Tim Schmitt, LimnoTech CWEA Fall Stormwater Seminar Dec. 14, 2016 Ensuring Adequate Data Collection to Take Credit for Non-Structural BMPs Tim Schmitt, LimnoTech CWEA Fall Stormwater Seminar Dec. 14, 2016 Thanks XXX. Today I want to talk about non structural BMPs and some of the difficulties in taking credit for them for TMDL load reduction.

Outline Background Quantifying impact Non-structural BMPs in DC Catch basin cleaning Bulk vegetative debris removal Street sweeping Pet waste removal I’ll start with some background on non-structural BMPs, focusing on what they are and how they are different than traditional structural BMPs Then I want to focus on the methodologies for quantifying load reduction for non-structural BMPs and the data collection necessary to use these methodologies. The I’ll move into some specific examples of non-structural BMPs being quantified in the District. I want to emphasize that there are a number of other non-structural BMPs for which quantification methodologies exist – like tree planting and buffer strips – but I want to focus on these and on the data collection challenges associated with them.

Non-Structural BMPs Programmatic activities Asset cleaning/ maintenance Restoration/creation of natural environment Difficult to quantify? Measure load in/load out? Non-structural BMPs encompass a variety of activities, programs, and actions that are not built structures designed to treat stormwater, but which help manage pollutants They include programmatic activities such as Outreach, Public education, Good housekeeping, and Pollution prevention Asset cleaning and maintenance activities like: Street sweeping Catch basin cleaning Restoration or management of the natural environment like tree planting It may be difficult to quantify the impact of non structural BMPs because you can’t measure load in/load out like traditional structural BMPs to determine load reduction efficiency

Quantifying Impact of Non-structural BMPs Quantifying impacts not always straightforward Tree planting? Yes Outreach? No Measurable activities vs. measurable outcomes? Outcome: load reduction Example: public education meeting? Quantifying impacts of non-structural BMPs on load reduction is not always straightforward For example, there are protocols for measuring the impact of tree planting on load reduction, but how do you measure the impact of outreach? So the question becomes, how do you translate measurable activities into measurable outcomes? And remember, the measurable outcome must be in terms of load reduction Example: how much load reduction credit can/should you take for holding a public education meeting?

Components Allowing Quantification of Impacts of Non-structural BMPs Methodology Amount of BMP implemented Other factors Data to use in methodology Amount of BMP implementation Additional data required by methodology There are two components in quantifying the impact of non-structural BMPs: the methodology to quantify the impact, and the data to use in that methodology With respect to the methodology, you have both the: Quantification method for the amount of the BMP implemented; and Quantification method for other factors used to translate units of BMP implementation into units of load reduction With respect to the data to use in methodology, then, you need to quantify both the amount of the BMP implemented (and make sure that it’s in the right units), but also any other additional data you need to use in the methodology – and the latter part is usually the tricky part.

Potential Roadblocks Sufficient data? Pollutant types Quantification of activities not typically quantified Close coordination with others Pollutant types You can probably see from the emphasis I put on the previous slide that there are a lot of potential pitfalls or roadblocks in trying to quantify nonstructural BMPs. First, even when there’s an approved methodology, there may not be sufficient data to use it… One reason may be that the method may require quantification of activities (or aspects of activities) that are not typically quantified – for example, the amount of material cleaned out of individual catch basins or the number of bags used at pet waste cleanup stations. Second, you may need to go to other agencies/departments outside MS4 program to collect the data, and this may cause its own issues Another issue is the type of pollutant that can be quantified. For the District, there are many TMDLs for pollutants other than nutrients and sediment, and there is not much information of impacts associated with reducing other pollutant types

Potential Roadblocks Issues for data collection Agreements Priorities Data collection requirements/protocols Manpower Funding Training Tracking Reporting Potential issues with coordinating with departments/agencies for data collection Problems developing MOUs to make sure that the data collection gets done; Conflicting priorities – does the data collection agency give this effort the same priority that you would?; New/additional data collection requirements/protocols; Lack of manpower, funding or training for the agency doing the data collection; Incompatible tracking between what the data collection agency collects and what the MS4 program needs. For example, are the assets called the same thig in different systems so they can be identified? This is slightly outside the realm of getting credit for BMPs, but in the District, the Inspections Branch uses a different system to track when a BMP has been inspected than does the Stormwater Branch, and it’s difficult for those system to talk to each other. Inconsistent reporting – for example, in the District, there were some inconsistencies in how many road miles were reported swept on individual sweeper routes vs. how many road miles were even in those routes

Question: How Do You Take Load Reduction Credit for These BMPs? Quantification method Expert Panel? Others? Collect data Existing data sufficient? Update data collection methods? Pilot studies? Who does data collection? Apply method Documentation Report What’s the process for taking load reduction credit for these BMPs? First, you need to identify a methodology for quantifying the BMP impact. For many of us here in the Chesapeake Bay region, that would involve checking to see if there was a methodology approved by a Chesapeake Bay Expert Panel. That would allow taking credit towards Chesapeake Bay TMDL load reductions. But for other local TMDLs, there may be other methods out there that would allow you to propose load reductions for other pollutants. The next step is to collect data necessary to use the chosen method. You may need to determine if you already have sufficient data to use the method or whether you need to do new data collection. You may need to develop pilot studies to refine that data collection method. Finally, you need to identify who will do the data collection. Next, you need to apply the method, do the calculations and determine the load reduction. You need to make sure that you document all of your steps, because that’s an important part of the crediting process. Last, you report all of the information to the regulatory agency.

