Ohio Environmental Law Blog : Ohio Environmental Lawyer & Attorney : Joseph Koncelik : Frantz Ward Law Firm : Environmental Regulation, Land Use, Compliance : Cleveland, Ohio

Traditionally, EPA has regulated storm water differently than point source discharges.  Regulators recognized that it was easier to install new technology to reduce pollutant loading from a specific industrial process with a specific "end of pipe" discharge point.  Storm water was much more unpredictable.

Therefore, U.S. EPA regulated storm water using general NPDES permits without specific numeric limits.  Instead, the general permit would require the development of a storm water pollution prevention plan (SWPPP) which required companies to institute "best management practices" (BMPs) to reduce pollution from run-off.  The effectiveness of BMPs were evaluated by monitoring pollutant levels in run-off. but permits did not contain specific numeric effluent limits that had to be met.

EPA recognized the difficulties in trying to establish a numeric effluent limit for storm water discharges due to the variables involved.  For instance, due to the variability of the size and nature of storm events, the amount of pollutant leaving a site in run-off was difficult to evaluate.

In 2002, EPA issued guidance that stated numeric limits would only be used "rarely" in storm water NPDES permits.  However, EPA believe technology has improved and has signaled a shift toward numeric limits for storm water control. In 2010, EPA issued a controversial revision to that guidance indicated numeric values may be appropriate.  (See, "Guidance on Establishing TMDL Waste Load Allocations for Storm Water Discharges in NPDES Permits"  EPA November 2010)

Benchmarks Versus Numeric Limits

The first step toward numeric limits is EPA's use of "benchmarks" in storm water permits.  EPA makes clear that benchmarks are not effluent limits.  This means an exceedence of the numeric value is not a violation.  However, the exceedence is evidence that BMPs need to be improved to reduce pollutant loading.

In December 2011, Ohio EPA followed U.S. EPA lead and incorporated benchmarks into its final version of the new NPDES General Permit for Industrial Activity.  This permit differs from the previous General NPDES Permit companies  in two significant ways. 

First, the permit contains industry specific requirements (which is why the permit is 141 pages long).  Second, it uses benchmarks tied to specific industrial activity that will be used to determine the effectiveness of BMPs.

Ohio EPA's new General  Permit became effective starting January 1, 2012.   However, facilities will still be covered by their old general permits, as long as they are still effective.  Existing facilities will begin the transition to the new permit upon notification from Ohio EPA. 

Ohio EPA will send written instructions to existing covered facilities on how to continue their general permit coverage with the submittal of a “re-notification” of intent to be covered. The existing facility will have 90 days to submit the re-notification.

Benchmark Monitoring

The new permit is effective for five years.  During the first four years of the permit, facilities to which the industry specific benchmarks apply, will monitor their compliance with the benchmarks.

In the first three years of the permit, monitoring and reporting is required for four out of the 12 quarters.  In year number four, the data is averaged and compared to applicable benchmarks for that industrial activity. If facilities are still exceeding the benchmarks after four years, they will be forced to review their BMPs, storm water control plans and house keeping activities to further reduce pollutant loading.

How Far will Facilities Need to Go to Comply with Benchmarks?

The permit makes very clear that the benchmarks are not enforceable effluent limits.  Therefore, an exceedence is not a violation which could subject the facility to an enforcement action.  However, the expectation is the facility will continue to improve storm water controls if the benchmarks are not met. 

The final permit does contain language that allows faculties to assert they have done all they feasibly can to reduce pollutants.  The permits states that facilities can demonstrate that “no further pollutant reductions are technologically available and economically practicable and achievable in light of best industry practice to meet the control measures/best management practices (BMPs) in Part 2 of this Permit.”

The determination must be documented and retained with the (SWPPP, and provide notification of this determination to Ohio EPA at the due date for the next benchmark monitoring report.  Of course, a company's determination as to what is economically practicable may not be the same as the Agency's. 

(For more information on Ohio EPA's NPDES General Permit for Industrial Activity- click here)

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The Northeast Ohio Regional Sewer District (NEORSD) has entered into a settlement with U.S. EPA to fix its combined sewer overflow issues (CSOs).  Included in the settlement is a provision which requires NEORSD to spend $42 million in eight years to eliminate 44 million gallons of storm water from entering its sewer system.  This portion of the settlement is known as the "Green Infrastructure" component.  

