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Title (dcterms:title)
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Transforming Tradition: A Case Study of Stormwater Management in Clark County, Washington to Assess Barriers to Low Impact Development Strategies
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Date (dcterms:date)
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2013
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Creator (dcterms:creator)
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Dochow, Dianne
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Environmental Studies
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extracted text (extracttext:extracted_text)
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TRANSFORMING TRADITION: A CASE STUDY OF STORMWATER
MANAGEMENT IN CLARK COUNTY, WASHINGTON TO ASSESS
BARRIERS TO LOW IMPACT DEVELOPMENT STRATEGIES
by
Dianne Dochow
A Thesis
Submitted in partial fulfillment
of the requirements for the degree
Master of Environmental Studies
The Evergreen State College
June 2013
©2013 by Dianne Dochow. All rights reserved.
This Thesis for the Master of Environmental Studies Degree
by
Dianne Dochow
has been approved for
The Evergreen State College
by
________________________
Martha L. Henderson
Director of the Graduate Program on the Environment
Member of the Faculty, The Evergreen State College
________________________
Date
Abstract
Transforming Tradition: A case study of stormwater management in Clark
County, Washington to assess barriers to low impact development strategies
Dianne Dochow
Stormwater runoff is one of the leading polluters of Puget Sound and other
Washington State waterways, adversely affecting human health and damaging
aquatic and terrestrial ecosystems that depend on clean water. Discharges from
traditional stormwater infrastructure, also known as point source pollution, are
main contributors to this problem. The Clean Water Act National Pollutant
Discharge Elimination System (NPDES) permits for municipal separate storm
sewer systems (MS4s) require municipalities and counties to develop stormwater
policies and implement codes and standards that help protect waters of the state
from the harmful effects of stormwater discharge. In contrast to traditional
stormwater management practices, NPDES permit protocols increasingly favor
low impact development (LID), site-specific surface water and land use
management strategies that mimic pre-disturbance water cycles, thereby
managing water in situ instead of exporting it for discharge into state waterways.
A mixed methods case study assesses barriers to low impact development
strategies for stormwater management in Clark County, Washington through the
lens of seven impediments developed by Australian researchers. The study
concludes that resistance to change and clarification of legislative mandates are
keystone barriers to LID strategies for stormwater management, and demonstrates
the need for collaborative interdisciplinary solutions. This research is significant
because the environmental problems associated with traditional stormwater
management dictate a transition from conventional methods to more sustainable
regimes. Assessing barriers to LID stormwater management strategies will inform
efforts, enhance outcomes, and educate and inspire participants so that with time
stormwater-caused water pollution will become the exception and not the rule.
Table of Contents
List of Figures & List of Tables................................................. v
Acronyms ................................................................................ vi
Acknowledgements ................................................................. vii
Chapter 1:
Introduction ......................................................................
Stormwater: An Overview...............................................
Stormwater Policies, Then and Now ...............................
Low Impact Development ...............................................
1
3
5
8
Chapter 2:
Pragmatism: A Statement of Theory ................................
Literature Review .............................................................
Knowledge Gaps ..............................................................
Methods ............................................................................
12
13
24
25
Chapter 3:
Getting to Know Clark County ........................................
Government Structure and Economic Overview ..............
Stormwater Management and Low Impact
Development (LID) in Clark County....................
Litigation ..........................................................................
31
34
35
41
Chapter 4:
Analysis ...........................................................................
Findings ...........................................................................
43
58
Chapter 5:
Conclusion ......................................................................
60
Bibliography ...................................................................
64
iv
List of Figures
Page
Figure 1:
Stormwater transports pollutants into infrastructure networks.
Figure 2:
Bioretention facilities are engineered LID features that reduce
stormwater flow and provide water treatment.
5
9
Figure 3:
Green roofs provide stormwater abatement for rooftop runoff.
Some green roofs provide outdoor living space.
10
Figure 4:
Clark County in southwest Washington State.
31
Figure 5:
Clark County watersheds and sub-watersheds.
32
Figure 6:
The innovative Grattix invented by PV employees removes
90-95% of zinc from roof runoff, and is simple and inexpensive
to build and maintain.
40
Figure 7:
Analysis of data using seven barriers devised by Roy et al. (2008).
44
Figure 8:
Clark County’s integrated approach to NPDES permit
responsibilities combats fragmentation by involving staff from
many different departments in stormwater management activities.
48
List of Tables
Table A:
Barriers 1 through 7 ranked according to influence on LID.
58
v
Acronyms
CCSC
Clark County Sustainable Communities
CREDC
Columbia River Economic Development Council
CWP
Clark County Clean Water Program
EDP
Clark County Economic Development Plan
EPA
U.S. Environmental Protection Agency
IT
Information Technology
LID
Low Impact Development
LIDTGM
Low Impact Development Technical Guidance Manual
NPDES
National Pollutant Discharge Elimination System
PV
Port of Vancouver
SARD
Sustainable Affordable Residential Development
SCPP
Sustainable Communities Pilot Program
SNAP
Stormwater Needs Assessment Program
SWMMWW Stormwater Management Manual of Western Washington
UW
University of Washington
WSC
Washington Stormwater Center
WSU
Washington State University
vi
Acknowledgements
I am surrounded by truly amazing people and am grateful for the unwavering
encouragement, patience, and support from my family of origin, my family of friends,
and my academic family, many of whom have become treasured friends. Special
recognition and appreciation goes out to my partner Mike who is simply the best.
Thank you to my reader Dr. Martha Henderson who introduced me to the art of
qualitative research and coaxed me out of my quantitative comfort zone. Her
encouragement and guidance were integral to the completion of this thesis.
Lori Peterson, MES (2012), and Laura Thelen, MES Candidate (2014), provided valuable
feedback, editing assistance, and much needed moral support. Thank you both.
With sincere appreciation to Walter Hill, Dr. Tyrus Smith, Dr. Paul McCreary, Dr.
Mingxia Li, Dr. Judy Cushing, Dr. Peter Bacho, Felix Serna, and Richard King.
vii
Chapter 1
“[Water] is the gold standard of biological currency, and the good news is
that we can conserve it in countless ways . . . Our task is to work out
reasonable ways to survive inside its boundaries” (Kingsolver, 2010, p.
49).
Introduction
Professional stormwater managers are in the midst of challenging times.
Overwhelming evidence indicates that traditional stormwater management schemes are
unsustainable. Federal and state mandates require local jurisdictions to adopt low impact
development strategies (LID) that mimic natural water cycles in order to protect receiving
waters from pollutants carried by stormwater. The transformation from old to new has
spawned research, innovation, unconventional partnerships, resistance, and conflict.
Stormwater runoff from disturbed landscapes causes flooding, damages aquatic
and terrestrial ecosystems, and is one of the leading polluters of state waterways. In
accordance with the U.S. Environmental Protection Agency (EPA) Clean Water Act,
National Pollutant Discharge Elimination System (NPDES) federal stormwater mandates
require local jurisdictions to develop stormwater policies and implement codes and
standards to safeguard state waterways from the adverse effects of stormwater discharge.
