Draining to the Ocean:
Written by Ted Morton
The Effects of Stormwater Pollution on Coastal Waters
Introduction to Stormwater Issues
1997 marks the twenty-fifth anniversary of the federal Clean Water Act.
Since 1972, our nation has made significant investments in cleaning up coastal
waters, lakes, and streams. Past practices of dumping untreated industrial
wastes and raw sewage in coastal waters have subsided. Still, our nation's
coastal waters are troubled.
Many are closed for shellfish harvesting and swimming. Others are subject
to fish consumption advisories. Our nation still has much work to do before
it meets one of the goals of the Clean Water Act -- to make all waters safe
for swimming and fishing.
Over the past year, disturbing accounts of our nation's coastal water
quality have been featured in the headlines. For example, the outbreak of a
toxic microbe, Pfiesteria piscicida,in tributaries of the Chesapeake Bay
caused fish kills and human health problems. Red tides along the Texas
shore killed an estimated 14 million fish in September and October.
Sea turtles with tumors are being found off the coast of Florida.
Sewage spills closed a number of Long Island Sound area beaches this past
summer. The "dead zone," an area approximately the size of New Jersey where
dissolved oxygen levels are too low to sustain fish, continues to appear
off the coast of Louisiana and Texas each year.
Pollutants running off lands and urban streets are contributing factors in many of these
disturbing events and countless other water quality problems across the nation. To reverse
the trends of poor coastal water quality, many states, cities, industries and individuals must
redouble their efforts to manage and control pollution associated with storm events. During
rainfalls and snow melts, a host of contaminants, including bacteria, nitrogen, phosphorus,
heavy metals, chemicals, pesticides, sediments, and litter is washed from streets and
land, carried by storm sewers, and eventually discharged into nearby lakes, rivers,
streams, and coastal waters. Problems associated with stormwater are exacerbated by
urbanization and suburban sprawl, for replacing natural lands with pavement and roofs
causes greater concentrations of pollutants in larger volumes to enter and contaminate our
waters. Because coastal areas of the country are among the most rapidly growing areas,
stormwater pollution is a significant cause of water quality impairment in coastal waters
and will continue to be unless actions to control stormwater pollution are taken. At stake
are the vital ecological and economic resources linked to clean coastal waters.
This report begins with a presentation of the importance of coastal waters and their
living resources to our nation. It follows with an account of the adverse impacts of
stormwater pollution, current approaches to control stormwater pollution, and finally,
recommendations for more effective stormwater management programs.
Coastal waters are among the most productive natural systems on Earth. Freshwater
draining from rivers and streams carry land-based nutrients that help support the diverse
life of the coastal environment. River flows, tides, and winds constantly mix these nutrients.
In addition, the shallowness of many coastal waters lets sunlight reach submerged
seagrasses and promotes thriving plant and animal communities. The combination of
sunlight, tidal actions, and balanced nutrient loading allows for productivity that rivals
Midwestern farmland in its food yield.
Coastal waters are known by many different names - estuaries, bays, sounds,
lagoons, sloughs, bayous, and inlets. Each distinct Water body, whether it is the
Chesapeake Bay, Puget Sound, or Santa Monica Bay, provides considerable benefit to
nearby coastal communities and the entire nation. For millions of Americans, coastal
waters are integral parts of their hometowns and cities. For others, oceans and beaches
are preferred vacation sites because of the abundant recreational activities and beauty
provided by these areas. Coastal waters are vital habitat for shellfish and both marine and
anadromous (those that migrate up rivers from the sea to spawn) fish, that in turn, support
humans and wildlife. Other wildlife, including manatees, sea turtles, and migratory birds,
use coastal waters, wetlands, and beaches as primary habitat or essential resting and
The ecological productivity and broad appeal of coastal waters make
coastal areas some of the most desired "living places" in our nation.
Increasing economic and recreational opportunities, attractive scenery,
and the perception of a better quality of life are luring Americans to the
Coastal areas of the United States are densely populated.
The population density of coastal counties was 341 persons per square mile
in 1988 - four-times the national average. Today, more than
one-half of the United States population lives in a county which borders
the Pacific Ocean, Atlantic Ocean, Gulf of Mexico, or Great Lakes. Projections indicate that coastal areas will continue to grow in the
The United States' coastal population is expected
to exceed 127 million people by 2010 - an increase of almost 60 percent from 1960.
Furthermore, it is estimated that by the year 2010, more than 75 percent
of the United States' population will reside within 50 miles of the
Population growth and development significantly affect coastal Water
quality. Increasing population results in the generation of more waste and
The wastewater systems designed to collect and treat sewage. Sewage
treatment plants and individual septic systems must be rigorously
maintained in order to prevent malfunctions. Also, as natural landscapes
are destroyed and replaced by pavement and buildings, increased loads of
sediments and other contaminants end up in the water, rather than being
absorbed by soils and vegetation.