At the same time NEORSD entered its settlement with U.S. EPA on CSOs, it has enacted its regional stormwater fee which will begin charging businesses a fee for stormwater that it sends to its collection system.  The fee is meant to create a strong incentive for businesses to implement stormwater projects that will reduce flow to the system.

The Sewer District is performing a large feasibility study to determine areas best targeted for green infrastructure projects.  The District is looking at using the many vacant lots (estimated around 6,000) to possibly perform projects. (See, "Turning huge vacant lots into stormwater areas and neighborhood centerpieces" from GreenCityBlueLake)

Hopefully the District will also see this as an opportunity to partner with businesses who will soon be experiencing the pain of another fee (tax) on their business.  Using the money not just on vacant lots, but with area businesses can help soften the blow of the fee.

If a businesses is going to qualify for a portion of the $42 million in funding available for the NEORSD Green Infrastructure program you must:

• Be in an area the District is targeting for reducing stormwater flow into its collection system;
• Eliminate flow that is currently getting into the collection system; and/or
• For new development projects- go beyond the stormwater controls currently planned
• Must also agree to provide NEORSD access to the project area if its on your property.

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 For over three years, U.S. EPA had been moving toward a seismic shift in how it regulated stormwater run-off from construction sites.  For the first time, U.S. EPA tried to impose a numeric permit limit on the turbidity of water (sediment mixed with water) that leaves construction sites following rain events.   EPA 's efforts are the result of a 2004 lawsuit by environmental group who obtained a Court order requiring development of a numeric standard.

Adjacent is a picture which shows bottles containing various amounts of sediment mixed with water.  The more dirt the higher the NTUs.  The picture is a good graphic illustration of EPA's proposed numeric standards.

Historically, U.S. EPA has never tried to impose a numeric limit to control stormwater discharges.   Rather, U.S. EPA  required the use of  "best management practices" (BMPs) as part of NPDES construction stormwater permits.  BMPs were engineering controls that were designed to collect or limit run-off to reduce sediment loading on streams and lakes.

In November 2008, U.S. EPA issued proposed effluent guidelines that contained a numeric turbidity standards of 13 NTUs.  EPA received a flood of comments questioning the data and assumptions behind that proposed standard.

On December 1, 2009, U.S. EPA issued its final effluent guidelines raising the propose numeric turbidity standard to 280 NTUs.  The standard would apply to construction sites 10 acres and larger.  It also included the requirement to take samples throughout the day.  The average of the samples would be compared to the 280 NTU standard for purposes of determining compliance.

Despite the dramatic increase from the proposed effluent guidelines, industry still was deeply concerned with the cost of compliance and questioned the benefits of such a standard.  Two petitions for reconsideration were submitted challenging the 280 NTU standard.  After raising the technical issues raised in those petitions, EPA decided to stay implementation of the provision.

The EPA submitted a proposed rule to revise the turbidity limit to the Office of Management and Budget (OMB) in December 2010. On August 17th, EPA announced it had withdrawn its most proposal from OMB. , EPA decided to seek additional treatment performance data from construction and development sites before proposing a revised numeric turbidity limit. Next step, EPA will publish a Federal Register notice soliciting data in the near future.

The battle over numeric limits is hardly over.  First, EPA still faces a court order to develop a numeric limit,  Second, on November 10, 2010, EPA issued memo that signaled its intention to shift toward numeric limits for most stormwater permits, not just construction sites.  Therefore, numeric limits are only a matter of time. 

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Bay Village has been debating establishing a riparian setback for the last few years.  The proposal which began with a 75 foot setback has now been scaled down to 25 feet.  Yet the ordinance is still controversial and City Council decided to delay its vote enacting the provision.

The debate before Council was covered in the West Shore Sun:

Council took the items off the March 21 meeting agenda after hearing concerns voiced by Lake Road resident and attorney, Homer Taft... 

Taft told council he felt the proposed legislation was onerous, would impose unfair hardships on some residents, and could be found unconstitutional.

Residents near creeks wanting to make changes on their property could face thousands of dollars in additional engineering expenses, he said. In addition, some residents could find themselves facing restrictions on developing significant portions of their property.

“I believe this ordinance is unfair to property owners and rather draconian,” Taft said.