Public sector NPDES Phase I Municipal Stormwater permit holders such as Clark County
in southwest Washington State serve key roles in curtailing stormwater-caused water
pollution including those of technologists, policymakers, educators, monitors, and
enforcers.
NPDES municipal stormwater permits have served as an impetus for positive
change in stormwater management practices, particularly over the past five years. At the
1
same time, permit requirements have been a source of conflict as jurisdictions seek
clarification on policy mandates and deal with resistance to shifting regimes.
Stormwater-caused water pollution has been created by innumerable actions of entire
populations since the onset of urbanization and so solutions will necessarily take time and
consist of a broad base of strategies and participants.
This mixed methods case study of stormwater management in Clark County
assesses barriers to LID strategies. Data are compiled from peer-reviewed studies,
government reports, government and private websites, journal articles, articles in
periodicals, published fact sheets, newspaper articles, court proceedings, and professional
discussions. The data, which exemplify the complexities of stormwater management, are
examined through the lens of seven impediments described by Australian researchers
Roy et al. (2008) in Chapter 3. The impediments (hereafter referred to as barriers) then
provide a framework for analysis in Chapter 5. The seven barriers identified by Roy et
al. (2008) are:
1.
2.
3.
4.
5.
6.
7.
Uncertainties in performance and cost
Insufficient engineering standards and guidelines
Fragmented responsibilities
Lack of institutional capacity
Lack of legislative mandate
Lack of sufficient funding and effective market incentives
Resistance to change (Roy, et al., pp. 347-350)
The thesis is organized into chapters covering the theoretical, background,
methods, and practical aspects of the case study. Chapter 1 looks at stormwater along
with its impacts and policies, and examines LID. Chapter 2 begins with a discussion on
pragmatic theory, moves into a review of the literature, and then presents the research
2
methodology. Chapter 3 provides contextual information for Clark County and
characterizes the county’s LID and stormwater management practices. Chapter 4
contains the analysis, findings, and discussion, and Chapter 5 presents the thesis
conclusions. The case study is important because it introduces interdisciplinarity into a
conversation that has historically concentrated on engineering and technology.
Problems associated with traditional stormwater management call for
environmentally responsible policies and practices. As a result, cities and counties are
gradually adopting LID strategies, largely due to NPDES permits regulations that are
becoming increasingly stringent with time. The case study characterizes some of the
challenges and successes associated with LID implementation on a local scale through
the perspective of the seven barriers, which are separated into three categories according
to influence on LID initiatives: Keystone, Prominent, and Moderate. Findings reveal
resistance to change and clarification of legislative mandates as keystone barriers, the
strongest influencers of LID initiatives, primarily due to ongoing litigation that will
ultimately affect the interpretation of NPDES permit requirements. Other findings
suggest that NPDES permit mandates precipitated the adoption of at least some LID
initiatives in Clark County, and note interdisciplinarity, community cohesion, and
innovation as common characteristics of successful LID ventures. An overview of
stormwater runoff provides a context for understanding stormwater management issues.
Stormwater: An Overview
Stormwater runoff and the problems associated with conventional stormwater
management systems pose considerable problems for local civic entities. This chapter
3
characterizes stormwater runoff and outlines NPDES stormwater management
requirements put forth by the EPA and administered by the Washington State Department
of Ecology (Ecology). LID is examined as a means to manage stormwater by mimicking
pre-disturbance water cycles, thereby promoting onsite infiltration instead of offsite
channelization and discharge.
Western Washingtonians are accustomed to rain pounding on rooftops,
stormwater-filled roadside ditches, and ribbons of water moving swiftly along gutters and
disappearing into metal grates: commonplace in a region that receives between 60-140
inches of precipitation annually (Jackson & Kimerling, 2003, p. 65). Over time urban
and industrial growth in Western Washington has replaced naturally permeable forests
and pasturelands with hard surfaces (e.g., pavement, rooftops, and compacted soils) that
severely inhibit or prohibit the ability of surface water to infiltrate into the ground. With
nowhere to go the water remains on the surface, seeking the path of least resistance. As
urbanization has risen, stormwater has become problematic, and depending on factors
like water volume, soil conditions, physical barriers, and terrain, stormwater can
submerge roadways, scour streambeds, seep into basements, and even trigger landslides
(Booth D. B., 2006, p. 7).
Stormwater runoff is widely documented as a leading cause of water pollution in
the Pacific Northwest (Stark, 2012, p. 44), (Dept of Ecology, 2011) and traditional
stormwater management practices continue to exacerbate this problem (Howie, Emmett,
& Winz, 2011, p. 1), (Girling & Kellett, 2002, p. 700). As it flows over impermeable
surfaces stormwater collects sediment, vehicle fluids, pesticides, fertilizers, pet waste,
and other pollutants along the way. These hazardous hitchhikers flow with the water into
4
stormwater infrastructure networks (Figure 1) that collect surface water, which, before
urbanization, infiltrated into the ground. Some stormwater is channeled into holding
ponds, but these facilities are costly to construct and maintain, they occupy valuable land,
and can create eyesores and safety
liabilities in neighborhoods. Most
captured stormwater is carried through
pipes or ditches and is eventually
deposited, along with the pollutants it
carries, directly into rivers, streams, lakes,
cityofbrandon.net
Figure 1: Stormwater transports
pollutants into infrastructure networks.
and other water systems (Burns, Fletcher,
Walsh, Ladson, & Hatt, 2012, p. 230),
which are collectively referred to in this paper as waterways. In response to these issues,
stormwater policies have evolved over time.
Stormwater Policies, Then and Now
Over time, anthropogenic interference in natural water cycles has compromised
the health and functionality of waterways and water-dependent ecosystems, including
those on which human populations rely. The adverse effects of stormwater effluent on
water quality were largely unregulated until 1990 when an amendment to the Clean
Water Act instituted NPDES regulations for stormwater discharge (Dept of Ecology,
2010). NPDES permits regulate water pollution caused by stormwater that is discharged
into waterways through conveyances such as pipes and ditches, which NPDES defines as
point sources (US EPA, 2012). Ecology, the NPDES permitting authority for
5
Washington State, must follow the EPA version of NPDES regulations as a minimum;
however, Ecology has the authority to enact stricter permit requirements. Similarly,
NPDES county and municipal permit holders within Washington State must follow
Ecology’s permit requirements as a minimum, but these permit holders can enact more
stringent permit requirements to address localized variations such as climate, hydrology,
and water quality (Dept of Ecology, 2012, pp. I-1). This paper focuses primarily on
NPDES Phase I Municipal Stormwater Permits, hereafter referred to as Phase I permits.
Phase I permits typically cover municipal separate storm sewer systems (MS4s)
with populations over 100,000 and Phase II permits are issued to urban municipalities
with populations under 100,000 (US EPA, 2008, p. 1). Washington State Phase I
permittees are Clark County, King County, Pierce County, Snohomish County, the City
of Seattle, and the City of Tacoma (Dept of Ecology, 2012, pp. 1-13). Since Clark
County is a Phase I permittee, the remainder of this paper pertains to Phase I permits.
