Draining to the Ocean:
The Effects of Stormwater Pollution on Coastal Waters

Introduction to Stormwater Issues

1997 marks the twenty-fifth anniversary of the federal Clean Water Act. Since 1972, our nation has made significant investments in cleaning up coastal waters, lakes, and streams. Past practices of dumping untreated industrial wastes and raw sewage in coastal waters have subsided. Still, our nation's coastal waters are troubled.

Many are closed for shellfish harvesting and swimming. Others are subject to fish consumption advisories. Our nation still has much work to do before it meets one of the goals of the Clean Water Act -- to make all waters safe for swimming and fishing.

Over the past year, disturbing accounts of our nation's coastal water quality have been featured in the headlines. For example, the outbreak of a toxic microbe, Pfiesteria piscicida,in tributaries of the Chesapeake Bay caused fish kills and human health problems. Red tides along the Texas shore killed an estimated 14 million fish in September and October. Sea turtles with tumors are being found off the coast of Florida. Sewage spills closed a number of Long Island Sound area beaches this past summer. The "dead zone," an area approximately the size of New Jersey where dissolved oxygen levels are too low to sustain fish, continues to appear off the coast of Louisiana and Texas each year.

Pollutants running off lands and urban streets are contributing factors in many of these disturbing events and countless other water quality problems across the nation. To reverse the trends of poor coastal water quality, many states, cities, industries and individuals must redouble their efforts to manage and control pollution associated with storm events. During rainfalls and snow melts, a host of contaminants, including bacteria, nitrogen, phosphorus, heavy metals, chemicals, pesticides, sediments, and litter is washed from streets and land, carried by storm sewers, and eventually discharged into nearby lakes, rivers, streams, and coastal waters. Problems associated with stormwater are exacerbated by urbanization and suburban sprawl, for replacing natural lands with pavement and roofs causes greater concentrations of pollutants in larger volumes to enter and contaminate our waters. Because coastal areas of the country are among the most rapidly growing areas, stormwater pollution is a significant cause of water quality impairment in coastal waters and will continue to be unless actions to control stormwater pollution are taken. At stake are the vital ecological and economic resources linked to clean coastal waters.

This report begins with a presentation of the importance of coastal waters and their living resources to our nation. It follows with an account of the adverse impacts of stormwater pollution, current approaches to control stormwater pollution, and finally, recommendations for more effective stormwater management programs. Coastal waters are among the most productive natural systems on Earth. Freshwater draining from rivers and streams carry land-based nutrients that help support the diverse life of the coastal environment. River flows, tides, and winds constantly mix these nutrients. In addition, the shallowness of many coastal waters lets sunlight reach submerged seagrasses and promotes thriving plant and animal communities. The combination of sunlight, tidal actions, and balanced nutrient loading allows for productivity that rivals Midwestern farmland in its food yield.

Coastal waters are known by many different names - estuaries, bays, sounds, lagoons, sloughs, bayous, and inlets. Each distinct Water body, whether it is the Chesapeake Bay, Puget Sound, or Santa Monica Bay, provides considerable benefit to nearby coastal communities and the entire nation. For millions of Americans, coastal waters are integral parts of their hometowns and cities. For others, oceans and beaches are preferred vacation sites because of the abundant recreational activities and beauty provided by these areas. Coastal waters are vital habitat for shellfish and both marine and anadromous (those that migrate up rivers from the sea to spawn) fish, that in turn, support humans and wildlife. Other wildlife, including manatees, sea turtles, and migratory birds, use coastal waters, wetlands, and beaches as primary habitat or essential resting and nesting areas.

Population Centers

The ecological productivity and broad appeal of coastal waters make coastal areas some of the most desired "living places" in our nation. Increasing economic and recreational opportunities, attractive scenery, and the perception of a better quality of life are luring Americans to the coast.

Coastal areas of the United States are densely populated. The population density of coastal counties was 341 persons per square mile in 1988 - four-times the national average. Today, more than one-half of the United States population lives in a county which borders the Pacific Ocean, Atlantic Ocean, Gulf of Mexico, or Great Lakes. Projections indicate that coastal areas will continue to grow in the near future.

The United States' coastal population is expected to exceed 127 million people by 2010 - an increase of almost 60 percent from 1960. Furthermore, it is estimated that by the year 2010, more than 75 percent of the United States' population will reside within 50 miles of the coast.

Population growth and development significantly affect coastal Water quality. Increasing population results in the generation of more waste and greater stress.

