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### Appendix **G –**  **Buffer Guidance .**  The purpose of this guidance is to assist you in complying with the requirements in Part 2.1.2 .1 of the permit regarding the establishment of natural buffers or equivalent sediment controls. This guidance is organized as foll ows:
**G.1 SITES THAT ARE REQUI**  **RED TO COMPLY WITH P ART 2.1.2.1**  **................................ .........................**  **2 G.1.1**  **Step 1 -**  **Determine if Your Site is Within 50 Feet of a Surface Water**  **................................ .**  **2 G.1.2**  **Step 2 -**  **Determine if Any Exceptions to the Requirements in Part 2.1.2.1 Apply ............**  **3 G.2**  **COMPLIANCE ALTERNATI VES GUID**  **ANCE ................................**  **................................ ....................**  **4 G.2.1**  **Guidance for Providing and Maintaining Natural Buffers ................................**  **.................. 4**  G.2.1.1 Buffer Width Measurement ................................ ................................ ................................ ....... 5 G.2.1.2 Limits to Disturbance Within the Buffer ................................ ................................ ............. 7 G.2.1.3 Discharges to the Buffer ................................ ................................ ................................ ............ 7 G .2.1.4 SWPPP Documentation ................................ ................................ ................................ ............. 8 **G.2.2 Guidance for Providing the Equivalent Sediment Reduction as the 50**  **- foot Buffer**  **........ 8**  G.2.2.1 Dete rmine Whether it is Feasible to Provide a Reduced Buffer ................................ ........ 8 G.2.2.2 Design Controls That Provide Equivalent Sediment Reduction as 50

- foot Buffer .......... 8 a. Step 1
- Estimate the Sediment Reduction from the 50

- foot Buffer .............................. 10 b. Step 2
- Design Controls That Match the Sediment Removal Efficiency of the 50

- foot Buffer ................................ ................................ ................................ ................................ ............ 11 **G.2.3 Small Residential Lot Compliance Alternatives**  **................................ ................................**  **. 12**  G.2.3.1 Step 1
– Determine if You are Eligible for the Small Residential Lot Co mpliance Alternatives ................................ ................................ ................................ ................................ .............. 13 G.2.3.2 Step 2
– Implement the Requirements of the Small Residential Lot Compliance Alternative Selected ................................ ................................ ................................ .............................. 13 a. Small Residential Lot Compliance Alternative 1 ................................ .............................. 13 b. Small Residential Lot Compliance Alternative 2 ................................ .............................. 14February 15, 2012

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-2 of 24 **G .1**  **SITES THAT**  **ARE REQUIRED TO COMP LY WITH P**  **ART 2.1.2.1** Th e purpose of this part is to help you determine if the requirements in Part 2.1.2.1 apply to your site. **G .1.1**  **Step 1 -**  **Determine if Your Site is Within 50 Feet of a Surface Water**  Part 2.1.2 .1 applies to you only if your earth

- disturbing acti vities will occur within 50 feet of a surface water that receives stormwater discharges from your site. Figure G
– 1 illustrate s when a site would be required to comply with the requirements in Part 2.1.2.1 due to their proximity to a surface water . If the surface water is not located within 50 feet of the earth
- disturbing activit i es , Part 2.1.2.1 does not apply. **Figure G -**  **1 .**  **E xample of**  **earth -**  **disturbing activities within 50 feet of a surface water .** 

If you determine that your earth
- disturbing activities will occur within 50 feet of a surface water that receives stormwater discharges from your site , the requirements in Part 2.1.2.1 apply , except for certain circumstances that are described in Step 2 . Note that where some natural buffer exists but portions of the area within 50 feet of the surface water are occupied by preexisting development disturbances , or if a portion of area within 50 feet of the surface water is owned by another party and is not under your control , the buffer requirements in Part 2.1.2.1 still apply , but with some allowances . C larity about how to implement the compliance alternatives for these situations is provided in G.2.1.2 and G.2.2.2 below.February 15, 2012

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- 3 of 24 Note that EPA

does not consider de signed stormwater control features (e.g., stormwater conveyance channels, storm drain inlets, stormwater basins) that direct storm water to surface waters more than 50 feet from the disturbance to constitute surface waters for the purposes of determining i f the buffer requirements apply . **G .1.2**  **Step 2 -**  **Determine if Any Exceptions to the Requirements in Part 2.1.2.1 Apply** The following exceptions apply to the requirements in Part 2.1.2.1 :  I f there is no discharge of stormwater to surface waters through the area between the disturbed portions of the site and any surface waters located within 50 feet of your site , you are not required to comply with the requirements in this Part . This includes situations where you have implemented controls measures, such as a berm or other barrier, that will prevent such discharges.
 Where no natural buffer exists due to preexisting development disturbances (e.g., structures, impervious surfaces) that occurred prior to the initiation of planning for the current development of t he site, you are not required to comply with the requirements in this Part. Where some natural buffer exists but portions of the area within 50 feet of the surface water are occupied by preexisting development disturbances , you are required to comply with the requirements in this Part . For the purposes of calculating the sediment load reduction for either compliance alternative 2 or 3 below , you are not expected to compensate for the reduction in buffer function that would have resulted from the area covered by these preexisting disturbances . C larity about how to implement the compliance alternatives for these situations is provided in G.2.1.2 and G.2.2.2 below. I f during your project, you will disturb any portion of the se preexisting disturbances, the area removed will be deducted from the area treated as natural buffer .  F or “linear construction projects” (see Appendix A) , you are not required to comply with this requirement if site constraints (e.g., limited right

- of

- wa y) prevent you from complying with t he requirements of the alternatives in Part 2.1.2.1a, provided that , to the extent practicable, you limit disturbances within 50 feet of the surface water and/or you provide supplemental erosion and sediment controls to treat stormwater discharges from earth disturbances within 50 feet of the surface water. You must also document in your SWPPP your rationale for why it is infeasible for you to comply with the requirements in Part 2.1.2.1a, and describe any buffer width retained and/or supplemental erosion a nd sediment controls installed.
 For “small residential lot” construction (i.e., a lot being developed for residential purposes that will disturb less than 1 acre of land, but is part of a larger residential project that will ultimately disturb greater tha n or equal to 1 acre) , you have the option of complying with the requirements in Part G.2.3 of this appendix .  The following disturbances within 50 feet of a surface water are exempt from the requirements in this Part :