Washington’s Phase I permit requires permittees to develop a stormwater management
program containing the following prescribed elements:
1.
2.
3.
4.
5.
Legal authority
MS4 Mapping and Documentation
Coordination
Public Involvement and Participation
Controlling Runoff from New Development, Redevelopment and Construction
Sites
6. Structural Stormwater Controls
7. Source Control Program for Existing Development
8. Illicit Connections and Illicit Discharges Detection and Elimination
9. Operation and Maintenance Program
10. Education and Outreach Program (Dept of Ecology, 2012, pp. 11-31)
The 2012 Stormwater Management Manual for Western Washington
(SWMMWW) is the latest version of a five-volume guidance document that offers
6
detailed information and strategies to assist permit holders in understanding and
complying with NPDES regulations. Additionally, stormwater professionals can refer to
the current version of the Low Impact Development Technical Guidance Manual for
Puget Sound (LIDTGM) (Washington St Univ; Puget Sound Partnership, 2012) for
information about LID applications, and for LID research and data. Effective stormwater
management is also an important aspect of emergency management (FEMA, 2011),
although the topic is beyond the scope of this paper.
In response to the need for NPDES technical guidance and training, the
Washington Stormwater Center (WSC), a nonprofit consortium of Ecology, Washington
State University (WSU), and the University of Washington (UW), was established by
legislative mandate and a grant from Ecology in December 2010 (Washington
Stormwater Center, 2013). WSC acts as a hub for emerging technologies, research and
development, technical assistance, training, and is an accessible source of stormwaterrelated information and guidance for government agencies and the public. WSC is
instrumental in forming connections among public and private stormwater professionals,
developers, elected officials, policy makers, and anyone else interested in stormwater
issues through training, workshops and other outreach activities. Additionally, WSC
offers myriad tools to help cities and counties develop and integrate LID practices into
codes and engineering standards that comply with NPDES permit requirements
(Washington Stormwater Center, 2013).
Funding for stormwater management programs comes from a variety sources
including stormwater and development fees, government general funds, and grants (US
EPA, 2008). For example, the State of Washington had $67 million of grant funding
7
available for stormwater construction projects in 2012 (Dept of Ecology, 2013). The next
section defines LID and discusses some of elements and benefits of LID as a stormwater
management strategy.
Low Impact Development (LID)
The Low Impact Development: Technical Guidance Manual for Puget Sound
(2012) defines LID as:
“a stormwater and land use strategy that strives to mimic pre-disturbance
hydrologic processes of infiltration, filtration, storage, evaporation and
transpiration by emphasizing conservation and use of on-site natural
features , site planning, and distributed stormwater management practices
that are integrated into a project design” (2012, p. 10).
The Phase I Municipal Stormwater Permit issued by Ecology in August 2012 (effective
in August 2013) has the same definition, except for referring to LID as a “stormwater and
land use management [underline for clarity] strategy” (Dept of Ecology, 2013, p. 70).
LID promotes onsite stormwater management in contrast to conventional methods
that export stormwater for discharge into downstream waterways. Furthermore, LID
provides other benefits including flood mitigation resulting from flow reductions and
groundwater recharge through infiltration (US EPA, 2012). Visible examples of LID are
bioretention facilities, rain gardens, permeable pavement, and green roofs. Bioretention
facilities (Figure 2) are engineered LID features that use prescribed soil blends,
vegetation, and other means to reduce stormwater flow and provide water treatment
(Wash. St. University & Puget Sound Partnership, 2012). Rain gardens, on the other
hand, are simple mechanisms that collect rain and stormwater on small scales to assist
with infiltration and, unless engineered for specific conditions are generally not classified
8
as bioretention facilities (Dept of Ecology, 2012, pp. 7-1). Permeable pavement is
asphalt or concrete that allows
water to flow through instead of
trapping it on the surface.
While permeable pavement is
not appropriate for all
conditions such as roadways
with heavy vehicle turning
motions, or where
sedimentation is a problem,
with proper maintenance
www.portvanusa.com
Figure 2: Bioretention facilities are engineered LID
features that reduce stormwater flow and provide
water treatment.
permeable pavement can be a suitable LID alternative for parking lots and other
residential and business applications (Stiffler, 2012, p. 1). Green roofs (vegetated roofs,
ecoroofs) are engineered structures that in place of shingles or metal sheeting contain
layers of soil and vegetation that provide stormwater abatement and other environmental
services (Figure 3). Green roofs are common in Europe and are gaining popularity in the
United States (Wash. St. University & Puget Sound Partnership, 2012, p. 217); Portland,
Oregon, a national leader in green roof promotion offers an incentive of five dollars per
square foot for green roof installation (US EPA, 2012). Other less conspicuous but
important LID components are site planning and construction sequencing. Site planning
begins early in the development planning process and characterizes historic and existing
environmental site conditions in order to minimize disturbances to trees, vegetation, soil,
and natural water cycles (Wash. St. University & Puget Sound Partnership, 2012, p. 12).
9
In the case of redevelopment, LID can aid in restoring pre-disturbance (also called predevelopment, pre-urban, and pre-settlement) water cycle conditions to meet NPDES
permit requirements. Construction sequencing is a phasing process that protects LID
features such as permeable pavement and bioretention facilities from sedimentation,
compaction, and other damage
during construction activities
(Hinman, 2012). For example,
operating vehicles and heavy
equipment during construction
compacts soil, and impedes its
infiltration abilities. One purpose
www.ecy.wa.gov
Figure 3: Green roofs provide stormwater
abatement for rooftop runoff. Some green roofs
provide outdoor living space.
of construction sequencing is
orchestrating vehicle and
equipment movement within the
site at various phases of construction to maintain natural soil integrity, thereby promoting
maximum site and LID functionality.
A current challenge in adopting LID is that knowledge and skill sets differ from
traditional stormwater infrastructure. For instance, compared to conventional concrete
and asphalt, permeable pavement requires unique site preparation and installation
techniques, protection of paved surfaces during the entire construction process, and
special inspection and maintenance protocols. Construction and inspection professionals
must be properly trained in LID methods, and qualified trainers are needed to conduct the
training. In contrast to the structural collect-channel-discharge paradigms of
10
conventional stormwater management, LID seeks first to understand the natural
hydrology of individual sites and then to develop site-specific stormwater management
plans. As such, the case study is well suited to a pragmatic philosophical perspective.
11
Chapter 2
Pragmatism: A Statement of Theory
Pragmatism as a worldview “arises out of actions, situations, and consequences”
(Creswell, 2009, p. 10). References to pragmatism are found in the writings of 18th
century philosophers; however, influenced by the theory of evolution, modern pragmatic
movements surfaced in philosophical circles in the late 1800s in response to what were
deemed as narrow-minded idealist views (Thayer & Rosenthal, 2013, p. 2). Charles
Sanders Peirce (1839-1914), William James (1842-1910), and John Dewey (1859-1952)
are regarded as classical pragmatists and, although there are different versions of
pragmatism, James (1907) wrote:
[A pragmatist] turns away from abstraction and insufficiency, from verbal
solutions, from bad a priori reasons, from fixed principles, closed systems,
and pretended absolutes and origins. He turns towards concreteness and
adequacy, towards facts, towards action . . . It means the open air and
possibilities of nature, as against dogma, artificiality and the pretence of
finality in truth” (pp. 22, Location 384).