He also questioned whether the city is really obligated to pass the legislation.

“I know you are being told the EPA requires this,” Taft said. “I challenge anyone to provide written evidence that’s true.”

Riparian setback ordinances are appearing all over Northeast Ohio due to a strong push by the Northeast Ohio Areawide Coordinating Agency, local officials with Ohio EPA and the Cuyahoga Soil & Water Conservation District.  I am willing to bet that more areas are covered by riparian setback requirements in Northeast Ohio than anywhere else in Ohio.

From the article is appears there is still confusion as to whether Ohio EPA is mandating local municipalities adopt the ordinances to comply with NPDES permit requirements to control stormwater.  As discussed in a previous post, setbacks are but one option municipalities can utilize to meet their stormwater control requirements.

From an environmental standpoint do setback have value?  There is no debate setbacks have value by providing flood retention, filtering of pollutants and habitat to improve water quality.  While there are benefits, they also restrict owners ability to fully utilize their property. 

Many municipalities passed setback ordinances without really understanding what they were placing on their books.  City Councils then faced outraged citizens who complained about "no build zones" on their properties.  Some Boards of Zoning Appeals were faced with controversial variance requests to appease local citizens.  Given the controversy its a good idea that Bay Village is having a robust debate. 

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The Board of the Northeast Ohio Regional Sewer District (NEORSD) could vote as soon as the end of this week on whether to create a stormwater utility within its service territory.  Through the imposition of a fee on homeowner's and businesses the District would hope to tackle some of the region's major stormwater issues. 

In my post on Monday I discussed some of the local battles that have emerged over whether the District has the legal authority to move forward with its proposal.  In today's post, I discuss some of the other issues and opportunities that may have gone unnoticed due to the contentious debate that is occurring.

Pro's and Con's of Regional Solution to Stormwater

At its core, the idea of treating stormwater as a regional issue makes sense.  Water does not know any boundaries.  Prioritizing the largest stormwater issues within the area also makes sense.  Some projects would be just too costly to do without aggregating resources.

However, this has to be balanced with making sure certain areas don't receive the lion share of  revenue collected by the Utility.  This is the concern of Summit County who fears revenue will be almost entirely be used to fund projects in Cuyahoga County.

The proposed regulations, especially upon revision, attempt to address this issue by establishing Watershed Advisory Committees.  These Committees would be made up of key local stakeholders in each watershed.  They would provide input into project selection and identification of stormwater issues.

However, even with recent language changes in response to comments, the Committee's are purely advisory.  The District retains the ability to ultimately make all decisions regarding use of the funds it collects.  There must be ways to balance the structure and use of the Committees to provide additional local control over resources.

Impact on Local Stormwater Ordinances Governing Storm Water

In Chapter 6 of the proposed regulations, NEORSD has the authority to establish its own standards for stormwater management.  Those standards must be consistent with Ohio EPA requirements for municipal stormwater systems. However, the District has the authority to impose more stringent requirements than Ohio EPA.  This may set up an interesting battle over ordinances passed by local municipalities within the District's jurisdiction.

The best example of where a potential battle may take place is riparian set back requirements.  Riparian setbacks establish "no build" zones adjacent to streams and wetlands in order to maintain their natural ability to control stormwater and filter run-off. 

Right now riparian setbacks are one option a municipality can choose to implement in meeting Ohio EPA's requirements for municipal stormwater systems.  This option has proved controversial.  Contentious debate has take place, including over the following issues:

• Size of the Setbacks-  Standards range from 25 feet to 300 feet. This is a very wide range and Ohio EPA has not formally endorsed a specific distance. 
• Takings- Issues have raised by property owners that the government imposing no-build areas on their property amounts to a "takings" under the Constitution which would entitle them to compensation
• Variances- What is the process for granting a variance from the set back requirements?  Communities have utilized very different processes in determining whether to grant a variance

Right now municipalities have had the flexibility to determine these and other issues associated with riparian set back on their own.  They can craft their ordinances to deal with local concerns of their constituents. While this has led to variations in standards, some would argue variation may be suitable based upon local conditions.

What if the Sewer District decides riparian set backs are mandatory and imposes certain standards on all communities related to the setbacks?  For example, what if they impose a mandatory 50 to 100 foot setback from all streams and wetlands?  This may lead to significant debate and outcry.

