Water Quality: Better Data and Evaluation of Urban Runoff Programs Needed to Assess Effectiveness
Published: 2001-06-29T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Environmental Protection Agency (EPA) considers the contaminants in storm water runoff as a significant threat to water quality across the nation. Prompted by Congress, EPA has responded with various initiatives, including the National Pollutant Discharge Elimination System Storm Water Program, which requires more than 1,000 local governments to undertake storm water management programs. Those municipalities in Phase I of the program have been trying to reduce pollutants in storm water runoff for several years, and it is time to begin evaluating their efforts. EPA however, has not established measurable goals for this program, nor has it attempted to evaluate the program's effectiveness in reducing storm water pollution or to determine its cost. EPA attributes its inaction to inconsistent data reporting from municipalities, insufficient staff resources, and other competing priorities within the Office of Wastewater Management. Although municipalities report monitoring and cost data to EPA or state regulatory agencies annually, these agencies have not reviewed this information to determine whether it can be useful in determining the program's overall effectiveness or cost.
section_title: What GAO Found
paragraphs: GAO found that the reported cost information will be difficult to analyze unless EPA and its state partners set guidelines to elicit more standardized reporting. Better data on costs and program effectiveness are needed--especially in light of the Phase II program that will involve thousands more municipalities in 2003. EPA's planned research grant to the University of Alabama and its pilot project to analyze data from annual reports and develop baseline indicators is a step in the right direction and could point the way for a more comprehensive approach.

section_title: Letter
paragraphs: Nonpoint source pollution—that is, pollution from contaminants picked up  and carried into surface water by water running over land—is known to be  one of the leading causes of water quality problems in the United States.   Water that runs over developed areas, including paved surfaces such as  roads and parking lots, before reaching a water body is known as urban  runoff and is an increasingly important category of water pollution.  As  urban areas have expanded over the past several decades, the amount of  urban runoff has also increased.  Although the overall quality of the nation’s  waters has improved since the passage of the Clean Water Act in 1972, a  significant number of water bodies still suffer from poor water quality.   Because the act brought discharges from “point sources,” such as industrial  plants and municipal treatment plants, under control, the continuing  pollution of these waters suggests that other sources, including urban  runoff, are contributing to water quality problems.  As a result, the  Environmental Protection Agency (EPA) now classifies urban runoff as a  significant cause of impairment to water quality.  The Water Quality Act of  1987, which amended the Clean Water Act, required EPA, among other  things, to regulate as a point source urban runoff that reaches municipal  sewer systems.  EPA’s National Pollutant Discharge Elimination System  Program for storm water requires that certain local governments take  measures to control storm water runoff.
Concerned about the degradation of water quality in urban areas, you  asked us to report on (1) the amount of runoff from urban areas,  particularly from roads, highways, and other impervious surfaces, and its  effects on water quality and (2) the programs that federal regulations  require local governments to develop to address urban runoff, and the  costs and effectiveness of those programs.  To address these issues, we  reviewed federal and other studies and interviewed experts on the  relationship between the amount of paved and other impervious surfaces  and the amount of runoff, and on the types of materials typically contained  in urban runoff.  We also reviewed studies and interviewed experts on the  sources of these materials and any actual or potential effects on water  quality from urban runoff.  We visited five urban areas and organizations  that are affiliated with their watersheds to obtain site-specific information  about urban runoff problems, programs these areas have implemented in  response to federal requirements, and the costs and effectiveness of these  programs.   Finally, we reviewed studies and estimates of the costs and  investment requirements associated with implementing storm water  management programs.  Because this report focuses on local governments’  actions, we did not review the portions of the National Pollutant Discharge  Elimination System Storm Water Program that address industrial facilities  and construction sites.
We performed our review from August 2000 through May 2001 in  accordance with generally accepted government auditing standards.
subsections: section_title: Background
paragraphs: Nonpoint source pollution can result when water, such as precipitation,  runs over land surfaces and into bodies of water.  Significant nonpoint  sources of pollution can include paved urban areas, agricultural practices,  forestry, and mining.  However, in urban and suburban areas, this runoff  generally enters a sewer system that can be regulated as a point source of  water pollution.  For example, precipitation from rain or snowmelt may run  into a municipal separate storm sewer system (MS4 or storm sewer) that  eventually discharges into a body of water.  The precipitation may also run  into a combined sewer system, which carries a combination of storm water  runoff, industrial waste, and raw sewage in a single pipe to a sewage  treatment facility for discharge after treatment.  Lastly, the precipitation  may run off of land or paved surfaces directly into nearby receiving waters.
EPA’s Office of Wastewater Management, which is within the Office of  Water, implements the National Pollutant Discharge Elimination System  (NPDES) Program.  The program was created in 1972 with the passage of  the Clean Water Act.  Created to control water pollution from point  sources—those sources, such as a factory or wastewater treatment plant,  that contribute pollutants directly into a body of water from a pipe or other  conveyance—the NPDES Program did not specifically address storm water  discharges.  In 1987, the Congress amended the Clean Water Act with the  Water Quality Act, which directed EPA to also control storm water  discharges that enter MS4s—essentially requiring EPA to treat such storm  water as a point source.  MS4s are defined as those sewers that collect and  convey storm water; are owned or operated by the federal, state, or local  government; and are not part of a publicly owned treatment (sewage)  facility.
To regulate urban storm water runoff, EPA published regulations in 1990  that established the NPDES Storm Water Program and described permit  application requirements.  According to EPA, the program’s objective, in  part, is to preserve, protect, and improve water quality by, among other  things, controlling the volume of runoff from paved surfaces and by  reducing the level of runoff pollutants to the maximum extent practicable  using best management practices (BMP).  The 1987 act also authorized  EPA to implement a program that provides federal funds and technical  assistance to states to develop their own nonpoint source pollution  management programs.  States can use the federal funds they receive for  nonpoint source programs to address nonpoint sources of pollution as well  as urban runoff.
Currently, EPA manages NPDES Storm Water programs in six states  (Alaska, Arizona, Idaho, Massachusetts, New Hampshire, and New Mexico)  and has delegated authority to the remaining 44 states to manage these  programs.  The storm water program is being implemented in two phases.   Local governments meeting the following criteria must comply with EPA’s  storm water program regulations.  First, Phase I of the program requires  that municipalities with a population of 100,000 or more obtain a permit for  their MS4 system; second, the program requires that entities obtain a  permit if they discharge storm water from sites with industrial activities,  including construction activities that disturb 5 acres or more of land.  In  addition, NPDES permitting authorities may also bring other municipalities  and industrial entities into the program if they deem it necessary.   Municipalities that meet these conditions must submit a permit application  to EPA or the governing regulatory state agency.  In 1990, the regulations  specifically identified 220 municipalities throughout the United States that  were required to apply for a Phase I permit.  According to EPA, as of April  2001, about 256 Phase 1 MS4 permits had been issued and about 17 more  still needed to be issued.  Because some permits cover more than one  municipality, these permits cover about 1,000 medium and large  municipalities nationwide.
The final rule for Phase II of the program was issued in December 1999.   Phase II extends Phase I efforts by requiring that a storm water discharge  permit be obtained by (1) operators of all MS4s not already covered by  Phase I of the program in urbanized areas and (2) construction sites that  disturb areas equal to or greater than 1 acre and less than 5 acres of land.   As with Phase I of the program, permitting authorities may require  additional small MS4s and construction sites to obtain a permit if they are a  significant contributor of pollutants.  Currently, EPA anticipates that about  5,000 municipalities may be subject to permitting requirements under  Phase II of the storm water program.  These municipalities are required to  obtain permits no later than March 10, 2003.
EPA also regulates combined sewer overflows (CSO) that can be caused by  urban storm water runoff.  Combined sewer systems, in which storm water  enters pipes already carrying sewage, may overflow when rain or snowmelt  entering the system exceeds the system’s flow capacity.  In the CSO that  results, the mixture of untreated sewage and runoff bypasses the water  treatment facility and is diverted directly into receiving waters.  (See fig. 1  for an illustration of combined and separate sewer systems.)  These  combined systems generally serve the older parts of approximately 900  cities in the United States.  Pipes carrying sewage and storm water  separately generally serve newer parts of cities.  EPA’s 1994 CSO policy  requires communities with combined sewer systems to take immediate and  long-term actions to address CSO problems.  The policy contains  provisions for developing appropriate, site-specific NPDES permit  requirements for all combined sewer systems that overflow because of wet- weather events.  The Wet Weather Water Quality Act of 2000 requires that  any permit, order, or decree issued for a CSO conform to the 1994 policy.   Under this act, EPA is also required to submit a report to the Congress by  September 2001 on the status of the program.
