As far as I know, nobody has come up with a good name for the type of pollution that gets picked up by rainwater that flows across the ground, carrying contaminants into ditches, streams and eventually large waterways, such as Puget Sound.
“Stormwater pollution” is a term I have frequently used. But Sheida Sahandy, executive director of Puget Sound Partnership, made a good point when I interviewed her last summer about the perils of stormwater.
“I don’t really like calling it ‘stormwater,’” Sheida told me. “It doesn’t have much to do with storms. It has to do with people. We’re talking about our dirt, our detritus, our filth. Everyone has it, and we all dump it into the sound to one degree or another.”
Stormwater is relatively pure when it falls from the sky as rain. It only gets dirty because the runoff picks up dirt, toxic chemicals, bacteria and other wastes, mostly left behind by people.
“Stormwater has gotten a bad wrap,” Sheida said. “It’s really what we’ve done to the poor thing that makes it evil.”
To read more about this discussion, check out my series “Taking the Pulse of Puget Sound” and the story “Stormwater solutions key in fight for Puget Sound.”
Officially, the Environmental Protection Agency and Washington Department of Ecology tend to call it “nonpoint source pollution.” It’s a term that tells us what this kind of pollution is not. Specifically, it is not pollution coming from a point source, such as a pipe. But “nonpoint” does not describe what it really is.
Technically, nonpoint pollution is more than stormwater. It includes waterborne sources such as marinas and atmospheric deposition from air pollution. Taken together, this form of pollution remains the most serious threat facing those who would clean up and protect Puget Sound.
We need a new term like “mess-left-behind pollution,” because it generally results from someone leaving some kind of contamination on the ground — such as animal waste or leaking motor oil — or failing to anticipate future problems — such as those caused by toxic flame retardants in furniture or mercury from a multitude of coal-fired power plants.
A new plan by Ecology to deal with this type of pollution is now under review. It is called “Washington’s Water Quality Management Plan to Control Nonpoint Sources of Pollution” (PDF 10.6 mb).
The general categories described in the plan are:
- Agriculture, including livestock wastes; fertilizers and pesticides; and erosion from grazing practices and over-cultivation of fields.
- Atmospheric deposition, including emissions from automobile, industrial and agricultural sources and backyard burning of trash.
- Forest practices, including turbidity from erosion caused by loss of vegetation and road-building, as well as pesticides and fertilizers from forest applications.
- Habitat alteration/hydromodification, including increased temperature from loss of vegetation or water impoundment; turbidity from erosion caused by shoreline alteration; and increased bacteria and chemical concentrations from loss of streamside vegetation.
- Recreation, including sewage, paint and solvents from boats.
- Urban/suburban areas, including bacteria from failing septic systems, pet wastes and urban wildlife; erosion from construction and landscaping; lawn chemicals; road runoff; chemical spills; and increased stream temperature from loss of vegetation.
The plan lists a variety of objectives and strategies for reducing the impacts of nonpoint pollution. Among them are these ideas:
- Complete 265 watershed cleanup plans by 2020, focusing on at least eight priority watersheds each year.
- Respond to all complaints about water quality by confirming or resolving problems.
- Provide grants and loans for projects designed to bring a waterway into compliance with state and federal water-quality standards.
- Support local pollution identification and correction programs to track down pollution sources and eliminate the problems. (Kitsap County was identified as a model program.)
- Support water-quality trading programs that allow water cleanup efforts in lieu of meeting increased requirements for industrial and sewage discharges.
- Increase education efforts to help people understand how to reduce nonpoint pollution.
- Coordinate with organized groups and government agencies, including tribes.
- Continue existing monitoring programs and increase monitoring to measure the effectiveness of water-quality-improvement projects.
- Develop a statewide tracking program for cleanup efforts with an annual goal of reducing nitrogen by 40,000 pounds, phosphorus by 14,000 pounds and sediment by 8,000 pounds.