The wastewater systems designed to collect and treat sewage. Sewage treatment plants and individual septic systems must be rigorously maintained in order to prevent malfunctions. Also, as natural landscapes are destroyed and replaced by pavement and buildings, increased loads of sediments and other contaminants end up in the water, rather than being absorbed by soils and vegetation.

Coastal communities are challenged by the necessity to balance their expanding population and development with sustaining local economies and with providing environmental protections. In the long term, ignoring environmental problems will jeopardize many of the resources that attract residents to coastal areas.

Recreational Opportunities

United States beaches and coastal areas rank as a favorite vacation destination for Americans, with the average resident spending ten recreational days on the coast each year. In 1993, more than 180 million Americans visited ocean and bay beaches.

During the summer months and peak weekends, many coastal communities experience substantial surges of population. In the summer, the area population around the Peconic Bays of New York exceeds 280,000 people an increase of 165,000 people (or 143 percent) from the year-round resident population. By the year 2000, the area's summertime population is anticipated to reach 365,000 people. Often, these beach resort communities do not have the infrastructure, such as sewage treatment capacity and trash collection to adequately address the additional threats to water quality that these seasonal population surges bring. The tourism industry is a significant contributor to coastal states revenues and employment rolls. The state of Florida estimated the revenue generated by coastal tourism to be $23 billion in 1995.

Tourism include:

Boating and sport fishing are recreational activities that provide important benefits to coastal communities. In 1990, more than 5,000 marinas, available to service 9 million recreational boats in the United States, were situated along the coastline., The state of Maryland calculated that recreational boating expenditures eclipsed $1 billion in 1993 and were responsible for 18,000 full-time jobs in the state.

It is estimated that the sport fishing industry supports a total of 924,000 full-time jobs nationwide. Over 205,000 of these jobs are generated by salt-water fishing. In 1991, recreational fishing in Florida generated approximately $3.5 billion in economic output and employed over 58,000 people.

Fisheries Habitat

Seagrasses, coral reefs, marshes, mangroves, and coastal wetlands provide excellent spawning and nursery habitat for fish and shellfish. Juvenile fish and shellfish also use the shallow, lush coastal habitats for shelter from larger predators. Later in their life cycle, many fish species migrate to other waters where they are commercially and recreationally caught.

Shellfish

Oysters, blue crabs, hard clams, scallops, Dungeness crabs, and other molluscan shellfish dwell in near-shore coastal waters. Many of these shellfish inhabit the bottoms of coastal waters and sustain themselves by filtering massive volumes of water in order to retain nutrients and phytoplankton. However, they also ingest pollutants that accumulate in their tissue and can be passed onto consumers of shellfish.

In many coastal communities, shellfish harvesting was historically a mainstay of the local economy. Despite the harvesting limitations due to shellfish bed closures, habitat destruction and overfishing, commercial shellfishing is still a significant part of coastal economies. In 1995, commercial fishermen harvested over 77 million pounds (meat weight) of molluscan shellfish, with a dockside value of $200 million.

Habitat for Other Wildlife

Coastal waters, wetlands, dunes, beaches, and other coastal habitats provide important dwelling places for birds, marine life, and terrestrial wildlife. Many of these habitats are threatened by development pressures.

Coastal habitats are especially vital to threatened and endangered species. Coastal areas provide habitat for more endangered and threatened species than inland areas. The average number of protected species for counties in the continental United States is three to four; however, close to one-half of the nation's coastal counties sustain ten to twenty listed species. Approximately 75 percent of the nation's endangered and threatened mammal and bird species rely on coastal habitats

Water moves through nature in cycles. Heat from sunlight causes the surface waters of oceans and lakes to evaporate and form clouds. Water also moves through vegetation and transpires to the atmosphere. Water returns to Earth as rain or snow. This precipitation may be naturally absorbed by soil and eventually infiltrate to groundwater, or, rainfall may run off the land and streets, and pick up oils, grease, and road salts from highways and parking lots; pesticides from lawns and parks; excess nutrients; sediments; disease-causing organisms found in pet and animal waste; litter; and toxic metals. This stormwater drains into storm sewer conveyances and occasionally is collected and diverted to treatment works. More often, the conveyances discharge the stormwater, at discrete points commonly called outfalls, directly into streams, rivers, coastal waters, and the ocean.