Creswell (2009) suggests pragmatism as an appropriate premise for mixed
methods research in part because “pragmatists do not see the world as an absolute unity .
. . [and] mixed methods researchers look to many approaches . . . rather than subscribing
to only one way” (p. 11). Four characteristics of pragmatism as a research methodology
are considering the consequences of actions, problem-centered, pluralism, and real-world
practice oriented (Creswell, 2009, p. 6). Furthermore, pragmatism examines problems
from a variety of viewpoints to determine “what works” (ibid, p. 10), rather than relying
on ingrained beliefs and practices.
The pragmatic worldview proposes that consequences cannot be estimated outside
of context (Cherryholmes, 1994, p. 16). Traditional export-discharge stormwater regimes
12
effectively separate natural site conditions (context) from stormwater management
regimes, thereby generating point source water pollution (consequences). In contrast,
LID advocates multifaceted context-sensitive mimicry of in situ pre-disturbance
landscape to restore natural hydrology through a mosaic of micro-local pieces. Thus, the
pragmatic theoretical paradigm is particularly applicable to exploring barriers to LID
stormwater management strategies in that the foundations of LID are contextual (site
conditions) and consequential (source management and reduced point source water
pollution). Given that pragmatism, mixed methods research, and LID promote varied
approaches predicated upon individual circumstances, they also exemplify
interdisciplinarity in that a single discipline (e.g., technology) cannot sufficiently respond
to the complexities of stormwater systems in human environments. The literature
expounds on the diverse nature of stormwater management.
Literature Review
This section highlights literature drawn from journal and periodical articles,
government reports, websites, published research, books, and fact sheets. The literature
first informs and characterizes LID and stormwater management and then is presented
through the lens of seven barriers devised by a team of Australian researchers in 2008.
Lastly, knowledge gaps in the literature are identified.
Literary discussions on LID are often combined with those of sustainable
housing; also referred to as sustainable affordable residential housing (Cascadia Region
Green Building Council, 2008), conservation subdivision design (Allen S. C., Moorman,
Peterson, Hess, & Moore, 2012), conservation development (Pejchar, Morgan, Caldwell,
13
Palmer, & Daily, 2007), low impact subdivision (Dietz & Clausen, 2008), or generically
as green development. Although definitions of the previous terms vary somewhat, the
overarching themes related to LID are the same; minimize impermeable surfaces, cluster
homes on smaller spaces to preserve environmental services, and provide natural
connectivity among developed sites. Recognizing LID as an integral component of
sustainable housing, the literature review includes some references to sustainable housing
but focuses mainly on the relationship of LID to development and redevelopment, which,
for the remainder of this paper are collectively referred to as development.
Urban and industrial growth has replaced natural terrains with hard surfaces that
impede the infiltration of surface water into the ground and cause excess surface water,
also known as stormwater (Stark, 2012, p. 44; US EPA, 2009, p. 1). Stormwater is
widely documented as a leading cause of water pollution (Howie, Emmett, & Winz,
2011, p. 1; Langeveld, Liefting, & Boogaard, 2012, p. 6868; Girling & Kellett, 2002, p.
100). Burns et al. (2012) maintain that the primary function of traditional stormwater
management is capturing surface water for exportation through infrastructure networks
(e.g., catch basins, pipes, and ditches), and often discharging it directly into waterways as
point source pollution (p. 230).
Along with disrupting natural water flow and infiltration cycles, capture-channeldischarge stormwater management practices increase sedimentation and the incidence of
pollutant discharge into waterways (Johnston & Braden, 2006, p. 35). A growing body of
research shows that LID strategies provide important environmental services including
water pollution remediation, flood control, and recharging of aquifers (US EPA, 2012, p.
2). In the case of combined sewer overflow (CSO) operations, stormwater is combined
14
with sewer and processed through wastewater treatment facilities. While acknowledging
that effective LID practices reduce the volume of stormwater in CSO systems, specific
discussions of CSO are beyond the scope of this paper.
Stormwater management is an international concern as is evidenced by literature
from countries like Portugal, The Netherlands, and Australia that point out the
shortcomings of traditional stormwater management practices (Barbosa, Jernandes, &
David, 2012; Langeveld, Liefting, & Boogaard, 2012; Ferguson, Brown, & Deletic,
2013). Facing extreme drought conditions Australian researchers are studying the effects
of traditional stormwater management regimes and Water Sensitive Urban Design (the
Australian equivalent of LID) in efforts to preserve water quality and harvest stormwater
for reuse (Roy, et al., 2008, p. 347).
Professor Rebekah R. Brown is a prolific Australian researcher and respected
authority on sustainable water issues and stormwater management. With a bachelor’s
degree in civil engineering and a Ph.D. in Environmental Studies, Brown is Director of
the Centre for Water Sensitive Cities at Monash University in Australia (Monash
University, 2012). Her profile describes a leader in “interdisciplinary research focused at
the interface between society and technology” (ibid). As of September 2012, Brown had
authored or collaborated on one book, five book chapters, thirty-three journal articles,
and participated in twenty-eight conference proceedings (ibid), with varied subject matter
that exemplify her interdisciplinary philosophy and abilities. Among Brown’s research
topics are Water Sensitive Urban Design, public policy, and the socio-technical and
institutional aspects of sustainable urban water management. Brown self-cites often,
probably because much of the existing research concentrates on stormwater technology
15
or addresses sustainable development in general, of which stormwater is only one
component. Separating stormwater management from the larger topic of sustainable
development is important partly because of the complexities inherent in stormwater
management (e.g., variability among different watersheds and individual development
sites). Furthermore, other than works by Brown, little published research is available on
the social science of stormwater management.
One of Brown’s collaborative efforts, Impediments and Solutions to Sustainable,
Watershed-Scale Urban Stormwater Management: Lessons from Australia and the
United States (Roy, et al., 2008) synthesizes topics addressed in the literature and relates
directly to this case study on assessing barriers to LID strategies for stormwater
management. The seven impediments presented by Roy et al. (2008) are important
because they introduce social elements into a literary conversation that has historically
concentrated on engineering and technology. Economics, land use equity, and societal
acceptance of new practices (e.g. the advent of stormwater management fees), go beyond
engineered solutions and so must be considered when examining new stormwater
regimes. Therefore, the impediments, referred to hereafter as barriers, provide a logical
structure in which to frame the literature. The remainder of this literature review
provides a brief synopsis of each barrier as characterized by Roy et al. (2008) and then
looks at how the barrier is addressed in the literature.
1. Uncertainties in performance and cost (Roy, et al., 2008, p. 347)
Site condition variables and a scarcity of localized data for performance outcomes
and for costs of implementing LID cause professionals involved in devising development
standards to hesitate in adopting LID practices in their own communities (pp. 347-348).