- C onstruction approved under a CW A Sect ion 404 permit; orFebruary 15, 2012

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-4 of 24 - C onstruction of a water
- dependent structure or water access areas (e.g., pier, boat ramp, trail) . Note that you must document in your SWPPP if any disturbances related to any of the above exceptions occurs within the buffer area on yo ur site . **G .2**  **COMPLIANCE ALTERNATI VES GUIDANCE**  If in Part G . 1 of this guidance you determine that the buffer requirements apply to your site , you have three compliance alternatives from which you can choose : 1. Provide and maintain a 50

- foot buffer undisturb ed natural buffer (Part 2.1.2.1a.i) ; 1 or 2. Provide and maintain an undisturbed natural buffer that is less than 50 feet and is supplemented by additional erosion and sediment controls, which in combination achieves the sediment load reduction equivalent to a 50
- foot undisturbed natural buffer ( Part 2.1.2.1 a. ii ) ; 1 or 3. If it is infeasible to provide and maintain an undisturbed natural buffer of any size, you must implement erosion and sediment controls that achieve the sediment load reduction equivalent to a 50
- foot undisturbed natural buffer (Part 2.1.2.1 a. iii) . 1 The compliance alternative selected above must be maintained throughout the duration of permit coverage . The following provides detailed guidance for how you can comply with each of the complian ce alte rnatives . Part G . 2.1 below provides guidance on how to provide and maintain natural buffers consistent with the alternatives 1 and 2, above . Part G . 2.2 below provides guidance on how to comply with the requirement to provide a 50
- foot buffer equivalent t hrough erosion and sediment controls consistent with alternatives 2 and 3, above . **G .2.1**  **Guidance for Providing and Maintaining Natural Buffers** T he following guidance is intended to assist you in complying with the requirements to provide and maintain a n atural buffer during construction. This part of the guidance applies to you i f you choose either alternative 1 ( 50
- foot buffer) or alternative 2 ( a buffer of < 50 feet supplemented by additional erosion and sediment controls that achieve the equivalent se diment load reduction as the 50

- foot buffer) , or if you are providing a buffer in compliance with one of the small residential lot compliance alternatives in Pa rt G .2.3 below .

1 For the compliance alternatives in 1 and 2, you are not required to enhance the quality of the vegetation that already exists in the buffer, or provide vegetation if none exists (e.g., arid and s emi

- arid areas). Y

ou only need to retain and protect from disturbance the natural buffer that existed prior to the commencement of construction. Any preexisting structures or impervious surfaces are allowed in the nat ural buffer provided you retain and protect from disturbance the natural buffer area outside the preexisting disturbance. Similarly, for alternatives 2 and 3, you are required to implement and maintain sediment controls that achieve the sediment load reduction equivalent to the undisturbed n at ural buffer that existed on the site prior to the commencement of construction. In determining equivalent sediment load reductions, you may consider naturally non

- vegetated areas and prior disturbances. See Part G.2.2 of this Appendix for a discussion ofhow to determine equivalent reductions.February 15, 2012

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- 5 of 24 **G .2.1.1**  **Buffer Width Measurement** Where you are retaining a buffer of any size , t he buffer should be measured perpendicularly from any of the following points, whichever is further landward from the water: 1. The ordinary high water mark of the water body , defined as the line on the shore established by fluctuations of water and indi cated by physical characteristics such as a clear, natural line impressed on the bank, shelving, changes in the character of soil, destruction of terrestrial vegetation, and/or the presence of litter and debris; or 2. The edge of the stream or river bank, bluff, or cliff, whichever is applicable. Refer to Figure G
– 2 and Figure G

- 3 . You may find that specifically measuring the se points is challenging if the flow path of the surface water changes frequently , thereby causing the measurement line for the buffer to fluctuate continuously along the path of the waterbody. Where this is the case, EPA suggests that rather than measuring each change or deviation along the water’s edge, it may be easier to select regular intervals from wh ich to conduct your measurement. For instance, you may elect to conduct your buffer measurement every 5 to 10 feet along the length of the water. Ad ditionally, not e that if earth
- disturbing activities will take place on both sides of a surface water that flows through your site, to the extent that you are establishing a buffer around this water, it must be established on both sides . F or example, if you choose alternative 1 above , and you r project calls for disturbances on both sides of a small stream , you would need to retain the full 50 feet of buffer on both sides of the water. However, if your construction activities will only occur on one side of the stream, you would only need to retain the 50

- foot buffer on the side of the stream where the earth

dis turbance will occur.February 15, 2012

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- 6 of 24 **Figure G -**  **2 .**  **This image shows buffer measurement from the ordinary high water mark of the water body, as indicated by a clear natural line impressed on the bank, shelving, changes in the**  **character of the soil, destruction of terrestrial vegetation, and/or the presence of litter/debris.** 

**Figure G -**  **3 . This**  **image shows buffer measurement from the edge of the bank, bluff, or cliff,**  **whichever is applicable.**February 15, 2012

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- 7 of 24 **G .2.1.2**  **Limits to Dis turbance Within**  **the Buffer** You are considered to be in compliance with this requirement if you retain and protect from construction activities the natural buffer that existed prior to the commencement of construction . If the buffer area contains no vegetat ion prior to the commencement of construction (e.g., sand or rocky surface), you are not required to plant any additional vegetation. As noted above, a ny preexisting structures or impervious surfaces are allowed in the buffer provided you retain and protec t from disturbance the vegetation in the buffer outside the preexisting disturbance. To ensure that the water quality protection benefits of the buffer are retained during construction, you are prohibited from conducting any earth

- disturbing activities wit hin the buffer during permit coverage. In furtherance of this requirement, prior to commencing earth

- disturbing activities on your site, you must delineate, and clearly mark off, with flags, tape, or a similar marking device , the buffer area on your site. The purpose of this requirement is to make the buffer area clearly visible to the people working on your site so that unintended disturbances are avoided . While you are not required to enhance the quality of the vegetation that already exists within the buffer, you are encouraged to do so where such improvements will enhance the water quality protection benefits of the buffer . (Note that any disturbances within the buffer related to buffer enhancement are permitted and do not constitute construction dist urbances. ) For instance , you may want to consider targeted plantings where limited vegetation exists, or replacement of existing vegetation where invasive or noxious plant species (see http://plants.us da.gov/java/noxiousDriver) have taken over . In the case of invasive or noxious species, y ou may want to remove and replace them with a diversity of native trees, shrubs, and herbaceous plants that are well

- adapted to the climatic, soil, and hydrologic co nditions on the site. You are also encouraged to limit the removal of naturally deposited leaf litter, woody debris, and other biomass, as this material contributes to the ability of the buffer to retain water and filter pollutants. If a portion of the bu ffer area adjacent to the surface water is owned by another party and is not under your control, you are only required to retain and protect from construction activities the portion of the buffer area that is under your control. For example, if you elect alternative 1 above (provide and maintain a 50