Coastal communities are
challenged by the necessity to balance their expanding population and
development with sustaining local economies and with providing
environmental protections. In the long term, ignoring environmental
problems will jeopardize many of the resources that attract residents to
coastal populations have grown, so too have the number of tourists who
vacation at ocean and bay beaches. Sunbathing, swimming, surfing, diving,
bird watching, pleasure boating, and fishing provide enjoyment for
millions of people.
United States beaches and coastal areas
rank as a favorite vacation destination for Americans, with the average
resident spending ten recreational days on the coast each year.
In 1993, more than 180 million Americans visited ocean and bay
During the summer months and peak weekends, many coastal
communities experience substantial surges of population. In the summer,
the area population around the Peconic Bays of New York exceeds 280,000
people an increase of 165,000 people (or 143 percent) from the year-round
resident population. By the year 2000, the area's summertime population is
anticipated to reach 365,000 people. Often, these beach resort
communities do not have the infrastructure, such as sewage treatment
capacity and trash collection to adequately address the additional
threats to water quality that these seasonal population surges bring.
The tourism industry is a significant contributor to coastal states
revenues and employment rolls. The state of Florida estimated the revenue
generated by coastal tourism to be $23 billion in 1995.
$8.6 billion for select counties of New Jersey (1996), $8.1 billion for the
state of South Carolina (1996) and $54.1 billion for select coastal counties of California
(1994). Coastal tourism is estimated to be responsible for over 320,000 jobs in
Boating and sport fishing are recreational activities that provide important benefits
to coastal communities.
In 1990, more than 5,000 marinas, available to service 9 million recreational boats in the United States,
were situated along the coastline., The
state of Maryland calculated that recreational boating expenditures eclipsed $1 billion in
1993 and were responsible for 18,000 full-time jobs in the state.
It is estimated that
the sport fishing industry supports a total of 924,000 full-time jobs nationwide. Over
205,000 of these jobs are generated by salt-water fishing. In 1991, recreational
fishing in Florida generated approximately $3.5 billion in economic output and employed
over 58,000 people.
Seagrasses, coral reefs, marshes, mangroves, and coastal wetlands provide
excellent spawning and nursery habitat for fish and shellfish. Juvenile fish and shellfish
also use the shallow, lush coastal habitats for shelter from larger predators. Later in
their life cycle, many fish species migrate to other waters where they are commercially
and recreationally caught.
75 percent of the fish caught in the United States use estuaries
during at least one stage of life - frequently the critical, early stages of life. In the
Southeastern United States, 96 percent of the commercial catch and over 50 percent of
the recreational catch are comprised of fish and shellfish that are dependent on
coastal wetlands. Furthermore, an estimated 75 percent of Florida's game fish
species and 90 percent of its commercial fish species depend on mangroves.
Many of the important recreational and commercial finish species which depend
on coastal waters for habitat include spotted seatrout, red drum, shad, salmon,
sturgeon, winter flounder, sand seatrout, weakfish, Atlantic croaker, and bluefish.
Oysters, blue crabs, hard clams, scallops, Dungeness crabs, and other molluscan
shellfish dwell in near-shore coastal waters. Many of these shellfish inhabit the bottoms
of coastal waters and sustain themselves by filtering massive volumes of water in
order to retain nutrients and phytoplankton. However, they also ingest pollutants that
accumulate in their tissue and can be passed onto consumers of shellfish.
In many coastal communities, shellfish harvesting was historically a mainstay of
the local economy. Despite the harvesting limitations due to shellfish bed closures,
habitat destruction and overfishing, commercial shellfishing is still a significant part of
coastal economies. In 1995, commercial fishermen harvested over 77 million pounds
(meat weight) of molluscan shellfish, with a dockside value of $200 million.
In some highly publicized cases, shellfish populations have significantly declined
or crashed. The oyster harvest in Chesapeake Bay dropped from 32 million pounds
to 4 million pounds between 1959 and 1989.
The most profitable fishery of Rhode
Island's Narragansett Bay is the quahog (hard clam), accounting for 84 percent of the
Bay's total fishing revenue. Yet the quahog catch in Rhode Island fell from 4.2
million pounds (in weight of meats), valued at $15 million in 1985, to 1.6 million
pounds, valued at $7.6 million in 1994.
Habitat for Other Wildlife
Coastal waters, wetlands, dunes, beaches, and other coastal habitats provide
important dwelling places for birds, marine life, and terrestrial wildlife. Many of these
habitats are threatened by development pressures.