16
Site variability, a performance factor, is exemplified in a Pennsylvania study conducted
by Christopher J. Woltemade (2010), who found that mean infiltration rates on residential
lawns were 69 percent higher in sites established prior to 2000 than in those developed
after 2000 (p. 709). Woltemade (2010) speculates that the variations in site conditions
stem from compaction by heavy equipment and disturbances of native soils and
vegetation in the course of site development (p. 709). The study concludes that soil
compaction in residential areas holds “profound environmental implications” (ibid, p.
710) in relation to stormwater runoff. Woltemade (2010) calls for comprehensive soil
databases that span regions to provide a robust foundation from which to construct soilmodeling tools to reduce the need for field studies in conjunction with design work (p.
710).
The EPA generated six fact sheets that “directly address specific concerns . . .
about adopting low impact development” practices; the concerns are cost, benefits,
effectiveness, aesthetics, terminology, and maintenance (US EPA, 2013). The
“effectiveness” fact sheet provides data from case studies in Seattle, Washington, Cross
Plains, Wisconsin, and Philadelphia, Pennsylvania (US EPA, 2012). Although the case
studies offer a semblance of localized data, they do not address site variations within
states or cities. Nevertheless, the studies demonstrate ongoing efforts to produce data
under a variety of conditions that could be extrapolated to other sites with similar
conditions. With regard to cost uncertainties, ECONorthwest (2007) reports a paucity of
single studies that compare the costs and benefits of LID with those of traditional
methods (p. 2). Conversely, the LID Technical Guidance Manual for Puget Sound
17
(2012) states, “native vegetation and soils are . . . the most cost effective and efficient
tools for managing stormwater quality and quantity” (p. 73).
Downstream “economic consequences” of site specific LID stormwater
management are explored by Braden and Johnston (2004, p. 498), who suggest that
valuing stormwater management strategies in economic terms is challenging because
outcomes are based on chance variations rather than transactions of goods and services in
the marketplace (p. 499). Uncertainties in performance and cost are further exemplified
by a dearth of definitive data for LID infrastructure costs and long-term functionality, and
by attempts to integrate environmental elements and economic methods to quantify
factors such as aquifer recharge (ibid, pp. 503-504).
2. Insufficient Engineering Standards and Guidelines (Roy, et al., 2008, p. 348).
Engineering standards and guidelines generally encourage traditional practices,
despite indications that LID has superior pollutant removal capabilities and other benefits
(Roy, et al., 2008, p. 348). Conflict between standard specifications and LID techniques
can be prohibitive to using LID, and professional guidance resources have yet to
incorporate some LID practices as design standards because of lack of supporting data
(ibid). Brown, Sharp, and Ashley (2006) use the term “technocratic expertise” to
characterize circumstances where standards and guidelines developed solely within
technical frameworks fail to consider political and social factors (p. 420). Technologybased criteria developed by technologists for technologists comply with technologybased codes and standards, yet yield unsuccessful results when crucial socio-political
elements (Brown, Sharp, & Ashley, 2006, p. 420) are omitted; in other words, a lack of
interdisciplinary collaboration.
18
Girling and Kellett (2002) illustrate some of the mixed messages associated with
LID standards in their discussion on impermeable versus permeable surfaces using three
neighborhood development models. In the study, lawns are generically referred to as
“permeable cover” (Girling & Kellett, 2002, p. 106). Conversely, as mentioned in the
first barrier, Woltemade (2010) found that land disturbances and the amount of time since
a disturbance causes significant infiltration rate variations in residential lawns, and
suggests that site-specific data are needed for accurate infiltration rate projections (p.
709). Therefore, lawn infiltration rates cannot be generically categorized for use in
engineering standards and guidelines.
3. Fragmented Responsibilities (Roy, et al., 2008, pp. 348-349).
Water management, regulatory, and enforcement responsibilities are spread
among many people in various levels of state and local government agencies, including
those dealing with human health, environmental issues, and land use concerns (Roy, et
al., 2008, pp. 348-349). Priorities, funding mechanisms, and coordination are
inconsistent among these groups, and delineation based on “political and geographic
boundaries, rather than watershed boundaries” exacerbates responsibility fragmentation
(ibid, p. 349). According to Juergensmeyer and Roberts (2007), land management
policies encompass a multitude of diverse, interrelated, and conflicting interests,
including stakeholders with varied agendas (p. 318). Booth et al. (2007) concur, pointing
to land use practices as the crux of stormwater issues and go further by eschewing a focus
on individual sites in favor of managing stormwater at the “basin or landscape level” (pp.
1-2). Barbosa, Fernandes, and David (2012) acknowledge layers of decision makers and
state that “a clear understanding” of variables and outcomes is required on all levels for
19
sound decision-making and to avoid wasted resources when devising stormwater
strategies (p. 6788).
4. Lack of Institutional Capacity (Roy, et al., 2008, p. 349)
Institutional capacity is defined as “funding, personnel, guidelines, and other
resources” (Roy, et al., 2008, p. 349). Design and planning professionals must be
educated about LID and watershed hydrology, and capacity for enforcement is another
important component of successful LID strategies (ibid). Characteristics and
ramifications of inadequate institutional capacity as outlined by Roy et al. (2008) are
exemplified by sanctions incurred by the Colorado Department of Transportation
(CDOT) stemming from improper stormwater management practices.
The Colorado Department of Public Health and Environment found multiple
CDOT projects in violation of stormwater regulations, which triggered extensive
remediation measures and initiated a “culture shift” in the manner in which CDOT
prioritizes and manages stormwater (Willard & Toppi, 2012, p. 49). Along with trading
half a million dollars in financial penalties for Supplemental Environmental Projects,
mandatory remedies undertaken by CDOT included the revision of “policies, procedures,
and construction specifications,” development and implementation of extensive employee
training programs, and the addition of six stormwater staff, for which special funding was
required (ibid). Furthermore, accountability measures were enacted; the chief engineer
was tasked with certifying official compliance documents and water quality components
were added to employee performance evaluations (ibid, p. 47-48). In another example, a
case study in Ames, Iowa revealed that city staff was somewhat familiar with LID
concepts; however, their lack of in depth knowledge about LID discouraged adoption of
20
LID practices in subdivision developments (Bowman, Thompson, & Tyndall, 2012, p.
53).
5. Lack of Legislative Mandate (Roy, et al., 2008, p. 349)
In the absence of comprehensive national stormwater directives, local stormwater
management policies and practices lack cross-boundary collaboration and cohesion (Roy,
et al., 2008, p. 349). Consequently, efforts to advance uniform LID practices are
constrained, policies are inconsistent, and human and environmental well-being is
compromised (ibid). The Clean Water Act NPDES mandates are the basis of point
source stormwater permitting in the U.S. The terms of the NPDES Phase I permit
include six required elements (Chapter 1); the third element calls for “coordination
mechanisms among entities . . . to encourage coordinated stormwater-related policies,
programs, and projects within a watershed” (Dept of Ecology, 2013, p. 14); a mandate
which promotes coordination and collaboration within jurisdictions and across political
boundaries within watersheds. The centralized (command and control) stormwater policy
regimes that were prevalent in the 70s have given way to what Zaccai (2012) refers to as
collaborative and market-based instruments that include stakeholders in the policy
process (pp. 84, 88). Robins (2007) concludes that understanding stakeholder views is an
important precursor to “capacity building policies,” especially in light of regional
differences (p. 698).