- foot buffer), but 10 feet of land immediately adjacent to the surface water is owned by a different party than the land on which your construction activities are taking place and you do not have control over t hat land, you must only retain and protect from construction activities the 40
- foot buffer area that occurs on the property on which your construction activities are taking place. EPA would consider you to be in compliance with this requirement regardless of the activities that are taking place in the 10

- foot area that is owned by a different party than the land on which your construction activities are taking place that you have no control over. **G .2.1.**  **3 Discharges**  **to the Buffer**  You must ensure that all d ischarges from the area of earth disturbance to the natural buffer are first treated by the site’s erosion and sediment controls ( for example, you must comply with the Part 2.1.2.2 requirement to establish sediment controls around the downslope perimeter o f your site disturbances ), and if necessary to prevent erosion caused by stormwater flows within the buffer, you must use velocity dissipation devices. The purpose of this requirement is to decrease the rate of stormwater flow and encourage infiltration so that the pollutant filtering functions of the buffer will beFebruary 15, 2012

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- 8 of 24 achieved . To comply with this requirement, construction operators typically will use devices that physically dissipate stormwater flows so that the discharge entering the buffer is spread out an d slowed down . **G .2.1.**  **4 SWPPP Documentation**  You are required to document in your SWPPP the natural buffer width that is retained. For example, if you are complying with alternative 1 , you must specify in your SWPPP that you are providing a 50

- foot buffer . Or, if you will be complying with alternative 2 , you must document the reduced width of the buffer you will be retaining (and you must also comply with the requirements in Part 2.1.2. 1c to describe the erosion and sediment controls you will use to achie ve an equivalent sediment reduction, as described in Part G . 2.2 below) . Note that you must also show any buffers on your site plan in your SWPPP consistent with Part 7.2.6.3. Additionally, if any disturbances related to the exceptions in Part 2.1.2. 1e oc cur within the buffer area, you must document this in the SWPPP. **G .**  **2.2 Guidance for Providing the Equivalent Sediment Reduction as the 50**  **- foot Buffer**  If you are selecting Alternative 2 ( provide and maintain a buffer that is less than 50 feet that is sup plemented by additional erosion and sediment controls that , together, achieve the equivalent sediment load reduction as the 50

- foot buffer) or A lternative 3 ( implement erosion and sediment controls that achieve the equivalent sediment load reduction as the 50
- foot buffer) , the following guidance is intended to assist you in demonstrating that you will achieve the equivalent sediment reduction as the 50

- foot buffer. **G .2.2.1**  **Determine Whether it is Feasible to Provide a Reduced Buffer** EPArecognizes that there will be a number of situations in which it will be infeasible to provide and maintain a buffer of any width . While some of these situations may exempt you from the buffer requirement entirely (see G.1.2) , if you do not qualify for one of the se exemption s , there still may be conditions or circumstances at your site that make it infeasible to provide a natural buffer. For example, there may be sites where a significant portion of the property on which the earth

- disturbing activities will occur is located within the buffer area , thereby precluding the retention of natural buffer areas. EPAbelieves there are likely to be other examples of situations that make it infeasible to provide any buffer area. Therefore, in choosing between the 2 different complianc e alternatives (Alternative 2 or 3), you should only elect to comply with Alternative 2 if it is feasible for you to retain any natural buffer on your site. (Note: For any buffer width retained, you are required to comply with the requirements in Part G. 2.1, above, concerning the retention of vegetation and restricting earth disturbances.) Similarly, if you determine that it is infeasible to provide a natural buffer of any size during construction, you should elect to comply with Alternative 3. After making this determination, you should proceed to Part G.2.2.2 to determine how to provide controls that, together with any buffer areas that is being retained, if applicable, will achieve an equivalent sediment load reduction as the 50
- foot buffer. **G .2.2.2**  **De sign**  **Controls That Provide Equivalent Sediment Reduction as 50**  **- foot Buffer**  Y ou must next determine what addition al controls must be implemented on your site that , alone or in combination with any retained natural buffer, achieve a reduction in sediment equ ivalent to that achieved by a 50

- foot buffer .February 15, 2012

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- 9 of 24 Note that i f only a portion of the natural buffer is less than 50 feet , you are only required to implement erosion and sediment controls that achieve the sediment load reduction equivalent to the 50

- foot buff er for discharges through that area . Y ou would not be required to provide treatment of stormwater discharges that flow through 50 feet or more of natural buffer . See Figure G

- 4 . **Figure G -**  **4 Example**  **of how to comply with the requirement to provide the equivalent sediment reduction when only a portion of your earth**  **- disturbances discharge to a buffer of less than 50**  **- feet.** 

To comply with this requirement, you are required to do the following: **Step1 -**  Estimate the sediment reduction expected from your site if you had retained a 50
- foot natural buffer; **Step 2 -**  Design controls that alone or in combination with any width of buffer retained achieve the equivalent sediment removal efficiency as that expect ed from the 50

- foot buffer; and **Step 3 -**  Document in your SWPPP h ow your controls will achieve the equivalent sediment removal efficiency of the 50

- foot b uffer . Guidelines to help you work through these requirements are provided below.February 15, 2012

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- 10 of 24 **a. Step 1**  **- Estimate th**  **e Sediment Reduction from the 50 -**  **foot Buffer** In order to design controls that match the sediment removal efficiency of a 50
- foot buffer, you first need to know what this efficiency is for your site. The sediment removal efficiencies of natural buffers va ry according to a number of site

-specific factors , including precipitation, soil type, land cover, slope length, width, steepness, and the types of sediment controls used to reduce the discharge of sediment prior to the buffer. EPAhas simplified this cal culation by developing buffer performance tables covering a range of vegetati on and soil types for the areas covered by the CGP . See At tachment 1, Table s G
- 8 through G
- 1 5 . Note: buffer performance values in Tables G
- 8 through G
- 1 5 represent the p ercent of sediment captured through the use of perimeter controls (e.g., silt fences) and 50

- foot buffers at disturbed sites of fixed proportions and slopes. 2 Using Tables G
- 8 through G
- 1 5 (see At tachment 1) , you can determine the sediment removal efficiency of a 50