The Total Maximum Daily Load (TMDL) Program, established under the  Clean Water Act, is intended to address water bodies that do not meet  water quality standards because of pollutant loadings from point and  nonpoint sources.  Currently, it is unclear how and when this program will  affect EPA’s and states’ issuance of storm water permits.  A TMDL is a  calculation of the maximum amount of a pollutant that a body of water can  receive and still meet the water quality standard set by the state.  Under  EPA’s regulations, the state is to allocate this “pollutant load” among the  point and nonpoint pollutant sources that flow into the water body and  then take steps to ensure that no source exceeds its assigned load.  In 1996,  EPA issued a policy that outlined an interim approach to including water  quality standards in storm water permits.  The policy promoted the use of  BMPs in the first 5-year term permits, followed by a tailoring of BMPs in the  second round of permits as necessary to comply with water quality  standards.  Until recently, few TMDLs had been established, and citizen  organizations sued EPA for its lack of action.  EPA issued a new set of  regulations for the TMDL Program in 2000, but the Congress prevented  EPA from spending money to implement the rule in 2000 and 2001.   It is  possible that establishing a TMDL for a body of water could result in the  application of a numeric effluent limit to outfalls that release storm water  into that body of water.  Some city officials we spoke with generally felt  that numeric effluent limits would significantly increase the cost of  managing storm water.
section_title: Volume of Urban Runoff Increases With the Expansion of Urban Development and Can Affect Water Quality
paragraphs: Since World War II, urban runoff has increased throughout the United  States.  This increase is directly related to growth in the amount of  impervious surfaces due to urban and suburban development and the  construction of roads, highways, and other impervious surfaces.   Coinciding with this growth in impervious surfaces has been a reduction in  wetlands and in the amount of storm water that infiltrates the ground to  recharge aquifers.  Moreover, the loss of vegetation due to development  and related runoff can cause major erosion.  Ultimately, much of this runoff  is channeled into gutters, storm drains, and paved channels, and vegetation  and sediment removed with the runoff may end up in receiving waters.   EPA has identified urban storm water runoff as one of the leading sources  of pollution to the nation’s rivers, streams, lakes, and estuaries.  Runoff  from impervious surfaces picks up potentially harmful pollutants and  carries them into receiving waters.  Studies have shown that urban runoff  and the pollutants it carries can negatively affect water quality, aquatic life,  and public health.
subsections: section_title: Paved Surfaces Have Increased With Urban and Suburban Expansion and Growth in Automobile Use
paragraphs: According to the U.S. Department of Agriculture, between 1945 and 1997,  urban land area increased by almost 327 percent, from 15 million acres to  about 64 million acres in the contiguous 48 states.  From 1992 through 1997,  the annual rate of development averaged about 1 million acres per year.   The land developed between 1945 and 1997 came primarily from forestland  and pasture and range.  For example, according to the Bureau of the  Census, between 1960 and 1990, the amount of land used for urban  purposes in Baltimore, Maryland, and Washington, D.C., grew by about 170  percent and 177 percent, respectively.  As a result, urbanization, with its  accompanying expansion of impervious surfaces like sidewalks, roofs,  parking lots, and roads, has significantly increased the nation’s total  developed land and paved surface area.  Figure 2 demonstrates the growth  in the urbanized areas of Baltimore and Washington, D.C., over the last half  of the 20th century.
The increase in paved surfaces has been spurred not only by urban and  suburban development, but also by a steady increase in the use of  automobiles, the primary mode of daily transportation for most Americans.   Roads also play an important role in the economy of the United States,  since trucks carry about 75 percent of the value of all goods shipped.   According to EPA, paved road mileage in the United States increased by  278 percent from 1945 to 1997.  In 1945, 19 percent of the public roads in  the country were paved; by 1997, that percentage had increased to 61. (See  fig. 3.)  According to a 1999 study, motor-vehicle infrastructure, such as  roads and parking lots, accounts for close to half of the land area in U.S.  urban cities.
section_title: Increase in Impervious Surfaces Leads to Increased Runoff
paragraphs: The increase in impervious surfaces over the past several decades has led  to an increase in storm water runoff.  In part, this has occurred because  highways and other developments have reduced the amount of wetlands  and other undeveloped land.  Wetlands mitigate the effects of storm water  runoff by acting as a natural form of flood control, facilitating sediment  replenishment, and improving water quality by removing excess nutrients  and other chemical contaminants before the contaminants can affect  receiving waters.  According to a 2000 EPA report, of the 12 states that  listed wetland losses, six reported that they had significant losses due to  highway construction, and 10 reported that they had significant losses due  to residential growth and development.  However, the effect of road  building on wetland loss has been reduced in recent years.  According to a  Federal Highway Administration (FHWA) official, since 1996, wetlands  have been replaced and restored under the Federal-Aid Highway Program  at an average rate of 2.7 acres for every acre lost to highway building.   Other undeveloped land with vegetation also performs some of the roles  that wetlands play in managing runoff, although to a lesser extent.
Furthermore, as impervious surfaces increase, less storm water is able to  infiltrate through the soil to groundwater.  Impervious areas allow only a  very small amount of initial infiltration compared with unpaved areas  whose infiltration capacity varies, depending on the soil type.  Figure 4  demonstrates EPA’s estimates of the impact of impervious surfaces on the  percentages of storm water that runs off, infiltrates the ground, and is lost  through evapotranspiration.  When natural ground cover is present over  an entire site, normally 10 percent of precipitation runs off the land into  nearby creeks, rivers, and lakes.  In contrast, when a site is 75- to 100- percent impervious, 55 percent of the precipitation runs off into these  receiving waters.  However, according to an FHWA official, the runoff rates  can be reduced if developers take mitigating actions to develop and  implement BMPs to control flooding or runoff.
The decrease in storm water infiltration that accompanies urbanization  also reduces the amount of water that is available to recharge groundwater  supplies.  For this reason, reduced infiltration may lead to problems with  the water table in certain urban areas.  For example, a Massachusetts  Department of Environmental Protection official noted that a low recharge  rate affects water quality because it can result in a loss of wetlands and  adversely affect aquatic habitat as water-table levels fall during dry  weather. In addition, officials from the Charles River Watershed  Association in Massachusetts are concerned that the lack of infiltration  might cause some communities to run short of drinking water in the next  20 years.
section_title: Urban Runoff Has the Potential to Impair Water Quality and Disrupt Biological Integrity
paragraphs: Urban runoff can adversely affect the quality of the nation’s waters, and  urban storm water runoff has been identified as one of the leading sources  of pollution to rivers, streams, lakes, and estuaries.  Section 305(b) of the  Clean Water Act requires states and other jurisdictions to report on the  quality of their waters to EPA every 2 years.  The 1998 National Water  Quality Inventory Report to Congress showed that 35 percent of assessed  river and stream miles, 45 percent of assessed lake acres, and 44 percent of  assessed estuarine square miles were impaired in terms of their ability to  support uses such as aquatic life, swimming, and fish consumption.  The  report identified urban storm water runoff as one of the leading sources of  impairment to the assessed waters.
Studies have shown that as the percentage of impervious cover increases  within a watershed, biodiversity also declines.  Research conducted by the  Center for Watershed Protection found that, generally speaking, when a  watershed has 10 percent or less impervious cover, the associated stream  can be categorized as sensitive.  Sensitive streams are characterized as  having high fish diversity and good water quality.  Once the percentage of  impervious cover exceeds 25 to 30 percent of the watershed, however,  streams tend to become nonsupporting.  Nonsupporting streams are highly  unstable, have poor diversity of fish and aquatic life, and have poor water  quality.  For example, one study evaluated the relationship between the  extent of impervious cover in watersheds to the number and diversity of  fish populations in 47 small streams in southeastern Wisconsin between the  1970s and 1990s.  The results revealed that the number of fish species per  site was highly variable for drainage areas that had less than 10-percent  imperviousness.  In contrast, sites that had greater than 10-percent  imperviousness had consistently low numbers of fish species.
