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Watershed AuditsWatershed Audits

How To Save 100 Feet of How To Save 100 Feet of Waterway In An HourWaterway In An Hour

Community & Environmental Defense Services410-654-3021 Help@ceds.org ceds.org/audit

Good afternoon. My name is Richard Klein. For the next 15 minutes I’ll explain how you can bring about some rather dramatic improvements in the quality of your favorite waterway. When done right a Watershed Audit allows both volunteers and professionals to literally save a hundred feet of waterway per hour. At the same time you can greatly expand the number of watershed residents actively supporting restoration. What you’ll see are methods I learned while serving as the director of Maryland Save Our Streams for ten years and from spending the last 24 years helping folks throughout the nation win battles big and small.

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Suburban-Urban Activities

Regulated By Clean Water Laws

Here are the regulated activities routinely included in an suburban-urban Watershed Audit:

construction site erosion and sediment control;

existing stormwater Best Management Practices (BMPs);

compliance with Environmental Site Design (ESD) requirements on proposed development projects;

Forest Conservation compliance;

Illicit and point source discharges; and

sewage collection system releases.

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Equitable Solutions vs. Conventional ApproachEquitable Solutions vs. Conventional Approach

Cooperation First;Cooperation First;

Public Image Second:Public Image Second:•• Ask elected officials to Ask elected officials to

contact responsible party;contact responsible party;•• Then ask other influentials Then ask other influentials

to contact too; to contact too; •• Increasing loss of public Increasing loss of public

image is more threatening image is more threatening and effective than litigation; and effective than litigation;

Smart Legal Strategies as Smart Legal Strategies as Last Resort.Last Resort.

Report to regulatory Report to regulatory agency;agency;

Threaten lawsuit when Threaten lawsuit when agency action inadequate; agency action inadequate;

Generate negative Generate negative publicity; withpublicity; with

Negotiated settlement as Negotiated settlement as best outcome.best outcome.

Equitable Solutions gets Equitable Solutions gets settlement without the settlement without the negatives.negatives.

For many of the pollution sources listed in the previous slide, simply reporting it does little. Instead, we urge clean water advocates to work cooperatively with the responsible party (aka polluter) to solve the problem. Your goal must be an Equitable Solution that fully protects the resource yet allows the party to achieve their goals. If the party refuses to cooperate then we ask elected officials to urge the party to do the right thing. If the partystill fails to act then we rapidly expand the number of influentials who learn of the party’s irresponsible action. This approach gets most problems fixed and builds public support for clean water protection. The conventional approach has a much lower success rate and tends to alienate potential allies.

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Temporary StabilizationTemporary StabilizationStraw Mulch, Seeding & Stone on Roads within 7Straw Mulch, Seeding & Stone on Roads within 7--14 Days14 Days

November 24, 2011

October 16, 2011

In the remainder of this presentation I’ll provide examples of methods to identify excessive pollution releases and win correction via Equitable Solutions. Here we have two photos of a massive construction site with lots of exposed soil. State law requires that all these soils be stabilized (protected) with straw, grass seedings, or a layer of stone in road beds. These erosion control measures must be applied within 7- to 14-days of initial disturbance. Note that though the two photos were taken 39 days apart none of the exposed soil has been treated. A clear violation of the State law.

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Volunteers & Volunteers & Perimeter Perimeter Control vs. Control vs. Temporary Temporary

StabilizationStabilizationConventional Volunteer Approach – Perimeter Control Focus

Two-Hour Training; Trespass; Confrontation; 30% - 50% Effective

Watershed Audit Approach - Temporary Stabilization FocusTraining = 15 Minutes; No Trespass; Cooperation First-Public Image;

90% - 99% Effective

Mulch, Grass or Stone Must Completely Obscure Soil

In the past volunteers focused on perimeter controls, like the silt fence and the trap pictured here. These perimeter controls are much more difficult to assess yet far less effective in protecting water quality. Mulching and seeding are far easier to assess and highly effective. In fact the only way you can protect sensitive waters from construction site mud pollution is by getting all disturbed soil stabilized ASAP. So, whenever you see exposed soil on a construction site you can assume a nearby waterway will be polluted come the next rain.

