Update on the Stormwater Technical Advisory Workgroup

About a year ago, this group of volunteer professionals (mostly engineers) from across Pennsylvania (with heavy southeastern PA representation) came together at a PADEP office in Harrisburg to discuss editing and updating of the current Pennsylvania Stormwater BMP Manual (December 2006).  Objectives of the group were diverse, anywhere from relatively straightforward editing and correction of typos in the existing Manual, to much more substantive changing of the Recommended Control Guidelines (i.e., stormwater management standards).  Early on, because of the focused and selective nature of the group (invitation list had originally been prepared by the Southeast Regional Office), PADEP headquarters staff decided to withdraw from direct participation, although many representatives from PADEP regional offices continue to participate.  This meeting of the complete Workgroup was hosted by Villanova University (Dr. Rob Traver) and the Villanova Urban Stormwater Partnership, starting at 9 and ending with an afternoon tour of the BMPs which have been constructed on the Villanova campus (Rob Traver gave a lunchtime summary of emerging research results from these Villanova BMPs, certainly the most intensive BMP monitoring program in Pennsylvania and one of the most active in the country).

Subgroups Suggest Major Changes:  New Methods for Calculating Stormwater

From the start, the Workgroup was divided into 9 subgroups, somewhat reflecting the chapter organization of the Manual itself.  The meeting, chaired by Mark Bowen (Kleinschmidt Associates, Inc.), started with summaries of subgroup progress.  Michele Adams, chairing the Calculation Methods Subgroup, presented new ideas on calculation methods, including Robert Pitt’s Small Storm Hydrology and the new WinSLAMM model as extremely useful for Low Impact Development and site design applications, overcoming many of the problems of the highly inaccurate Rational and Soil Cover Complex/Curve Number methods (also mentioned were TetraTech’s SUSTAIN and EPA’s LID version of SWMM) with their event-based design storm approaches.  The enormous challenge here would be to integrate these new methods into literally hundreds of municipal ordinances across Pennsylvania.

All subgroups reported, though amount of work performed has varied.  The Standards/Control Guidelines subgroup  acknowledged that any discussion of standards would need to be predicated on the new Chapter 102 regulations and everything that has been specified in these new regulations.  It’s highly unlikely that new and/or different standards will be developed in the near future after so much energy has been spent on the Chapter 102 revisions (by the way, CG-2 is dead).  The Water Quality subgroup continues to evaluate other state programs, trying to make the Pennsylvania program which focuses on sediment and nitrogen and phosphorus more inclusive (i.e., hydrocarbons, metals, other pollutants).  The Infiltation subgroup has been targeting the site evaluation procedures set forth in the existing Manual appendices.  Perc tests are dead!

The Workgroup is hoping to assemble edited and expanded sections of the Manual this Fall.  An enormous challenge to overcome is an effective and efficient mechanism for editing a very large document with many different chapters being developed by many different subgroups, where so many of the chapters are interdependent.  And the fact that all of this has to be done on volunteered time doesn’t help!  Much time has been spent on editing logistics, and the issues are far from resolved.

Stay tuned!

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Update: The Pennsylvania Manual Revision Committee (now renamed Pennsylvania Stormwater Technical Workgroup) met formally for the third time on Thursday, April 8, 2010 at the PADEP Lab in Harrisburg, including approximately 30 attendees.  Dr.Rob Traver, director of the VUSP chaired the meeting, as he has done in the past, with PADEP SE Region stormwater chief, Domenic Rocco, acting as chief note taker. Although PADEP regional office staff were well represented, PADEP Central Office/Headquarters staff are not participating.  The Workgroup has been divided into nine sub-groups focusing on major technical/substantive issues in the existing Stormwater BMP Manual.