Other studies have associated urban runoff with basic changes in the  receiving body of water.  Runoff can carry sediment into surface water, and  this sediment can carry contaminants, harm aquatic plants, and smother  organisms.  Runoff can also be warmed by the impervious surfaces it flows  across.  When sufficient amounts of warmed runoff enter a water body, the  water temperature can rise.  Less oxygen is then available for aquatic  organisms because water holds less oxygen as it becomes warmer.  These  combined factors lead to the degradation of aquatic habitat.  According to  EPA, the common effects of these types of pollution on aquatic life include  a decline in biodiversity and an increase in invasive species.
An increase in the volume of storm water runoff also increases the  likelihood of erosion, which allows for transport of eroded sediment  downstream into receiving waters.  For example, during a site visit, we  observed extensive erosion along the Gingerville Creek Subbasin in Anne  Arundel County, Maryland, that was caused by urban runoff channeled into  the creek.  Figure 5 depicts the eroded banks and channel of this creek.
section_title: Contaminants in Urban Runoff Can Affect Aquatic Life and Human Health
paragraphs: There have been several efforts to characterize the chemicals and other  constituents in urban runoff.  The Nationwide Urban Runoff Program,  conducted by EPA between 1978 and 1983, examined the characteristics of  urban runoff.  Another federal effort to characterize urban runoff is an  ongoing joint project of the U.S. Geological Survey (USGS) and the FHWA  to evaluate guidelines for highway runoff.  As table 1 indicates, these  studies and others have shown that the principal contaminants found in  urban runoff include nutrients, solids, pathogens, metals, hydrocarbons,  organics, salt, and trash.  Water flowing over various surfaces, such as  streets, parking lots, construction sites, industrial facilities, rooftops, and  lawns, carries these pollutants to receiving waters.  The contaminants have  the potential to impair water quality, degrade aquatic ecosystems, and pose  health risks to swimmers.
In our visits to cities with Phase I permits and their watersheds, we  identified specific instances in which these contaminants had affected  water quality.  The Chesapeake Bay, for example, has been polluted with  the nutrients nitrogen and phosphorus and with excess sediment caused, in  part, by urban runoff.  The excess nutrients cause algae blooms that block  sunlight from reaching bay grasses—which are a source of food, shelter,  and nursery grounds for many aquatic species.  In an effort to control  nutrient pollution in the Chesapeake Bay, the Executive Council of the  Chesapeake Bay Program established a goal to reduce the nitrogen and  phosphorus entering the Chesapeake Bay by 40 percent, including through  control of runoff from urban areas.  In addition, an assessment of the status  of chemical contaminant effects on living resources in the bay’s tidal rivers  found “hot spots” of contaminated sediment.  As a result, the Baltimore  Harbor and the Patapsco River in Maryland; the Anacostia River in  Washington, D.C.; and the Elizabeth River in Virginia were designated as  “regions of concern.”  Urban storm water runoff is a significant source of  contaminants in the three regions.  The Chesapeake Executive Council has  committed to reduce by 30 percent the chemicals of concern in the regions  of concern by 2010 through pollution prevention measures and other  voluntary means.
Pathogens such as bacteria and viruses, which are often present in urban  runoff, can pose public health problems.  For example, the Santa Monica  Bay Restoration Project conducted a study to identify adverse health  effects of untreated urban runoff by surveying over 13,000 swimmers at  three bay beaches.   The study established a positive association between  an increased risk of illness and swimming near flowing storm-drain outlets.   Table 2 explains health outcome measures at various distances from storm  drains.  For example, the study found a 1-in-14 chance of fever for  swimmers in front of the drain versus a 1-in-22 chance at 400 or more yards  away.
Metals and polycyclic aromatic hydrocarbons (PAH) in urban runoff can  present a threat to aquatic life.  Studies have found the following:  Storm water runoff from an urban area proved to be toxic to sea urchin  fertilization in the Santa Monica Bay, and dissolved zinc and copper  were determined to be contributors to this toxicity.
Brown bullheads (a bottom-dwelling catfish) in the Anacostia River  developed tumors that were believed to be caused by PAHs associated  in part with urban runoff.
High PAH and heavy metal concentrations were found in crayfish tissue  samples from several urban streams in Milwaukee.  The study  associated these contaminants with storm water runoff.
In addition, USGS tracked trends in the concentrations of PAHs found in  sediment in 10 lakes and reservoirs in six metropolitan areas over the last  several decades.  This study found that PAH concentrations in developed  watersheds are increasing and that these increases may be linked to the  amount of urban development and vehicle traffic in urban and suburban  areas.  For example, from 1982 to 1996, PAH concentrations in the  sediment core in Town Lake (Austin, Texas) and total miles driven in  greater Austin both increased by about 2.5 times.  Figure 6 illustrates this  correlation.
Although the studies we reviewed show that certain contaminants are  likely to be present in urban runoff, factors such as land development  practices, climate conditions, atmospheric deposition, and traffic  characteristics all can affect the characteristics of runoff from a particular  area.  Therefore, given the diffuse nature of many storm water discharges  and the variability of other contributing factors, characterizing the  concentrations of pollutants contained in storm water runoff has been  challenging.  Recent USGS reports also suggest that improvements are  needed in the methods used to analyze sediment and metals in runoff.
section_title: Local Governments Take Actions to Manage Urban Storm Water Runoff, but Information Is Limited on the Cost and Effectiveness of These Actions
paragraphs: To comply with federal and state storm water management for Phase I  permitting requirements, permitted municipalities must create and  implement storm water management programs.  The three primary  activities used in these programs include efforts to characterize storm  water runoff; BMPs aimed at reducing pollutants in storm water runoff to  the maximum extent practicable; and reporting program activities,  monitoring results, and costs of implementing the program.  Some BMPs  are structural—meaning that they are designed to trap and detain runoff  until constituents settle or are filtered out.  Other BMPs are  nonstructural—meaning that they are designed to prevent contaminants  from entering storm water through actions like street sweeping and  inspections.  Many permitted municipalities use specialized BMPs tailored  to address particular runoff problems in their locations.  Over 1,000 cities  are undertaking these efforts under the NPDES Storm Water Program, but  information on the overall costs of managing urban runoff and the  effectiveness of the actions taken is limited.  EPA’s attempts to forecast  costs have not encompassed the entire program or are out of date.  In  addition, the permitted municipal agencies we visited estimated their  annual storm water management costs and reported them to state agencies  or EPA, but the approaches they used to calculate these estimates varied  considerably, making it difficult to draw any conclusions.  Although EPA  and state agencies believe that the program will be effective in improving  water quality, EPA has not made a systematic effort to evaluate the  program.  Without such an effort, EPA cannot tell what effect the program  is having on water quality nationally.
subsections: section_title: Municipalities Comply With Federal and State Requirements Through Monitoring, Best Management Practices, and Reporting
paragraphs: The NPDES Storm Water Program requires municipalities operating under  a Phase I MS4 permit to characterize and monitor storm water runoff,  implement BMPs to reduce pollutants to the maximum extent practicable,  and report costs and monitoring results to the permitting authorities.   Because of these requirements, local governments have generally shifted  the focus of their storm water management from water quantity control or  flood management to water quality concerns.
Besides following the basic federal requirements, municipalities must  follow any additional regulations developed by states that have been  delegated the authority to manage the NPDES Storm Water Program.  For  example, Wisconsin’s Department of Natural Resources broadened the  requirements for determining which municipalities must get permits.  The  state requires local governments with storm sewer systems in priority  watersheds (based on the significance of storm water runoff as a pollutant  source) that serve a populace of 50,000 or more to obtain a permit with  requirements similar to those for a Phase I permit.  Wisconsin’s Department  of Natural Resources also requires municipalities that are located in one of  the state’s five Great Lakes Areas of Concern to obtain a state permit.   Furthermore, in line with specific criteria in Wisconsin’s Administrative  Code, the state requires other municipalities to obtain a permit if the  municipality is found to significantly contribute storm water pollutants to  waters of the state.  These various requirements increased the number of  municipalities that must get permits from the two under federal  requirements to over 70 under the states’ requirements.