BMPs with Crediting Methods Proposed in Washington, DC Approved Collection system cleaning Catch basins End-of-pipe Street sweeping Proposed Pet waste cleanup There are a number of non-structural BMPs that have been proposed for use for credit in Washington, DC, including street sweeping, collection system cleaning, and pet waste cleanup. Several of these have methods approved by Chesapeake Bay Expert Panels, but one does not, and I want to talk about each of these BMPs in a bit more detail.

Catch Basin Cleaning Credit Approved Load per catch basin cleaned Steps: Mass on annual basis Convert wet mass to dry mass Multiply by nutrient enrichment factor Let’s start with catch basin cleaning. This is something that a lot of municipalities do, and it has a crediting methodology approved by an Expert Panel, so it seems like a natural fit to claim this for credit. But the tricky thing here is that the required data for claiming credit may be difficult to get. This BMP is quantified as the actual load of pollutants removed per catch basin cleaned, and it is determined using the following steps: First, the actual wet mass of solids/organic matter captured and disposed by storm drain cleaning practice are measured Next, this wet mass is converted into a dry mass And finally, the dry mass is multiplied by a nutrient enrichment factor to get loads of TN, TP and TSS removed.

Catch Basin Cleaning in Washington, DC Conducted by DC Water Data collection/reporting inconsistent Formalized data collection In Washington, catch basin cleaning is done by DC Water under an MOU with DOEE. DC Water does both catch basins in the combined area, where it holds the permit, but also in the MS4 area, where DOEE is the permit holder Historically, data collection/reporting has been inconsistent - New methodology has sparked formalized data collection effort

Catch Basin Cleaning Quantification App to quantify percent filled for each catch basin Quantification of volume removed Also tracks ID Location of catch basins in different watersheds Permit requires annual catch basin cleaning Catch basin cleaning optimization study DC Water developed app to quantify percent filled for each cleaned catch basin cleaned Allows quantification of volume removed for each catch basin Different catch basin configurations require evaluation of standard engineering details to determine volume of different catch basin types App also tracks ID of each catch basin Allows location of catch basins in different watersheds for “local” TMDL credit Permit requires annual catch basin cleaning This is “baseline” Catch basins cleaned more than once annually are considered additional load reduction Draft permit requirements require catch basin cleaning optimization study

Bulk Vegetative Mass Removal Credit for removal at outfalls Identical to catch basin cleaning District trash traps capture bulk vegetation Trash TMDL requires quantification of removal Expert Panel to Define Removal Rates for Street and Storm Drain Cleaning Practices allows credit for removal at outfalls Method identical to catch basin cleaning method District has trash traps that also capture bulk vegetation Anacostia Trash TMDL requires quantification of removal at trash traps

Quantifying Bulk Vegetative Mass Removal Trash traps at outfalls Modify monitoring agreements Monitoring done by non-profits Current focus on quantifying trash Identify trash traps at outfalls Modify monitoring agreements to include quantification of bulk vegetative mass Monitoring currently done by non-profits Current focus on quantifying trash Need to add quantification of bulk vegetative mass to procedures Logistical issues Already being done in some cases

Future Directions for Quantifying Bulk Vegetative Mass Removal Refine methodology Use a “discount factor” Debris from both sewer system and overland flow Credit for “local” TMDLs Leverage permit requirements Refine methodology for measuring wet mass of bulk vegetative debris Use a “discount factor” to quantify bulk vegetative debris from instream trash traps Vegetative debris from both sewer system and overland flow Use for credit for “local” TMDLs Leverage permit requirements for trash monitoring

Street Sweeping Approved methodology Data collection challenges Data collected by DPW Reporting inconsistent Departments working for consistency Methodology approved by Expert Panel Data collection challenges in the District Data collected by Department of Public Works (DPW) Reporting inconsistent Different reporting for different types of roads Difficulty getting spatial data for routes swept Reported mileage swept data inconsistent with route lengths DOEE and DPW working together to make reporting consistent

Pet Waste Removal Proposed method by CWP Account for behavior changes Increases in waste pick-up in dog parks Bag usage Proposed method developed by Center for Watershed Protection Attempts to account for increases in pet waste removal through behavior changes Increases in owners picking up after dogs when using dog parks Quantified through pet waste bag usage

Difficulties in Applying Pet Waste Removal Methodology Quantifying pet waste bag usage Informal management Behavior changes hard to quantify Needs better documentation Other factors Pollutant load/unit of pet waste Percent delivered to stream Quantifying pet waste bag usage Informal management of dog parks Do not track bag usage Bags may be donated Behavior changes hard to quantify Increase in owners picking up after pets at dog parks needs better documentation Other factors need additional documentation Pollutant load/unit of pet waste Percent delivered to stream

Potential Methods for Tracking Pet Waste Removal in the District DOEE tracks pet waste complaints Geodatabase Request for signs and bag dispensers Pilot project? DOEE Pollution Prevention groups tracks pet waste complaints Tracked in geodatabase Fulfills request for signs and bag dispensers Potential for pilot project before and after putting up signs/bag dispensers

Summary Identify quantification methodologies Quantify implementation and translate to load reduction Data collection may be a challenge Different data New studies/pilots Working with other agencies/departments Existing tasks and relationships Pay off - additional load reduction Need to identify methodologies to quantify non-structural BMPs Quantify amount of implementation and translate this to load reduction Data collection may be a challenge Different data compared to traditional structural BMPs May require new studies/pilots Other agencies/departments may be involved Priorities Budgets Training Reporting Leverage existing tasks and relationships Effort can pay off with additional load reduction

Tim Schmitt LimnoTech (202) 864-6821 tschmitt@limno.com Jonathan Champion DOEE Stormwater Management Division (202) 535 1722 jonathan.champion@dc.gov www.dcstormwaterplan.org