Colonial waterbirds, shorebirds, songbirds, waterfowl, and raptors use coastal
waters and wetlands as breeding grounds, nesting areas, and foraging habitat. For
migratory birds, coastal habitats provide essential feeding and resting points along
"flyways," or migratory routes. It is estimated that nearly 50 percent of the nation's
migratory songbirds use coastal habitats for a variety of purposes
More specifically, -
Gulf of Mexico coastal wetlands provide essential habitat for 75 percent of
United States' migratory waterfowl.
Finally, more than 70 percent of the migratory
shorebirds using the "Pacific Flyway" rest or winter in the San Francisco Bay area.
Coastal habitats are especially vital to threatened and endangered species. Coastal
areas provide habitat for more endangered and threatened species than inland areas. The
average number of protected species for counties in the continental United States is three
to four; however, close to one-half of the nation's coastal counties sustain ten to twenty
Approximately 75 percent of the nation's endangered and threatened
mammal and bird species rely on coastal habitats
Water moves through nature in cycles. Heat from sunlight causes the surface waters
of oceans and lakes to evaporate and form clouds. Water also moves through vegetation
and transpires to the atmosphere. Water returns to Earth as rain or snow. This
precipitation may be naturally absorbed by soil and eventually infiltrate to groundwater, or,
rainfall may run off the land and streets, and pick up oils, grease, and road salts from
highways and parking lots; pesticides from lawns and parks; excess nutrients; sediments;
disease-causing organisms found in pet and animal waste; litter; and toxic metals. This
stormwater drains into storm sewer conveyances and occasionally is collected and
diverted to treatment works. More often, the conveyances discharge the stormwater, at
discrete points commonly called outfalls, directly into streams, rivers, coastal waters, and
Urbanization and increasing population growth exacerbate stormwater pollution
problems in two critical ways. First, increasing populations generate more contaminants.
Second, to accommodate expanding populations, communities radically alter land uses by
replacing wetlands, forests, and other natural areas with impervious surfaces, such as
roads and buildings. Because these impenetrable surfaces do not allow rainwater to be
absorbed through soils, the runoff flows in greater velocities and volumes. This
combination of greater velocity and volume can increase the frequency and intensity of
flooding, cause stream banks and beds to erode, alter the depth and width of urban
streams, increase downstream sedimentation, and destroy habitats.
Not only does greater imperviousness reduce rainfall absorption through soils, but it
also prevents contaminants from being trapped and neutralized in the soil. So, as the rate
of imperviousness in an area increases, greater concentrations of contaminants, in
greater flows will enter storm sewers, rivers, streams, and coastal waters.
Contaminants in stormwater degrade the water quality of our nation's coastal waters.
Since many coastal waters are semi-enclosed and poorly flushed by tides cause severe discomfort and can result in substantial economic losses to society from
lost days of work. In addition, the health risks of these diseases are more significant
for sensitive segments of our population, such as children, the elderly, expectant
mothers, and persons with compromised immune systems.
1995, Santa Monica Bay Restoration Project and University of Southern California
researchers conducted an epidemiological study to examine the health effects of
swimming near storm drain outfalls in Santa Monica Bay. Researchers sampled beach
waters at sites zero, 100, and 400 yards from storm drain outlets. The samples were
analyzed for the presence of pathogen indicators. Over 13,000 persons were
telephoned within two weeks of swimming in these monitored beach waters. The
swimmers were asked questions to ascertain whether they exhibited symptoms
associated with swimming in pathogencontaminated waters. The study concluded
there is an increased risk of illness associated with swimming near flowing storm
drain outfalls in Santa Monica Bay. A comparison of the individuals swimming at the
outfall location with those swimming 400 yards away found substantial increases in
experiencing fever, chills, ear discharge, vomiting, coughing with
phlegm, respiratory diseases, and
gastrointestinal illnesses among
those swimming directly in front of the outfalls.
Toxins are another potential
human health problem linked to stormwater pollution. Many toxic contaminants, such
as heavy metals and organic chemicals, do not degrade once they enter coastal
waters, but instead persist in the sediments along the waters bottom. Eventually,
aquatic life that inhabit the bottoms of coastal waters, are exposed to the toxics. Over
time, these toxics "bio-accumulate" in the fatty tissues of shellfish and fish. Humans
who eat fish and shellfish contaminated by toxics may experience increased
incidences of cancer, neurological disorders, and birth defects. For those individuals
that eat larger quantities of fish and shellfish, such as subsistence fishers, these risks
are considerably magnified.
A young mother unknowingly tows her son in water coming from a storm drain outfall. No
signs were posted warning her of potential health risks.
After a heavy rainfall, pathogens enter beach waters from storm drain outfalls.
Pathogens can also be found in "dry-weather flows" of storm drains, due to lawn sprinklers
and other activities. Pathogens contaminate recreational waters and can lead to human
illnesses. For this reason, several local and state public health agencies have developed
beach water testing protocols in order to protect individuals who recreate in beach waters.