The local governments we reviewed were undertaking three primary  activities when applying for permits and implementing their storm water  management programs.  Specifically, these activities were (1)  characterizing storm water runoff; (2) developing BMPs to reduce  discharges of pollutants to the maximum extent practicable; and (3)  reporting program activities, monitoring results, and reporting program  costs.
First, to characterize runoff, applicants are to provide quantitative data that  describe the volume and quality of discharges from municipal storm  sewers.  For example, cities must map all storm sewer outfalls—an  undertaking that one group representing cities described as significant.   After the permit application is approved, additional monitoring is required  throughout the life of the permit to facilitate the design of effective storm  water management programs and to document the nature of the storm  water.  The local governments we visited were all monitoring for a variety  of purposes, including characterizing runoff from different types of land  use in order to target their BMPs, testing the effectiveness of a particular  BMP, or establishing a baseline for their storm water quality evaluations.
Second, the storm water management programs that local governments  develop focus on implementing BMPs. While active treatment, such as  sending storm water through a treatment facility, is a possible BMP, the  cities we visited were generally not using active treatment.  EPA’s February  2000 report on the Phase I program described the program as based on  the “use of low-cost, common-sense solutions.” The five cities we visited  were generally using similar types of structural and nonstructural BMPs, as  follows:   Structural BMPs are designed to separate contaminants from storm  water.  For example, detention ponds temporarily hold storm water  runoff to allow solids and other constituents in the runoff to settle  before the water is released at a predetermined rate into receiving  waters.  In addition, catch-basin inserts, placed in a storm drain, catch  trash and other debris, and particle separators, placed beneath the  surface of an impervious area such as a parking lot, separate oils from  runoff and allow sediment and debris to settle.  Structural devices such  as these require regular maintenance to function properly and remain  effective.
Nonstructural BMPs are primarily designed to minimize the  contaminants that enter storm water.  These nonstructural BMPs  include  “good housekeeping” practices by the local government, such as oil  collection and recycling, spill response, household and hazardous  waste collection, pesticide controls, flood control management, and  street sweeping;   public education programs, such as storm-drain stenciling, to remind  the public that trash, motor oil, and other pollutants thrown into  storm drains end up in nearby receiving waters; new ordinances to control pollution sources, such as prohibiting the  disposal of lawn clippings in storm drains and requiring pet owners  to clean up after their pets;    requirements that developers comply with storm water regulations  and incorporate erosion and sediment controls at all new  development sites;  requirements that runoff from properties owned or activities  sponsored by the municipality be properly controlled; and   efforts to identify and eliminate illicit connections and illegal  discharges to the storm sewer systems, such as those from pipes  carrying sewage.
We found that the NPDES Program’s requirements allowed local  governments to tailor their storm water management efforts to prioritize  local concerns, such as a particular type of contaminant, a particular  climatic condition, or a particular body of water.  Some cities also  developed specialized BMPs to address these concerns.  The following  information highlights specific storm water-related concerns in the five  cities we visited and the specialized BMPs these municipalities have  developed to address these particular concerns.  (See apps. I to V for  additional information on these cities’ storm water management  programs.)
In Baltimore, Maryland, excessive levels of nutrients, particularly  phosphorus and nitrogen, are among the city’s major water quality  concerns because of the city’s participation in the Chesapeake Bay  Program.  Baltimore City agreed to assist the state in reaching the  Chesapeake Bay Program’s goal to reduce nutrients discharged to the  bay by 40 percent by the year 2000.  According to a Chesapeake Bay  Program Office representative, as of March 2001, the program has not  met this goal but expects to reach it within the next several years.
In Boston, Massachusetts, the Boston Water and Sewer Commission,  which holds the permit for Boston’s storm sewer system, is concerned  about runoff from roadways, especially runoff containing salt and sand  used in the winter months and dissolved metals (copper and zinc) from  automobiles.  In September 2000, the commission began a 3-year  program to develop and implement a citywide catch-basin inspection,  cleaning, and preventive maintenance program.  The program will also  include the development of a database and map that can be linked to the  commission’s Geographic Information System.
Los Angeles County, California, is responding to a TMDL for trash in  the Los Angeles River Watershed that will require the county, over a 10- year period, to eliminate trash in runoff.  The county is testing a variety  of devices that remove trash from runoff and specialized catch-basin  devices that are designed to prevent trash from ever reaching the storm  sewers.
Milwaukee, Wisconsin, changed its monitoring and public education  activities in its recent permit to test the effectiveness of a BMP targeting  public education efforts to a specific community.  The new permit also  requires a monitoring program aimed at the community, its associated  watershed, and city employees who work in the area.
Worcester, Massachusetts, had a significant problem with illicit  connections to its storm sewers and with flow in these sewers during  dry weather. Worcester’s Department of Public Works (DPW) screened  71 of its storm water outfalls and determined that 32 of them had  drainage areas that carried both sanitary sewage and storm drainage in  separate conduits through common manholes.  DPW has retrofitted over  65 percent of the manholes to prevent sewage from mixing with storm  water.
Third, local governments participating in the Phase I program are required  to report annually to EPA or the state regulatory agency on their storm  water programs.  These reports are to include a status report on the  program; a summary of data, including monitoring results collected during  the reporting year; information on annual expenditures on the program and  a budget for the coming year; and a description of any water quality  improvements or degradation.
section_title: Information on the Costs of Addressing Storm Water Runoff Is Limited
paragraphs: Good information about the cost of implementing federal storm water  requirements is limited.  EPA conducted a survey to estimate the nation’s  future water infrastructure needs over a 20-year period—from 1996 to 2016.    In its 1996 report, EPA estimated that states would require over $50 billion  to meet their current (as of 1996) water infrastructure needs.  The estimate  consists of storm water management needs (at $7.4 billion) and CSO needs  (at $44.7 billion).  EPA noted, however, that estimated storm water  management needs are likely too low and could increase following an  analysis of data collected to prepare the agency’s 2000 clean water needs  survey—to be released in 2002.  According to EPA, many cities have  implemented the Phase I program since EPA reported to the Congress in  1996, and municipalities should now be better able to provide documented  cost data.  As a result, EPA will need to rely less on modeled storm water  needs than it did in the 1996 needs survey.   EPA did not project the costs  and benefits of the program when it was initiated; therefore, no initial cost  estimates are available.  When EPA promulgated the Phase I program  regulations in 1990, the agency decided that the storm water program did  not meet the requirements for preparing a benefit/cost analysis.
The costs to local governments of complying with the Phase I program  have generally been portrayed as high.  However, because of  inconsistencies in cost accounting and reporting practices, we could not  determine the cost of the program to several of the cities we visited.   Although municipalities are required to provide information on the  expenditures that they anticipate will be needed to implement their storm  water management programs for each fiscal year covered by the permit,  EPA has not issued any cost reporting guidelines.  Consequently, while the  reported fiscal year 1999 total cost to manage and treat storm water runoff  across the five municipalities in our review ranged from less than $1 million  (Milwaukee) to $135 million (Los Angeles County), these numbers are not  comparable because the municipalities did not have consistent cost  accounting and reporting practices and did not fully express storm water  management costs. For example, some cities reported only the costs of  activities that were funded by the city department that held the permit.   Significant activities funded by other city departments were not reported,  even if they were important components of the storm water program.   Officials in the Milwaukee Department of Infrastructure Services and the  Boston Water and Sewer Commission told us that other city departments  perform and fund activities such as street sweeping and flood control.  The  costs of these activities are not reported as storm water program costs  because the activities serve other purposes besides preventing storm water  pollution.
In addition, according to some city officials, these activities were in place  before the permit was issued and, therefore, cannot be characterized solely  as storm water costs.  The cost of street sweeping can be significant—for  fiscal year 1999, Baltimore City and Worcester, which did include street- sweeping costs in their storm water program’s cost estimate, stated that  their street-sweeping expenses totaled about $9.5 million and $1.2 million,  respectively.  Similarly, Milwaukee did not report the cost of a significant  project related to storm water runoff because it was mostly funded by the  state of Wisconsin.
An EPA official told us that the agency had not yet made a national effort to  analyze the information that Phase I permittees submitted on the costs of  their storm water programs.  This official cited the inconsistent formats of  the annual reports as a reason that the information was not readily  available at the national level and also indicated that adequate staff are not  available to analyze the data.  In addition, other EPA officials informed us  that the Office of Wastewater Management must divide its resources among  a number of issues that will challenge the agency’s water program over the  next decade.