Cost of the Program- Opportunities to Offset CSO Compliance Costs Should Be Explored

One of the other major concerns with the proposal is the imposition of a new fee (tax) during these tough economic times.  Certainly it is a legitimate concern to worry about imposing new costs on businesses after the worst recession in decades. 

However, it is possible the stormwater utility could save money.  The Sewer District is still in a battle with U.S. EPA over its combined sewer overflows (CSOs).  The ultimate fix to those problems runs into the billions of dollars over the next few decades.  This translates into ever escalating sewer rates to pay for those improvements.

It is possible to offset some of the costs through the stormwater utility?  There are opportunities, such as the use of "green infrastructure" to reduce infiltration of stormwater into the Sewer District's system.  Reducing infiltration diminishes the need for costly "grey" infrastructure to hold stormwater to prevent overflows.

The Cincinnati Metropolitan Sewer District faced years of litigation with U.S. EPA over its CSOs.  Ultimately a very costly judicial order was agreed to satisfy the federal agency.  However, built into that Order were unprecedented flexibility to explore the use of  "green infrastructure" instead of constructing deep tunnels to hold stormwater.  Here is an excerpt from a report recently submitted to U.S. EPA regarding viability of green infrastructure to solve CSO issues (Note: while it says for settlement purpose this document is available on the web):

All of the parties clearly desire significant improvement to water quality currently impacted by MSD's CSOs and SSOs. If cost were no object, this could be done by conventional, so-called "grey" methods, such as massive deep storage tunnels. However, as discussed openly among the parties, MSD's service area faces huge economic problems due to its increased urbanization, population and industry losses, and related matters. MSD maintains that the sewer rate increases required through construction of massive "grey" solutions would be economically and socially devastating. This problem has the potential to create a stalemate or gridlock in finalizing the WWIP. It also presents a lose-lose situation where neither side obtains what it wants or needs. As recognized by USEPA, green infrastructure has the potential to provide water quality improvements at a fraction of the cost of "grey" infrastructure projects.--  Cincinnati MSD "Green Infrastructure" Program

Sounds very similar to the issues facing our Region.  Perhaps there is a real opportunity to see if the stormwater utility could be used as a means to reduce the District's compliance costs to solve its CSO problems. 

Has the District even studied or discussed whether a "green infrastructure" program implemented by the proposed utility could be a cost saver versus another tax imposed on businesses and residents?

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The Northeast Ohio Regional Sewer District (NEORSD) is pushing forward with a proposed storm water utility that would extend through out its service area.  The Board is expected to vote on the proposal January 7th.

Under the proposal the District would assess the average homeowner $4.75 per month or around $57 per year.  The fees would be aggregated to run a regional storm water program administered by the Sewer District to perform the following activities:

• Create master storm water plans
• Inspect and maintain storm water control infrastructure
• Build storm water control projects
• Support green infrastructure
• Restore streams
• Assist municipalities in complying with Phase II storm water requirements

(click here for NEORSD's power point on the proposed storm water utility)

Recent newspaper articles have discussed battle over the District's legal authority to implement the plan.  The Plain Dealer has had a series of articles discussing the storm water utility proposal in depth as well as an editorial in support. As reported in the Hudson-Hub Times, Summit County has already filed a lawsuit challenging the proposal.

A complaint for declaratory judgment and permanent injunction was filed by Summit County Dec. 30 in the Summit County Court of Common Pleas. Other plaintiffs include Northfield Center and Sagamore Hills townships, the cities of Macedonia, Hudson and Bath, and the villages of Boston Heights and Richfield.

The complaint states, among other allegations, that NEORSD has no authority to impose “stormwater fees, taxes or assessments on Summit County residents” and states the county engineer’s office is better suited to manage stormwater issues in the county.

Communities within Cuyahoga County have also expressed concern.  As reported in theSun-Star Courier, Broadview Heights and Strongsville also have issues with the proposal.

The fee doesn’t sit well with Broadview Heights Mayor Sam Alai either. With the city already having fees in place, residents may be seeing a double charge if the district has their way.

“My opinion is that Broadview Heights has its own sewer fee,” Alai said. “I can’t see us billing our residents twice for the same service.”