- foot buffer for your geographic area by matching the vegetative cover type that best describes your buffer area and the type of soils that predominate at your site. For example, if your site is l ocated in Massachusetts (Table G
- 9 ) , and your buffer vegetation corresponds most closely with that of tall fescue grass , and the soil type at your site is best typified as sand , your site ’ s sediment removal efficiency would be 81 percent . In this step , you should choose the vegetation type in the tables that most closely matches the vegetation that would exist naturally in the buffer area on your site regardless of the condition of the buffer. However, because you are not required to plant any additional vegetation in the buffer area , in determ ining what controls are necessary to meet this sediment removal equivalency in Step 2 below, you will be able to take credit for this area as a fully vegetated “natural buffer. ” Similarly, if a portion of the buffer area adjacent to the surface water is owned by another party and is not under your control, you can treat the area of land not under control as having the equivalent vegetative cover and soil type that

2 EPA used the following when developing the buffer performance tables:
 The sediment removal efficiencies are based on the U.S. Department of Agriculture’s RUSLE2 (“Revised Universal Soil Loss Equation 2”) model for sl ope profiles using a 100

-foot long denuded slopes.
 Sediment removal was defined as the annual sediment delivered at the downstream end of the 50

-foot natural buffer (tons/yr/acre) divided by the annual yield from denuded area (tons/yr/acre).
 As peri meter controls are also required by the CGP, sediment removal is in part a function of the reduction due to a perimeter control (i.e., silt fence) located between the disturbed portion of the site and the upstream edge of the natural buffer and flow travel ing through a 50

-foot buffer of undisturbed natural vegetation.
 Itwas assumed that construction sites have a relatively uniform slope without topographic features that accelerate the concentration for erosive flows.
 Itwas assumed that vegetation has been removed from the disturbed portion of the site and a combination of cuts and fills have resulted in a smooth soil surface with limited retention of near

-surface root mass To represent the influence of soil, EPA analyzed 11 general soil texture classifications in its eva lu ati on of buffer performance. To represent different types of buffer vegetation, EPA evaluated 4 or more common vegetative types for each state/territory covered under the permit. For each vegetation type evaluated, EPA considered only permanent, non - gra zed and non
- harvested vegetation, on the assumption that a natural buffer adjacent to the surface water will typi cally be undisturbed. EPA also evaluated slope steepness and found that sediment removal efficiencies present in Tables G
-8 through G
- 15 are achievable for slopes that are less than nine percent.February 15, 2012

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- 11 of 24 predominates on the portion of the property on which your construction activities are occurri ng. For example, if your earth

- disturbances occur within 50 feet of a surface water, but the 10 feet of land immediately adjacent to the surface water is owned by a different party than the land on which your construction activities are taking place and you do not have control over that land, you can treat the 10 foot area adjacent to the stream as having the equivalent soil and vegetation type as predominates in the 40 foot area under your control. You would then make the same assumption in Step 2 for p urposes of determining the equivalent sediment removal. Alternatively, you may do your own calculation of the effectiveness of the 50

- foot buffer based upon your site

-specific conditions, and may use this number as your sediment removal equivalency standa rd to meet instead of using Tables G

- 8 through G
- 15. This calculation must be documented in your SWPPP. **b. Step 2**  **- Design Controls That Match the Sediment Removal Efficiency of the 50**  **- foot Buffer**  Once you have determined the estimated sediment removal efficiency of a 50

- foot buffer for your site in Step 1 , you will be required to select stormwater controls that will provide an equivalent sediment load reductions. These controls can include the installation of a single designed control, such as a sediment pond , additional perimeter controls, or other type of device . Al ternatively, you may elect to install a combination of stormwater controls and to retain some amount of a buffer . W hichever control(s) you select , you must demonstrate in your SWPPP that th e controls will provide at a minimum the same sediment removal capabilities as the 50
- foot buffer (Step 1 ). You are allowed to take credit for the removal efficiencies of your required perimeter controls in your calculation of equivalency, because these we re included in calculating the buffer removal efficiencies in tables G

- 8 through G
- 15. (Note: You are reminded that the controls must be kept i n effective operating condition until you have completed final stabilization on the disturbed portions o f th e site discharging to the surface water.) To make the determination that your controls and/or buffer area achieve an equivalent sediment load reduction as the 50

- foot buffer, you will need to use a model or other type of calculator. As mentioned above, th ere are a variety of models available that can be used to support your calculation, including USDA’s RUSLE
-series programs and the WEPP erosion model , SEDCAD, SEDIMO T, or other model s. A couple of examples are provided in Attachment 3 to help illustrate h ow this determination could be made . If you are retaining a buffer of less than 50 feet, you may take credit for the removal that will occur from the reduced buffer and only need to provide additional controls to make up the difference between the removal efficiency of a 50 foot buffer and the removal efficiency of the narrower buffer. For example, if you are retaining a 30 foot buffer, you can account for the sediment removal provided by the 30

- foot buffer retained, and you will only need to design contro ls to make up for the additional removal provided by the 20

- foot of buffer that is not being provided. To do this, you would plug the width of the buffer that isFebruary 15, 2012

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- 12 of 24 retained into RUSLE or another model, along with other stormwater controls that will together achieve a sediment reduction equivalent to a natural 50

- foot buffer. Asdescribed in Step 1 above, you can take credit for the area you have retained as a “natural buffer” as being fully vegetated, regardless of the condition of the buffer area. For exam ple, if your earth

- disturbances occur 30 feet from a surface water, but the 10 feet of land immediately adjacent to the surface water is owned by a different party than the land on which your construction activities are taking place and you do not have con trol over that land, you can treat the 10
- foot area as a natural buffer, regardless of the activities that are taking place in the area. Therefore, you can assume (for purposes of your equivalency calculation) that your site is providing the sediment removal equivalent of a 30

- foot buffer, and you will only need to design controls to make up for the additional removal provided by the 20

- foot of buffer that is not being provided. **c. Step 3**  **- Document How Site**  **- Specific Controls Will Achieve the Sediment Removal**  **Efficiency of the 50 -**  **foot Buffer** In Steps 1 and 2, you determined both the expected sediment removal efficiency of a 50

- foot buffer at your site, and you used this number as a performance standard to design controls to be installed at your site, which al one or in combination with any retained natural buffer, achieves the expected sediment removal efficiency of a 50

- foot buffer at your site . The final step is to document in your SWPPP the i nformation you relied on to calculate the equivalent sediment reduc tion as an undistu rbed natural buffer. EPAwill consider your documentation to be sufficient if it generally meets the following:

– For Step 1, refer to the table in Attachment 1 that you used to derive your estimated 50
- foot buffer sediment removal effici ency performance . In clude information about the buffer vegetation and soil type that predominate at your site, which you used to s elect the sediment load reduction value in Tables G
- 8 through G
- 1 5 . Or, if you conduct ed a site

-specific calculation for sediment removal efficiency , provide the specific removal efficiency , and the information you relied on to make your site

-specific calculation.