Several officials in the cities we visited said that their annual costs are  likely to increase. A number of factors could affect the costs.  For example,  a Baltimore City official explained that the anticipated, future program  costs depend on several factors, including (1) requirements in watershed- management plans currently being developed, (2) pollution-reduction goals  the city will be required to achieve, (3) requirements of the state regulatory  agency in future permits, and (4) requirements the city may have to meet if  TMDLs or numeric effluent limits are incorporated into NPDES storm  water permits.  Other city officials also expressed concern about the extent  to which TMDLs could affect their future costs.  These city officials are  concerned that when and if TMDLs are established, their future storm  water permits may require that storm water runoff meet specific water  quality standards.  For example, Los Angeles County’s trash TMDL could  potentially drive the county’s storm water management costs upward, and  the county expects additional TMDLs to be imposed.  On the other hand,  Worcester officials estimated that their future storm water costs would be  about the same as they were at the time of our review—about $4.5 million  per year.
In a separate analysis, EPA estimated in 1999 that it will cost Phase II  municipalities about $848 million to $981 million per year (in 1998 dollars)  to manage storm water runoff.  Because Phase II permits have not been  issued as of May 2001, we did not gather any cost information on them from  these cities.
section_title: Funding for Managing Storm Water Runoff Is Available From Local and Federal Sources
paragraphs: The five cities we visited had not generally obtained federal funds for their  storm water management efforts.  They used local sources, including  general revenues, bonds, revenue from specifically created storm water  utilities, state grants, and inspection and permit fees.
While several sections of the Clean Water Act provide funding that can be  used for municipal storm water control, relatively few federal funds have  been directed to these types of projects.  The most significant source of  funds is the state revolving loan funds administered by states.  These  revolving loan funds provide loans for eligible storm water control  projects.  In some cases, nonpoint source projects may also qualify for  funding when storm water permits are not required or issued.  However,  municipal storm water management is generally a low priority in these  programs.  Specifically, in the year 2000, revolving fund loans were made in  the “storm sewers” category in the amount of $38.76 million for 44 different  projects.   These funds represented less than 1 percent of the amounts  loaned from these revolving funds that year.  Activities eligible for  revolving fund loans include constructing BMPs to control runoff, but  support for ongoing operations and maintenance is not eligible.  Revolving  fund loans can also be used for eligible CSO control projects.  In 2000,  Clean Water State Revolving Fund Program loans were made in the “CSO  Correction” category of a national EPA database in the amount of $411.3  million for 69 different projects and could have been used for CSO or  sanitary sewer overflow projects.  This amount represented about 9  percent of the funds loaned in 2000.
According to EPA, the agency also issues grants to universities and other  research institutions to help implement the storm water program.  Some of  these grants provide training and guidance to Phase I permittees on  watershed protection and the proper selection of BMPs.
Other sources of funding may be available to local governments beginning  in 2002.  In December 2000, the Congress authorized programs for fiscal  years 2002 through 2004 to provide grants to local governments for (1) pilot  projects for managing municipal CSOs, sanitary sewer overflows, and  storm water discharges on a watershed basis and for testing BMPs and (2)  controlling pollutants from MS4s to demonstrate and determine cost- effective, innovative technologies for reducing pollutants from storm water  discharge.  EPA’s proposed budget does not request funds for these  programs.  In addition, the Congress authorized programs for fiscal years  2002 and 2003 to provide grants to local governments for planning,  designing, and constructing treatment works to intercept, transport,  control, or treat municipal CSOs and sanitary sewer overflows.  EPA’s  proposed budget requested $450 million for this program.
section_title: EPA, States, and Local Governments Believe the NPDES Storm Water Program Is Effective, but It Has Not Been Evaluated
paragraphs: EPA, state, and municipal officials generally believe that the NPDES Storm  Water Program will improve water quality.  These officials believe that the  program will result in more bodies of water that meet water quality  standards, improved aesthetic conditions, reduced risk from bacterial  contamination, and improvements attributable to the discovery and  management of pollutants in storm water that otherwise would have gone  unnoticed.   EPA attempted to put a dollar value on these benefits in its  benefit/cost analysis prepared for the Phase II storm water regulations,  estimating that such benefits could range from $672 million to $1.1 billion  per year (in 1998 dollars).
However, little information is currently available on the benefits of the  storm water program or its general effectiveness.  There is no doubt that it  will take time for the results of the Phase I program to be demonstrated.  As  EPA notes in its February 2000 report to the Congress, pollution control  efforts under water quality management programs produce long-term  changes, and the agency expects water quality improvements attributable  to the Phase I program to become evident in the future, as the program  matures.  In this report, EPA concluded that the program has improved  storm water management at the local level, improved water quality, and  decreased pollutant loads in storm water.  However, EPA relied on a survey  of only nine Phase I cities in making these conclusions and, therefore, also  reported that the agency could not provide national estimates on water  quality protection and improvements generated by Phase I of the program.   To evaluate the entire program, EPA would have to establish goals for the  program that are based on its mission; obtain information about the  program’s results; compare the results with the goals; and make changes to  the program, if warranted, to get closer to achieving the agency’s goals.
EPA and the states also have not taken advantage of information that is  available to evaluate the program.  Each city we visited was regularly  monitoring its storm water to establish baseline information on pollutant  levels and was reporting this information to EPA or the regulatory state  agency each year.  Although cities with Phase I permits are required to  report on their storm water monitoring results and changes in water  quality, overall, EPA and the states have not successfully developed  measurable goals for the program or demonstrated its effectiveness  through the review of municipal reports.  An EPA official said that some  states had requested funding to analyze program data because they did not  have the resources to do so, and that EPA had provided the funding in a few  cases.  EPA also has not established any guidelines for how these data  should be reported.  Therefore, the reports may be as variable as the cost  information we obtained in our five site visits.
EPA has not yet taken any of these data-analysis steps because, according  to EPA officials, other program challenges within the Office of Wastewater  Management compete with storm water management efforts for priority.   For example, EPA officials stressed that available resources within the  office must address other significant wet-weather pollution problems, such  as CSOs and sanitary sewer overflows, and nonpoint source pollution  problems, such as agricultural practices, forestry, and mining.  One agency  official noted that the highest priority is addressing needs that the agency  and local governments have identified for improving wastewater  infrastructure, such as sewage treatment facilities.  The program also has  relatively few staff assigned—about five in the headquarters office and  about 10 in the regional offices—for the municipal, industrial, and  construction portions of the program.  In a program plan recently prepared  for the storm water program, EPA estimated that nine to 10 staff would be  needed in EPA headquarters to evaluate the program and implement other  program requirements.
EPA officials described two efforts that may be the first steps in developing  better information about the program.  First, EPA intends to issue a grant to  the University of Alabama in June 2001 to evaluate monitoring data  submitted by a sample of municipalities with Phase I permits.  This effort  will (1) determine the different types of monitoring being conducted by  Phase I municipalities, (2) assess water quality in and around permitted  municipalities and determine any correlation between program  implementation and impacts on water quality, and (3) recommend  approaches for improving the effectiveness of municipal storm water  monitoring programs.  EPA expects the results of this study in 2003.   Second, an EPA official stated that the agency would like to establish a  system for analyzing program findings, incorporating necessary changes  that are based on these findings, and evaluating the program’s  effectiveness.  The agency plans to implement a pilot project in 2001 in the  agency’s Atlanta Region IV office for analyzing data reported in annual  reports and developing key indicators for the program.  If this project is  successful and resources are available, the project could be expanded.