Not only does greater imperviousness reduce rainfall absorption through soils, but it also prevents contaminants from being trapped and neutralized in the soil. So, as the rate of imperviousness in an area increases, greater concentrations of contaminants, in greater flows will enter storm sewers, rivers, streams, and coastal waters. <

Contaminants in stormwater degrade the water quality of our nation's coastal waters. Since many coastal waters are semi-enclosed and poorly flushed by tides cause severe discomfort and can result in substantial economic losses to society from lost days of work. In addition, the health risks of these diseases are more significant for sensitive segments of our population, such as children, the elderly, expectant mothers, and persons with compromised immune systems.

Toxins are another potential human health problem linked to stormwater pollution. Many toxic contaminants, such as heavy metals and organic chemicals, do not degrade once they enter coastal waters, but instead persist in the sediments along the waters bottom. Eventually, aquatic life that inhabit the bottoms of coastal waters, are exposed to the toxics. Over time, these toxics "bio-accumulate" in the fatty tissues of shellfish and fish. Humans who eat fish and shellfish contaminated by toxics may experience increased incidences of cancer, neurological disorders, and birth defects. For those individuals that eat larger quantities of fish and shellfish, such as subsistence fishers, these risks are considerably magnified.

Beach Closures

After a heavy rainfall, pathogens enter beach waters from storm drain outfalls. Pathogens can also be found in "dry-weather flows" of storm drains, due to lawn sprinklers and other activities. Pathogens contaminate recreational waters and can lead to human illnesses. For this reason, several local and state public health agencies have developed beach water testing protocols in order to protect individuals who recreate in beach waters. A few states consistently close beaches or issue health advisories after tests indicate health-based standards for pathogens have been exceeded. However, beach water quality monitoring programs vary greatly from beach to beach; in fact, there is significant variance within many states. At least six coastal states do not regularly monitor their beach waters for swimmer safety.

For each of the past seven years, the Natural Resources Defense Council (NRDC) has surveyed public health agencies and compiled the most comprehensive list of closures and health advisories at ocean, bay, and Great Lakes beaches. Since 1988, over 18,590 beach closures and health advisories have been issued to safeguard swimmer health. During 1996, beaches were closed or subject to public health advisories on more than 2,596 individual occasions. Several of these lasted for more than one day. By adding the extended and individual closures, the number of beach closures and health advisories issued in 1996 increases to 3,685 days.

The figures underestimate the extent of pathogen-contaminated beach waters since many states do not regularly monitor recreational waters, and therefore untested, unsafe beaches remain open.

For its 1997 report, NRDC identified the pollution sources causing the closures and advisories to be issued. Stormwater was a significant source of the beach water pollution, responsible for 407 of the closures and advisories.

Because of the association between heavy rainfalls and pathogen contamination at recreational beaches, a growing number of communities are taking precautionary measures. These communities automatically issue warnings against swimming once a certain threshold of rainfall per 24-hour period is exceeded. The thresholds have been determined using results of baseline monitoring activities.

Shellfish Bed Closures

Pathogen contamination is also a principal reason for restrictions placed on shellfish harvesting in many of our nation's coastal waters. Approximately one-third of the nation's shellfish harvesting areas are closed or harvest-limited based on water quality concerns, such as pathogen or toxic contamination.

In a 1995 survey of shellfish harvesting areas, polluted urban stormwater was identified as the leading source of pollution contributing to harvest limitations. Health officials advised against eating some non-commercially caught fish and wildlife because of their increased sensitivity to potential adverse health effects.

The number of water bodies that are under some fish or wildlife consumption advisory has steadily increased in the past few years. In 1996, states issued 2,193 fish and wildlife consumption advisories - a 26 percent increase from 1995.

Habitat Destruction

Silt and sediment carried by stormwater destroy coastal habitats. Seagrasses are smothered by heavy loads of sediments. Sedimentation can also cause cloudy, or turbid waters. Turbid conditions make it difficult for sunlight to penetrate to the submerged vegetation of bay bottoms. Robbing the aquatic vegetation of sunlight inhibits the growth of plant life which is essential to fish and shellfish.

Heavy volumes of stormwater can also damage stream banks and beds. Increased flows of urban streams after rainfalls or snow melts typically accelerate the rate of erosion of stream banks and create large sand bars downstream.