A few states consistently close beaches or issue health advisories after tests indicate
health-based standards for pathogens have been exceeded. However, beach water quality
monitoring programs vary greatly from beach to beach; in fact, there is significant variance
within many states. At least six coastal states do not regularly monitor their beach waters
for swimmer safety.
For each of the past seven years, the Natural Resources Defense Council (NRDC)
has surveyed public health agencies and compiled the most comprehensive list of
closures and health advisories at ocean, bay, and Great Lakes beaches. Since 1988, over
18,590 beach closures and health advisories have been issued to safeguard swimmer
health. During 1996, beaches were closed or subject to public health advisories on more
than 2,596 individual occasions. Several of these lasted for more than one day. By adding
the extended and individual closures, the number of beach closures and health advisories
issued in 1996 increases to 3,685 days.
The figures underestimate the extent of
pathogen-contaminated beach waters since many states do not regularly monitor
recreational waters, and therefore untested, unsafe beaches remain open.
For its 1997 report, NRDC identified the pollution sources causing the closures and
advisories to be issued. Stormwater was a significant source of the beach water pollution,
responsible for 407 of the closures and advisories.
Because of the association between
heavy rainfalls and pathogen contamination at recreational beaches, a growing number of
communities are taking precautionary measures. These communities automatically issue
warnings against swimming once a certain threshold of rainfall per 24-hour period is
exceeded. The thresholds have been determined using results of baseline monitoring
Shellfish Bed Closures
Pathogen contamination is also a principal reason for restrictions placed on shellfish
harvesting in many of our nation's coastal waters. Approximately one-third of the nation's
shellfish harvesting areas are closed or harvest-limited based on water quality concerns, such as pathogen or toxic contamination.
In a 1995 survey of shellfish harvesting areas, polluted urban stormwater was
identified as the leading source of pollution contributing to harvest limitations. Health
officials advised against eating some non-commercially caught fish and wildlife because of
their increased sensitivity to potential adverse health effects.
A study of pregnant women who ate PCB-contaminated fish from Lake Michigan
documented increased incidences of children born with smaller heads, lower birth
weights, and slower reflexes. In addition, researchers are linking dioxin and other
chemicals with human reproductive problems, such as lower sperm counts and
smaller sexual organs. Increased cancer risks are also associated with consumption
of toxic-contaminated fish.
The number of water bodies that are under some fish or wildlife consumption
advisory has steadily increased in the past few years. In 1996, states issued 2,193 fish
and wildlife consumption advisories - a 26 percent increase from 1995.
Silt and sediment carried by stormwater destroy coastal habitats. Seagrasses are
smothered by heavy loads of sediments. Sedimentation can also cause cloudy, or
turbid waters. Turbid conditions make it difficult for sunlight to penetrate to the
submerged vegetation of bay bottoms. Robbing the aquatic vegetation of sunlight
inhibits the growth of plant life which is essential to fish and shellfish.
Heavy volumes of stormwater can also damage stream banks and beds. Increased
flows of urban streams after rainfalls or snow melts typically accelerate the rate of
erosion of stream banks and create large sand bars downstream.
Because of the increasing public awareness about the adverse impacts of stormwater
pollution, plans to better manage and control this pollution are underway in many
communities and at various levels of government. Public education efforts on a range of
stormwater pollution issues - from storm drain stenciling to restricted beach access after
heavy rains - are helping to build support for difficult stormwater management decisions.
Local ordinances concerning unauthorized discharges into storm drains, sediment and
erosion controls at construction sites, and municipal vehicle operations are becoming
more commonplace. In addition, stormwater management activities are typically included
in comprehensive watershed management plans for urban streams and coastal waters.
Several states are developing or revising statewide stormwater management programs.
Stormwater pollution controls are also addressed by the federal Clean Water Act and the
Coastal Zone Act Reauthorizing Amendments of 1990.
Stormwater Permitting Program of the Clean Water Act
Since the passage of the Clean Water Act in 1972, considerable attention has been
placed and progress made in controlling water pollution from sewage treatment plants
and industrial operations. Contaminants discharged from these facilities enter waters
from distinct and identifiable points (i.e. pipes, outfalls), and thus are classified as "point
sources" of pollution under the Clean Water Act. "nonpoint sources" of pollution enter
waters from dispersed locations, rather than pipes or outfalls. Much of the pollution
associated with logging areas, agricultural lands, and marinas is considered to be
Under the Clean Water Act, the U.S. Environmental Protection Agency (U.S. EPA)
requires most facilities discharging wastewater through point sources to apply for permits.