section_title: Conclusions
paragraphs: EPA regards urban runoff as a significant threat to water quality across the  nation and considers it to be one of the most significant reasons that water  quality standards are not being met nationwide.  Prompted by the  Congress, EPA has responded with a variety of programs, including the  NPDES Storm Water Program, which requires more than 1,000 local  governments to implement storm water management programs.  Those  municipalities that are currently involved in Phase I of the program have  been attempting to reduce pollutants in storm water runoff for several  years.  It is time to begin evaluating these efforts.  However, EPA has not  established measurable goals for this program.  In addition,  the agency has  not attempted to evaluate the effectiveness of this program in reducing  storm water pollution or to determine its cost.  The agency attributes this  problem to inconsistent data reporting from permitted municipalities,  insufficient staff resources, and other competing priorities within the  Office of Wastewater Management.  Although Phase I municipalities report  monitoring and cost data to EPA or state regulatory agencies annually,  these agencies have not reviewed this information to determine whether it  can be of use in determining the program’s overall effectiveness or cost.   Our analysis shows that the reported cost information will be difficult to  analyze unless EPA and its state partners set guidelines designed to elicit  more standardized reporting.  Better data on costs and program  effectiveness are needed—especially in light of the Phase II program that  will involve thousands more municipalities in 2003.  EPA’s planned research  grant to the University of Alabama and its pilot project in the agency’s  Region IV to analyze data from annual reports and develop baseline  indicators is a step in the right direction and could point the way for a more  comprehensive approach.
section_title: Recommendation
paragraphs: To determine the extent to which activities undertaken through the NPDES  Storm Water Program are reducing pollutants in urban runoff and  improving water quality, and the costs of this program to local  governments, we recommend that the Administrator, EPA, direct the  Assistant Administrator for the Office of Water to   establish measurable goals for the program;  establish guidelines for obtaining consistent and reliable data from local  governments with Phase I permits, including data on the effects of the  program and the costs to these governments;   review the data submitted by these permittees to determine whether  program goals are being met and to identify the costs of the program;  and  assess whether the agency has allocated sufficient resources to oversee  and monitor the program.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to EPA and DOT for their review and  comment.  EPA generally agreed with the report and with the  recommendation, although it did not explicitly comment on all parts of it.   (EPA’s comments appear in app. VI.)  In response to our recommendation  that EPA set measurable goals for the storm water program, EPA stated  that under the second phase of the program, local governments will  establish their own goals.  Although this is an important activity, EPA will  have difficulty evaluating the program’s effectiveness at a national level  without setting goals that reflect the program’s mission of improving water  quality.  The agency (1) agreed that it should establish guidelines for  obtaining consistent and reliable data from local governments about their  programs and (2) plans to award grants to two universities for reviews of  monitoring data reported by local governments.  EPA did not comment on  whether local governments should report on the costs of their programs.    EPA also agreed that it and its state partners should review data reported  by local governments to determine whether the program’s goals are being  met.  In April 2001, EPA officials told us that the agency planned to  undertake a project in the Region IV (Atlanta) office to evaluate the  methods local governments are using to control storm water.  EPA’s letter  indicates that the agency now plans to implement this project in three  regional offices and 10 states.   EPA did not comment on the part of our  recommendation that the agency review the level of resources devoted to  overseeing and monitoring the program.  EPA also provided technical  comments that we incorporated where appropriate.
DOT generally agreed with the draft report and provided technical  comments that we incorporated where appropriate.  In particular, DOT  suggested that we revise several references in the draft report to paved  surface area and its relationship to increases in urban runoff, to emphasize  that impervious surfaces, of which paved surfaces are a significant subset,  cause increases in runoff.  We revised the language in these places.
As agreed with your offices, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 7 days after the  date of this report.  At that time, we will send copies of this report to the  Administrator, Environmental Protection Agency, and the Secretary of  Transportation.  We will make copies available to others on request.  If you  or your staff have any questions about this report, please call me at (202)  512-2834.  Key contributors to this report are listed in appendix VII.
section_title: The Storm Water Program in Baltimore City, Maryland
paragraphs: Baltimore City’s municipal separate storm sewer system (MS4) is regulated  by the Maryland Department of Environment (MDE) and, according to a  city official, services the entire city.  The city is currently implementing its  second, 5-year National Pollutant Discharge Elimination System (NPDES)  permit, issued on February 8, 1999.  Before obtaining the first NPDES  storm water permit in 1993, Baltimore City addressed the adverse affects of  storm water runoff by implementing Maryland’s Storm Water Management  Program and Erosion and Sediment Control Program.  According to the  2000 census, Baltimore City’s population is about 651,000.
subsections: section_title: Urban Runoff Problems in Baltimore City
paragraphs: Baltimore City’s urban runoff discharges to four major areas—Gwynns  Falls, Jones Falls, Herring Run, and the Patapsco River—and then  ultimately to the Chesapeake Bay.  In 1990, the Environmental Protection  Agency’s (EPA) 319(a) report implicated urban runoff as the main source  of pollution in these waters.  Moreover, Baltimore City was one of the areas  studied in EPA’s Nationwide Urban Runoff Program in the 1980s.  This  study reported that urban runoff contributed over 60 percent of the total  nitrogen, phosphorus, and organic carbon; over 70 percent of the chemical  oxygen demand; and over 80 percent of the total suspended solids, lead,  and zinc in local water bodies.
An MDE official told us that nutrients, zinc, and suspended solids are  among the constituents most commonly found in urban runoff, but the  quantitative contribution to water quality impairment in the state’s waters  was not known.  Also, in 1996, the Chesapeake Executive Council  designated the Baltimore Harbor as one of three toxic regions of concern in  the Chesapeake Bay.  The harbor suffers from sediment contaminated by  banned substances (such as the termiticide chlordane) and contaminants  currently being released (such as metals and organics).  Furthermore,  according to the Chesapeake Bay Program Office, data collected from  Phase I permittees indicate that storm water runoff can be a significant  source of metals and organics in the harbor.
A Baltimore City official told us that some portions of Maryland’s waters  are impaired because of unacceptable levels of nutrients, metals,  suspended sediments, and chlordane.  Moreover, this official noted that the  state does not consider data that municipalities collect under their NPDES  storm water permits during the 303(d) listing process.  Therefore, he  believes that streams in Maryland are much more impaired than indicated  by the listing process.
section_title: Baltimore City’s Use of Best Management Practices
paragraphs: Like other NPDES storm water permit holders, Baltimore City uses a  variety of best management practices (BMP) to reduce the amount of  pollutants in runoff to the maximum extent practicable.  These BMPs  include detention ponds, shallow marshes (which use the biological and  naturally occurring chemical processes in water and plants to remove  pollutants), sand filter devices, public education programs, and the  identification of illicit discharges to the MS4 system.  Furthermore,  Baltimore City participates in Maryland’s effort to reduce nutrient levels in  the Chesapeake Bay.  Refer to the section of this report describing local  government efforts to manage storm water for details concerning this  nutrient-reduction goal.  One other BMP includes the following:  Baltimore City has incorporated the 2000 Maryland Storm Water  Design Manual’s management policies, principles, methods, and  practices into its current NPDES storm water discharge permit.  The  purpose of the design manual is to (1) protect the waters of the state  from the adverse effects of urban storm water runoff; (2) provide design  guidance on the most effective structural and nonstructural BMPs for  development sites; and (3) improve the quality of BMPs that are  constructed in the state, with particular attention to their performance,  longevity, safety, ease of maintenance, community acceptance, and  environmental benefit.
section_title: Costs Associated With Managing Storm Water
paragraphs: We were not able to obtain comprehensive information on the total cost to  Baltimore City of managing storm water.  Therefore, we do not present that  information here.
section_title: Funding Sources
paragraphs: Baltimore City funds its storm water management control efforts with city  water and sewer user fees and with state funds.
section_title: The Storm Water Program in Boston, Massachusetts
paragraphs: The Boston Water and Sewer Commission received a NPDES storm water  permit in October 1999.  The commission is a separate entity from the city  of Boston and, therefore, does not manage some storm water controls that  are common in Phase I permits, such as street sweeping, winter deicing,  and many of the urban runoff controls required for new developments.  Boston has combined sewer systems as well as separate sanitary sewers  and storm drains.  The commission maintains 206 storm water outfalls and  serves approximately 33 percent of the city through its separate MS4  system.  In addition to the resident population of about 589,000, this system  also almost daily serves 340,000 commuting workers; 70,000 shoppers,  tourists, and business people; and 75,000 commuting students.  The  commission’s sanitary and combined flows are transported to the  Massachusetts Water Resources Authority at Deer Island.  The commission  is also the permittee for EPA’s Combined Sewer Overflow Program.
subsections: section_title: Urban Runoff Problems in Boston
paragraphs: The commission considers the identification and elimination of illegal  sanitary sewer connections as the most effective means of improving water  quality and protecting public health.  It is also concerned with the washoff  of animal wastes from residential and open land, which is another major  contributor to the impairment of water quality because it can cause an  increase in coliform levels in the storm water discharges to the receiving  waters.
