Stormwater Runoff and Puget Sound – Problems, Issues and
Analyses Needed
By
Derek Booth, Curt Crawford, Bill Derry, Curtis Hinman, Rich Horner, Chris May,
Bill Moore, Joanna Richey, Phil Roni, Bruce Wulkan
[Authors’ Affiliations are in the attachments at end of paper]
Introduction
This paper describes: 1) the most pressing problems associated with stormwater runoff in
Puget Sound; 2) specific areas where scientific certainty calls for action; and 3) priority
stormwater-related analyses to undertake in the short term (before September 2008 to
inform development of the Action Agenda) and in the long-term (beyond September
2008) to contribute to the goal of Puget Sound recovery by 2020. Throughout this paper,
Puget Sound includes the whole system across all the watersheds that drain from the
crests of the mountains, all rivers, tributaries, lakes and wetlands, to the estuaries, coastal
areas and the marine waters of Puget Sound.
Problem Statement
Science and research show that numerous species in Puget Sound are significantly
threatened and in serious decline (e.g., salmon, orcas, marine birds, rockfish). Similarly,
many other important beneficial uses with high social and economic value to the region
are also threatened and in some areas, are not longer available or greatly reduced
(shellfish harvesting, commercial and recreational fishing, recreational activities
including swimming and boating, drinking water supplies).
Stormwater runoff quantity and quality contribute extensively to this decline. Unless
significant changes are made in how stormwater runoff is managed, these declines and
loss of beneficial uses will worsen substantially as another 1.4 million people come into
the Puget Sound area over the next 20 years. We know that once the beneficial uses in
fresh or marine waters are lost, it is very hard and very costly to get them back. The costs
and challenges are in money, technology and the resistance to changing social habits and
expectations. Prevention of problems must therefore be more strongly emphasized.
We have well documented evidence that the impairment associated with stormwater
runoff is primarily a land use problem, and that we cannot fully mitigate its effects if we
approach it only site-by-site. We know that the problems must be addressed at a basin or
landscape level – but we continue to manage land use and stormwater primarily on a siteby-site, end-of-pipe basis. At the same time, we also know that current site-by-site
development techniques that result typically in wholesale loss of vegetation, compaction
of native soils and connected impervious surfaces, can and should be improved upon
significantly if we are to address stormwater problems.
Stormwater Runoff and Puget Sound – Problems, Issues and Analyses Needed
Submitted to the Puget Sound Partnership
June 27, 2007
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We know that if we started managing these problems at a landscape level, and
significantly improve site level practices with a goal of no net increase in runoff
discharge, the rate of decline would be slowed. However, we do not know the extent of
that slowing. We know that in most parts of Puget Sound, land use controls on new
development need to address basin/landscape scale targets for impervious surface, forest
cover, pollutant loading, and low impact development standards. We know that local
governments will need to increase their investments to ensure compliance with, and
maintenance of, these controls. Finally, we believe that we should be prioritizing our
investments to protect existing beneficial uses first and restoring lost beneficial uses next;
however we are not doing this as a result of social, economic, market and regulatory
driven realities.
In addition to the key problems outlined above, several additional challenges exist:
1. Much of the development around Puget Sound was constructed with no or
substandard stormwater management controls, as well as sited on the landscape with
limited consideration of impacts to nearby receiving waters.
2. Some classes of pollutants (relatively highly soluble contaminants, pollutants
widespread in atmospheric deposition, and transportation related pollutants) are
difficult to remove with currently known, economically feasible stormwater treatment
technologies and are ubiquitous in the environment. In particular, dissolved zinc,
dissolved copper, some pesticides, phthalates, and polybrominated diphenyl ethers
(PBDEs) may require source substitution to adequately address associated problems.
3. State vesting laws work against the application of effective stormwater management
by allowing development to occur in areas that have been subsequently shown to be
inappropriate for development and by allowing vested development to be built under
older, substandard stormwater standards.
4. Reliance solely on Clean Water Act regulatory programs, such as the NPDES permit
program (including the recently issued municipal stormwater NPDES permits) to
protect and restore Puget Sound will fall short. While these regulatory programs are a
necessary element of a strategy for restoring and protecting Puget Sound they are not
the sole solution, and, taken by themselves without additional actions, will fail.