As early as 1973, the U.S. EPA identified stormwater discharges as point sources for
purposes of their coverage under the Clean Water Act, but exempted many of these
discharges from permit requirements because of insufficient agency resources,
challenges in setting and measuring the contaminants, and the potentially large number
of stormwater dischargers requiring permits.
Between 1972 and 1987, several federal regulations covering stormwater discharges
were proposed. These proposed regulations were routinely challenged by industries,
environmental organizations, and municipalities for a variety of reasons, ranging from
being too burdensome to being inadequate. In addition, changes in presidential
administrations and policies within the U.S. EPA often delayed progress on issuing and
implementing stormwater regulations. At the time Congress reauthoized
boating, hydromodification, and urban land
uses - were identified in the EPA guidance. A
few of the management measures identified for urban areas address stormwater
discharges. These include measures for new development; watershed protection; site
development; construction activities; existing development; pollution prevention; and
roads, highways, and bridges.
In addition to the municipalities, EPA identified eleven categories of industrial facilities
that need to apply for stormwater discharge permits. A few examples of these industrial
facilities include mining operations; oil and gas operations; hazardous waste treatment,
storage, and disposal facilities; land fills receiving industrial waste; vehicle maintenance
operations; and certain construction sites.
These industrial facilities are required to
identify pollution sources, develop pollution prevention plans, and adopt "best
management practices" for controlling, reducing, and preventing pollutants associated with
The 1987 amendments also require U.S. EPA to study and identify potential
sources to be covered under the second phase of the stormwater permitting program
and to examine the extent of pollutants in such discharges. Regulations were to be
issued and a comprehensive stormwater management program for "phase two"
sources was to be established. By October, 1993 EPA did not meet these deadlines.
The final rule to controlling stormwater discharges from these additional sources is
scheduled to be issued by March, 1999 - more than five years past due.
Coastal Polluted Runoff Control Programs
Since the 1970s, coastal states have been working with the U.S. EPA and the National
Oceanic and Atmospheric Administration (NOAA) to protect coastal resources. The federal
Coastal Zone Management Act (CZMA), enacted in 1972, provides financial incentives for
states to voluntarily produce comprehensive coastal programs to ~address land uses,
water uses, and development in the state's coastal zones.
In 1990, Congress passed a critically important amendment to the federal Coastal
Zone Management Act, commonly called section 6217 of the Coastal Zone Act
Reauthorization Amendments (CZARA). A central objective of the amendment was to
improve coordination among state coastal zone management agencies, state water
quality agencies, and federal agencies so that land uses impairing coastal water quality
could be better managed. The amendment required states with approved coastal zone
management plans to develop coastal polluted runoff control programs.
As part of the states coastal polluted runoff control programs, states are required to
identify land uses which individually, or cumulatively may cause or contribute to coastal
waters not meeting water quality standards. Also, states are to identify coastal waters that
are threatened by foreseeable increases of pollutant loading. Finally, states are to include
"management measures," or protective actions, for a variety of land uses in their
programs. Such measures should be designed and implemented with a goal of
controlling and preventing polluted runoff.
In 1993, the U.S. EPA issued guidance to the states on management measures for
nonpoint pollution sources in coastal waters. Management measures for five categories of
nonpoint pollution sources - agriculture, forestry, marinas/recreational.....
Bay focuses on a strategy to reduce both nitrogen loading and toxic contamination of
sediments by preventing and treating stormwater discharges. Key elements of the
stormwater management action plan include: (1) expanding a public awareness campaign
for homeowners and businesses about landscape design and maintenance practices; (2)
assisting business owners in developing pollution prevention plans for their operational
sites; (3) promoting the use of integrated pest management programs by local
governments; (4) minimizing impervious surface coverage by developing targets for
pervious-to-impervious surface coverage for new development and parking lots; (5)
requiring older developed sites to meet current stormwater treatment standards as they
are redeveloped; (6) working with planners to study projected growth patterns with the
objective of looking for ways to promote compact development; and (7) improving
compliance with stormwater permits.
Recommendations for effective stormwater management programs
As coastal populations continue to grow and development mounts, local governmental
officials, planners, business leaders, environmentalists, and other community members
will need to examine strategies for effectively preventing and controlling pollution
associated with stormwater discharges. In the interest of promoting sustainable
development and protecting aquatic resources, a number of recommendations for
developing stormwater programs are being promoted by environmental and citizen
activists. These ideas include among others: public participation, compliance and
enforceability, construction activities, and flow issues.
1. Public Participation and Education
Members of the general public have several important reasons to see that
municipalities develop effective stormwater management programs. First, through their
actions, residents are contributors to the pollution entering storm sewers, and often impact
water bodies farther downstream. Second, as taxpayers, they finance the infrastructure
needs and enforcement authorities. Finally, the public uses nearby waters and resources
for fishing, boating, and other recreational activities. These pursuits can be adversely
affected by stormwater pollution.