The commission has contracted for various studies to determine the impact  of storm water runoff.  The following two studies identified sources of  bacterial contamination and characterized the quality of storm water  discharged from different types of land uses.  The studies included  metering storm water flows, collecting and analyzing the storm water and  receiving water quality samples, and identifying and remediating illegal  sewer connections.  Observations from the studies include the following:  A 1996 study determined that pet waste, rather than sanitary sewage,  was a key contributor of bacteria to the storm drain system that had  possibly led to beach closings in the area.
A 1998 study identified several illegal connections to the storm drain  system.  Furthermore, the study showed that deicing and sanding efforts  resulted in levels of  sodium, chloride, total dissolved solids, and  cyanide that exceeded EPA’s acute (high dose) toxicity levels.
section_title: Boston’s Use of Best Management Practices
paragraphs: To meet the NPDES permit’s requirements, the commission, like other  permittees, continued BMPs, such as identifying illegal connections, and  implemented new BMPs aimed at preventing the discharge of pollutants to  storm drains and receiving waters.  Refer to the section of this report  describing local government efforts to manage storm water for details  describing the commission’s citywide catch-basin inspection cleaning and  preventative maintenance program.  Other efforts include the following:   The commission has placed particle separators, which remove oil,  grease, and sediments from storm water flows, throughout the city.  The  commission requires particle separators to be installed by developers on  all newly constructed storm drains that serve outdoor parking areas.   Fuel-dispensing areas not covered by a canopy or other type of roof  enclosure must also have a particle separator.
The commission requires developers to consider on-site retention of  storm water for all new projects, wherever feasible.  On-site retention  aids in controlling the rate, volume, and quality of storm water  discharged to the commission’s storm drainage system.
section_title: Costs Associated With Managing Storm Water
paragraphs: We were not able to obtain comprehensive information on the total cost to  the commission of managing storm water because the commission does  not separate the cost of its storm water program from the cost of its sewer  operations.  Therefore, we do not present that information here.
section_title: Funding Sources
paragraphs: The commission funds its storm water management control efforts  primarily with city water and sewer user fees and bond proceeds.
section_title: The Storm Water Program in Los Angeles County, California
paragraphs: Under the NPDES Storm Water Program, the Los Angeles Regional Water  Quality Control Board issues 5-year permits to Los Angeles County for its  municipal storm water program.  The Los Angeles County permit, issued in  July 1996, is the county’s second storm water permit.  This permit includes  Los Angeles County as the principal permittee and 85 cities as permittees.   According to the 2000 census, Los Angeles County’s population is about 9.5  million.
subsections: section_title: Urban Runoff Problems in Los Angeles County
paragraphs: The effects of urban runoff on the ocean are of particular concern in  southern California. Contaminated sediments, impaired natural resources,  and potential human illness could threaten the county’s tourism economy,  estimated to be about $2 billion a year.
The following three studies have shown that urban runoff can pose health  risks to swimmers near storm drains and contribute toxic metals to  receiving water sediments:  The Santa Monica Bay Restoration Project conducted a study to assess  the possible adverse health effects of swimming in waters contaminated  by urban runoff.  This study revealed that there is an increased risk of  illness associated with swimming near flowing storm drain outlets and  an increased risk of illness associated with swimming in areas with high  concentrations of bacteria indicators.  Furthermore, illnesses were  reported more frequently on days when the samples were positive for  enteric viruses.  Refer to the section of this report describing the effects  of runoff on aquatic life and human health for more details.
Τhe Southern California Coastal Water Research Project coordinated a  study that assessed microbiological water quality and found that the  majority of shoreline waters exceeded water quality standards during  wet-weather conditions.  Furthermore, the ocean waters near storm  water outlets demonstrated the worst water quality regardless of the  weather.
The Southern California Coastal Water Research Project also compared  the runoff from an urban area and a nonurban area in the Santa Monica  Bay Watershed.  The results of the study indicated that storm water  plumes extended up to several miles offshore and persisted for a few  days.  Furthermore, the runoff from the urban area proved to be toxic to  sea urchin fertilization, and dissolved zinc and copper were determined  to be contributors to the toxicity.  The study also found that in urban  areas, sediments offshore generally had higher concentrations of  contaminants such as lead and zinc.
section_title: Los Angeles County’s Use of Best Management Practices
paragraphs: As in the other sites we visited, the county is managing its runoff through  the use of conventional BMPs.  These BMPs include the elimination of  illicit connections and discharges to the storm sewer system, construction  control measures, routine inspections, staff training, pollution prevention  plans for public vehicle maintenance and material storage facilities,  sweeping and cleaning public parking facilities, street sweeping, catch- basin cleaning, and public education.
The Los Angeles Regional Water Quality Control Board recently adopted a  Total Maximum Daily Load (TMDL) Program to reduce trash loads to the  Los Angeles River.  As a result, the county is exploring a number of trash  reduction BMPs, which are discussed in the section of this report  describing local government efforts to manage storm water.
section_title: Costs Associated With Managing Storm Water
paragraphs: Table 3 indicates that the county and the other permittees have allocated  significant funding for storm water management activities over the years.   For example, for fiscal year 1999, projected funding for storm water  management activities for the county and the other permittees amounted to  over $134 million.  The largest projections for both went toward public  agency activities.  For example, during fiscal year 1999, the principal  permittee and the permittees together projected almost 67 percent of storm  water management funds to public agency activities.  The activities in this  program include staff training, inspections of construction projects, street  sweeping, and catch-basin cleaning.
As shown in table 3, the county maintains primary responsibility for  monitoring activities, having projected over $2 million for storm water  monitoring activities in fiscal year 1997, almost $2 million in fiscal year  1998, and over $1.5 million in fiscal year 1999.  Conversely, the permittees’  projected funding levels for monitoring activities amounted to only  $619,000 in fiscal year 1997, $729,000 in fiscal year 1998, and $737,000 in  fiscal year 1999.  According to an official with the Los Angeles Regional  Water Quality Control Board, the County has consistently maintained  primary responsibility for monitoring activities required under the permit.
section_title: Funding Sources
paragraphs: The primary source of funds for the county’s storm water program is flood  control assessments collected throughout the district.  Although the county  has not applied for any state revolving funds, it has applied for and received  approval for federal funds through the Transportation Equity Act for the  21st Century (TEA-21) for a pilot study of an engineering device that would  remove trash from storm water.  Additionally, the county has received  partial funding through Proposition A of the Safe Neighborhood Parks of  1992 and 1996 for two Vortex Separation Systems—a Continuous  Deflective Separation unit and a Stormceptor unit.  Additionally, the county  received grant money from the Metropolitan Transit Authority, which  partially funded catch-basin screens, a Continuous Deflective Separation  unit, and 120 catch-basin inserts.
section_title: The Storm Water Program in Milwaukee, Wisconsin
paragraphs: The Wisconsin Department of Natural Resources (WDNR) has the  authority to regulate the discharge of storm water from municipalities,  construction sites, and industries under Natural Resources Code 216.  This  rule identifies Wisconsin municipalities that are required to obtain a storm  water discharge permit under the Wisconsin Pollutant Discharge  Elimination System (WPDES).  Milwaukee completed its application  process in 1994, and WDNR issued a WPDES permit to the city in October  1994.  This was the first municipal storm water permit issued to a  municipality in EPA’s Region 5 covering the midwest.  In July 2000, WDNR  reissued Milwaukee’s storm water permit.  According to the 2000 census,  Milwaukee’s population is about 597,000.
subsections: section_title: Urban Runoff Problems in Milwaukee
paragraphs: Milwaukee has a combined sewer system as well as a separate sanitary  sewer system.  The Milwaukee Metropolitan Sewerage District  implemented a rehabilitation program that cost over $2 billion to reduce  the number of combined sewer overflow (CSO) events each year.  The  rehabilitation program involved the construction of deep tunnels to store  untreated wastewater and rainwater for later treatment at a wastewater  treatment plant.  Since 1996, the deep tunnels have significantly reduced  the number of overflow events from an average of 50 to 60 per year before  the construction to an average of two per year afterwards.