Because of the increasing public awareness about the adverse impacts of stormwater pollution, plans to better manage and control this pollution are underway in many communities and at various levels of government. Public education efforts on a range of stormwater pollution issues - from storm drain stenciling to restricted beach access after heavy rains - are helping to build support for difficult stormwater management decisions. Local ordinances concerning unauthorized discharges into storm drains, sediment and erosion controls at construction sites, and municipal vehicle operations are becoming more commonplace. In addition, stormwater management activities are typically included in comprehensive watershed management plans for urban streams and coastal waters. Several states are developing or revising statewide stormwater management programs. Stormwater pollution controls are also addressed by the federal Clean Water Act and the Coastal Zone Act Reauthorizing Amendments of 1990.

Stormwater Permitting Program of the Clean Water Act

Since the passage of the Clean Water Act in 1972, considerable attention has been placed and progress made in controlling water pollution from sewage treatment plants and industrial operations. Contaminants discharged from these facilities enter waters from distinct and identifiable points (i.e. pipes, outfalls), and thus are classified as "point sources" of pollution under the Clean Water Act. "nonpoint sources" of pollution enter waters from dispersed locations, rather than pipes or outfalls. Much of the pollution associated with logging areas, agricultural lands, and marinas is considered to be "nonpoint pollution."

Under the Clean Water Act, the U.S. Environmental Protection Agency (U.S. EPA) requires most facilities discharging wastewater through point sources to apply for permits. As early as 1973, the U.S. EPA identified stormwater discharges as point sources for purposes of their coverage under the Clean Water Act, but exempted many of these discharges from permit requirements because of insufficient agency resources, challenges in setting and measuring the contaminants, and the potentially large number of stormwater dischargers requiring permits.

Between 1972 and 1987, several federal regulations covering stormwater discharges were proposed. These proposed regulations were routinely challenged by industries, environmental organizations, and municipalities for a variety of reasons, ranging from being too burdensome to being inadequate. In addition, changes in presidential administrations and policies within the U.S. EPA often delayed progress on issuing and implementing stormwater regulations. At the time Congress reauthoized boating, hydromodification, and urban land uses - were identified in the EPA guidance. A few of the management measures identified for urban areas address stormwater discharges. These include measures for new development; watershed protection; site development; construction activities; existing development; pollution prevention; and roads, highways, and bridges.

In addition to the municipalities, EPA identified eleven categories of industrial facilities that need to apply for stormwater discharge permits. A few examples of these industrial facilities include mining operations; oil and gas operations; hazardous waste treatment, storage, and disposal facilities; land fills receiving industrial waste; vehicle maintenance operations; and certain construction sites. These industrial facilities are required to identify pollution sources, develop pollution prevention plans, and adopt "best management practices" for controlling, reducing, and preventing pollutants associated with stormwater discharges.

The 1987 amendments also require U.S. EPA to study and identify potential sources to be covered under the second phase of the stormwater permitting program and to examine the extent of pollutants in such discharges. Regulations were to be issued and a comprehensive stormwater management program for "phase two" sources was to be established. By October, 1993 EPA did not meet these deadlines. The final rule to controlling stormwater discharges from these additional sources is scheduled to be issued by March, 1999 - more than five years past due.

Coastal Polluted Runoff Control Programs

Since the 1970s, coastal states have been working with the U.S. EPA and the National Oceanic and Atmospheric Administration (NOAA) to protect coastal resources. The federal Coastal Zone Management Act (CZMA), enacted in 1972, provides financial incentives for states to voluntarily produce comprehensive coastal programs to ~address land uses, water uses, and development in the state's coastal zones.

In 1990, Congress passed a critically important amendment to the federal Coastal Zone Management Act, commonly called section 6217 of the Coastal Zone Act Reauthorization Amendments (CZARA). A central objective of the amendment was to improve coordination among state coastal zone management agencies, state water quality agencies, and federal agencies so that land uses impairing coastal water quality could be better managed. The amendment required states with approved coastal zone management plans to develop coastal polluted runoff control programs.

In 1993, the U.S. EPA issued guidance to the states on management measures for nonpoint pollution sources in coastal waters. Management measures for five categories of nonpoint pollution sources - agriculture, forestry, marinas/recreational.....

Bay focuses on a strategy to reduce both nitrogen loading and toxic contamination of sediments by preventing and treating stormwater discharges. Key elements of the stormwater management action plan include: (1) expanding a public awareness campaign for homeowners and businesses about landscape design and maintenance practices; (2) assisting business owners in developing pollution prevention plans for their operational sites; (3) promoting the use of integrated pest management programs by local governments; (4) minimizing impervious surface coverage by developing targets for pervious-to-impervious surface coverage for new development and parking lots; (5) requiring older developed sites to meet current stormwater treatment standards as they are redeveloped; (6) working with planners to study projected growth patterns with the objective of looking for ways to promote compact development; and (7) improving compliance with stormwater permits.