The public has a strong stake in the quality of their waters and therefore, should have
access to and be involved with the processes related to developing and administering
stormwater pollution plans. From an early point in the development of municipal
stormwater plans, local officials should explore ways to actively engage members of the general public. One prominent way for municipal officials to involve the
public is to recruit citizens to participate in a community advisory committee that has a
meaningful role in plan development. To be inclusive, municipal officials should invite
individuals from all sectors of the community, especially representatives of lower-
income groups that may have frequently been omitted from key advisory roles in past,
community-wide environmental decisions, to participate in the process. Such
community advisory committees can provide guidance to the key decisionmakers in
determining the major sources of stormwater pollution to target, developing effective
pollution control measures, creating and distributing understandable educational
materials, and increasing public support for the additional investments needed to
properly manage stormwater pollution. By meaningfully involving the public during the
early stages of a program, municipal officials will more likely build a unified, broad-
based constituency to support difficult decisions related to regulation, enforcement,
and funding. In addition, citizens that are able to participate at the outset will have a
better understanding of the varied concerns of municipal and business leaders. This
deeper awareness could help craft objectives and priority actions that receive greater
During the development and implementation of local stormwater programs,
members of the public should be consulted about how to develop and distribute
educational materials effectively and efficiently. Using technical assistance from U.S.
EPA and other networks, municipal officials should craft informational materials for
special sectors of the community, such as industries that are more likely to be
responsible for stormwater pollution problems and school children. Municipal officials
should also consider providing stormwater information and programmatic
updates to local citizens groups and encourage them to include these reports in
membership newsletters and materials. In addition, specific businesses could provide
information to their customers and staff about certain actions for preventing
stormwater pollution. For example, nursery owners could display information about
lawn care and landscaping practices to prevent or reduce pollution running off
residential lawns. Likewise, automobile service stations could display information
about proper disposal of used motor oil and automotive fluids.
It is equally important that members of the general public have the opportunity to
participate in the actual administration of local stormwater programs. The public
should have access to important information related to stormwater pollution, such as
industrial facilities' "notices of intent," sediment and erosion control plans at
construction sites, and municipal stormwater pollution management plans. Through
this information, citizens would gain a greater ability to protect aquatic resources that
are important to their community.
In sum, a way to better ensure more successful stormwater management
programs is to include representatives of many sectors of the community in the
development and implementation of the program, and also in efforts to educate the
public-at-large. Allowing community members to be a part of key decisions helps to
generate a stronger public commitment and a greater assumption of personal
responsibility for cleaning up waters.
2. Roads and Highways
Highway construction activities, ongoing road operations and maintenance, and
vehicle use can contribute to significant stormwater pollution problems. Highway
construction activities destroy natural vegetation, alter landscapes, and can cause
sedimentation problems. Road de-icing materials add chloride, sulfates, and cyanide to
water bodies. Automobile emissions and leaks are potentially significant sources of
heavy metals that contaminate rivers, streams, and coastal waters. A study conducted
for the Santa Clara Valley Nonpoint Source Control Program revealed that automobile
brake pad wear is responsible for up to 50 percent of the copper loads entering lower San Francisco Bay Other associated with vehicle exhaust, tire wear, and
parts wear are lead, zinc, cadmium, nickel, chromium, bromide, oil, and grease, among
However, too often, stormwater management plans overlook or only slightly
consider these large sources of toxic contaminants. States and localities should
require state Departments of Transportation to be covered by stormwater permits and
pollution management plans. This coverage would compel highway departments to
develop and use best management practices as they design, build, maintain, resurface,
and widen roads and highways. Many best management practices for reducing
stormwater pollution from road and highways are being applied and tested. A few examples of these management practices include median strip
detention ponds, roadside grassed swales, vegetated ditches, sediment control
procedures during construction, and alternatives to applying road salts for de-icing
3. Construction Activities
Construction activities loosen large amounts of sediments and contaminants that
can eventually be washed into coastal waters. Because coastal communities are
rapidly growing, controlling erosion and sediment loss on construction sites is an
important step toward protecting coastal water quality and aquatic resources.
Under the first phase of the federal stormwater permitting program, construction
sites that disturb more than five acres of land are required to apply for a general
permit. However, smaller construction projects can impair water quality and habitat,
and can individually and cumulatively, cause significant degradation. For this reason, it
is imperative that contractors and developers take adequate steps to prevent erosion
and control sediment loss on their construction sites. Construction activities disturbing
one-half acre and greater should be covered by a general permit and be subject to a
stormwater pollution prevention plan. In their pollution prevention plans, developers
should be allowed to determine, using a menu of best management practices, how they
will control erosion and sediment loss during construction. These plans need to be
reviewed by water quality agencies and should always be measured against clear and
objective performance standards.