Urban runoff has been identified as a leading source of pollution to the  Milwaukee River basin’s streams, lakes, and wetlands and the Milwaukee  River estuary.  To address pollution from urban runoff, WDNR issues storm  water permits to municipalities with MS4s serving areas with populations  of 100,000 or more, municipalities in Great Lakes “areas of concern” where  water quality has been identified as a serious problem, municipalities with  populations of 50,000 or more that are located in priority watershed  planning areas, and designated municipalities that contribute to the  violation of a water-quality standard or are significant contributors of  pollutants to state waters.
section_title: Milwaukee’s Use of Best Management Practices
paragraphs: In addition to BMPs such as the elimination of illicit connections and  discharges to the storm sewer system, the reduction of pollutants in storm  water runoff from construction sites, public education, catch-basin  cleaning, street sweeping, and the use of detention basins, Milwaukee has  explored the use of innovative BMPs.  Refer to the section of this report  describing local government efforts to manage storm water for more  details about an educational campaign directed at a specific watershed.    Additional BMPs include the following:  An innovative storm water control device was installed in a parking lot  at a heavily used municipal public works yard that was found to  discharge significant amounts of storm water pollutants.  Termed the  Multi-Chambered Treatment Tank (MCTT), this device is suitable for  areas with limited space, cleans up polluted runoff close to its source,  removes pollutants that are not susceptible to other treatment methods,  and is hidden from view.  The MCTT consists of a catch basin, a settling  chamber, and a filter.  Although the results of the monitoring studies  have revealed that the device has a positive effect on water quality,  officials with the Department of Public Works explained that it is cost- prohibitive and suitable only for sites with limited space.
The permittee has also been working with WDNR, the Department of  Transportation, the U.S. Geological Survey, and a neighborhood  association in a joint effort to develop a storm water monitoring  assessment program consisting of two innovative storm water treatment  devices.  One device removes grit, contaminated sediments, heavy  metals, and oily floating pollutants from surface runoff.  The other  device removes a broad range of pollutants from runoff, such as  bacteria, heavy metals, nutrients, petroleum hydrocarbons, and  suspended solids.  The devices are to be installed along a new reach of  the Milwaukee Riverwalk through the third ward of Milwaukee.
section_title: Costs Associated With Managing Storm Water
paragraphs: Reliable data on the total cost to manage storm water in Milwaukee were  not available and cannot be presented here because certain activities are  not reported as program costs in the city’s annual report.  These activities  include street sweeping; leaf collection; catch-basin and inlet cleaning;  maintenance of public boulevards, parks, and public green spaces; and the  recycling of waste oil and antifreeze.  Therefore, the program costs  reflected in the annual report do not take into account many of the  nonstructural BMPs employed by the city nor do the totals include  activities funded through grants.  The storm water management activities  that were included in the city’s 2000 budget request were estimated to cost  $460,000.
section_title: Funding Sources
paragraphs: Milwaukee’s storm water program is primarily funded through the city’s  sewer maintenance fund.  Unlike the general revenue account, which is  based on property taxes, the sewer maintenance fund is based on water  consumption.  The city has also received supplemental funding from the  Wisconsin Nonpoint Source Water Pollution Abatement Program in the  form of WDNR grants.  The city has received over $1 million since 1991 for  a wide variety of storm water management activities.
section_title: The Storm Water Program in Worcester, Massachusetts
paragraphs: Worcester’s Department of Public Works (DPW) received a NPDES permit  on November 1, 1998. The Sewer Operations Division, within the DPW, is  directly responsible for operating and maintaining the city’s separate storm  sewer system, along with the sanitary and combined sewer system.  Since  1993, the Sewer Operations Division has had a full-time storm water  coordinator, reflecting Worcester’s increased emphasis on meeting NPDES  program requirements.  Worcester has a population of about 173,000.  Its  water system covers an extensive area, including 371 miles of sanitary  sewers, 340 miles of storm sewers, 56 miles of combined sewers, 27,000  manholes, over 14,000 catch basins, and 263 outfalls.  Worcester’s separate  storm drain systems consist of 93 main drainage areas covering  approximately 6,680 acres.
subsections: section_title: Urban Runoff Problems in Worcester
paragraphs: The constituents that are typically found in urban runoff in Worcester are  the same as those normally found in urban runoff in older cities.  Because  virtually all of the paved surfaces in the Worcester area are devoted to the  city’s transportation infrastructure, the constituents generated include  automobile-related petroleum products, such as total petroleum  hydrocarbons, oil and grease, along with total suspended solids.  Also,  coliform, silt, and sediment have been identified in the city’s runoff.
section_title: Worcester’s Use of Best Management Practices
paragraphs: Like other permittees, the DPW has implemented BMPs under the major  areas of education outreach, pollution prevention and source controls,  storm-drainage system maintenance, regulatory efforts, and storm-drainage  system infrastructure.  Additionally, to reduce storm water pollution, the  DPW has retrofitted a number of twin manholes in the city as discussed  below.  BMPs that are specific to Worcester include the following:   The DPW implemented a demonstration project to determine the  effectiveness of an oil and grit separator installed on a street drain.  The  drain is a major surface sewer main that services approximately 226  acres of heavily urbanized area with a typical mix of residential,  commercial, and industrial use.  The drain discharges into Lake  Quinsigamond, which is a large lake used for recreational purposes such  as swimming and boating.   In its April 2000 annual plan submitted to  EPA, the DPW noted that because of drought conditions, it currently did  not have sufficient sampling data to determine the effectiveness of the  project.
The DPW has embarked on a comprehensive program to minimize the  possibility that sewage and storm water will be mixed in its twin invert  manholes.  Since the program began, the DPW has installed hold-down  devices on over 1,680 of the approximately 2,580 twin invert manholes  in the city.  The DPW expects to continue the program until all of the  manholes have been retrofitted.
The DPW is also working closely with the Massachusetts Department of  Environmental Protection in its ongoing tracking efforts to ensure that  industries in Worcester are doing their part to reduce storm water  pollution.
To improve its storm-drainage infrastructure, the city has established a  voluntary plan to reduce the number of unpaved private roads.  The dirt  from these roads, especially after rain storms, causes sediment to build  up in the drainage system.  The DPW has developed a plan to pave the  streets at a lower grade than would be necessary to meet the legal  requirements for a public street.  Under this plan, residents would not  have to pay the additional betterment taxes that are now required to  cover the costs of sediment removal and less sediment would be  transported in runoff.
section_title: Costs Associated With Managing Storm Water
paragraphs: Since 1993, the DPW has allocated significant funding from the water and  sewer utility fees it collects for controlling the effects of runoff, especially  through catch-basin cleaning, street sweeping, and correcting illegal  connections.  For example, its fiscal year 1993 budget for storm water  programs included about $1.6 million for specific programs and another $1  million for capital improvement programs, such as inflow/infiltration and  flood control.   The DPW also spent $500,000 to develop and submit its  permit application.  Furthermore, as shown in table 4, Worcester made  extensive capital expenditures during fiscal years 1994 through 1999 on  pertinent storm water projects to improve the quality of storm water runoff  emanating from the city’s storm water sewer system.
Furthermore, during fiscal year 1999, the DPW spent approximately  another $2.1 million to operate and maintain storm water activities.  Key  expenditures included about $1.2 million for street sweeping, about  $617,000 for catch-basin maintenance, $52,000 for root control, and another  $48,000 for street paving.  Also included was $40,000 per year for sampling  five outfalls around the city three times per year as required by the permit.   According to a DPW official, in previous fiscal years, the DPW funded the  same or similar operation and maintenance activities to help control storm  water runoff.  As a result, the costs since 1994 were similar to those for  1999, except for annual adjustments for inflation. Therefore, the annual  operation and maintenance expenditures ranged from about $1.7 million  for 1994 to about $2.1 million for 1999.
According to a DPW official, the department expects to spend from $3  million to $4.5 million annually over the next several years on storm water- related activities.  The amount of the cost increase will depend on whether  EPA asks the city to increase its spending.
section_title: Funding Sources
paragraphs: The DPW funds its storm water management controls effort from the water  and sewer user fees it assesses to homes and businesses.
section_title: Comments From the Environmental Protection Agency
section_title: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: In addition to those named above, Jennifer Clayborne, Richard LaMore,  Sally Coburn, Elizabeth McNally, Charles Bausell, and Timothy Guinane  made key contributions to this report.
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