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Archive for November, 2009

Riparian and Wetland Buffers for Water Quality Protection: A Review of Stormwater Journal’s “Literature Review”

November 24th, 2009

Last week we alerted you to the release of the November/Decemberedition of Stormwater Magazine, including a reference to an article entitled “Riparian and Wetland Buffers for Water-Quality Protection: A Review of Current Literature,” the full text of which is available here.

Upon a more careful reading, we have some questions and concerns about the piece.

First, their buffer recommendations substantively appear to us to be weak.  Authors seem to recommend a buffer width of 50 feet:

For streambank stability, temperature control, minimization of direct impacts, and pollutant removal capacities, substantial benefits are achieved within the first 50 feet of vegetated buffer width.

In contrast, the Pennsylvania Campaign for Clean Water recommends a buffer width which varies from 100 feet total for all streams, to 150 feet for first order streams and impaired streams, to 300 ft for Special Protection (EV and HQ) streams (roughly comparable to New Jersey state regulations). PADEP is recommending 150 feet for EV streams in its Draft Chapter 102 regulations.

Secondly, authors draw their conclusions based on extremely dated references — many from the 1970’s, ’80’s, and ’90’s.  References also seem to omit or ignore so many other commonly accepted riparian buffer authorities and respected sources (Correll, Lowrance, Peterjohn, Sweeney, Welsch, US Forest Service, Chesapeake Bay Foundation, and so many others), omitting some important recent work which is the advertised purpose of this article (viz., “…A Review of Current Literature”)!  We would expect attention to both recently published journal articles with new research findings as well as the more recently published manuals and guidance documents.  If this is a summary of review of 137 different sources, it seems to be an extremely selective summary.

The authors ostensibly focus only on water quality — which is a fine and very important objective.  However, before final buffer width recommendations can be made (by anyone), there needs to be acknowledged the reality that riparian buffers provide a much longer list of “ecosystem services” which should be integrated into buffer width recommendation decisionmaking, management, regulation.

A related concern is what is being regulated and how it is being regulated within the riparian buffer zone - a dimension of issues which is not really addressed by the authors here either.  In any case, the article, we believe, needs to acknowledge that buffer width recommendations should integrate all of these more complex issues - before rushing to a 50-foot buffer width judgment which it seems to want to do.

In addition, the authors seem not to understand some basic Pennsylvania context and government form elements – despite the fact that the article uses Southeastern Pennsylvania references quite liberally (which would seem to imply specialized knowledge and understanding of applicability in a Pennsylvania context). Consider the following statements made in the article:

Wetland and riparian buffer widths are instead decided at a county or township level.

When does the county level enter into this process?

Local environmental approvals that may require riparian and wetland buffers may include Sediment Erosion and Sediment Control Plans, County Grading Permits, and Nontidal/Tidal Wetland Permits.

The above terminology is not accurate.  And what does County Grading Permit mean?

In the absence of state-level rules, buffer widths are determined on the county and township jurisdictional level.

Where are counties determining buffer widths?

Critical elements of riparian buffer management are being ignored in this article.  And what is being included seems to be inaccurate - at least in some cases.  There is no discussion of PADEP’s Draft Chapter 102 regulations, which are so enormously important at the moment, and proposed riparian buffer language or the riparian buffer recommendations in PADEP’s Stormwater BMP Manual (2006) or other important “milestones” of riparian buffer management or lack of management in Pennsylvania.

In sum, we are concerned that this respected national technical journal would present this article as a summary of the science with special relevance to Pennsylvania municipalities.   We have been told that a presentation similar to this was recently made by ENTRIX authors at a Pennsylvania Builders Association conference.  If there is a point of view to this piece, Stormwater Magazine should have made this clear and not presented the article as objective science and as “…A Review of Current Literature.”

“…A Selective Review” might ring a little more true.

What do you think?

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A Closer Look at Stormwater Management Paradigm Shift: From Peak Rate Control to Total Volume Control

November 16th, 2009

“Volume Based Hydrology” - A Much-Delayed Comment From the Editors

In the September issue of the Stormwater Journal, Andy Reese gives us an intelligent summary of stormwater management’s recent (and ongoing) paradigm shift - from peak rate control with detention basin solutions to control of total volumes of stormwater being discharged, using infiltration or evapotranspiration or capture and re-use and other management practice strategies including preventive Low Impact Development BMPs.