– For Step 2 : (1) Specify the model you used to estimate sediment load reductions from your site ; and (2 ) the results of calcula tions showing how your controls will meet or exceed the sediment removal effic i ency from Step 1 . If you choose Alternative 3, you must al so include in your SWPPP a description of why it is infeasible for you to provide and maintain an un disturbed natural buffer of any size . **G .**  **2.3 Small Residential Lot**  **Compliance Alternative s**  In this part of A ppendix G , EPA provides additional compliance alternative s for operators of small residential lots . In accordance with Part 2.1.2. 1e . i v, operators of A **s mall**  **r esidential**  **lot** is a lot or grouping of l ots being developed for residential purposes that will disturb less than 1 acre of land , but that is part of a larger residential project that will ultimately disturb greater than or equal to 1 acre.February 15, 2012

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- 13 of 24 smal l residential lots who do not provide a 50

- foot buffer are not required to make the demonstration outlined in Part G.2.2.2. Instead, qualifying operators can comply with the buffer requirement by choosing to implement a set of traditional sedimen t and erosion controls from the menu of practices provided in Part G .2.3.2 . EPAhas developed two different alternatives for compliance. The following steps describe how a small residential lot operator would achieve compliance with these 2 alternat ives. **G .2.3.1**  **Step 1 –**  **Determine if You are Eligible for the Small Residential Lot Compliance Alternative** **s** In order to be eligible for the small residential lot compliance alternatives , the following conditions must be met : **a.** T he lot or grouping of lots me ets the definition of “small residential lot”; and **b.** T he operator must comply with all other requirements in Part 2.1.2.1 , including: **i.** Ensure that all discharges from the area of earth disturbance to the natural buffer are first treated by the site’s erosion and sediment controls , and use velocity dissipation devices if necessary to prevent erosion caused by stormwater within the buffer; **ii.** Document in the SWPPP the natural buffer width retained on the property , and show the buffer boundary on your site plan; a nd **iii.** D elineate, and clearly mark off, with flags, tape, or other similar marking device , all natural buffer areas. **G .2.3.2**  **Step 2 –**  **Implement the Requirements of the Small Residential Lot Compliance Alternative Selected**  Y ou must next choose from one of two s mall residen tial lot compliance alternative s and implement the stormwater control practices associated with that alternative. Note : The compliance alternatives provided below are not mandatory. Operators of small residential lots can alternatively ch oose to comply with the any of the options that are available to other sites in Part 2.1.2.1a, described in Parts G .2.1 and G .2.2 in this appendix. **a. Small Residential Lot Compliance Alternative 1**  A lternative 1 is a straightforward tiered

- technology approa ch that specifies the controls that a small residential lot must implement based on the buffer width retained. To achieve compliance with Alternative 1 , you must implement the controls specified in Table G
– 1 based on the buffer width to be retained. See footnote 3 , below, for a description of the controls you must implement. For example, if you are an operator of a small residential lot that will be retaining a 35

- foot buffer and you choose Small Residential Lot Compliance Alternative 1 , you must impleme nt double perimeter controls between earth disturbances and the surface water. In addition to implementing the applicable control, you must also document in your SWPPP how you will comply with Alternative 1.February 15, 2012

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- 14 of 24 **Table G -**  **1 .**  **Altern ative**  **1 Requirements**  **3** 

### Retain 50 **- foot Buffer**  **Retain <50 and >30 foot Buffer**  **Retain ≤ 30 foot Buffer**  No Additional Requirements Doubl e Perimeter Control s Doubl e Perimeter Control s and 7
- Day Site Stabil ization **b. Small Residential Lot Compliance Alternative 2**  A lternative 2 specifies the controls that a builder of a small lot must imp lement based on both the buffer width retained and their risk of sediment discharge . By incorporating the sediment risk, this approach may result in the implementation of controls that are more appropriate for the site’s specific conditions. Step 1
– Determine Your Site’s Sediment Risk Level To meet the requirements of A lternative 2 , you must first determine your site’s sediment discharge “ risk level ” based on the site’s slope, location , and soil type. To help you to determine your site’s sediment risk le vel , EPAhas developed five different tables for different slope conditions . You must select the table that most closely correspond s to your site’s average slope . For example, if your site’s average slope is 7 percent, you would use Table G
– 4 to determine your site’s sediment risk. After you determine which table applies to your site , you must then use the table to determine the “risk level” (e .g ., “low”, “moderate”, or “high”) that corresponds to your site’s location and predominant soil type . 4

3 **Description of Additional Controls Applicable to Small Residential Lot Compliance Alternative** **s 1 and 2:** 
 **No Additional Requirements:** If you implement a buffer of 50 feet or greater, then you are not subject to any additional requirements. Note that you are required to install perimeter controls between the disturbed portions of your site and the buffer in accordance with Part 2.1.2.2.
 **Double Perimeter Control:** In addition to the reduced buffer wid th retained on your site, you must provide a double row of perimeter controls between the disturbed portion of your site and the surface water spaced a minimum of 5 feet apart.
 **Double Perimeter Control and 7 -**  **Day Site Stabilization:** In addition to the redu ced buffer width retained on your site and the perimeter control implemented in accordance with Part 2.1.2.2, you must provide a double row of perimeter controls between the disturbed portion of your site and the surface water spaced a minimum of 5 feet ap art, and you are required to complete the stabilization activities specified in Parts 2.2.1.2a and/or 2.2.1.2b within 7 calendar days of the temporary or permanent cessation of earth

- disturbing activities.
4 One source for determining your site’s predomi nant soil type is the USDA’s Web Soil Survey located at http://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx .February 15, 2012

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- 15 of 24 For example, based on Table G
- 3, a site located in New Hampshire with a 4 percent average slope and with predominately sandy clay loam soils would fall into the “ moderate ” risk level. **Table G -**  **2 .**  **Risk Level s**  **for Sites with Average**  **Slopes of**  **≤ 3**  **Percent**



### Soil Type **Location Clay**  **Silty Clay Loam or Clay** **- Loam**  **Sand Sandy Clay**  **Loam, Loamy Sand or Silty**  **Clay Loam, Silt,** 