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Exposed Soil = Exposed Soil = PollutionPollution

Cooperation First/Public Image SecondCooperation First/Public Image Second

• Positive letter to developer;• Letter to Elected Officials asking

them to contact developer (cc developer); then

• Press Event: In one week scouts will spread mulch on the site.

Let’s make exposed construction site soil as socially unacceptable as junk cars on

lawns and littering!

One construction can damage three miles of downstream waters for 10- to 100-years;Each dollar spent keeping mud on the site saves $100 in damages avoided; andEach hour a volunteer spends winning good control through the Audit approach saves 100 feet of waterway.

So how do you get builders to make greater use of mulching and seeding? Well, we believe its possible to create a widespread public perception that Exposed Soil equals Pollution. In other words, when people see exposed soil on a construction site they will react the same as when they see junked cars on lawns or littering. Once ES=P becomes a widely held belief, voluntary compliance with construction site stabilization requirements may become as common as voluntary participation in curbside recyclables collection.

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For Further For Further Detail on Detail on

Exposed Soil Exposed Soil = Pollution = Pollution

visit visit ceds.org/espceds.org/esp

For further detail on exposed soil equals pollution, visit ceds.org/esp.

You can also report exposed construction site soil by clicking the text circled with red on the upper left of our ES=P webpage.

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Stormwater Best Stormwater Best Management Management

Practices (BMPs)Practices (BMPs)Infiltration Basin – No Longer Infiltrating – Now A Cattail Marsh

Infiltration Basin Should Drain Completely in Two Days

Bioretention – Montgomery County Bioretention – Anne Arundel County

Throughout Maryland there are more than 30,000 ponds, filters and other stormwater BMPs. Here you see examples of two of the more effective BMPs: an infiltration basin and bioretention. The basin is supposed to store runoff until it can soak into underlying soils. Between rains the basin floor should be dry. But far too many basins have clogged and turned into wetlands, which trap far fewer pollutants. Bioretention areas have a one-foot surface depression to store runoff until it can infiltrate. Note that you have a foot below the Anne Arundel storm drain inlet opening but not the one in Montgomery County which has filled with sediment.

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Finding Stormwater Finding Stormwater BMPs In Your BMPs In Your

WatershedWatershed

http://www.mde.state.md.us/programs/Water/StormwaterManagementProgram/stormprint/Pages/index.aspx

A preliminary audit of the Severn River watershed indicated that a third to all BMPs had failed. As a result large amounts of pollution are being needlessly discharged into the Severn.

To see if this is true for your watershed then begin by visiting the new MDE Stormprint website. For most areas Stormprint is a highly accurate means of locating existing BMPs. However, its quite inaccurate in at least one county.

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Assessing Stormwater BMPsAssessing Stormwater BMPs

Google: MDE Stormwater Manual ceds.org/audit

So what do you look for when you find a BMP?

Well, for a Preliminary Audit its pretty simple. Are infiltration basins dry between runoff events? Do wet ponds have most of their original capacity or have they filled to the point where they are more wetland than pond? Do bioretention facilities and sand filters still treat an inch of runoff without overflow into a storm drain inlet or other outfall? The CEDS checklist on the right makes assessing BMPs easier. You can download the checklist from our Audit webpage. The Checklist is based on the 2009 Maryland Stormwater Design Manual on the left and is available at MDE’s webpage.

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Rain Gage & Rain Gage & Float MethodFloat Method

1.1. When rain of When rain of inch or more is inch or more is predicted, ppredicted, place lace rain gage next to rain gage next to BMP. BMP.

2.2. Place an object Place an object that floats, like a that floats, like a stick, where stick, where runoff would first runoff would first overflow from overflow from BMP (inlet lip). BMP (inlet lip).

3.3. Tie string to float Tie string to float then to a fixed then to a fixed object so float object so float doesndoesn’’t wash t wash away. away.