If you haven’t read the article, take the time and read it.  It’s enlightening and even entertaining (”As Mark Twain said, sacred cows make the best hamburger.”)  It’s gotten a lot of attention in recent months.  In “Volume-Based Hydrology” (or VBH, as he coins), Reese makes some provocative assertions (and know that we are barely even addressing the tip of the iceberg in our very summary comment here):

So it seems VBH is a water scarcity phenomenon

So, maybe VBH is a runoff volume reduction phenomenon.

VBH is really a stormwater pollution reduction phenomenon.

So it seems VBH is a channel erosion and habitat protection phenomenon.

So, VBH is a flood control phenomenon.

So…VBH is a floodplain management phenomenon.

Although we’re not sure that the technical arguments are as equally compelling for all of these stormwater management functions or benefits which Reese points out here (some do seem more important than others although relative importance may indeed vary with the specific situation, locality, watershed context, etc.), the point is that volume control is now known to provide much more bang for the management buck than previous strategies focusing exclusively on peak rate control.

This is a paradigm shift based on something of a revolution in our understanding of the stormwater problem itself and superior ways to prevent and mitigate these stormwater-linked problems.

It is important here to point out that the Pennsylvania Stormwater BMP Manual is substantially compatible with Reese’s VBH line of argument (he acknowledges this in the article).  The Manual’s Chapter 3, Recommended Stormwater Management Standards for Pennsylvania, sets forth an array of integrated peak-volume-quality standards which emerged as the Manual was being developed by PADEP, its consultant, and the Oversight Committee.  Assisted by the Villanova Urban Stormwater Partnership (VUSP) during the extended and arduous Manual development process, this set “recommended site control standards” emerged in many ways from thinking very similar to Reese’s VBH article discussion.  Reese develops a nice graphic showing it all as a kind of integrated set of objectives which work together to provide maximum management benefit:

Various stormwater objectives

Various stormwater objectives

This concept of integration is especially useful for so many developing Pennsylvania communities where this sudden paradigm shift in stormwater management, reinforced by state and federal mandates, is potentially too complicated and too costly and too politically challenging to embrace.  Yes, the bad news is that stormwater management is so much more complicated than we have conventionally understood it to be.

The good news is that this new “volume” focus which is designed to match pre-development and post-development hydrology allows us to accomplish so many stormwater management objectives in an integrated fashion and perhaps even reasonably cost-effective.

Use volume-based BMP strategies and related BMPs, and you can often go far in achieving volume and even peak rate (peak control for large storms is most challenging) and water quality and streambank erosion and flooding and floodplain objectives!  Many BMPs, (including many described in the PA Manual), give convincing performance across multiple objectives - clever design doesn’t require separate BMPs to satisfy management objectives.  With any degree of luck, you can kill two birds - perhaps even several birds - with one BMP stone.  Understanding the problem more completely is the first step in formulating a more comprehensive (and perhaps less complex and costly) solution.

Read the article.  Though some of this line of argument might vary a bit in other regions of the country with substantially different climate and physiography, we would argue that VBH and the discussion in the article is very applicable for so much of humid Pennsylvania.  Reese’s examples and interesting tables and graphs make sense in most of Pennsylvania.

Our only point of criticism is that this VBH paradigm shift article doesn’t in any direct way acknowledge the concept of prevention and its importance in this new management paradigm.  Preventive BMPs are given substantial attention in the Pennsylvania Manual.

The first step in comprehensive stormwater management - even before all of the vital objectives of VBH are wrestled with - needs to be ways to prevent runoff from occurring in the first place even as the same number of houses and square footage and cars are accommodated.

The complete article from the Stormwater Journal is available here.


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Maintenance of Stormwater BMPs, Stream Restoration, Riparian Buffers, and Templates for Rain Garden Designs

November 16th, 2009

Stormwater BMP Maintenance Practices

Regular maintenance of stormwater facilities is necessary to save time and expense in the long term, and to ensure that the facilities are working as designed.  Maintenance programs for various stormwater management facilities and products are discussed in this article by William Atkinson in the current issue of the Stormwater Journal.  Products that are discussed include: StormFilter; Stormceptor; HydroKleen; Drain Guard; and cleaning equipment. Read the full article here

Refer also to Chapter 6 of the Stormwater BMP Manual for maintenance considerations for Structural BMPs. You can download a pdf of the complete text of Chapter 6 here.