21
6. Lack of Sufficient Funding and Effective Market Incentives (Roy, et al., 2008, pp.
349-350)
Transitioning from traditional stormwater systems to LID incurs costs beyond
installation, including removal and/or retrofitting of existing systems, price tags
associated with operation and maintenance, missed opportunities for other uses, and
training programs for designers, contractors, and homeowners (Roy, et al., 2008, p. 349).
Incentive strategies such as fee reductions and rebates must offer high enough financial
benefits to attract businesses and homeowners (ibid, pp. 349-350). Cap-and-trade options
encounter challenges in defining parameters and enforcement, and garnering a broad base
of support (ibid, p. 350).
The EPA states that the presence of LID elements results in higher property
values (Benefits of Low Impact Development, 2012). Bowman et al. (2012) employ
several methods including surveys and “experimental real estate negotiations” to
ascertain whether homebuyers value LID elements and conservation subdivisions (pp.
102-103). Although they do not precisely echo EPA’s statement on the positive effect of
LID features on property values, Bowman et al. (2012) suggest that homebuyer
knowledge of LID systems builds value for properties with LID features (p. 111). In
another study, Bowman and Thompson (2009) find that consumers indicate interest in
LID; however, developers do not recognize this interest, nor do developers research what
homebuyers want and are willing to pay for (p. 105). The study concludes that cities can
provide incentives to developers by way of streamlined permit processes and providing
market research information on consumer preferences to developers (ibid).
Researchers in North Carolina utilize surveys and case studies to investigate
barriers to conservation subdivision development and identify a “lack of incentives for
22
developers” as the dominant barrier (Allen S. C., Moorman, Peterson, Hess, & Moore,
2012, p. 246), while economic incentives were deemed by developers as the most
successful strategies (ibid, p. 250).
7. Resistance to Change (Roy, et al., 2008, p. 350)
As discussed in Barrier 3, stormwater management encompasses diverse interests
among myriad stakeholders. Along with diversity come disagreements on definitions of
success and failure, knowledge gaps, and exposure to varying degrees of risk (Roy, et al.,
2008, p. 350). These elements present formidable barriers that manifest as resistance to
LID implementation (ibid). Resistance to change “arises when goals of subsystems are
different from and inconsistent with each other” (Meadows, 2008, p. 113). The goals of
LID are markedly different from traditional stormwater management. Instead of surface
water exportation through infrastructure networks, LID strives to protect waterways and
landscapes by mimicking pre-disturbance hydrologic cycles that promote onsite
infiltration and evapotranspiration (Wash. St. University & Puget Sound Partnership,
2012, p. 10). Nevertheless, dependability, straightforward design and modeling abilities,
ease of maintenance, and predictable dollar costs continue to support conventional
stormwater regimes (ibid, p. 9).
The desire to avoid risk is a main motivator for maintaining the status quo
(Barbosa, Jernandes, & David, 2012, p. 6792). Developers and local governments resist
change to avoid the risks inherent in adopting new policies and practices. For example,
the City of Battleground, Washington cites inadequate resources, perceived inequities,
disagreement with proposed changes, and unclear parameters as reasons for resistance to
revisions in the Phase II NPDES permit (City of Battleground, n.d.).
23
Belief systems surrounding property rights can create resistance to change,
ironically, through an unwillingness to resist change. Peterson and Liu (2008) suggest
that convictions supporting natural property rights (the right of all property owners to do
what they want on their property) override direct observations and experiences of
environmental degradation or destructive development practices in communities (p. 131).
Hence, even in the midst of distress over landscape destruction and uncurbed
development, citizens who support natural property rights are unwilling to participate in
land planning forums or support sustainable agendas (ibid). Jin Xue (2012) condenses
the essence of the seven barriers succinctly into a single sentence “For technological fixes
to be successful, the cultural, economic, and political conditions cannot be ignored” (p.
32).
Knowledge gaps
Although the research provides examples of diverse stormwater groups and
collaborative endeavors among jurisdictions, the literature review revealed no discussions
on the benefits of collaboration among stormwater managers. Court challenges related to
LID were not found in research papers, possibly because the topic is more suited to legal
discourse than to scientific research. Other than works by Brown, interdisciplinarity
associated with stormwater management is not covered in the literature, although the
complexity of stormwater issues and the diversity of stakeholders clearly demonstrate a
need for more research. Finally, although there is disagreement about LID with regard to
NPDES permits, the literature revealed no peer reviewed research that disputes the
24
effectiveness or sensibility of LID. In Chapter 4, the seven barriers are revisited as a
foundation for analysis of Clark County stormwater policies and practices.
Methods
Case studies provide researchers with the ability to move beyond statistical data
and explore the contextual aspects of a research topic. A certain amount of flexibility is
inherent in a case study design, which is particularly advantageous in circumstances
where the path is revealed as research progresses. Furthermore, case studies allow
researchers to delve below the surface of issues, discover deeper meaning, and fill
knowledge gaps that cannot be revealed by quantitative methods. In contrast, case
studies run the risk of introducing subjectivity and bias into the research.
The research methodology for this case study employs a mixed methods approach
to assess barriers to LID strategies for stormwater management in Clark County,
Washington. A case study was selected as a means to investigate and gain a holistic
portrayal of the current situation of LID strategies beyond the technical aspects of
stormwater management. To reduce the potential for subjectivity and bias mentioned in
the previous paragraph, data were compiled from a variety of sources that are described
later in this section, and the study is then framed in the context of seven barriers
established by Roy et al. (2008). The methodology is limited in that public opinion,
political influences, and other social nuances surrounding each barrier are touched upon
but not thoroughly explored. Nevertheless, the results are applicable to other
jurisdictions because while landscapes, hydrologic conditions, and social variables might
differ, dealing with stormwater-caused pollution and complying with government
25
regulations are universal issues as is confirmed by the variety of geographical origins of
the literature.
Clark County was selected for the case study because the county is the sole Phase
I permit holder in southwest Washington (Dept of Ecology, 2013) and the only Phase I
permit holder in Western Washington that discharges stormwater into the Columbia
River instead of Puget Sound. Additionally, the county’s 2011 NPDES Annual Report
states that the county has very “few shared waterbodies” (p. 4) and, assuming that shared
waterbodies increase the complexity of stormwater management, the results from this
study are conservative in that regard. Furthermore, the geographic separation of Clark
County from other Western Washington Phase I permit holders (King, Pierce, and
Snohomish counties, the City of Seattle, and the City of Tacoma) provides what is
presumed to be a relatively stand-alone circumstance compared to the potential
interactions among other permit holders due to close proximity. Although Clark
County’s propinquity to Portland, Oregon is recognized, Oregon’s stormwater policies
are beyond the scope of this paper.
