Regional Stormwater Quality Management Plan: A Comprehensive Approach
| Infiltration "tree boxes" being pilot-tested as part of a roadway and streetscape improvement project in the City of Reno. (image courtesy of Sue Donaldson)
Nevada has experienced a tremendous growth in population over the past decade and is presently the fastest growing state in the country. Washoe County currently has a population of just under 400,000 people, an increase of roughly 20 percent since 2000 (Nevada State Demographer, 2006). The majority of this population resides in an area called Truckee Meadows, which includes the cities of Reno and Sparks and unincorporated areas of the County immediately adjacent. The climate is arid, with low humidity and an average annual rainfall of approximately seven inches. The Truckee River bisects Truckee Meadows into north and south sections and provides the major source of drinking water supply to the area, as well as recreational opportunities and habitat for fish and wildlife.
The Cities of Reno and Sparks, Washoe County, and the Nevada Department of Transportation (NDOT) operate and maintain the municipal storm drainage system, which includes conventional catch basin and storm drain pipes, open ditches, and wet pond structures and dry pond detention basins that are used primarily for flood control. Most of the stormwater that drains into the Truckee Meadows municipal storm drain system is conveyed untreated to the receiving waters of the Truckee River, and to three playas in unincorporated Washoe County.
Total Maximum Daily Load (TMDL) requirements have been established for the Truckee River, addressing three pollutants: nitrogen, phosphorus, and total dissolved solids. Nitrogen and phosphorus concentrations in the river have historically caused excessive plant and algal growth, which depletes oxygen when the plants die and decay. Oxygen depletion can result in the destruction of fish, wildlife, and habitats. The Nevada Division of Environmental Protection (NDEP), the cognizant regulatory authority, does not set specific requirements for TMDL implementation, but does expect that the cities and county will undertake programs that will improve water quality in the Truckee River and support the goals of the TMDL program.
The "Early Years"—Formation of the Truckee Meadows Interlocal Stormwater Committee
The first Phase I National Pollutant Discharge Elimination System permit (NPDES) was issued jointly to the City of Reno, the City of Sparks, Washoe County, and NDOT in 1990. With the City of Reno as the lead agency, the permittees entered into an interlocal agreement and formed the Truckee Meadows Interlocal Stormwater Committee (TMISC), to better define responsibilities and address permit requirements in a coordinated effort. Responsibilities of the committee include the following:
- Complying with the NPDES permit conditions
- Coordinating and participating in committee meetings
- Funding and implementing NPDES permit compliance efforts
- Coordinating and implementing annual operating budgets for jointly shared tasks
- Submitting reports prepared by various parties to NDEP and the USEPA as required by the NPDES permit
- Maintaining knowledge of current and proposed state and federal policies, regulations and programs that impact "nonpoint" source pollution programs
The permit required preparation of a drainage basin map with outfalls to the Truckee River identified, an inventory of existing Best Management Practices (BMPs), an inventory of potential sources of commercial and industrial pollution, a work plan for a stormwater monitoring program, and submittal of monitoring program reports at 24, 36, and 48 months after the effective date of the permit. Stormwater monitoring took place between October 1990 and February 1992 with samples collected from all major storm drain outfalls located along the Truckee River within the
Truckee Meadows and monitoring reports submitted at the specified intervals.
The Impetus for Change—Creation of the Regional Stormwater Management Quality Program
This initial permit (and most of the compliance activities) lapsed in 1995. The permit was finally reissued by NDEP in 2000. It required the permittees to establish a Regional Stormwater Quality Management Program and to implement methods for controlling pollutants "to the maximum extent practicable." "Maximum extent practicable" is a regulatory standard, developed by the U.S. Environmental Protection Agency, that has been interpreted to give local governments some flexibility in developing stormwater management programs that respond to their unique circumstances and local conditions.
The Stormwater Quality Management Program was further required to include the following components:
- Best Management Practices—BMPs for local government operations, including standard plans and specifications, storm drain maintenance, street sweeping, litter control, spill response and hazardous material disposal.
