Remember the first time you came home with a bad grade? I mean a really bad grade. I recall that myself. It was chemistry in eighth grade. I remember opening up the envelope from school and seeing that mid-term grade showing a big, fat “D” staring back at me. How was I going to explain this to my parents? How would I ever dig myself out of this mess? Is this really the best I could do? These were my thoughts, and these should be the thoughts in the storm water sector as well, but we don’t know for sure, as there has never been an effort to determine a grade for storm water in the U.S.
The most well-known barometer for the nation’s infrastructure—the American Society of Civil Engineers (ASCE) Infrastructure Report Card—does not currently include the storm water sector in its overall infrastructure assessment. Considering urban runoff is the only growing source of water pollution—as noted by the U.S. Environmental Protection Agency (EPA)—it is disappointing and alarming that there is no regular national assessment of the condition of the storm water sector. That’s about to change, but more on that in a bit. First, let’s consider why it is important for storm water to be graded, who else already has actually done this, what currently is being done to promote the idea of a storm water grade, and how it can be done in a meaningful way in the future.
As storm water professionals know, the biggest driver for urban storm water runoff is impervious cover. The reasons for this are simple: impervious cover “stores” pollutants such as heavy metals and nutrients for ready delivery downstream during the next runoff-producing storm event, and impervious cover—even at relatively low percentages in a watershed—increases the volume of runoff and rate of discharge, which leads to combined sanitary sewer overflows, degraded headwater streams and downstream flooding.
While the amount of impervious cover across the U.S. is only 2%—approximately the size of Ohio—the impact of this footprint goes much deeper, with the latest information showing that the percentage of impaired lakes, rivers and estuaries impacted by urban runoff is between three and five times as large as the national impervious cover footprint. These impairments occur in urban areas where more than 80% of Americans live. In other words, we are polluting the water bodies closest to us and upon which we rely for many services. Lastly, as Williams Ruckelshaus (the first EPA administrator) has pointed out, while only 15% of impairments in the U.S. were attributed to nonpoint and urban runoff in 1970 when the Clean Water Act was being formed, by 2010 these sources comprised more than 85% of all impaired waters. As urbanization continues, these impacts will continue until significant investments are made to address urban runoff. The nature of our water quality challenges is shifting, and urban runoff is one of the most significant water quality issues of the 21st century, giving greater reason for a storm water report card.
The idea of a storm water report card is not new. Several countries, such as New Zealand and Canada, include the storm water sector in their respective national infrastructure assessments. Even in the U.S., the idea of a report card for the storm water sector is not new or even necessarily unique. For instance, Orange County, Calif., developed a Surface Water Quality Infrastructure Report Card in 2016 to, “assess the ability of existing and near future surface water quality infrastructure to support healthy resilient watersheds, ensure safe and healthy aquatic resources, and promote the use of storm water as a resource,” with evaluation categories of condition, capacity, operations and maintenance, and resiliency. In Texas, a study led by the Environment Texas Research and Policy Center focused on the green storm water infrastructure/low-impact development policies of the state’s five largest cities to ascertain the progressiveness of the storm water programs in these metropolitan areas. With storm water included in report cards at the state level in the U.S., and with other countries around the world, there is precedent for the U.S. to have its own.
To meet the challenge, the National Municipal Stormwater Alliance (NMSA), a newly-formed 501.c.3 dedicated to the municipal separate storm sewer system (MS4) sector, has taken the initiative to drive the conversation on a storm water report card. NMSA represents 12 state- and regional-level storm water organizations in seven of the 10 EPA regions. It developed and posted an online form for professionals to assess the storm water sector based on ASCE Infrastructure Report Card criteria for two conditions: current and “StormSmart.” A StormSmart condition assumes all innovative approaches and technologies are used to their fullest extent, which includes technological arenas, project delivery and financing.
Dominique Lueckenhoff, the keynote speaker at StormCON, a national storm water conference, led a live poll on this. Lueckenhoff, acting director for Water Protection Division for EPA Region 3 (Mid-Atlantic), let storm water professionals grade the sector, and more than 200 participants joined to give it an overall grade of “D.” NMSA seeks to continue this momentum, and professionals are encouraged to visit www.nationalstormwateralliance.org/reportcard to grade the sector. NMSA’s intent is not to supersede the ASCE Infrastructure Report Card, but rather to inspire ASCE to answer the call and integrate storm water into the ASCE Infrastructure Report Card. Stormwater has been a rising sector for many years, and now it is time for it to be treated as legitimate infrastructure.