that ask if an area greater than an acre is going to be disturbed. If the answer is in the affirmative, then the municipality grants a Maine construction general permit. When a routine inspection is conducted, the site plan and the effectiveness of the BMPs are reviewed. If the BMPs are not effective, changes are suggested. If the problems are not fixed, Ladd’s department is called in to ensure compliance. The inspection records are entered into the ASIST database. Tracking Data for
Stormwater Utilities In an article Brown wrote for Stormwater’s September/October 2003 issue (“Developing a Database to Support a Stormwater Utility,” ), he points out that keeping track of various data elements of a stormwater utility is essential to ensure efficient and cost-effective deployment of resources. The legitimacy of a utility ultimately depends on reminding the community that the method of revenue collection is fair and equitable. “The best way to demonstrate that is to have an open and accessible database that affords transparency and public accountability,” Brown writes. For the Columbus stormwater utility, the fee is included as a line item on the sanitary sewer and water bills to minimize costs of setting up a separate billing system. The stormwater utility uses a GIS to track building improvements, developments, and demolition and maintains that information in a separate database. In Michigan, the issue of stormwater utilities became a legal one. Powell describes a legal challenge contending stormwater utilities essentially are taxes and all taxes have to be approved by the voters. Some communities, such as Ann Arbor, have characterized their stormwater utilities in a different fashion, she adds. “But there’s a lot of new examination of the issue, because people recognize we’ve got to come up with some funding structures to pay for the work that needs to be done in order for us to actually address these issues,” Powell says. “It becomes very problematic in this state about what kinds of actual entities we are going to be able to put together to pay for the work that has to be done, because we have to treat stormwater now and very few people actually have any in-place mechanism to do that without any funding.” Ann Arbor has a stormwater utility, with the rate structure based on land use. For commercial property, for example, city engineers calculate the fee based on the amount of a property’s impervious area. Onsite detention also affects the rate; Hancock points out that any construction that took place within the last 20 years will probably have some form of onsite detention. For single-family units, the stormwater utility charges a flat rate, but the city is presently studying a multilayer charge based on lot size. Credits will be given for rain gardens and other BMPs individual property owners choose to implement on their own. Hancock notes some have installed rain gardens and native landscaping, such as prairies, and they burn them on an annual basis. “We want to provide some incentive for that. The only problem is our stormwater utility, compared to the other taxes, is a fairly small amount, maybe $10 a quarter. To give somebody a percentage break on that isn’t going to amount to a large monetary incentive, but we still want to do it regardless.” The utility fee appears as a line item on the water and sewer bill. Ladd describes a pilot project in southern Maine in which 15 regulated entities have combined efforts to develop a model stormwater utility based on a given residential unit and impervious areas. One of the municipalities had been working on a photo project that looks at the relationship of lot size, structure, driveways, and impervious surfaces to come up with what that unit will be. A report was scheduled to be issued to city managers to ascertain how they like the plan. Maine needs revenue to deal with stormwater issues, Ladd points out. He’s been looking at utilities around the country for ideas. Shockley notes that anyone forming a stormwater department or building up an existing one should make mapping out the system the first priority. “Be aware of inventory and know what you’ve got,” he says. “Most of our decisions after that were based on that. In our original program, we were targeting to try to go to a Web-based program we could share with the citizens if they wanted to find out what was going on in their part of town.” Oklahoma City is now converting its information to a Web site, expected to soon be up and running. Cave agrees. “You need to think about it really early and get things in place to help you put the report together at the end of the year,” she says. “If you have a large organization like a county or a big city, you have a lot of different departments that do things and it’s hard to get that all coordinated. A lot of times, they track for their purposes differently than you would track for the permits, and just getting them to tweak their own system a little bit really helps you out.” “The city has really been in favor of our water program,” Shockley says. “I know at the onset, it was one of those federally mandated things, but we’ve really benefited. Our city is cleaner now than it has ever been. We’ve just recently put three dams on our river downtown, so we can no longer walk across our rivers or mow them. “We have three urban lakes on the river and have jogging trails and a whole new development area. The Army Corps of Engineers wouldn’t let the city dam them in the past because of the concern over recreational waters being polluted in the downtown area.” But the city’s water program has been progressive and has conducted more than 1,800 investigations and cleaned up many of the problems the city started out with in the early 1990s. “There are no heavy metals and our oil sheens are a minimum,” Shockley says, adding the department assigns interns in the summer with field sampling kits. Some 545 spots are monitored each summer. “With our stormwater program, the corps finally agreed to let us dam the rivers. Now it’s a real plus for our community,” Shockley says. “A lot of good things have come out of this program. In the beginning, everybody was complaining, but actually our city is cleaner, healthier, and our streams are much better. Part of our program is to do outreach and education. We did 36 events last year with 48,000 contacts, so we are very proactive and positive in our program.” Like others, Ladd affirms that databases are only as good as the information that is entered into them. He tells municipalities to enter in every bit of information, such as public education efforts. “It never happened unless it gets entered into the ASIST database,” he says. “The problem I see with this is that the stormwater coordinator will have lapses of time when they are not using the software as much. If you don’t use it, you are not as familiar with it. It’s like working with GIS or any type of software application—you have to use it in order to be proficient.” Carol Brzozowski is
a journalist in Coral Springs, FL. SW May/June 2005
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