Recommendations for effective stormwater management programs

As coastal populations continue to grow and development mounts, local governmental officials, planners, business leaders, environmentalists, and other community members will need to examine strategies for effectively preventing and controlling pollution associated with stormwater discharges. In the interest of promoting sustainable development and protecting aquatic resources, a number of recommendations for developing stormwater programs are being promoted by environmental and citizen activists. These ideas include among others: public participation, compliance and enforceability, construction activities, and flow issues.

1. Public Participation and Education

Members of the general public have several important reasons to see that municipalities develop effective stormwater management programs. First, through their actions, residents are contributors to the pollution entering storm sewers, and often impact water bodies farther downstream. Second, as taxpayers, they finance the infrastructure needs and enforcement authorities. Finally, the public uses nearby waters and resources for fishing, boating, and other recreational activities. These pursuits can be adversely affected by stormwater pollution.

The public has a strong stake in the quality of their waters and therefore, should have access to and be involved with the processes related to developing and administering stormwater pollution plans. From an early point in the development of municipal stormwater plans, local officials should explore ways to actively engage members of the general public. One prominent way for municipal officials to involve the public is to recruit citizens to participate in a community advisory committee that has a meaningful role in plan development. To be inclusive, municipal officials should invite individuals from all sectors of the community, especially representatives of lower- income groups that may have frequently been omitted from key advisory roles in past, community-wide environmental decisions, to participate in the process. Such community advisory committees can provide guidance to the key decisionmakers in determining the major sources of stormwater pollution to target, developing effective pollution control measures, creating and distributing understandable educational materials, and increasing public support for the additional investments needed to properly manage stormwater pollution. By meaningfully involving the public during the early stages of a program, municipal officials will more likely build a unified, broad- based constituency to support difficult decisions related to regulation, enforcement, and funding. In addition, citizens that are able to participate at the outset will have a better understanding of the varied concerns of municipal and business leaders. This deeper awareness could help craft objectives and priority actions that receive greater support.

During the development and implementation of local stormwater programs, members of the public should be consulted about how to develop and distribute educational materials effectively and efficiently. Using technical assistance from U.S. EPA and other networks, municipal officials should craft informational materials for special sectors of the community, such as industries that are more likely to be responsible for stormwater pollution problems and school children. Municipal officials should also consider providing stormwater information and programmatic updates to local citizens groups and encourage them to include these reports in membership newsletters and materials. In addition, specific businesses could provide information to their customers and staff about certain actions for preventing stormwater pollution. For example, nursery owners could display information about lawn care and landscaping practices to prevent or reduce pollution running off residential lawns. Likewise, automobile service stations could display information about proper disposal of used motor oil and automotive fluids.

It is equally important that members of the general public have the opportunity to participate in the actual administration of local stormwater programs. The public should have access to important information related to stormwater pollution, such as industrial facilities' "notices of intent," sediment and erosion control plans at construction sites, and municipal stormwater pollution management plans. Through this information, citizens would gain a greater ability to protect aquatic resources that are important to their community.

In sum, a way to better ensure more successful stormwater management programs is to include representatives of many sectors of the community in the development and implementation of the program, and also in efforts to educate the public-at-large. Allowing community members to be a part of key decisions helps to generate a stronger public commitment and a greater assumption of personal responsibility for cleaning up waters.

2. Roads and Highways

Highway construction activities, ongoing road operations and maintenance, and vehicle use can contribute to significant stormwater pollution problems. Highway construction activities destroy natural vegetation, alter landscapes, and can cause sedimentation problems. Road de-icing materials add chloride, sulfates, and cyanide to water bodies. Automobile emissions and leaks are potentially significant sources of heavy metals that contaminate rivers, streams, and coastal waters. A study conducted for the Santa Clara Valley Nonpoint Source Control Program revealed that automobile brake pad wear is responsible for up to 50 percent of the copper loads entering lower San Francisco Bay Other associated with vehicle exhaust, tire wear, and parts wear are lead, zinc, cadmium, nickel, chromium, bromide, oil, and grease, among others.