5. Meeting state water quality standards may not be possible in some parts of Puget
Sound, particularly since a significant percentage of stormwater enters surface waters
from rural and agricultural lands that are largely developed without any controls.
Even where possible, meeting state numeric water quality standards may be
inadequate to achieve ecological health because a) the standards are not
comprehensive; they are primarily limited to water quality and not to other factors
necessary for a functioning ecosystem and protection of aquatic beneficial uses; and
b) the implementing vehicle for the standards is imperfect.
6. The majority of land area throughout Puget Sound is in private ownership. Private
property owners therefore have a very significant role in reducing or eliminating
stormwater problems, and current understanding by property owners of problems and
their role in helping to solve these problems is limited. Without broader public
understanding of the problem, their role in helping address problems, and their
commitment to make changes on their properties, problems will likely continue.
Stormwater Runoff and Puget Sound – Problems, Issues and Analyses Needed
Submitted to the Puget Sound Partnership
June 27, 2007
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Fundamental changes by the public, perhaps in both lifestyle expectations and
lifestyle practices, are likely necessary to solve the region’s stormwater problems.
7. Roads and other transportation corridors (bridges, railways, and trails) crisscross the
landscape throughout Puget Sound, total acres of transportation corridors are
increasing due to population growth, and vehicular use is popular and also increasing.
Runoff from roads and other transportation corridors is a significant part of the
stormwater problem. Road crossings cumulatively impact stream and river corridors
and cause fish passage barriers. Societal habits and expectations regarding
transportation opportunities are also a consideration in terms of current and future
stormwater runoff from existing and new roads.
Areas of Scientific Certainty that Call for Action without Additional
Analyses
Although the scope of this document is limited to articulating new studies or research
needs, many of the key actions necessary to reduce the impacts of stormwater runoff on
marine and freshwater ecosystems are already widely recognized and languish only for
lack of funding, implementation of articulated planning policies, or enforcement of
existing regulations. The principles, parameters, and methods to take these actions are all
known. Implementation of these actions on a systematic and comprehensive scale across
Puget Sound requires analyses to understand better how to apply them on a broad scale
basis. The following section outlines these actions.
1. Begin developing and instituting a program to preserve watersheds with an
existing high level of ecological functioning through land purchases, conservation
easements, and other land use management mechanisms, and provide funding and
incentives to support the program.
2. Begin developing a program to retrofit large portions of existing development
within all watersheds in Puget Sound sufficient to make progress towards
restoration of watershed scale hydrologic functions to pre-development
conditions, and provide funding and incentives to local governments to implement
the program.
3. Begin developing a program to restore lost forest and native vegetative cover and
to reduce impervious area on public and private property within all watersheds in
Puget Sound, and provide funding and incentives to local governments and
private land owners to implement the program.
4. Begin developing and applying low impact site design standards for new
development and re-development within all watersheds in Puget Sound sufficient
to prevent further degradation of the waters receiving stormwater runoff from
these developments, and provide funding and incentives to local governments to
implement the program.
Analyses to Address these Problems and Issues
The following section proposes seven priority analyses necessary to address the problems
associated with stormwater runoff identified above. These analyses, when coupled with
Stormwater Runoff and Puget Sound – Problems, Issues and Analyses Needed
Submitted to the Puget Sound Partnership
June 27, 2007
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the actions above will achieve progress towards Puget Sound recovery in 2020 through
more effective management of stormwater runoff. While these are not the only possible
useful analyses, the authors of this paper believe they are the most important near-term
analyses. The authors also stress that any analyses undertaken should in no way delay the
taking of actions that are known to be needed to significantly improve stormwater
management efforts in the Puget Sound basin.
1. Protection and restoration strategies, by watershed. By watershed (and by subbasin if necessary), and including near shore areas, set priorities for future
investments by identifying land development and stormwater runoff risks to
existing beneficial uses and identify where enhanced protection measures should
be targeted vs. enhanced restoration efforts. Assess risks to existing beneficial
uses using past and current land use data and population growth estimates to
project future land use. Compile a Puget Sound wide data base. Create a
prioritization for investment type (protection and restoration) based on the risk
analysis. Short term, completed by September 2008.
