Moving toward a national testing & evaluation program
In February 2014, the National Stormwater Testing and Evaluation of Products and Practices workgroup (STEPP) of the Water Environment Federation published a white paper titled, “Investigation into the Feasibility of a National Testing and Evaluation Program for Stormwater Products and Practices.” The paper provides a thorough summary and analysis of seven state and regional storm water technology evaluation programs in the U.S. and recommends development of a national testing and evaluation program for storm water products and practices. Although no agency or organization has taken charge of administering a program yet, letters of support have been issued by some important allies, including the Washington State Department of Ecology and the New Jersey Department of Environmental Protection—organizations that each administer their own programs.
There is little dispute that a wide variety of storm water management tools is needed to respond to the range of local and watershed management priorities, specific site constraints, and operations and maintenance capabilities. Although there is important ongoing research in the public and private sectors in response to this need, the adoption rate of new technology is slow. Recently, emphasis on green infrastructure and LID often is misinterpreted as an effort to remove innovative technology from storm water infrastructure in favor of simple landscape-based designs that, at most, may include some imported sand and organic amendments. This return to restoring basic landscape hydrologic functionality is critical and should not be discouraged where there is ample space to implement it, where adequate maintenance can be assured and where it fits within the intended use of the site. Our most difficult storm water management challenges, however, often occur in dense urban environments with numerous site constraints and specific pollutant removal requirements.
In order to move new technology from the research and development phase to release for public use, performance verification is critical. Approving agencies need assurance that the use of specific storm water control measures and practices will meet their water quality protection goals. As noted in the STEPP paper, there are many active programs that have spent precious time and money establishing methods to ensure that the storm water control measures used in their jurisdiction are appropriate. Currently, these programs tend to operate separately, often with different performance standards and testing requirements. This lack of coordination is an inefficient use of storm water program resources and a barrier to technology development.
Proprietary and public domain storm water control measures and practices would benefit from a comprehensive national testing and evaluation program. Although there is a wide range of climatic conditions, influent characteristics and treatment goals throughout the country, it is impractical to require separate field tests for each combination of factors. Better coordination between agencies under the leadership of a national organization could reduce data collection needs by standardizing testing protocols and developing analytical techniques to extrapolate results to represent a range of conditions. Until then, the lack of standardization and coordination between agencies virtually guarantees that multiple designs and field tests will be required. It is our hope that a streamlined, objective and rigorous testing and evaluation program will emerge. With so many standing to benefit, the question remains: Who will step up and put these recommendations into action?
Vaikko Allen is regional regulatory director for Contech Engineered Solutions. Allen can be reached at [email protected]. Sean Darcy is regional regulatory manager for Contech Engineered Solutions. Darcy can be contacted at [email protected].