Although information about permitted construction activities is to be publicly
available, it is often difficult to access such information from the construction site
operator and/or the water quality agencies. Concerned citizens are routinely frustrated
when they seek basic information about specific construction activities, on-site
measures to prevent erosion and sediment loss, and potential impacts to local water
quality resulting from construction site stormwater discharges. Stormwater pollution
prevention plans filed with a general permit for construction activities should be made
available, within a reasonable period of time, to individuals who seek such information.
Access to this information is consistent with Clean Water Act requirements to make
permit-related documents available to the public. On-site inspection reports which are
filed should also be made available to the public.
Too often, land clearing activities commence before water quality agencies and
interested members of the public have the opportunity to study a particular construction
project. Currently, the permit applicant for construction activities must file a
notice of intent "NOI" at least two days before clearing activities begin. Allowing 30
to 60 days for a more thorough review of a proposed stormwater pollution prevention
plan should result in stronger protections for water quality and habitat. Three
advantages of extending the review period are (1) better assessments of proposed
projects; (2) greater protection of water quality projects without adequate safe
guards are temporarily delayed to establish stronger control measures; and (3) potential
opportunities to increase cooperation between concerned citizens and developers.
4. Agriculture and Forestry
Pollution associated with stormwater is not solely an urban land use problem. Timber
harvesting and agricultural practices also contribute sediments, nutrients, and fertilizers
after storm events and snow melts, and often impair rivers, lakes, and coastal waters.
Municipal officials object, with justification, to being held responsible for impaired water
quality due to stormwater contaminants that enter their sewer systems or water bodies
from upstream sources outside of their jurisdiction.
A comprehensive approach to protecting water quality should examine the individual
and cumulative impacts of all sources of stormwater pollution in a particular watershed
and undertake actions for recovery. To improve effectiveness, such watershed planning
needs to require measures for achieving greater reductions of runoff if timber or
agricultural activities are having an impact on downstream water quality. One advantage ge of
a comprehensive approach is its greater equity. Municipalities and industries would
benefit from activities undertaken upstream that prevent water pollution, since they would
be relieved of pollution loading introduced upstream.
To achieve a more equitable approach, there needs to be more accountability and
enforceability for "non-point" sources, such as agriculture and forestry. Currently, polluted
runoff from these sources are being addressed with an overemphasis on voluntary
practices. Coastal states are developing enforceable polluted runoff control programs for
their coastal zones, however, their record of gaining programmatic approval and actually
implementing the programs is sub-par. Adopting, implementing, and enforcing the
management measures for non-point sources identified in state coastal polluted runoff
control programs would advance water quality in coastal states and create more balance
between point and nonpoint source approaches to prevent water pollution. Coastal states
should expand the measures of the coastal nonpoint pollution program into their non-
coastal areas. For noncoastal states, an enforceable system to prevent polluted runoff
associated with agriculture, forestry, and other sources should be established.
5. Issues of Stormwater Flow
Increased flows of stormwater drainage can severely damage aquatic habitats in
urban, suburban, and rural areas. A few of the most notable, adverse habitat effects
include flooding outside the stream bank, stream channel widening, increased stream
bank erosion, changes in stream pool and riffle structures, streambed alterations, and
larger sandbars. These alterations create conditions that can diminish the number and
diversity of fish species, especially sensitive cold water species such as trout and salmon.
Increased stormwater flows can also lead to increased loading of sediments along the
bottoms of bays and rivers farther downstream. Aquatic vegetation necessary for estuarine
and marine fish and shellfish can be smothered by the increased sedimentation.
As states and local officials prepare comprehensive stormwater management plans,
the impact that stormwater flow has on waterways and habitats deserves to be
considered. Because of the interface between stormwater flow and impervious surfaces,
communities should examine ways to make land use decisions that will minimize
impervious surfaces. Community leaders should consider designating future growth
areas in portions of the watershed that will have minimal impacts on local water quality
and limiting development activities in areas that are more sensitive to impacts of greater
imperviousness. In addition, community planners should concentrate more projects in
areas where roads and development centers already exist, such as blighted, older areas
or underused, newly-developed sectors. Finally, community planners should be
encouraged to design more compact development projects, such as cluster homes, to
minimize individual lot size and provide a large area of open space that absorbs excess
stormwater runoff from the developed area and enhances recreational opportunities for
Local management plans. should also feature techniques that minimize the amount
and velocity of stormwater emptying into nearby streams and coastal waters.
Using stream side buffers has been documented as an effective practice in reducing
stormwater flow and protecting downstream habitat from increased stormwater flows.