4.4. Check float and Check float and gage after storm. gage after storm. If float washed If float washed down inlet with down inlet with less than an inch less than an inch of rain in 24 hrs, of rain in 24 hrs, then BMP needs then BMP needs cleaning.cleaning.

SAND FILTER

Storm Drain Inlet

Float

RainGage

A number of BMPs are designed to treat the first inch of runoff from the buildings, streets, and other impervious surfaces draining to the facility. This first inch is called the Water Quality Volume. Most facilities contain a storm drain inlet, like that pictured here, or some other point where runoff in excess of the first inch can flow from the practice. A common cause of failure is the accumulation of sediments which rob storage capacity. CEDS developed the Rain Gage & Float Method to check for adequate capacity. Its pretty simple as shown by the four steps on the right.

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BMP Neighbors BMP Neighbors –– An An Untapped Constituency?Untapped Constituency?

WELL MAINTAINED BMP:Enhances Property ValueAttractive Green SpaceEnvironmental Benefits

FAILED BMP: Lower Property Value Dead or Weedy Vegetation Unsightly Mosquitoes Odors No Environmental Benefits

Well Maintained Bioretention

Failed Sand Filter

An Audit wouldn’t accomplish much if it only documented failing BMPs. What we really need are new ways of expanding the constituency for BMP maintenance. I believe those who live near existing BMPs are an untapped constituency with tremendous potential. By helping these folks understand the benefits of well-maintained BMPs and how failures may harm them, many neighbors will be motivated to provide active support. By this I mean monitoring BMPs for maintenance needs, performing simple maintenance, and supporting government programs.

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Environmental Site DesignEnvironmental Site DesignAre Proposed Watershed Development Projects Making Full Use of EAre Proposed Watershed Development Projects Making Full Use of ESD?SD?

Will all proposed impervious surfaces drain to one of the 15 ESD practices,

like this bioretention facility?

Are all forest conservation requirements being met onsite?

Are stream-wetland buffers preserved; no waivers?

In 2009, Maryland adopted a new and extremely promising approach to development known as Environmental Site Design. Here you see the three most important elements of ESD. Unlike the past approach, ESD requires site planners to identify all sensitive environmental features first, then design development to protect these features. Forest conservation requirements should be met onsite and stream-wetland buffers protected from disturbance. Proposed buildings, streets and parking areas must drain to soils suited to the 15 ESD practices. These practices are highly-effective in preventing pollution and maintaining groundwater recharge.

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Identifying Proposed Identifying Proposed Development Projects In Development Projects In

Your WatershedYour Watershed

A number of local governments now have online sources such as My

Neighborhood.

So to determine if future development in your watershed will make full use of ESD, you first need to identify projects proposed for your area.

See if your local planning office has an online source like these which show development proposals.

Or drive watershed roads looking for signs, such as that in the upper-right corner, announcing proposed development projects.

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Evaluating A Evaluating A Concept Plan For Concept Plan For ESD ComplianceESD Compliance

ceds.org/esd

Typical ESD Concept Plan

CEDSESD

Checklist If you have difficulty interpreting the plan, mail it to CEDS for a quick, no-cost

assessment: CEDS, 811 Crystal Palace Court, Owings Mills, MD 21117

Make arrangements to review the ESD Concept Plan and Narrative for each project. You’ll find evaluation guidance for both on the CEDS-ESD webpage. There’s also a checklist you can download.

But if you run into difficulty then mail the plan and narrative to us. We’ll be delighted to take a quick, no-cost look at both to see if ESD will be fully utilized to protect your favorite waterway. We can then help you use cooperation first to encourage the applicant to make full use of ESD.

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Forest Conservation EasementsForest Conservation EasementsGoogle: Maryland Plats.Net

Since the early 1990s, most proposed development projects have been required to preserve 15% to 50% of a site as forest. These forest conservation easement areas are depicted on the plat for each project. Most plats can be viewed online via the Maryland Archives Plats.Net website. As part of an Audit you should obtain the plat for any part of your watershed developed since the early 1990s. Compare the easement area on the plat with the forest visible on recent aerial photos. If the entire easement area is not forested then its time for cooperation first.