However, too often, stormwater management plans overlook or only slightly consider these large sources of toxic contaminants. States and localities should require state Departments of Transportation to be covered by stormwater permits and pollution management plans. This coverage would compel highway departments to develop and use best management practices as they design, build, maintain, resurface, and widen roads and highways. Many best management practices for reducing stormwater pollution from road and highways are being applied and tested. A few examples of these management practices include median strip detention ponds, roadside grassed swales, vegetated ditches, sediment control procedures during construction, and alternatives to applying road salts for de-icing streets.

3. Construction Activities

Construction activities loosen large amounts of sediments and contaminants that can eventually be washed into coastal waters. Because coastal communities are rapidly growing, controlling erosion and sediment loss on construction sites is an important step toward protecting coastal water quality and aquatic resources.

Under the first phase of the federal stormwater permitting program, construction sites that disturb more than five acres of land are required to apply for a general permit. However, smaller construction projects can impair water quality and habitat, and can individually and cumulatively, cause significant degradation. For this reason, it is imperative that contractors and developers take adequate steps to prevent erosion and control sediment loss on their construction sites. Construction activities disturbing one-half acre and greater should be covered by a general permit and be subject to a stormwater pollution prevention plan. In their pollution prevention plans, developers should be allowed to determine, using a menu of best management practices, how they will control erosion and sediment loss during construction. These plans need to be reviewed by water quality agencies and should always be measured against clear and objective performance standards.

Although information about permitted construction activities is to be publicly available, it is often difficult to access such information from the construction site operator and/or the water quality agencies. Concerned citizens are routinely frustrated when they seek basic information about specific construction activities, on-site measures to prevent erosion and sediment loss, and potential impacts to local water quality resulting from construction site stormwater discharges. Stormwater pollution prevention plans filed with a general permit for construction activities should be made available, within a reasonable period of time, to individuals who seek such information. Access to this information is consistent with Clean Water Act requirements to make permit-related documents available to the public. On-site inspection reports which are filed should also be made available to the public.

Too often, land clearing activities commence before water quality agencies and interested members of the public have the opportunity to study a particular construction project. Currently, the permit applicant for construction activities must file a notice of intent "NOI" at least two days before clearing activities begin. Allowing 30 to 60 days for a more thorough review of a proposed stormwater pollution prevention plan should result in stronger protections for water quality and habitat. Three advantages of extending the review period are (1) better assessments of proposed projects; (2) greater protection of water quality projects without adequate safe guards are temporarily delayed to establish stronger control measures; and (3) potential opportunities to increase cooperation between concerned citizens and developers.

4. Agriculture and Forestry

Pollution associated with stormwater is not solely an urban land use problem. Timber harvesting and agricultural practices also contribute sediments, nutrients, and fertilizers after storm events and snow melts, and often impair rivers, lakes, and coastal waters. Municipal officials object, with justification, to being held responsible for impaired water quality due to stormwater contaminants that enter their sewer systems or water bodies from upstream sources outside of their jurisdiction.

A comprehensive approach to protecting water quality should examine the individual and cumulative impacts of all sources of stormwater pollution in a particular watershed and undertake actions for recovery. To improve effectiveness, such watershed planning needs to require measures for achieving greater reductions of runoff if timber or agricultural activities are having an impact on downstream water quality. One advantage ge of a comprehensive approach is its greater equity. Municipalities and industries would benefit from activities undertaken upstream that prevent water pollution, since they would be relieved of pollution loading introduced upstream.

To achieve a more equitable approach, there needs to be more accountability and enforceability for "non-point" sources, such as agriculture and forestry. Currently, polluted runoff from these sources are being addressed with an overemphasis on voluntary practices. Coastal states are developing enforceable polluted runoff control programs for their coastal zones, however, their record of gaining programmatic approval and actually implementing the programs is sub-par. Adopting, implementing, and enforcing the management measures for non-point sources identified in state coastal polluted runoff control programs would advance water quality in coastal states and create more balance between point and nonpoint source approaches to prevent water pollution. Coastal states should expand the measures of the coastal nonpoint pollution program into their non- coastal areas. For noncoastal states, an enforceable system to prevent polluted runoff associated with agriculture, forestry, and other sources should be established.

5. Issues of Stormwater Flow

Increased flows of stormwater drainage can severely damage aquatic habitats in urban, suburban, and rural areas. A few of the most notable, adverse habitat effects include flooding outside the stream bank, stream channel widening, increased stream bank erosion, changes in stream pool and riffle structures, streambed alterations, and larger sandbars. These alterations create conditions that can diminish the number and diversity of fish species, especially sensitive cold water species such as trout and salmon. Increased stormwater flows can also lead to increased loading of sediments along the bottoms of bays and rivers farther downstream. Aquatic vegetation necessary for estuarine and marine fish and shellfish can be smothered by the increased sedimentation.

