September 2008

Stormwater Management for the Wastewater Organization

Why stormwater is not sewage

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By Andrew J. Reese

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“Do not free a camel of the burden of his hump; you may be freeing him from being a camel.” –G. K. Chesterton

A consolidation of water organizations is taking place in the United States. It is growing more and more common to see a water or sewer organization (or both) that is taking on stormwater as the “third leg in the water resources stool.” While there are a number of organizations that started this way, or assumed stormwater duties long ago, the trend is now moving to ever-smaller communities. This tendency to consider water as a resource that just happens to exist interchangeably in the forms of rain water, drinking water, sewer water, and groundwater (and even sea water) is a direct result of a number of interrelated drivers, including

  •  mixed media regulatory mandates
  •  the ability to trade pollutant credits between wastewater and nonpoint sources
  • the growing emphasis in stormwater management on chemical quality of the “effluent”
  • total maximum daily load (TMDL) regulatory mandates moving from the planning to the implementation phase
  • the fact that wastewater is already a utility with a billing mechanism
  • the complementary skill sets involved in managing water-related activities
  • the growing scarcity of clean water in the face of growing demand and potential climate disruption

Some communities are beginning to realize that as stormwater is becoming more complex and more driven by regulations, public works or street maintenance organizations may feel ill-equipped to make the transition and take on stormwater management duties. Many public works-type organizations have been successful, of course, but it takes a concerted, dedicated focus and budget to bring it about. Stormwater as “other duties as assigned”—in an organization that has other primary duties and is engaged in stiff competition for general fund revenues—is a recipe for failure. Such failure could be tolerated before it meant state or federal permit violations and potential fines, and when citizens were blissfully unaware of green design concepts. Now, it increasingly cannot.

When casting about for alternatives, city leaders increasingly come to the realization that wastewater (and, less commonly, water) organizations may be the right place for stormwater to land—at least parts of stormwater. There are some advantages to placing stormwater responsibilities in another water-related utility organization, mostly revolving around the organization’s mindset to run its activities as business enterprises under local government or in a regional setting. (We will not talk about the nefarious practice of “hiding” stormwater within a wastewater organization to be able to fund it out of wastewater revenues or through use of an “environmental surcharge.” This is, at best, a short-term fix that eventually backfires on all involved.)

These organizations tend to think of themselves terms of

  • a municipal business
  • serving customers
  • having a fully funded, comprehensive program
  • operating a well-defined and owned system
  • handling a quantifiable resource
  • meeting strict regulatory standards as a matter of course

That is very different from past standard stormwater management practice and has some unique advantages as we look to the pressures of the future. It has led some wastewater operators to relish the idea of merging the two types of programs.

However, in my experience in helping a number of wastewater entities take on stormwater duties, there are significant pitfalls, normally realized by wastewater operators only a year or two into the process of assuming stormwater responsibilities. They may tend to think that stormwater management is fairly simple, consisting mostly of getting water to flow downhill and not through homes, and cannot fully appreciate the subtle and hidden complications. It is like Winston Churchill commenting on the United States and Great Britain as “two nations separated by a common language.” Stormwater is expressed in a different language. Next Page >

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