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Point Source DischargesPoint Source Discharges

http://www.epa-echo.gov/echo/index.html

There are more than 14,000 facilities in Maryland which hold a permit to discharge pollutants via a discrete point. Each permit contains limits on the quantity of pollutants that can be discharged. The limits are set to prevent a violation of water quality criteria. To learn if such a facility is located in your watershed, visit the USEPA ECHO website. ECHO also tells you how frequently each facility has violated pollution limits. A word of caution though, the ECHO data can be quite inaccurate. So cooperation first should begin be verifying that permit limits have in fact been exceeded.

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Illicit DischargesIllicit Discharges

Check storm drains and other pipes in industrial-commercial areas for dry-weather discharges. If a discharge has a strange appearance, odor or it seems unusually hot or cold then it may indicate pollution.

Check storm drain outfalls in commercial-industrial portions of your watershed for dry-weather discharges. Discolored discharges almost always indicate a violation of clean water laws. For clear discharges, hold your hand a few inches away to see if its heated. Dip a leaf in the discharge then carefully sniff for unusual odors. Either heat or odor could indicate pollution. This is one of those situations where you should immediately report suspected pollution to an enforcement agency, such as your local health department or MDE.

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Sewage OverflowsSewage OverflowsMDE Hotline: 1 866 633MDE Hotline: 1 866 633--46864686

http://www.mde.state.md.us/programs/Water/OverFlow/Pages/ReportedSewerOverflow.aspx

From nearby public areas, look for toilet paper or other indicators of recent

overflows. Ask nearby residents about sewage releases.

Sewage Pumping Station

The Maryland Reported Sewer Overflow Database indicates that about 1600 releases occur annually throughout Maryland. Begin this portion of your Audit by checking this database for overflows in your area. Next, look around sewage pumping stations and sewerline manholes for overflow indicators: toilet paper, condoms, tampons, etc. Ask those who live nearby if they recall odors or discharges that might indicate an overflow. Make sure they know whom to call in the event of future overflows, such as the MDE Hotline: 1 866 633-4686.

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Stream IndicatorsStream IndicatorsPoorly Treated Sewage Discharge

Calverton SchoolCedar Bog

Upstream Station

Downstream Station

I suspect most of you are familiar with benthic monitoring. In the 1970s Save Our Streams was the first to train volunteers in these techniques. At that time we favored methods that gave a gross indication of stream health and allowed us to quickly trace problems to a source. Here you see an example. More pollution sensitive benthos are present at the upstream station. In between the two is the discharge from a failing wastewater treatment plant, a possible cause for the loss of sensitive organisms. Also in between is a school where numerous BMPs were installed, yet the benefits were masked by the upstream pollution source. This illustrates the importance of a thorough Audit before making a large investment in restoration practices.

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Auditing Your WatershedAuditing Your Watershed

ceds.org/audit

For further advice on Auditing your watershed, visit ceds.org/audit. Here you’ll find a general description of Watershed Auditing How-To’s. Further detail can be found in our Severn River Preliminary Audit report, which you can download from the Audit webpage. You can also click the text circled with red to sign up for a workshop. When we get enough folks in your area we’ll schedule a Watershed Audit training session. Or we can schedule a workshop now if you know a dozen or so folks who will participate.

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LetLet’’s Do A Preliminary Audit of Your Watersheds Do A Preliminary Audit of Your WatershedWeWe’’ll Volunteer A Few Hours If You Willll Volunteer A Few Hours If You Will

Richard KleinRichard KleinCommunity & Environmental Defense ServiceCommunity & Environmental Defense Service

Rklein@ceds.orgRklein@ceds.org 410410--654654--30213021

In the meantime, we’d be delighted to do a Preliminary Audit in your watershed. We can spend a few hours touring your watershed and evaluating problems you’ve found and looking for others. We can then offer advice on how to use cooperation first to begin correction of each problem. This service is made available free of charge to watershed advocates and others seeking to preserve aquatic resource health.

Thank you.