Buffers also provide important water quality benefits by removing sediments, nutrients, and
pathogens. Forested buffer strips along a stream can also enhance water quality by
providing shade to help maintain water temperatures. Finally, stream buffers provide
habitat for wildlife and many communities use them as recreational "green ways." Other
best management practices to minimize stormwater flows include retention basins and
6. Compliance and Enforceability
In recent years, there has been much heated debate about using enforceable
mechanisms to better control stormwater and polluted runoff sources. During the 104th
Congress, a bill to reauthorize the Clean Water Act (H.R. 961) proposed changing the
approach of permitting stormwater discharges to relying on voluntary measures spread
that could have been delayed for fifteen to nineteen years.
Voluntary measures to prevent and manage stormwater discharges are important
components to a successful stormwater program; however, depending solely on voluntary
efforts will not provide the results which are needed to protect water quality and aquatic
resources. The national nonpoint source pollution program (section 319 of the Clean
Water Act) relies on voluntary measures and "demonstration projects" to address the
pollution running off of agricultural lands, forests, mining sites, grazing pastures, and other
areas. While there are several individual success stories identified with the 319 program,
there is no demonstrable evidence to support the notion that a purely voluntary approach to
reduce water pollution provides adequate protection for our nation's waters and resources,
nor will achieve the goals of the Clean Water Act.
For a pollution source as widespread and damaging as stormwater pollution, our
national policies on water pollution should tie requirements for reducing stormwater
discharges with enforceable mechanisms. It is important for major sources of
contaminants entering storm sewer systems to be held accountable for the pollution they
generate. The penalties and consequences of violating stormwater rules and permit
requirements should be clearly conveyed, strong enough to promote improved compliance
records, and consistently applied to violators.
To ensure maximum, long-term success in reducing pollution associated with
stormwater and to build public support for stormwater programs, a common-sense
approach to enforcement activities should be considered. Public education efforts centered
around stormwater pollution problems and management practices for improving water
quality and complying with new stormwater management requirements should be part of
comprehensive stormwater management programs. If stormwater pollution problems
persist after the initial rounds of inspections, more concerted efforts to notify and educate
significant pollution dischargers should be undertaken. If violations continue to occur, water quality agencies should be prepared
to take every action to fully enforce water pollution laws. And, water quality agencies
must initiate enforcement actions against significant and habitual violators of
stormwater pollution laws.
In addition, a comprehensive stormwater plan should include objective measures
to determine the program's success. Municipal stormwater management plans and
discharge permits should include some measurable goals, such as specific best
management practice requirements and compliance records tied to water quality
standards, that a discharger strives to obtain. Such goals would provide community
leaders a better understanding of successful pollution-reducing activities and actions
that need further refinement. These goals would also help members of the community
better assess how their individual actions are improving or hurting the municipality's
efforts to achieve stormwater pollution reduction.
Finally, the U.S. Environmental Protection Agency and states need to improve upon
and expand their enforcement and compliance efforts related to stormwater pollution.
Citizen activists in many cities currently regulated under the first phase of the
stormwater permitting program are discouraged by the shortcomings in enforcement
activities, particularly among industrial permittees. Because of possible government
inaction, the rights of concerned citizens to step in and take direct legal actions to
protect the waters they care about from uncontrolled stormwater discharges must be
The many contaminants found in stormwater are having a significant, adverse
impact on water quality in coastal areas across the nation. Many important ecological
and economic resources, including beaches, shellfish areas, fisheries, and wildlife are
at risk from these contaminants. The ocean is the ultimate collector of all the
pollutants that run off lands and urban streets. What we once thought of as a vast
expanse capable of assimilating our wastes is showing extraordinary signs of stress,
most evidently along the coastlines.
In order to protect our shorelines, bays, oceans, and their resources, many coastal
communities must adopt measures to prevent and reduce stormwater pollution.
However, only when each one of us - citizens, business owners, elected officials,
farmers, and developers - commits to taking actions to reduce stormwater pollution
will the health of our own communities, downstream towns and cities, local streams,
and oceans be restored.
Several colleagues made valuable contributions to the
completion of this report. The author thanks Peter Lehner,
Barbara Jeanne Polo, Lauren Yannotta, and Richard
Salcedo for their insightful review of early drafts and
creative assistance in designing this report. In addition,
the author wishes to thank Diane Cameron, Roy
Hengerson, Babafemi Adesanya, Michael Houck, Jessica
Landman, Tim Eichenberg, and Kathy Nernsick for their
assistance in preparing this report.
American Oceans Campaign gratefully acknowledges the
generous financial support of The Pew Charitable Trusts
and the Clean Water Network for the printing and
distribution of this report.
American Oceans Campaign founded in 1987, is a national non-profit organization dedicated to the protection of
marine ecosystems. To obtain more information on-line about AOC and its work, visit our website at:
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