As states and local officials prepare comprehensive stormwater management plans, the impact that stormwater flow has on waterways and habitats deserves to be considered. Because of the interface between stormwater flow and impervious surfaces, communities should examine ways to make land use decisions that will minimize impervious surfaces. Community leaders should consider designating future growth areas in portions of the watershed that will have minimal impacts on local water quality and limiting development activities in areas that are more sensitive to impacts of greater imperviousness. In addition, community planners should concentrate more projects in areas where roads and development centers already exist, such as blighted, older areas or underused, newly-developed sectors. Finally, community planners should be encouraged to design more compact development projects, such as cluster homes, to minimize individual lot size and provide a large area of open space that absorbs excess stormwater runoff from the developed area and enhances recreational opportunities for residents.

Local management plans. should also feature techniques that minimize the amount and velocity of stormwater emptying into nearby streams and coastal waters. Using stream side buffers has been documented as an effective practice in reducing stormwater flow and protecting downstream habitat from increased stormwater flows. Buffers also provide important water quality benefits by removing sediments, nutrients, and pathogens. Forested buffer strips along a stream can also enhance water quality by providing shade to help maintain water temperatures. Finally, stream buffers provide habitat for wildlife and many communities use them as recreational "green ways." Other best management practices to minimize stormwater flows include retention basins and stormwater ponds.

6. Compliance and Enforceability

In recent years, there has been much heated debate about using enforceable mechanisms to better control stormwater and polluted runoff sources. During the 104th Congress, a bill to reauthorize the Clean Water Act (H.R. 961) proposed changing the approach of permitting stormwater discharges to relying on voluntary measures spread that could have been delayed for fifteen to nineteen years.

Voluntary measures to prevent and manage stormwater discharges are important components to a successful stormwater program; however, depending solely on voluntary efforts will not provide the results which are needed to protect water quality and aquatic resources. The national nonpoint source pollution program (section 319 of the Clean Water Act) relies on voluntary measures and "demonstration projects" to address the pollution running off of agricultural lands, forests, mining sites, grazing pastures, and other areas. While there are several individual success stories identified with the 319 program, there is no demonstrable evidence to support the notion that a purely voluntary approach to reduce water pollution provides adequate protection for our nation's waters and resources, nor will achieve the goals of the Clean Water Act.

For a pollution source as widespread and damaging as stormwater pollution, our national policies on water pollution should tie requirements for reducing stormwater discharges with enforceable mechanisms. It is important for major sources of contaminants entering storm sewer systems to be held accountable for the pollution they generate. The penalties and consequences of violating stormwater rules and permit requirements should be clearly conveyed, strong enough to promote improved compliance records, and consistently applied to violators.

To ensure maximum, long-term success in reducing pollution associated with stormwater and to build public support for stormwater programs, a common-sense approach to enforcement activities should be considered. Public education efforts centered around stormwater pollution problems and management practices for improving water quality and complying with new stormwater management requirements should be part of comprehensive stormwater management programs. If stormwater pollution problems persist after the initial rounds of inspections, more concerted efforts to notify and educate significant pollution dischargers should be undertaken. If violations continue to occur, water quality agencies should be prepared to take every action to fully enforce water pollution laws. And, water quality agencies must initiate enforcement actions against significant and habitual violators of stormwater pollution laws.

In addition, a comprehensive stormwater plan should include objective measures to determine the program's success. Municipal stormwater management plans and discharge permits should include some measurable goals, such as specific best management practice requirements and compliance records tied to water quality standards, that a discharger strives to obtain. Such goals would provide community leaders a better understanding of successful pollution-reducing activities and actions that need further refinement. These goals would also help members of the community better assess how their individual actions are improving or hurting the municipality's efforts to achieve stormwater pollution reduction.

Finally, the U.S. Environmental Protection Agency and states need to improve upon and expand their enforcement and compliance efforts related to stormwater pollution. Citizen activists in many cities currently regulated under the first phase of the stormwater permitting program are discouraged by the shortcomings in enforcement activities, particularly among industrial permittees. Because of possible government inaction, the rights of concerned citizens to step in and take direct legal actions to protect the waters they care about from uncontrolled stormwater discharges must be retained.