- Stormwater Discharge Monitoring—Development and implementation of a monitoring program to assess the quality of stormwater discharges, the effectiveness of BMPs, and impacts on receiving waters.
- Illegal Discharge Detection and Elimination—Development and implementation of a program to detect and eliminate illegal discharges.
- Structural BMP Controls for Water Quality Improvements—Consideration of structural controls in site drainage plans, storm drain projects, and flood control projects.
- Discharges to Storm Drains and Watercourses—A plan and schedule for developing and implementing a local program for the regulation of stormwater discharges from industrial facilities and construction sites.
- Public Education and Participation—Outreach to the public to provide information on stormwater pollution and its management and to ensure public participation in program development and implementation.
- Intergovernmental Coordination—Inclusion of appropriate government agencies in implementation of the program.
The first monitoring report was to include a plan and implementation schedule for regulating stormwater discharges from construction and industrial sites, which, given the rapid pace of development in the County, posed particular concerns.
To address coordination, the TMISC was reconstituted as the Stormwater Permit Coordinating Committee (SWPCC), consisting of two representatives each from the City of Reno, the City of Sparks, and Washoe County. The City of Reno contributes legal counsel services, clerical support, and a Stormwater Coordinator. The Committee's activities, including development of plans and guidance documents, compliance monitoring, and outreach, are funded primarily through three sources: the City of Reno's Sanitary Sewer Fund, the City of Sparks' Sanitary Sewer Fund and Stormwater Utility, and Washoe County and NDOT's General Fund accounts.
The state's Regional Water Planning Commission (RWPC) also contributed financial resources to the development of the Stormwater Quality Management Program. This entity was created in 1995 by state legislation, to serve as a forum for the planning and coordination of water use, flood control, and wastewater management. Revenue is derived through a surcharge of 1.5 percent applied to each customer's water bill.
To develop the Program, the Committee hired a consulting team, led by Kennedy/Jenks Consultants. Fourteen public workshops were conducted between May 2000 and September 2001 to research, discuss, and develop required elements of the program. The NDEP also participated in the program development process. The resulting document included a detailed description of plans and implementation action steps for each element, anticipated staff requirements, quantifiable goals to track progress, and a detailed implementation schedule through 2007. By December 2001, the document had been approved by each of the participating permittees.
Implementation Success—From "Zero to 60" in Response to an EPA Mandate
|Vegetated swale at Costco parking lot (image courtesy of Sue Donaldson)
In January 2002, the Committee hit a "bump in the road" that, in retrospect, significantly accelerated permittees' implementation of a very well-organized, multi-faceted approach to water quality management.
EPA conducted an audit of the Program, interviewing staff from Community Development, Municipal Operations, Environmental Control, and other departments to assess compliance with requirements of the Phase I permit. EPA representatives expected to find a fully implemented program - not just a Program plan - and was particularly concerned that inspection programs for construction and industrial sites had not yet been implemented. Further, the implementation schedule for the Program indicated that full implementation would not be achieved until 2004 or 2005—two to three years away.
In August 2002, permittees were directed to accelerate the schedule for Program implementation with specific emphasis placed on implementing inspection programs for construction and industrial sites by July 2003. Initially, this seemed like a nearly impossible challenge, given that the Committee relied on each co-permit-holder's Public Works staff as in-kind resources. Committee staff, however, took it as a challenge, and took the issue to the Reno and Sparks City Councils, the Washoe County Board of Commissioners, and the Regional Water Planning Commission (RWPC), explaining the situation in a series of presentations. The RWPC agreed to contribute just over $175,000 for the development of two manuals: one addressing construction site BMPs, the other addressing structural BMP controls, which would provide a foundation for the next phases of program implementation.
To maximize visibility and buy-in, the construction BMP handbook development process included extensive participation from the developer/builder/contractor community, including the local Builders' Association, Associated General Contractors, and professional organizations representing the engineering and design communities (for example, the American Society of Civil Engineers).
