You may have already seen parts of the new National Research
Council report, “Urban Stormwater Management in the United States.” At EPA’s
request, the NRC reviewed the EPA’s entire stormwater program—basically,
everything EPA has done with it since 1987, when Congress brought stormwater in
as part of the Clean Water Act. Not surprisingly, the NRC has some sweeping
suggestions—logical ones, perhaps, but difficult to implement and in many ways a
complete departure from the current permitting system that everyone’s been
working so hard to comply with for the last several years.
The report’s main recommendation
is that stormwater permits (and other wastewater discharge permits as well)
should be based not on political boundaries as they are now but rather on
watershed boundaries. In many ways, this makes perfect sense. Authority would
still rest at the local, municipal level, but each municipality would have to
work with others in its watershed; they would all be co-permittees with one as
the lead. Some NPDES Phase II permittees have done this, often to save money by
pooling resources. Under the system outlined by the report, the permitting
authority would set a goal for each watershed to avoid, or to reverse, loss of
beneficial uses for the waterbodies within it. The permittees would come up with
the solutions, using improved monitoring and, possibly, credit trading among
dischargers in the watershed. It’s basically the TMDL concept expanded to the
watershed rather than to individual waterbodies.
The report also puts much emphasis
on source control, suggesting that EPA should regulate at a national level
certain products that contribute stormwater-borne pollutants, such as
fertilizers and de-icing materials.
One other recommendation in the
report: the federal government should provide more financial support to state
and local stormwater efforts. Last week Brant Keller wrote a somewhat
tongue-in-cheek blog
suggesting exactly that, but this one is completely serious.
You can see a summary of the
report here,
or pre-order the complete report from the National Academies Press Web site at
www.nap.edu.
Do you think it’s likely that EPA
will adopt these recommendations—perhaps, as the report suggests, as a pilot
program? What do you think would be the main challenges to moving in that
direction?