**Sandy Loam or Silt Loam**  **Guam** Moderate Moderate Moderate Moderate High **Puerto Rico** Moderate Mod erate Moderate Moderate High **Virgin Islands** Low Moderate Low Moderate Moderate **American Samoa** Moderate Moderate Moderate Moderate High **Massachusetts and New Hampshire**  Low Moderate Low Low Moderate **Idaho** Low Low Low Low Low **New Mexico** Low Low Low Low Low **Washington D.C.** Low Moderate Low Low Moderate **Table G -**  **3 .**  **Risk Level s**  **for Sites with Average**  **Slopes of > 3 Percent**  **and ≤ 6 Percent** 



### Soil Type **Location Clay**  **Silty Clay Loam or Clay** **- Loam**  **Sand Sandy Clay**  **Loam, Loamy Sand or Silty**  **Clay Loam, Silt,** 

**Sandy Loam or Silt Loam**  **Guam** Moderate Moderate Moderate Moderate High **Puerto Rico** Moderate Mo derate Moderate Moderate High **Virgin Islands** Moderate Moderate Moderate Moderate High **American Samoa** High High Moderate High High **Massachusetts and New Hampshire**  Moderate Moderate Low Moderate High **Idaho** Low Low Low Low Low **New Mexico** Low Low Low Low Moderate **Washington D.C.** Moderate Moderate Moderate Moderate High **Table G -**  **4 .**  **Risk Levels for Sites with Average Slopes of > 6**  **Percent and ≤**  **9 Percent** 



### Soil Type **Location Clay**  **Silty Clay Loam or Clay** **- Loam**  **Sand Sandy Clay**  **Loam, Loamy Sand or Silty**  **Clay Loam, Silt,** 

**Sandy Loam or Silt Loam**  **Guam** Moderate High Moderate High High **Puerto Rico** Moderate High Moderate Moderate HighFebruary 15, 2012

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- 16 of 24 

### Virgin Islands Moderate Moderate Moderate Moderate High **American Samoa** High High High High High **Massachusetts and New Hampshire**  Moderate Moderate Moderate Moderate High **Idaho** Low Low Low Low Low **New Mexico** Low Low Low Low Moderate **Washington D.C.** Moderate Moderate Moderate Moderate High **Table G -**  **5 .**  **Risk Levels for Sites with Average Slopes of >**  **9 Percent and**  **≤ 15 Percent**



### Soil Type **Location Clay**  **Silty Clay Loam or Clay** **** **Loam Sand**  **Sandy Clay Loam, Loamy**  **Sand or Silty Clay**  **Loam, Silt,**

**Sandy Loam or Silt Loam**  **Guam** High High High High High **Puerto Rico** High High High High High **Vi rgin Islands**  Moderate High Moderate High High **American Samoa** High High High High High **Massachusetts and New Hampshire**  Moderate Moderate Moderate Moderate High **Idaho** Low Low Low Low Low **New Mexico** Low Moderate Low Moderate Moderate **Washington D.C.** Mode rate High Moderate Moderate High **Table G -**  **6 .**  **Risk Levels for Sites with Average Slopes of > 15 Percent**



### Soil Type **Location Clay**  **Silty Clay Loam or Clay** **** **Loam Sand**  **Sandy Clay Loam, Loamy**  **Sand or Silty**  **Clay Loam, Silt,** 

**Sandy Loam or Silt Loam**  **Guam** High High High High High **Puerto Rico** High High High High High **Virgin Islands** High High High High High **American Samoa** High High High High High **Massachusetts and New Hampshire**  High High Moderate High High **Idaho** Low Low Low Low Moderate **New Mexico** Moderate Moderate Moderate Moderate High **Washington D.C.** High High Moderate High High

Step 2
– Determine Which Additional Controls ApplyFebruary 15, 2012

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- 17 of 24 Once you determine your site’s “risk level” , you must next determi ne the additional controls you need to implement on your site , based on the width of buffer you plan to retain. Table G
- 7 specifies the requirements that apply based on the “risk level” and buffer width retained. See footnote 3 , above, for a descriptio n of the additional controls that are required. For example, if you are the operator of a small residential lot that falls into the “ m oderate” risk level , and you decide to retain a 20

- foot buffer , using Table G
- 7 you would determine that you need to imple ment double perimeter controls to achieve compliance with Part 2.1.2 . 1 . You must also document in your SWPPP your compliance with Alternative 2. **Table G -**  **7 .**  **Alternative 2 Requirements**  **2 Risk Level Based**  **on Estimated Soil Erosio**  **n Retain**  **≥ 50’**

**Buffer Retain <50’ and** 

**>30’ Buffer Retain**  **≤ 30’ and** 

**>10’ Buffer Retain**  **≤ 10’ Buffer**  **Low Risk** No Additional

Requirements No Additional

Requirements Double Perimeter

Control Double Perimeter

Control **Moderate Risk** No Additional

Requirements Do uble Perimeter

Control Double Perimeter

Control Double Perimeter

Control and 7
- Day Site Stabilization **High Risk** No Additional

Requirements Double Perimeter

Control Double Perimeter

Control and 7
- Day Site Stabilization Double Perimeter

Control and 7
- Day Si te StabilizationFebruary 15, 2012

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- 18 of 24 - **ATTACHMENT 1**

Sediment Removal Efficiency Tables 5 EPArecognizes that very high removal efficiencies, even where theoretically achievable by a 50
- foot buffer, may be very difficult to achieve in practice using alternative controls. Therefore in the tables below, EPA has limited the removal efficiencies to a maximum of 90%. Efficiencies that were calculated at greater than 90% are shown as 90%, and this is the minimum percent removal that must be achieved by alternative controls. **Ta ble G**  **- 8**  **. Estimated**  **50 -**  **foot Buffer Performance in Idaho******* **Estimated %**  **Sediment Removal Type of Buffer Vegetation**  ****** **Clay Silty Clay**  **Loam or Clay**  **- Loam**  **Sand Sandy Clay**  **Loam, Loamy Sand**  **or Silty Clay Loam, Silt,** 

**Sandy Loam or Silt**  **Loam Tall Fescue Grass**  42 52 44 48 85 **Medium -**  **density Weeds** 28 30 28 26 60 **Low -**  **density Warm -**  **season Native Bunchgrass (i.e.,**  **Grama Grass)** 25 26 24 24 55 **Northern Mixed Prairie Grass** 28 30 28 26 50 **Northern Range Cold Desert Shrubs**  28 28 24 26 50 * Ap p lic able for sites with l ess than nine percent slope ** Characterization focuses on the under

-story vegetation **Table G -**  **9 .**  **Estimated 50**  **- foot Buffer Performance in Massachusetts and New Hampshire** ***** **Estimated % Sediment Removal Type of Buffer Vegetation**  ****** **Clay Silty Clay**  **Loam or Clay**  **- Loam**  **Sand Sandy Clay**  **Loam, Loamy Sand**  **or Silty Clay Loam, Silt,** 

