Filling the Void
As the economic downturn continues to shrink state coffers, budget cuts have rendered numerous government programs nearly inoperable. Considering that many state and municipal storm water programs were operating with a skeleton staff and shoestring budget before the downturn, it is easy to imagine the adverse impact additional cuts are having.
Program managers have been forced to pull the plug on or drastically scale back aspects of programs once considered vital. Efforts to evaluate new best management practices (BMPs) have been particularly hampered, as staff time largely is spent on more mission-critical functions such as permitting. The result: Innovative BMPs are prohibited in many jurisdictions because there is no time and/or expertise to evaluate their performance.
This trend is particularly concerning given increasingly complex storm water quality criteria. As we focus on addressing nutrients, bacteria, metals and other pollutants not readily addressed by retaining solids, innovation seems inevitable. In assessing the situation, we need not look further than what were the three most robust, innovative BMP evaluation programs in the U.S.:
- The U.S. Environmental Protection Agency’s Environmental Technology Verification (ETV) program;
- The Washington Department of Ecology’s (WADOE) Technology Acceptance Protocol-Ecology
- The Technology Acceptance Reciprocity Partnership (TARP) storm water protocol, as administered by the New Jersey Department of Environmental Protection (NJDEP).
The BMP performance data produced by these programs is utilized by numerous local and state agencies. Unfortunately, however, both the TAPE and ETV programs essentially have ground to a halt and NJDEP’s TARP program has sputtered recently due to resource limitations.
BMP providers often are left on the outside looking in; storm water programs refuse to allow innovative technologies because of a perceived lack of performance data, yet these same programs often refuse to review data when it is available. Equally frustrating for BMP providers are blanket presumptions of performance for public-domain BMPs despite highly variable or limited performance data.
It seems logical to declare that we need as many viable tools as possible to meet the challenges inherent in mitigating storm water impacts. There are not many successful carpenters who avoid using power tools because they were once new and innovative, yet storm water managers routinely leave tools on the theoretical shelf because they do not have the time to learn how to use them properly.
Given the dismal state of many BMP evaluation programs, perhaps a change is in order. Rather than asking state and municipal programs to shoulder the burden of evaluating innovative technology, maybe it is time for a national program that evaluates public-domain and innovative technologies against consistent criteria.
A national program seemingly would make life easier for everyone involved. BMP providers could participate in a single program rather than continuing to invest millions of dollars in the patchwork of current local programs, and state and local storm water staff could devote their limited resources to other important issues such as permit compliance and BMP maintenance.
Programs like WADOE’s TAPE and NJDEP’s TARP provide a strong model from which to build, so all we need now is action.