Concern has focused mostly on the following issues associated with proposal:

• Wisdom of imposing a new tax during these tough economic times
• Legal authority to create the utility
• Summit County is concerned fees will be assessed in their County for projects in Cuyahoga County
• Local governments are concerned with infringement upon their authority

These are all serious issues worthy of debate which have already resulted in litigation.   In fact, this list of issues may be so serious that many are not paying close attention to other, more practical, issues associated with the proposal.   

NEORSD just concluded its public comment period and has revised its proposed regulations that would govern the utility.  It is a valuable exercise to review the proposed regulations to get a better understanding of how the District will administer the program. (Click here to see revised regulations)  In future posts I will be discussing some of the issues that perhaps have been overlooked as a result of the debate over legal authority.  These include:

• Impact on local ordinances governing storm water
• Proposed use of Watershed Advisory Committees to solicit input on projects and planning
• Advantages and disadvantages to a regional program to address storm water
• Green infrastructures relationship to combined sewer overflows

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On November 23, 2009, the U.S. Environmental Protection Agency (EPA) finalized new rules intended to control stormwater pollution from construction sites.  The rule takes effect on February 2010 and will be phased in over four years. 

The most significant new requirement is the imposition of numeric discharge limits from larger construction sites.  In the past, U.S. EPA required construction site owners/operators to implement best management practices (BMPs) to control stormwater runoff without monitoring or discharge limits.  Once the new standards are phased in, owners/operators will be required to sample stormwater discharges and comply with a numeric standard for the pollutant turbidity in discharges according to the following schedule:

• In 18 months (August 2011), construction sites 20 acres or larger will be required to monitor and meet numeric discharge limits
• In four years, construction sites 10 acres or larger will be required to monitor and meet numeric discharge limits

From the EPA press release:

Owners and operators of sites that impact 10 or more acres of land at one time will be required to monitor discharges and ensure they comply with specific limits on discharges to minimize the impact on nearby water bodies. This is the first time that EPA has imposed national monitoring requirements and enforceable numeric limitations on construction site stormwater discharges.

There are also impacts to smaller construction sites ranging from 1 acre to 10 acres in size.  The rule will impose a series of mandatory Best Management Practices (BMPs) relating to: Erosion and Sediment Controls; Soil Stabilization BMPs; Dewatering BMPs; Pollution Prevention Measures; and Prohibited Discharges.  Previously, owners/operators were allowed to pick and choose their BMPs as long as they met specified engineering requirements.

Stringency of the Numeric Limits

Dirt particles in storm water discharges typically cannot be effectively removed by conventional BMPs (such as sediment basins). In November 2008, U.S. EPA had proposed a numeric limit of 13 nephelometric turbidity units (NTU). To meet the proposed numeric turbidity limit, sites may have been forced to actively treat stormwater.  Active treatment could have included use of chemical treatment and filtration of their storm water discharges.

However, U.S. EPA backed off the stringent 13 NTU proposed limit.  The final rule has a far more relaxed standard of 280 NTU.  EPA decided to increase the limits based upon a flood of comments suggesting the 13 NTU limit would represent less than background levels at some sites and would be nearly impossible to meet.

Even with the high numeric standard, Industry is concerned with the implications of the new rules.  The construction industry is simply not accustomed to being required to take samples and meet specific permit limits.  As detailed on the Associated General Contractors of America, the following could be implications for contractors at larger construction sites:

On all jobsites where the numeric limit applies, the rule requires contractors to collect numerous stormwater runoff samples from all discharge points during every rain event and calculate the NTU level(s). (This may entail taking "grab" samples by hand and performing measurements with a field turbidimeter; however the rule doesn't specify any sort of monitoring protocol or methods - instead EPA is leaving it up to that states to spell that out in their permits.) If the average NTU level of the samples taken over the course of a day exceeds the "daily maximum limit" of 280 NTU on any given calendar day, then the site is in violation of the federal limitation requirement. EPA is also leaving it up to the states to specify applicable requirements for contractors to report on the samples they take of their construction site discharges...

AGC is deeply concerned about the potential impact this rule will have on the construction industry and will provide more information in the near term as we continue to analyze EPA's C&D ELG rulemaking

No doubt the final rule represents a significant increase in the stringency of regulations applicable to the construction industry. 

