Manufactured Stormwater Treatment Devices (MTDs) Frustrations, Misperceptions, and Concerns. Part 1: Frustration is a Two-Way Street
Having spent the last sixteen years immersed in the world of stormwater best management practices (BMPs), with particular emphasis on manufactured treatment devices (MTDs), I’ve repeatedly borne witness to the frustrations, misperceptions, and concerns raised by all walks of stormwater professionals relative to MTDs. They’re too complicated, you have to maintain them, they don’t work, and there’s no performance data are commonly muttered from regulatory circles. Meanwhile, a visit to any given MTD provider is likely to yield plenty of grumbling as well. Regulators are way too slow, why do we get scrutinized so much more than land based BMPs, this test protocol is excessive and when are we going to start testing green infrastructure (GI) practices using the same protocols are common themes at MTD camps.
While there is no shortage of misguided scrutiny on both sides of MTD issues, experience typically affirms that by the time something finds a place in industry lore, there is some truth lurking within even the most unfounded stigmas. Having spent my entire professional career working for an MTD provider, I can cite numerous instances of being treated like a lesser class of stormwater citizen without any regard for my actual intentions or qualifications. As someone that has always advocated for water quality first and foremost and has been fortunate enough to work for an organization that supports doing so, I’ve certainly been offended by those directing unfounded bias toward MTD providers. My response has always been to work harder, do the testing, provide the data, share the facts, and let the work speak for itself. I’ve broken down many barriers with this approach and softened no shortage of once dismissive professionals. However, I’d be remiss if I didn’t acknowledge that I still observe others representing MTD providers exhibiting the behaviors that propel the ongoing stigmatization of the entire industry.
Nearly every MTD provider I’ve ever engaged with shares a common desire for fair treatment, consistent standards, and an established pathway to acceptance. Despite these goals, I’d argue that many fail to act in a manner that’s likely to get them there. Disparaging academics and NGOs that don’t share their views, disparaging representatives industry knowledge, advocating against testing and sizing criteria, and publishing misleading information still occur far too often. Just a few weeks ago, I reviewed a marketing document published by another MTD provider that purposely misconstrues the test results from the New Jersey MTD certification program in order to paint their technology in a more favorable light. Given the lingering prevalence of disingenuous behavior, it’s no wonder other stormwater professionals are frustrated, so MTD providers shouldn’t be surprised by the resulting scrutiny.
To our credit, MTD providers are routinely subjected to bias, unnecessary road blocks, and outright contempt by the regulatory community. I recognize that most stormwater programs are forced to operate with limited resources, which often leads to closed doors, illogical standards, or no standards at all. Additionally, MTD issues tend to take up a disproportionate amount of time relative to the scope of a stormwater program and national leadership on MTD issues has been limited. As a result, MTD providers are routinely forced to endure extensive delays for even simple reviews and the patchwork of testing, sizing, and submittal criteria in place throughout North America create a seemingly endless line of hurdles. The net result is often adversarial relationships between MTD providers and the regulatory community that stifle innovation and discourage investment in stormwater research.
Despite the frustration on both sides of MTD issues the cause is not lost. In Part 2 I’ll share my thoughts on bridging the MTD divide while putting water quality first.