There is no doubt that the Manual needs to be edited and updated.  For example, new technical information relating to BMPs has emerged which can and should be integrated.  At the same time, the line between “technical” and “policy” is a slippery one.   Sub-groups have been formed assigned to control Guidelines (i.e., stormwater standards) as well as methodologies.  Though issues surrounding both of these vital topics are hugely technical, they ultimately also are very policy oriented.  One could even argue that design specifications relating to how to build infiltration BMPs are policy oriented as well.

Understanding this somewhat “murky” separation between technical and policy, state environmental groups such as the Pennsylvania Campaign for Clean Water have contacted PADEP and are requesting that  the Revision Committee be expanded (see their letter below) in order to guarantee that important issues of water quality, hydrology, habitat, landscape ecology, and other aspects of environmental planning be fully represented and balanced in this Manual revision process (similar to the Oversight Committee which oversaw development of the existing Manual).  We will try to keep you informed as this process unfolds…

September 14, 2009

John Hines
Deputy Secretary
PA DEP
Rachel Carson Office Building
Harrisburg PA 17105

Dear John:

We recently learned about a series of meetings being convened by Domenic Rocco of the Southeast Regional Office to consider possible changes to the Stormwater BMP Manual.  We are very concerned that the group invited to these meetings includes few if any environmental stakeholders, and is overly representative of the interests of the regulated community–developers and the engineers that work and advocate for them.

As you know, the development of the BMP Manual was a rigorous process that included an Oversight Committee with broad stakeholder involvement and several public hearings to solicit public input.  The product of that effort was a technically sound guidance manual for reducing the generation of and properly managing post-construction stormwater runoff in Pennsylvania.  While we agree that the Manual should not be a static document and should be revised over time to reflect advances in the state of the art, any changes should be made in a very transparent way, with full involvement by a broad range of stakeholders, including the environmental and conservation communities. We believe the current process falls far short of this standard.

We encourage the Department to clarify the purpose of the meetings convened by Mr. Rocco.  If this is indeed the start of a process to revise the Manual, particularly the control guidances, we strongly encourage the Department to broaden the participants in the group, in particular adding representatives of the environmental and conservation communities, along with other interested groups including Conservation Districts and municipal officials.  In addition, the Department should clarify its plans regarding public participation in the Manual review process and the goals for such a process.

We look forward to hearing from you regarding our concerns at your earliest convenience.

Sincerely,

Bob Wendelgass
PA Campaign for Clean Water
1315 Walnut Street, Suite 1650
Philadelphia PA 19107

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