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Municipalities and counties are utilizing riparian and wetland setbacks in their zoning and planning efforts on a more frequent basis.  Setbacks can be an effective tool to control growth, protect valuable natural resources as well as meet federal and state Phase II stormwater requirements. 

While setbacks are beneficial, officials must understand the level of impact on both large scale and small development within their communities before adopting them.  Are they prepared to require alteration of major new commercial or residential developments?  Are they prepared to face angry residents whose plans for a deck or storage shed are influenced by no build zones?  Do they understand the environmental benefits gained by adopting setbacks?

Some local officials that quickly enacted setbacks without fully comprehending the requirements or educating their residents have faced strong push back.  Some communities have responded by frequently issuing variances that dilute the effectiveness of setbacks. Other communities are delaying action on stormwater ordinances until ordered to by the State.

I have worked with local governments on stormwater ordinances, including setbacks.  In my experience, it is critical for local officials to gain a thorough understanding of the ordinances, how they will be applied, as well as the benefits and consequences of setbacks. 

QUICK PRIMER ON RIPARIAN SETBACKS:

Riparian and wetland setbacks are typically adopted through local ordinance.  The most common form prohibits any development, with narrow exceptions, within specified distances from either wetlands or streams. 

In Northeast Ohio, many communities have used the model ordinances developed by NOACA and the Chagrin River Watershed Partners.  The basic approach used in these ordinances is to establish  "no-build" areas equal to specific distances from all streams or wetland.  The distances in the model ordinances range from 300 ft to 25 ft based on the drainage area of the stream or quality of wetland.  A property owner can try and obtain a variance from the setback requirements by demonstrating hardship.

Some local governments have taken this basic approach much further.  They have invested significant resources to map all of the sensitive environmental resources within their communities.  Once mapped, areas are either designated for planned development or are to be avoided and protected.   

An excellent example of this approach is the Chippewa Creek Balanced Growth Plan developed by the Cuyahoga River Community Planning Organization through a Balanced Growth grant awarded by the Lake Erie Commission.

The map on the left show the entire watershed.  Each color designates a different environmental attribute (such as wetlands, streams or steep slopes) that should be protected.  The map on the right is a satellite image with the critical areas highlighted.  Dark green are "no build zones" (PCAs- Priority Conservation Areas) and light green are designated for future development (PDAs- Priority Development Areas).

Creative approaches can be used to compensate landowners whose land lies in area designated for protection. 

• Transfer of Development Rights- compensating a landowner for the development value of the land that is being preserved by allowing higher density development elsewhere in the community.  (A good primer on Transfer of Development Rights)
• Mitigation Banking- establish wetland or restoration areas that can be used to compensate if an impact occurs to a setback area.  This provides flexibility while ensuring the environmental benefits stay within the watershed.

WHAT TO CONSIDER BEFORE ENACTING SETBACK ORDINANCES

1. Flexibility-  Have you built in a level of flexibility within the ordinance that fits your community's needs?  For instance, will you allow development in a setback if mitigation is provided for the impacts.

2.  Takings-  Do the legal standards for granting a variance provide sufficient protection against taking claims?  Because takings case law is fact specific, requirements within the ordinances must have inherent legal flexibility to avoid providing a basis for a claim.  Application of a setback ordinance that results in a valid takings claims can result in significant compensation to the landowner thus draining local government finances.

3.  Distance of the Setback-  Currently in Ohio there is no minimum setback distance specified in state law.  In addition, there are many different distances utilized.  Some are based upon a formula like the one in the Ohio Department of Natural Resources Rainwater Manual.  Others use standard distances like the approach in the NOACA model ordinance.  The key consideration in choosing a distance is whether it will provide the protection your desire without unnecessarily burdening property owners.

4.  Alternatives to Setbacks-  In Ohio, Phase II stormwater communities must adopt both structural and non-structural "best management practices" as part of their stormwater management plans.  Right now, the State does not mandate adoption of setback ordinances unless the community committed to one in their stormwater management plan.  Would an alternative non-structural BMP requirement, such as mandating use of green infrastructure (green roofs, pervious pavement, rain gardens) be more palatable to residents?

5.  Education-  It is critical that communities use effective public education techniques so citizens understand the value of setbacks.  Good education can be the difference between local governments effective implementation of a setback ordinance or a community that issues frequent variances to avoid confrontation with residents. 

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