Challenges of Stream Restoration as a Stormwater Management Tool

The first article of this series dealt with stream restoration as a valuable watershed management practice. The second article discussed construction issues. This final article combines these perspectives and ties them together through a lessons-learned perspective. Read the full article here

Riparian and Wetland Buffers for Water Quality Protection

A compelling review of 137 published scientific papers written over the last 40 years on riparian and wetland buffer widths, and on the subject of providing “ecosystem services” such as: temperature control; streambank stability and sediment control; minimization of direct human impact; removal of total suspended solids; maintaining surface water supply and quality; nitrogen removal; phosphorus removal; removal of pesticides; removal of bacteria; and removal of metals.   The authors conclude that vegetated buffers “provide substantial benefits for protecting and enhancing water quality. For streambank stability, temperature control, minimizing degradation from direct impacts, and pollutant removal capacities, substantial benefits are achieved within the first 50 feet of vegetated buffer width. Marginal increases in benefits may accrue when buffer widths are increased beyond 50 feet”.  Read the full article here

The PA Stormwater BMP Manual also provides data on ecosystem services.  Appendix A for Pollutant Event Mean Concentrations by Land Cover and BMP Pollutant Removal Efficiencies. Download a pdf of Appendix A here.

Rain Garden Design Templates from the Low Impact Development Center

Looking for planting plans for rain gardens in the Piedmont or Mountain regions of Pennsylvania?  The Low Impact Development Center provides dozens of Rain Garden Design Templates for a range of conditions that can be used “as is”, or modified to suit specific needs.  The designs are colorfully  illustrated and can be found here.

Homeowners and others can also find a step-by-step guide to design, build, plant and maintain a rain garden. Download a pdf  How-To Manual for Homeowners here .

Also, see also Appendix B of the PA Stormwater BMP Manual for a list of plant species native to Pennsylvania that are suitable for use in any number of BMPs.

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EPA Announces New Region 3 Administrator, SRBC Seeks Water Quality Monitoring Partners

November 12th, 2009

EPA News

On Thursday, November 5th the US EPA announced that Shawn M. Garvin will be the agency’s new Regional Administrator for the EPA’s mid-Atlantic region (Region 3).  Garvin previously worked for EPA Region 3 as EPA Region 3’s Senior State and Congressional Liaison.  He joined EPA in 1997, and is a graduate from the University of Delaware.  For the full announcement, go to the EPA Newsroom.

Susquehanna River Basin Commission (SRBC) Seeks Partners for Proposed Real-Time Water Quality Monitoring Networks for Small Streams

The water quality monitoring network will record water quality data for several small rivers and streams in the northern tier of PA and southern tier NY.  The data would be received in real-time by state and federal water management officials and other participating watershed groups.  The monitoring will help to determine whether streams are being impacted by development including activities associated with the natural gas industry. Read DEP’s news release, or go to SRBC’s website for more information.

Call for presenters…

The Delaware County Environmental Network (DCEN) would like to hold an Environmental Summit in March of 2010 and is interested in learning from anyone wishing to present a topic. Anyone wishing to submit a proposal please send them to Ed Magargee - Delaware County Conservation District, Rose Tree Park - Hunt Club, 1521 N. Providence Road, Media, PA 19063.  Email address : MagargeeE@co.delaware.pa.us

R.S.V.P. by December 15, 2009.

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Chapter 102 Revision Deadline Approaches: Comments Due Nov 30

November 12th, 2009

The deadline for submitting comments on PADEPs proposed Chapter 102 amendments which are considerable is looming - November 30.  Get your comments in.

For an overview of proposed revisions to 25 Pa. Code Chapter 102 (Erosion and Sediment Control) click here.  Hot issues include: Phase II NPDES;  riparian forest buffers; and permit-by-rule.

For the full proposal click on Environmental Quality Board (EQB) proposal to amend Chapter 102.

The EQB will accept written comments through November 30, 2009. Comments should be submitted to

Environmental Quality Board, P. O. Box 8477, Harrisburg, PA 17105-8477 (express mail: Rachel Carson State Office Building, 16th Floor, 400 Market Street, Harrisburg, PA 17101-2301), or emailed to regcomments@state.pa.us

The Pennsylvania Campaign for Clean Water has posted official Chapter 102 comments; see their website for more information.

As we understand it, some uncertainty continues to exist regarding the forward movement of the Pennsylvania Stormwater Manual Revision Committee (see previous weekly blogs for more discussion on the Revision Committee and its process).  As we understand it, budget woes and uncertainties regarding scope of the revisions has bogged down the Committee process, although the 9 sub-groups continue to meet.  We’ll try to keep you posted.

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