Public comments will be taken on the plan until June 5. Three remaining public meetings are scheduled before then. For information, check out Ecology’s webpage, “Washington State’s Plan to Control Nonpoint Pollution.”
Unfortunately, the name does matter: if it is “storm water,” federal and state agencies can require holders of water quality permits to be legally and financially responsible for its control and cleanup, even if it doesn’t come from them. If its “nonpoint source pollution,” it is the state’s legal and financial responsibility for its control and cleanup under law. So by calling it “storm water,” the state gets to push its legal and financial duties to cities and counties, since they are the ones who are issued permits by — none other than — the state. It can be argued that it boils down to one government or another paying for the clean up of nonpoint pollution so what’s the big deal? Well, it matters because it isn’t fair to make those who did not cause the pollution or who the Legislature hasn’t said is responsible for its clean up to have to pay for its clean up. In other words, when the state tries to make cities and counties pay for cleaning up nonpoint source pollution (which the Legislature says is the state’s duty) by calling it storm water, it violates the state’s own “polluter pays principal.” Names matter.
Dan,
I’ve been thinking about your post, and I believe it may need a little more explanation for me to understand your point.
It is true that cities and counties are issued federal permits through the state Department of Ecology for discharges from their stormwater systems. Those permits include requirements for monitoring stormwater outfalls, public education and some efforts toward source control. Is this what you mean when you say it is not fair to make those who did not cause the pollution responsible for the cleanup? I don’t believe those regulations are triggered by what anyone calls this type of pollution, but perhaps you can enlighten me further.
Sure, happy to add.
The permits also include requirements to conduct operations and maintenance and source control inspections; conduct maintenance on jurisdiction-owned facilities; require maintenance on privately-owned facilities; identify and correct “illicit discharges” and respond to spills; and adopt land use codes that require low impact development. Finally, the permits also include “water body cleanup plan” (TMDL) requirements for parameters that are impairing the water.
The essence of these requirements in the permits (particularly, the source control inspections, illicit discharge and spills requirements and TMDL requirements, afford the obligation to cities and counties for the quality of “discharges out of their MS4.” When the source of that discharge happens to be, say a farm or a failing septic system, the city or county remains responsible for the receiving water body’s water quality. (See Department of Ecology, publication no. 15-10-015, page 28: “If nonpoint sources are not addressed [in a TMDL], federal law shifts reduction requirements to point source dischargers [i.e., holders of permits]”
In fact, “storm water” was one of the original “nonpoint sources of pollution” (first Puget Sound Water Quality Management Plan, 1987). It has become known as a “point source” because permits are assigned to cities and counties for its control. Meanwhile, pollution coming from forest lands runoff, agricultural practices, and failing septics, while technically “nonpoint,” is increasing being captured in TMDLs (clean up plans) for municipal storm water permit holders because of the poor track record of EPA and states to get at it. (See US GAO Report, GAO-14-80, Changes needed if key EPA program is to help fulfill the nation’s water quality goals, 12/13).
So, yes, name does matter….Thanks for the follow up.
Here’s a note I received today from state water-quality officials:
The Washington State Department of Ecology has finalized the update to Washington’s Water Quality Management Plan to Control Nonpoint Sources of Pollution (NPS Plan). It replaces the formerly approved June 2005 version of the NPS Plan. An electronic version of the new NPS Plan is available on the Washington State Department of Ecology website.
We would like to thank all of you for providing comments on the draft plan. We received 34 comment letters on the draft plan. A response to comments is available as a separate document attached to the NPS Plan in Appendix F. As described in that document we have made several changes to the plan based on the feedback that we received from stakeholders. We appreciate that time, effort and thoughtfulness of the comments that were provided to us.
Now that the update process has been completed, Ecology will be shifting its focus toward implementing the actions outlined in the plan. Specifically, we look forward to working with partners and stakeholders to implement the important actions that it will take to get to clean water.
Again, thank you to all that provided comments. If you have any questions please feel free to contact Ben Rau at ben.rau@ecy.wa.gov or 360-407-6551.