**Sandy Loam or Silt Loam**  **Warm -**  **season Grass (i.e., Switchgrass, Lemongrass)**  79 9 0 9 0 9 0 9 0 **Cool -**  **season Dense Grass (Kentucky Bluegrass,**  **Smooth Bromegrass, Timothy)**  78 9 0 9 0 9 0 9 0 **Tall Fescue Grass** 76 90 81 89 9 0 **Medium -**  **density Weeds** 66 76 60 72 66 * Ap plicable for sites with l ess than nine percent slope ** Characterization focuses on the under

-story vegetation

5 The buffer performances were calculated based on a denuded slope upgradient of a 50

- foot buffer and a perimeter controls, as perimeter controls are a standard requirement (see Part 2.1.2.2).February 15, 2012

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- 19 of 24 **Table G -**  **10 .**  **Estimated 50**  **- foot Buffer Performance in New Mexico** ***** **Estimated % Sediment Removal Type of Buffer Vegetation**  ****** **Clay Silty Clay**  **Loam or Clay**  **- Loam**  **Sand Sandy Clay**  **Loam, Loamy Sand**  **or Silty Clay Loam, Silt,** 

**Sandy Loam or Silt Loam**  **Tall Fe scue grass**  71 85 80 86 9 0 **Medium -**  **density Weeds** 56 73 55 66 78 **Low -**  **density Warm -**  **season Native Bunchgrass (i.e.,**  **Grama Grass)** 53 70 51 62 67 **Southern Mixed Prairie Grass** 53 71 52 63 50 **Southern Range Cold Desert Shrubs**  56 73 55 65 53 * Ap plicable for si te s with l ess than nine percent slope ** Characterization focuses on the under

-story vegetation **Table G -**  **11 .**  **Estimated 50**  **- foot Buffer Performance in Washington, DC**  ***** **Estimated % Sediment Removal Type of Buffer Vegetation**  ****** **Cla y**  **Silty Clay Loam or**  **Clay -**  **Loam Sand**  **Sandy Clay Loam,**  **Loamy Sand or Silty Clay**  **Loam, Silt,**

**Sandy Loam or Silt Loam**  **Warm -**  **season Grass (i.e., Switchgrass, Lemongrass)**  82 9 0 9 0 9 0 9 0 **Cool -**  **season Dense Grass (**  **Kentucky Bluegrass, Smooth Bromegrass, Timothy** **)** 81 9 0 9 0 9 0 9 0 **Tall Fescue Grass** 79 9 0 83 89 9 0 **Medium -**  **density Weeds** 71 79 66 75 74 * Ap plicable for sites with l ess than nine percent slope ** Characterization focuses on the under

-story vegetation **Table G -**  **12 .**  **Estimated 50**  **- foot Buffer Performance in American Samoa**  ***** **Estimated % Sediment Removal Type of Buffer Vegetation**  ****** **Clay Silty Clay**  **Loam or Clay**  **- Loam**  **Sand Sandy Clay**  **Loam, Loamy Sand**  **or Silty Clay Loam, Silt,** 

**Sandy Loam or Silt Loam**  **Bahiagrass (Permanent cover)** 8 2 9 0 9 0 9 0 83 **Warm -**  **season Grass (i.e., Switchgrass, Lemongrass)**  82 9 0 9 0 9 0 85 **Dense Grass** 82 9 0 9 0 9 0 83 **Tall Fescue Grass** 82 89 82 89 79 **Medium -**  **density Weeds** 70 73 62 75 59 * Ap plicable for sites with l ess than nine percent slope ** Characterization focuses on the under

-story vegetationFebruary 15, 2012

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-20 of 24 **Table G -**  **13 .**  **Estimated 50**  **- foot Buffer Performance in Guam**  ***** **Estimated % Sediment Removal Type of Buffer Vegetation**  ****** **Clay Silty Clay**  **Loam or Clay**  **- Loam**  **Sand Sandy Clay**  **Loam, Loamy Sand**  **or Silty Clay Loam, Silt,** 

**Sandy Loam or Silt Loam**  **Bahiagrass (Permanent cover)**  80 9 0 9 0 9 0 89 **Warm -**  **season Grass (i.e., Switchgrass, Lemongrass)**  80 9 0 9 0 9 0 9 0 **Dense Grass** 79 9 0 90 9 0 89 **Tall Fescue Grass** 76 90 80 88 87 **Medium -**  **density Weeds** 63 73 53 68 61 * Ap plicable for sites with l ess than nine percent slope ** Characterization focuses on the under

-story vegetation **Table G -**  **14 .**  **Estimated 50**  **- foot Buffer Performance in**  **Puerto Rico******* **Estimated % Sediment Removal**
**Type of Buffer Vegetation**  ****** **Clay Silty Clay**  **Loam or Clay**  **- Loam**  **Sand Sandy Clay**  **Loam, Loamy Sand**  **or Silty Clay Loam, Silt,** 

**Sandy Loam or Silt Loam**  **Bahiagrass (Permanent cover)**  83 9 0 9 0 9 0 9 0 **Warm -**  **season Grass (i.e., Switchgrass, Lemongrass)**  83 9 0 9 0 9 0 9 0 **Dense Grass**  83 9 0 9 0 9 0 9 0 **Tall Fescue Grass** 82 9 0 84 9 0 89 **Medium -**  **density Weeds** 72 78 65 76 64 * Ap plicable for sites with l ess than nine percent slope ** Characterization focuses on the under

-story vegetation **Table G -**  **15 .**  **Estima ted**  **50 -**  **foot Buffer Performance in Virgin Islands**  ***** **Type of Buffer Vegetation  ** Clay** **Silty Clay Loam or**  **Clay -**  **Loam Sand**  **Sandy Clay Loam,**  **Loamy Sand or Silty Clay**  **Loam, Silt,**

**Sandy Loam or Silt Loam**  **Bahiagrass (Permanent cover)**  85 9 0 9 0 9 0 9 0 **Warm -**  **season Grass (i.e.,**  **Switchgrass, Lemongrass)** 86 9 0 9 0 9 0 9 0 **Dense Grass** 85 9 0 9 0 9 0 9 0 **Tall Fescue Grass** 85 9 0 88 9 0 89 **Medium -**  **density Weeds** 75 77 71 78 63 * Ap plicable for sites with l ess than nine percent slope ** Characterization focuses on the under

-story vegetation **ATTACHMENT 2** Using the Sediment Removal Efficiency Tables
– Questions and AnswersFebruary 15, 2012

G
-21 of 24 – What if my specific buffer vegetation is not represented in Tables G
- 8 through G
- 1 5 ? Tables G
- 8 through G
- 1 5 provide a wide range of factors affecting buffer performance; however, there may be instances where the specific buffer vegetation type on your site is not listed. If you do not see a description of the type of vegetation present at your site, you should choose the vegetation type that most clos ely matches the vegetation type on your site. You can contact your local Cooperative Extension Service Office (www. csrees.usda.gov/Extension ) for assistance in determining the vegetation type in Tables G
- 8 through G
- 1 5 that most closely matches your site

-specific vegetation.