2. Improved site development standards: Analyze landscape or basin scale and site
scale new development and redevelopment standards and practices. Evaluate
known options for improving new land development standards in test basins and
sites to achieve no net increase in surface runoff. Identify practices that create the
most problems and identify options for improvement (this could include for
example, preservation of native vegetation, reducing EIA, improving the
protection of wetlands and riparian buffers, improving erosion control practices,
reducing soil compaction, etc.). Where preservation of 65% native vegetation
and/or protecting the headwaters of small streams is not feasible, evaluate how
much native vegetation can/should be protected and identify the suite of other
practices needed to protect beneficial uses. Use this information to develop
improved new site development standards and plan population growth and land
development at a basin/landscape level. Short term, completed by September
2008.
3. Retrofitting of existing developments: Evaluate different scenarios to retrofit
existing development in pilot basins with diverse land use conditions to determine
what options could reduce stormwater impacts and to what extent. Using test
basins that support various land use types (e.g., industrial, commercial,
residential, agricultural and/or forested areas), evaluate options to reduce polluted
runoff discharges and pollutant loadings to improve flow and water quality
conditions. Consider the extent to which techniques such as increased forest and
wetland cover, riparian zone protection and rehabilitation, low impact
development, and other techniques could lessen the negative impacts of
development on ecosystem functions and habitat conditions. Define performance
standards and/or management goals that protect or reduce impairments to existing
beneficial uses. Use this information to help improve restoration techniques of
watersheds, and plan population growth and land development at a
basin/landscape level. Longer term, but fully scoped by September 2008.
Stormwater Runoff and Puget Sound – Problems, Issues and Analyses Needed
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June 27, 2007
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4. Existing regulatory framework: Investigate and propose changes to the current
regulatory structure for stormwater to more effectively address the cumulative
landscape effects of new development and re-development. Coordinate with and
inform the EPA’s National Research Council’s panel evaluating possible
improvements to permitting stormwater discharges under the Clean Water Act.
Work with Local and State agencies (including the AG if necessary) to clarify the
extent of local jurisdictional legal authority to regulate development to address
stormwater impacts on water quality and habitat in the context of property rights
and land use vesting. Evaluate options for changes to current state vesting laws.
Longer term, but fully scoped by September 2008.
5. Public campaign for behavioral change. Evaluate means for significantly
improving and expanding public education to inform citizens and businesses
about stormwater problems and practices that can minimize effects on beneficial
uses in Puget Sound. Evaluate other successful social change/social marketing
campaigns including recycling and anti-smoking to understand the basis of those
broad social campaigns for behavior change. Identify the key things citizens and
businesses can do to improve or reduce stormwater runoff from private properties.
Target property types that produce the most significant loadings of pollutants of
concern. Evaluate options for financial incentives to businesses and private
property owners, for example through property tax discounts, cost sharing of
BMPs, or property tax pollutant surcharges, to encourage change. Longer term,
but fully scoped by September 2008.
6. Strategy for pollutants : Identify a strategy for dealing with ubiquitous and/or
persistent pollutant sources. Align/partner in this analysis with the Pap’s Toxics
Group to accomplish this task. Evaluate options for source control and/or
substitution for pollutants of concern. Analyze options for treating dissolved
pollutants in stormwater runoff that are not removed using current technologies
(conventional BMPs, LID, etc.) and/or are derived from atmospheric deposition.
Explore national options for source substitution with industry leaders (e.g.,
automakers and parts suppliers). Longer term, but fully scoped by September
2008.
7. Effects on biota. a) Using the existing literature, develop a clear, concise case
statement of the effects of stormwater on biota that can be easily read and
understood by citizens, politicians, business community and others in the Puget
Sound area. Short term, completed by March 2008. b) Conduct analyses to
improve our understanding of the specific stressors within stormwater (flow and
contaminants) and the specific effects (lethal and sub-lethal) on biota. Longer
term, but fully scoped by September 2008.
The costs to complete these seven analyses will be estimated during the next month by
the authors.
Stormwater Runoff and Puget Sound – Problems, Issues and Analyses Needed
Submitted to the Puget Sound Partnership
June 27, 2007
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Attachments
Summary Meeting Notes from June 7, 2007 Stormwater Workshop
Stormwater Workshop Participants and Authors and Affiliations
Stormwater Runoff and Puget Sound – Problems, Issues and Analyses Needed
Submitted to the Puget Sound Partnership
June 27, 2007
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