Conclusion

In order to protect our shorelines, bays, oceans, and their resources, many coastal communities must adopt measures to prevent and reduce stormwater pollution. However, only when each one of us - citizens, business owners, elected officials, farmers, and developers - commits to taking actions to reduce stormwater pollution will the health of our own communities, downstream towns and cities, local streams, and oceans be restored.

Acknowledgments

Several colleagues made valuable contributions to the completion of this report. The author thanks Peter Lehner, Barbara Jeanne Polo, Lauren Yannotta, and Richard Salcedo for their insightful review of early drafts and creative assistance in designing this report. In addition, the author wishes to thank Diane Cameron, Roy Hengerson, Babafemi Adesanya, Michael Houck, Jessica Landman, Tim Eichenberg, and Kathy Nernsick for their assistance in preparing this report.

American Oceans Campaign gratefully acknowledges the generous financial support of The Pew Charitable Trusts and the Clean Water Network for the printing and distribution of this report.

American Oceans Campaign founded in 1987, is a national non-profit organization dedicated to the protection of marine ecosystems. To obtain more information on-line about AOC and its work, visit our website at: www.americanocean.

United States Department of Commerce, National Oceanic and Atmospheric Administration, Coastal Zone Management Issues: Silver Spring MD: National Oceanic and Atmospheric Administration.

National Oceanic and Atmospheric Administration, Fifty Years of Population Change Along the Nation's Coasts (Rockville MD: National Oceanic and Atmospheric Administration 1990.)

Michael L. Weber and Judith A. Gradwohl, The Wealth of Oceans (New York: W.W. Norton 1995.)

National Oceanic and Atmospheric Administration, Fifty Years of I Population Change Along the Nation's Coasts.

United States Fish and Wildlife Service, Coastal Ecosystems Program Prospectus (Washington: U.S. Fish and Wildlife Service 1995.)

National Oceanic and Atmospheric Administration, Fast Facts on the Coast (fact sheet.)

Suffolk County Department of Health Services, Brown Tide Comprehensive Assessment and Management Program Summary (New York: Suffolk County Department of Health Services 1992.)

Suffolk County Department of Health Services, Brown Tide Comprehensive Assessment and Management Program. Volume I (New York: Suffolk County Department of Health Services) 1992) 1-9.

Sarah Chasis, Peter Lehner, and Marci Bortman, Testing the Waters VII: How Does Your Vacation Beach Rate? (New York: Natural Resources Defense Council, 1997) 10.

Chasis, Lehner, and Bortman.

Weber and Gradwohl.

Ben Sherman, Recreational Boating Provides $1 Billion Impact in Maryland (Annapolis: Maryland Sea Grant Extension), 1995. Sherman quotes a study performed by Douglas W. Lipton, Director of the University of Maryland Sea Grant College Extension Program.

Sport Fishing Institute, Economic Impact of Sport Fishing in the United States (Washington: Sport Fishing Institute, 1994) 5.

Sport Fishing Institute, 7.

Elliot A. Norse, Global Marine Biological Diversity: A Strategy for Building Conservation into Decision Making (Washington: Island Press, 1993) 65.

United States Environmental Protection Agency, Wetlands Fact Sheet #2 (Washington: U.S. EPA, 1995.)

William A. Nering, Wetlands of North America (Charlottesville VA: Thomasson-Grant, Inc. 1991) 101.

United States Department of Commerce, National Oceanic and Atmospheric Administration, The 1995 National Shellfish Register of Classified Growing Waters (Silver Spring MD: National Oceanic and Atmospheric Administration, 1997) 9.

Restore America's Estuaries, Working Together for Healthy Estuaries (brochure).

Narraganseft Bay Project, 1995 Biennial Report (Providence: Narraganseft Bay Project, 1995) 6.
Rhode Island Department of Environmental Management, Division of Fish, Wildlife, and Estuarine Resources, Coastal Fisheries Laboratory, Quahog Landings for Rhode Island (Wakefield, RI: Department of Environmental Management, 1994.)

United States Fish and Wildlife Service, Coastal Ecosystems Program Prospectus 1.

National Safety Council, Environmental Health Center, Covering the Coasts: A Reporter's Guide to Coastal and Marine Resources (Washington: National Safety Council, 1993) 24.

Laura and William Riley, Guide to the National Wildlife Refuges (New York: Macmillan, 1992) 568.