– What if there is high variability in local soils? EPA recognizes that there may be a number of different soil type(s) on any given construction site. General soil information can be obtained from USDA soil survey reports ( http://websoilsurvey.nrcs.usda.gov ) or from individual site assessments performed by a certified soil expert. Tables G
- 8 through G
- 1 5 present eleven generic soil texture classes, grouping individual textu res where EPA has determined that performance is similar. If your site contains different soil texture classes , you should use the soil type that best approximates the predominant soil type at your site.

– What if my site slope is greater than 9 percent after final grade is reached? As indicated in the buffer performance tables, the estimated sediment removal efficiencies are associated with disturbed slopes of up to 9 percent grade. Where your graded sit e has an average slope of greater than 9 percent, you should calculate a site

-specific buffer performance.

– How do I calculate my own estimates for sediment reduction at my specific site? If you determine that it is necessary to calculate your own sedime nt removal efficiency using site

specific conditions (e.g., slopes at your site are greater than 9 percent), you can do so by choosing from a range of available mathematical models that are available to facilitate this calculation , including USDA’s RUSLE

-s eries programs and the WEPP erosion model, SEDCAD, SEDIMO T, or other equivalent model s .

– What is my estimated buffer performance if my site location is not represented by Tables G
- 8 through G
- 1 5 ? If your site is located in an area not represented b y Tables G
- 8 through G

- 1 5 , you should use the table that most closely approximates conditions at your site. You may also choose to conduct a site

-specific calculation of the buffer performance.

– What if only a portion of my site drains to the buffer area? If only a portion of your site drains to a surface water, where that water is within 50 feet of your construction activities, you are only required to meet the equivalency requirement for the stormwater flows corresponding to those portions of the s ite. See Example 2 below for an example of how this is expected to work.February 15, 2012

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-22 of 24 **ATTACHMENT 3** Examples of How to Use the Sediment Removal Efficiency Tables Example 1. Comparatively Wet Location (7.5 acre site located in Massachusetts) The operator of a 7.5

- acre construction site in Massachusetts has determined that it is infeasible to establish a buffer of any size on their site, and is now required to select and install controls that will achieve an equivalent sediment load reduction as that estimated in G
- 9 for their site conditions. The first step is to identify what percentage of eroded sediment is estimated to be retained from a 50

- foot buffer. For this example, it is assumed that the site has a relatively un iform gentle slope (3 percent), so Table G
- 9 can be used to estimate the 50

- foot buffer sediment load reduction. If the site’s buffer vegetation is best typified by cool

-season dense grass and the underlying soil is of a type best described as loamy sand, the 50

- foot buffer is projected to capture 90 percent of eroded sediment from the construction site. The second step is to determine what sediment controls can be selected and installed in combination with the perimeter controls already required to be implemented at the site (see Part 2.1.2.2), wh ich will achieve the 90 percent sediment removal efficiency from Table G
- 9 . For this example, using the RUSLE2 profile model, it was determined that installing a pair of shallow

sloped diversion ditches to convey runoff to a well

- designed and maintained sediment basin provides 99 percent sediment removal. Because the estimated sediment reduction is greater than the required 90 percent that a 50
- foot buffer provides, the operator will have met the buffer requirements. See Figure G

- 5 . The operator could also choose a different set of controls, as long as they achieve at least a 90 percent sediment removal efficiency.February 15, 2012

G
-23 of 24 **Figure G -**  **5 . Example 1**  **– Equivalent Sediment Load Reductions at a 7.5 ac Site in**  **MA.**

Example 2. Arid Location Wi th Pre
- existing Disturbances in the Natural Buffer (6.5 acre site located in New

Mexico) An operator of a site in New Mexico determines that it is not practicable to provide a 50

- foot buffer, but a 28

- foot buffer can be provided. Because the operator will provide a buffer that is less than 50 feet, the operator must determine which controls, in combination with the 28

- foot buffer, achieve a sediment load reduction equivalent to the 50
- foot buffer. In this example, the proj ect will disturb 6.5 acres of land, but only 1.5 acres of the total disturbed area drains to the buffer area. Within the 28

- foot buffer area is a preexisting concrete walkway. Similar to Example 1, the equivalence analysis starts with Step 1 (Part G .2.2.2 ) with a review of the New Mexico buffer performance (Table G
- 10 ). The operator determines that the predominate vegetation type in the buffer area is prairie grass and the soil type is similar to silt, and that the site is of a uniform, shallow slope (e .g., 3 percent grade) . Al though the operator will take credit for the disturbance caused by the concrete walkway as a natural buffer in Step 2 , here the operator can treat the entire buffer area as being naturally vegetated with prairie grass. Based on thi s information, the operator refers to Table G
- 10 to estimate that the 50

- foot buffer would retain 50 percent of eroded soil .February 15, 2012

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-24 of 24 The second step is to determine, based on the 50 percent sediment removal efficiency found in Table G
- 10 , what sediment control s in combination with the 28

- foot buffer area, can be implemented to reduce sediment loads by 50 percent or more . T he operator does not have to account the reduction in buffer function caused by the preexisting walkway, and can take credit for the entire 2 8
- foot buffer being fully vegetated in the analysis. For t his example, using the RUSLE2 profile model, the operator determined that installing a fiber roll barrier between the silt fence (already required by Part 2.1.2.2) and the 28
- foot buffer will achiev e an estimated 84 percent sediment removal efficiency. See Figure G

- 6 . Note that this operator is subject to the requirement in Part 2.1.2.1b.i to ensure that discharges through the silt fence, fiber roll barrier, and 28
- foot b uffer do not cause erosion within the buffer . The estimated sediment reduction is greater than the required 50 percent; therefore the operator will have met the buffer alternative requirement. **Figure G -**  **6 . Example 2**  **– Equiva**  **lent Sediment Load Reductions at a 6.5 ac Site in NM.**