Another reason for Clark County’s suitability for this study is its setting in the
midst of a robust transportation hub with north/south and east/west interstate highway
corridors, an international airport, maritime port activities, and a conflux of commercial
railroad lines. Furthermore, Clark County’s population distribution is equalized between
incorporated (within city limits) and unincorporated (outside city limits) areas; in 2010
about half (53.1 percent) of Clark County’s 425,363 residents lived in incorporated areas
(US Census Bureau, 2013). It is expected that development (and so stormwater
management) activities reflect this balance to some extent, thereby minimizing potential
26
bias caused by predominantly urban or rural population distributions. The final reason
for selecting Clark County for this study is the county’s involvement in two ongoing legal
challenges related to NPDES permits and LID, which elucidate barriers and offer insights
into conflict generated by stormwater regulations.
Sources of qualitative data include peer-reviewed research papers, government
reports and documents, government and private websites, journal articles, articles in
periodicals, published fact sheets, newspaper articles, and court proceedings. Data also
consist of meeting agendas, minutes, and videos, and public responses and comments
related to LID and stormwater issues. Stormwater documents and county and municipal
codes serve as sources for policy and standard procedures. Online documentation from
the Ecology website is used to identify NPDES permit holders and as the source of a
majority of the permit-related information. Court and hearing board documents
characterize the nature of legal conflicts and provide information on the processes and
outcomes of the proceedings. Quantitative data contribute to the study in two main areas:
1) Establishing context through census-derived statistics; and 2) Utilizing scientific
studies, reports, and professional manuals to provide technical data associated with LID.
The prominent portion of the methodology is adapted from a study conducted by
Australian researchers Roy et al. (2008) that was described in the literature review
(Chapter 2). The seven criteria provide a logical foundation from which to assess barriers
to LID strategies for stormwater management in Clark County. The same criteria are
used in Chapter 4 as a foundation for analysis, which relies on widely accepted evidence
that recognizes stormwater runoff as a main polluter of waterways (Howie, Emmett, &
Winz, 2011, p. 1; Stark, 2012; Dept of Ecology, 2011).
27
The first phase of the research process involved gathering literature and
government documentation related to stormwater management policies and practices,
legal documents surrounding LID litigation in Clark County, and other resources. Nearly
all of the written research materials were obtained as electronic files and transferred to
the hard drive of a password-protected lap top computer that was used for the case study.
Hardcopies of the most applicable documents were printed and the electronic versions
were archived in a comprehensive organized research file that was backed up nightly
onto a flash drive and weekly onto an external hard drive. Printed documents were
numbered as they were collected with the goal of keeping the research inventory to a
manageable level given the time allowed for the study (47 documents were printed over
the course of the study). The numbering system had the unintended consequence of
elevating the quality of the material because a sense of finitude encouraged judicious
choices, although electronic documents (not to be printed) were collected and archived at
will, as they are easily stored and retrieved. Generally, large documents (over 100 pages)
and reference-only documents (e.g., technical and guidance manuals) were not printed.
Websites of interest and other online resources were electronically bookmarked for future
reference. An Amazon Kindle electronic reader held some reference books and, since
Kindle page numbers do not necessarily correspond with hardcopy books, Kindle
location numbers are included in cites from these sources.
The second phase of the research involved an inductive process of reviewing the
material to further investigate relevant topics and determine common themes.
Highlighter pens, underlining, and handwritten notes in margins effectively accomplished
this portion of the research and the materials were then sorted by general themes:
28
economic, technical, natural science, social science, policy, sustainable and LID,
litigation, and Clark County documents. Adhesive notepaper was attached to the front of
each document summarizing main themes. The discovery of the research by Roy et al.
(2008) that is mentioned earlier in this section and in the literature review (Chapter 2)
precipitated a third review of the printed material with the goal of associating each with
Roy et al.’s (2008) seven criteria. The material was then labeled with the number of the
corresponding criterion; a majority of the material was associated with multiple criteria.
Since time constraints were prohibitive to the use of focus groups and personal
interviews, professional discussions were used as an alternative. A Human Subjects
Review was not required because conversations were strictly professional in nature; no
personal opinions or observations were elicited during the discussions or included in this
research. Three potential candidates were selected based on their involvement in largescale stormwater management; these individuals were contacted via email and invited to
participate in a professional discussion about stormwater management. Two candidates
did not respond. One person, a division manager, forwarded the email to the
organization’s environmental manager who agreed to meet and requested specific
information about the topics of discussion. This person was provided with a list of the
seven barriers as potential topics and told that the actual subjects discussed were entirely
up to the individual and did not need to come from the list. An informal meeting was
also scheduled with a stormwater manager from a different organization. Both meetings
took place in Clark County at each person’s place of business, and one meeting resulted
in visits to two sites in Vancouver, Washington: the Water Resources Education Center,
and the Fred Meyer Grand Central parking lot where permeable pavement is installed.
29
With permission from the stormwater professionals, handwritten notes were taken at the
meetings and later transferred to an electronic file. While the professional discussions
provided little direct information for use in this study, they pointed to valuable sources of
information.
This research is significant because assessing barriers to LID strategies for
stormwater management in Clark County offers insights into the efficacy of federal
NPDES policies on a local level, thereby informing future policy, enhancing local
engagement efforts, and improving the predictability of LID stormwater management
strategies and outcomes in Clark County and beyond. Chapter 3 introduces the oldest
county in Washington State and characterizes the trials and achievements surrounding
LID in Clark County.
30
Chapter 3
This chapter provides an overview of Clark County including its historical
context, geography, government structure and economic base. Stormwater management
in Clark County is examined including some successes and challenges, innovative
practices, and conflict encountered in conjunction with LID strategies for stormwater
management.
Getting to Know Clark County
Located in the southwest corner of Washington State (Figure 4), Clark County
was established in 1844 as the expansive Vancouver District, reaching north to Alaska
and east to the Rocky Mountains (Proud
Past, 2013). Rechristened “Clarke”
County in 1849, boundary adjustments
formed the county’s existing borders and
the spelling was corrected to “Clark”
County in 1925 (ibid). Washington’s
oldest county, Clark County is the
wikipedia.org
Figure 4: Clark County in
southwest Washington State
namesake of William Clark from the
Lewis and Clark expedition team that explored the Pacific Northwest in the early 1800s.
Native tribes that populated the area including the Klickitat, Cowlitz, Clackamas, and
Chinook revered the Columbia River, the salmon, and other Pacific Northwest resources
that furnished their communities with food and served as the foundation of rich cultures
with deep connections to the environment. Once the Lewis and Clark Expedition spread
31
the word about the natural abundance and beauty of the region, fur traders and then
settlers headed west to Clark County. Fort Vancouver was established by the British
Hudson’s Bay Company as a fur trading post in 1825 with a diverse population including
a robust Hawaiian contingent (National Park Service, 2013; Proud Past, 2008).
Eventually the fort housed the first hospital, school, library, mills, and shipyard in the
Pacific Northwest (ibid); not surprising since Fort Vancouver became the Hudson’s Bay
Company’s regional headquarters.
