As the economic downturn continues to shrink state coffers budget cuts have rendered numerous government programs nearly inoperable. Unfortunately, stormwater management and other water quality initiatives have not been spared from a similar fate.
Considering that many state and municipal stormwater programs were already operating with a skeleton staff and shoestring budget before the downturn it’s easy to imagine the adverse impact additional cuts are having. Program managers have been forced to pull the plug or drastically scale back aspects of their programs that were once considered vital.
Efforts to evaluate innovative best management practices (BMPs) have been particularly hampered as staff time is largely spent on more mission critical functions like permitting. The result, innovative BMPs are prohibited in many jurisdictions because there is no time and/or expertise to evaluate their performance.
TAPE, TARP, and ETV
This trend is particularly concerning given our increasingly complex stormwater 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 needn’t look any further than what were the three most robust innovative BMP evaluation programs in the United States, the EPA’s Environmental Technology Verification (ETV) program, the Washington Department of Ecology’s Technology Acceptance Protocol- Ecology (TAPE) or the Technology Acceptance Reciprocity Partnership (TARP) stormwater 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, but unfortunately both the TAPE and ETV programs have essentially ground to a halt and NJDEP’s TARP program has sputtered recently due to resource limitations.
Innovation and BMPs
BMP providers are often left on the outside looking in as stormwater 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 stormwater impacts. There aren’t many successful carpenters that do not use power tools because they were once new and innovative, yet stormwater managers routinely leave tools on the theoretical shelf because they don’t have the time to learn how to properly use them.
Time for a change
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’s time for a national program that evaluates public domain and innovative technologies against consistent criteria. A national program would seemingly 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 local programs in existence today and state and local stormwater staff could devote their limited resources to other important issues like 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.