Previous meetings had been devoted largely to organizational/administrative issues of the group  - how to make decisions, Workgroup eligibility criteria, formation of a Leadership Board or board of directors, etc..  After a quick vote of confirmation by the Workgroup members, Sub-Groups launched into their progress reports.  Although some Subgroups had not been able to meet and make much progress, several Subgroup reports were both substantively detailed and powerful.  From Infiltration to Water Quality to Methods to Control Guidelines, sub-group reports included impressive data gathering from other states, other sources, typically expanding on existing Manual content. Some highlights:

There was an especially detailed report from Infiltration (Russ Losco, soil scientist) on better soil testing methods, demonstrating that an enormous amount of progress in thinking/understanding has occurred since similar discussions/arguments occurred in the Rachel Carson Bldg yrs ago when the current Manual was being prepared.

Michele Adams talk about Methods Subgroup discussions, reflecting once again the progress in stormwater “science,” including use of continuous simulation modeling, focus on smaller storms, and the like.

Frank Browne and Shirley Clark talked about complexities which the Water Quality Subgroup is wrestling with, again an impressive discussion which suggests a need for making Manual guidance more sophisticated, more complex.  A major issue affecting Manual revisions here seems to be PADEPs revisions to Chapter 102 which, for good or bad, are providing some sort of “anchor” for stormwater management in Pennsylvania municipalities.

There’s much more to add.  Subgroups were directed to review the existing Manual and provide any editorial changes by the end of May.  By the end of June, Subgroups should provide a scope of work which provides an outline for the changes to the technical provisions of the Manual.  Although the Subgroups continue to meet on a monthly basis, the next workgroup meeting will be on July 14 at Villanova University.  Of course, the huge challenge facing the Workgroup will be moving from development of critically good ideas into readable Manual form which is so time consuming and challenging for a volunteer effort…

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As reported previously here, the PADEP-organized effort to revise its Stormwater BMP Manual (2006) re-convened for an almost day-long session at the South Central Regional Office in Harrisburg on 12/15/09.

The Manual Revision Committee met once in September and has resulted in the formation of 9 sub-groups. Each sub-group was assigned a specific substantive topic, and continued meeting during the Fall.

The appropriateness and transparency of this process has been questioned.  As a result (and also for budgetary reasons), PADEP has reduced its direct sponsorship of the now all-volunteer Committee. To the extent that PADEP staff continue to participate, they do so on their own time.

The intent of the December 15 meeting was to summarize and review sub-group findings and determine future actions.  Dr. Robert Traver from Villanova University had been asked by PADEP to chair the meeting, rather than PADEPs Domenic Rocco, the Committee’s initial organizer and coordinator.  About 30 attended, including several staff from regional PADEP offices (PADEP Central Office staff have been directed not to participate; however, regional office are free to participate as they see appropriate).

Some major actions included:

1.  Re-Constituting the Group:  considerable time was spent in re-affirming the existence of the group and establishing an organizational structure

• including its separation from PADEP
• to be called a “stormwater technical work group”

2..  A mission statement was defined, expanding future work beyond Manual editing to include all related aspects of PADEPs stormwater management program

• its primary focus is to be “technical”
• but the group work also is likely to include aspects of policy (the group seems to feel that a technical focus invariably involves weighing in on policy issues such as recommended control guidelines or standards, as well as other important issues like Chapter 102 Revisions or the pending Draft MS4 General Permit and others)

3.  Goals were defined

• Manual editing, both simple and complex
• possible comment on Chapter 102 Revisions and Draft MS4 General Permit program and others

4.  Membership in the group was given some definition

• additional representatives can be added with submission of a resume, etc. provided that any/all focus on the “technical” work and agree to work cooperatively

5.  Roberts Rules of Order will be used

6.  The work group will have a board composed of the existing chairs of each of the 9 existing sub-groups; without establishing more complex by-laws, this board will meet and decide whatever needs to be decided

7.  In terms of group outputs, “minority opinions” will be included when substantive disagreements emerge

8.  No end or completion date was established.

Sub-group reports were given, mostly in verbal form but some with written attachments (to be included in the minutes of the meeting).  Some highlights include:

Control Guidelines - Rob Traver stressed that CGs interrelate with so many of the other sub-groups.  Thus far this sub-group is thinking that there…should be a collection of CGs rather than the more prescriptive Manual approach which is probably limiting use of LID at sites

Calculation Methods - The point was made that given the enormous shortcomings of rational, soil cover complex, and related methodologies, continuous flow modeling is likely to be the preferred way to go, though it is frustratingly data intensive and difficult to make happen across Pennsylvania’s 2550+ municipalities.  Furthermore, this method isn’t compatible with event-based standards such as CG1 and its 2-yr storm.  The methods are related to the standards that are being recommended!

Vegetated Systems - This sub-group is arguing for explicit Standards of Practice so that explicit engineering standards can be applied at sites.

Capture/Re-Use - This sub-group has substantially expanded the definition of this BMP from the current Manual.

Water Quality - This sub-group wants to establish water quality standards which transcend the current Manual, especially in light of new standards being promulgated for the Chesapeake Bay by EPA and others.

Infiltration - The major focus of this sub-group has been revising the appendices dealing with soil testing and site testing.

The Redevelopment and Highways and Maintenance sub-groups provided very condensed reports.

StormwaterPA will continue to report on this important effort in future weeks as it continues to evolve.

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As noted in previous posts, PADEP has organized an effort to revise its BMP Manual (released December 2006).  A Manual Revision Committee was formed and as a result of a meeting in September, 9 sub-groups were formed and assigned specific topics.

The sub-groups have been meeting during the Fall.  Some controversy has emerged regarding this revision process, leading PADEP to reduce its direct sponsorship of its process. Nevertheless, the Revision Committee and sub-groups are meeting again today (Dec. 15) at the South Central PADEP Regional Office to summarize and review sub-group findings and determine future actions.

We will report next week on the outcomes.

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In the wake of PA DEPs new budget cutbacks, our understanding is that PA DEP officials are still evaluating how the massive budget cuts are going to impact specific DEP programs.  A revised detailed budget hasn’t been released by DEP, and many critical questions remain.

StormwaterPA is not clear, for example, what the apparent deletion of the “stormwater” line item means for the total stormwater program.  Are we looking at the elimination of any 167 planning matches, or something far more  severe?  We have been told that optional projects such as the BMP Manual Revision Committee, which has been described and discussed in this blog in recent weeks, are no longer being supported by PA DEP staff, offices, and budgets, although sub-group meetings are continuing (more discussion on this below).

In the midst of so many stormwater-related program changes from Chapter 102 to MS4/NPDES Phase II to the BMP Manual itself, impacts of budget cutbacks and staff reductions would seem especially dangerous…

Status of the BMP Manual Revision and Activities of sub-group Committee

The nine sub-groups designated by PA DEP as part of the Manual Revision Committee will continue to meet, though in an unofficial capacity with no guarantees that any of their work or recommendations will have an impact on the Manual as it currently reads.

StormwaterPA  welcomes any news that results from these efforts and is more than happy to provide a forum for discussion.  Write to us, Sub-Group Scribes, so we can keep all stakeholders informed! You can email us at info@stormwaterpa.org

As an example of what may come out of these meetings: we attended the recent (October 27) Capture and Re-Use sub-Group meeting outside of Allentown (Newton Engineering Group offices) ,where the discussion was far-reaching and explored the concept of adding another technology, spray irrigation, to this BMP itself or to the broader BMP list.

The DEP regional office and other sub-group members described extensive use of spray irrigation as a technique for stormwater volume control, especially in areas such as super-sensitive mined lands where infiltration BMPs for volume control could entail serious groundwater problems (i.e., increased acid mine drainage).  Clearly, Pennsylvania has large areas where such groundwater sensitivities exist and where a spray BMP could provide a useful stormwater management answer.  Though the Capture and Re-Use Sub-Group has yet to compile its recommendations for forwarding to DEP, this is an interesting example of adding to the Manual and making it more comprehensive…

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