As a next step, checklists were developed that identified requirements for obtaining a construction permit and for implementing on-site BMPs for the duration of construction. Administrative charges for construction permits were revised, so that longer-duration projects, projects with extreme risks of erosion (due to steep slopes), and projects in closer proximity to a floodplain, paid more to compensate for their (potentially) greater impact. An inspection program was developed that relied on cross-training Washoe County and City of Reno Public Works inspectors, City of Sparks Community development inspectors, and Nevada Department of Transportation inspectors. Regulatory staff at NDEP also conduct inspections at construction sites.
Structural BMP Controls
The implementation of structural BMPs in areas of new development and significant redevelopment was also fast-tracked. Development of a structural BMP manual was initiated in April 2003, with a public workshop held in May. The manual was completed on schedule in Fall 2003, and approved for implementation beginning in January 2004. It provides written guidance and training to local government staff, project designers, developers and structural BMP owners regarding the design, operation, inspection and maintenance of structural controls.
Land Use Planning and Low Impact Development Tools
Though EPA did not require that the SWPCC accelerate the development of land use planning and low impact development tools, Committee staff viewed them as critical components of the program, given the rapid pace of development in the Truckee Meadows region. By mid-2005, a draft Low Impact Development Handbook was developed, which outlines principles for land use planning that minimize runoff and protect water quality. It also incorporates a set of tools, including new site design requirements (e.g. riparian setbacks and calculation of impervious coverage), land conservation tools (e.g., conservation easements and deed restrictions) and public outreach methods to encourage land use planning designs that protect water quality.
As the Program began to "ramp up" and guidance documents were developed and written, the Committee also accelerated its public outreach campaign. A new website for the RSQMP was developed that provides a central location for learning about the program; downloading guidance documents, forms, and worksheets; learning about training opportunities; and posting news and meeting agendas.
RSQMP website: http://www.tmstormwater.com
The Committee also formed an important partnership with the NEMO-Nevada program, operated through the University of Nevada Cooperative Extension Service. The Cooperative Extension program operates a public outreach program referred to as "Water Wise," hosted on KRNV Channel 4. Cooperative Extension also hosts a revolving series of public information sessions to educate area residents on water quality concerns and the role of both structural BMPs and Low Impact Development, in protecting water quality. Focused training sessions are also held on a regular basis for members of the construction and landscape contractor industry (primarily focused on the construction discharge program) and for engineers and landscape architects (focused on low impact development and structural BMPs). NEMO-Nevada has also sought speakers from across the country to provide practical lessons from other communities with similar climates and soil conditions.
NEMO-Nevada program— http://www.unce.unr.edu/western%20new/SubWebs/NEMO
Water Wise— http://krnv.iewatershed.com/
|"Rain garden" in residential neighborhood
The 2002 EPA mandate proved to be an important "tipping point" in building momentum for the Truckee Meadows region's adoption of a comprehensive Regional Stormwater Quality Management Program. Members of the Stormwater Permit Coordinating Committee followed through, making the initial investment in preparing necessary manuals and guidance documents and insisted on completing these both on a very aggressive schedule so they would be ready for implementation. They did this through a transparent process that involved major developer and builder stakeholders, in addition to the public. The Committee was also fortunate to contract with a local engineering consultant who was knowledgeable about, and supportive of, landscape-based water quality treatment and low-impact development techniques to develop the guidance documents. The emphasis on public outreach, and the strong partnership with NEMO-Nevada and Cooperative Extension was also am important asset in raising awareness in both professional circles and with the general public.
Momentum is definitely building in the Truckee Meadows region. In 2006, a municipal street improvements project in the City of Reno incorporated infiltration tree boxes into the streetscape component, to "pilot-test" this approach to capturing storm runoff from the roadway. Vegetated swales and rain gardens are being incorporated into retail settings and new community design. Though the Committee would suggest that much more remains to be done, their aggressive and timely response to EPA's mandate, as well as their attention to public outreach have allowed them to make rapid and meaningful progress in a relatively short amount of time.
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