Located in a region of distinct natural beauty and a rich geological history, Clark
County boasts 40 miles of scenic Columbia River shoreline and close proximity to an
assortment of natural landscapes including mountains, forests, prairies, deserts, lakes, and
streams. The county’s eighteen main watersheds (Figure 5) and numerous subwatersheds support a variety of flora
and fauna and provide a multitude of
recreational opportunities. In contrast,
Portland, Oregon a major urban
population center is just across the river
and Clark County is considered as part
of the greater Portland metropolitan
area. Although water plays a major role
in the commerce and quality of life in
Clark County, curiously, the county
website “Promising Future” (2012) cites
www.co.clark.wa.us
Figure 5: Clark County watersheds and
sub-watersheds.
the main challenges in the region as
32
traffic congestion, air quality and other priorities, but does not mention water quality as a
concern.
With a population of 425,363 in 2010, Clark County contains just over six percent
of the state population and covers an area of about 629 square miles (US Census Bureau,
2013). The county’s population is almost evenly distributed among incorporated and
unincorporated areas, with urban dwellers comprising about 53 percent of the population
(ibid). Although it is the smallest of Washington State counties located along the
Interstate-5 corridor, Clark County enjoys a prominent location amidst main
transportation corridors for trucking, maritime, rail, and air. Interstate-5 runs north/south
through the county and Interstate-205 provides a detour for vehicles to bypass the busy
metropolitan Portland area. The Burlington Northern Sante Fe and Union Pacific
railroads converge in Clark County for overland freight connections to the north, south,
and east; and the Columbia River forms Clark County’s western and southern borders,
providing both economic and recreational benefits. According to Jackson and Kimerling
(2003), the Columbia River Gorge is “Probably the natural corridor of greatest strategic
significance . . . the only water-level route through the Cascade Mountains” (p. 31). The
vibrant maritime thoroughfare bustles with tugboats, barges, various types of cargo ships,
cruise ships, paddle wheel boats, and tankers that transport agricultural and petroleum
products, logs, automobiles, bulk cargo, and windmill towers (Columbia River Pilots,
2009).
Number three in size and age compared with other ports in Washington State (WE
CAN! Task Force, 2011, p. 3), the Port of Vancouver moved 5.6 metric tons of domestic
and international goods in 2011 and a recently completed Columbia River Channel
33
Deepening Project that enables the port to accommodate larger ships. A railway access
project that is slated for completion in 2017 is estimated to increase rail service to and
from the port by 300 percent (ibid, p. 3-4). Assuming the extra capacity is utilized, this
translates to more jobs for Clark County. Finally, Portland International Airport is only a
15-minute drive across the Columbia River from Vancouver, the county’s main
population center with approximately 165,500 residents in 2012 (US Census Bureau,
2013).
Government Structure and Economic Overview
Clark County’s citizens elect three officials who serve on the Board of Clark
County Commissioners (BOCC) as policy and decision makers for ordinances, planning
and zoning policies, committee and board appointments, and approving county budgets.
According to the county organization chart (March 7, 2013), the commissioners oversee
the following departments: Community Planning, Community Development, Community
Services, Public Health, Public Works, Public Information and Outreach, Environmental
Services, and the Board of Equalization. The County Administrator manages the
aforementioned departments and reports to the BOCC; the Clean Water Program, part of
the Department of Environmental Services, is responsible for NPDES compliance.
The Columbia River Economic Development Council (CREDC), a regional entity
and sponsor of the 2011 edition of the Clark County Economic Development Plan (EDP),
describes itself as a “private-public partnership of 140 investors working together to
advance the economic vitality of Clark County through business growth and innovation”
that works to transform EDP goals into reality (CREDC Economic Development, 2013).
34
Economic growth is a mantra for many counties and cities, particularly given the
economic challenges faced by communities in recent years; the EDP echoes these
concerns. While, the main employers in Clark County are currently in the government,
healthcare, and retail sectors (TIP Strategies Inc, 2011, p. 44), the EDP promotes an
“aggressive” strategy to attract business to the area and identifies information technology
(IT) and international investments as viable economic growth vehicles. (p. 2).
Furthermore, the EDP suggests that a negative correlation exists between a skilled
workforce and unemployment rates and looks to the county’s two colleges, WSU
Vancouver and Clark Community College to assist in developing a workforce that can fill
the anticipated need for skilled IT workers (TIP Strategies Inc, 2011, p. 1). Tied to these
goals is the creation of development-related amenities to attract businesses to the county
and a quest to recruit highly educated professionals as new Clark County residents (ibid,
p. 1-2).
Stormwater Management and LID in Clark County
Clark County has come a long way since the first NPDES permit was issued there
in 1999. Ongoing efforts in conjunction with NPDES permit regulations have ushered in
stormwater fees, sparked LID innovation, and spawned projects designed to improve
stormwater management through a variety of diverse and collaborative endeavors. At the
same time, NPDES regulations are the focus of litigation as Clark County argues for
clarification on LID, land use equity, and environmental protection, while seeking relief
from NPDES regulations that are deemed unreasonable, costly, and excessively
restrictive. In an effort to improve efficiency and promote cooperative environmental
35
efforts within the county, Clark County’s Department of Environmental Services was
created in 2010 by combining seven departments, including the Clean Water Program
(CWP), the department responsible for stormwater management and NPDES compliance
(Clark County Environmental Services, 2012).
Since 2000, Annual Clean Water Fees levied on residences, businesses, industry,
government offices, schools, and churches in unincorporated Clark County has generated
$4.9 million in annual revenue for stormwater programs (Clark County, 2012, p. 4). Yet
the rates in unincorporated areas of Clark County are a fraction of rates paid in
unincorporated King, Pierce, and Snohomish counties (Clark County Environmental
Services, 2012). One urban “equivalent residential unit” (e.g., a single-family home on
less than one half acre) pays $33 per year, with declining rates as residential lots increase
in size (ibid); nonresidential rates are calculated using square feet of “hard surfaces”
(Clark Co. Environmental Services, n.d.). A protocol was devised to evaluate and
prioritize county stormwater projects.
The Stormwater Needs Assessment Program (SNAP) corresponds with the
NPDES five-year permit period and through prescribed research methods and data
analyses strives to “most effectively implement the NPDES permit requirements . . .,
[take] an integrated, basin-oriented approach to stormwater management . . . [and
safeguard water quality]” (Clark County, 2007, pp. 2-3). The results of SNAP provide
recommendations for the Stormwater Capital Improvements Program and, while SNAP
recognizes that deliverables provide value to a number of county departments including
wetland mitigation, growth planning, and habitat and species protection, it anticipates that
outside agencies also benefit from these efforts (ibid, pp. 2, 6).
36
Clark County and its largest city Vancouver have actively pursued a sustainable
housing initiative, which includes LID components. In 2008, they partnered with the
Cascadia Region Green Building Council (Cascadia) to audit county and city regulations
and codes in order to expose “barriers to sustainable, affordable, residential development
(SARD)” (Cascadia Region Green Building Council, 2008, p. 3). The project, which was
funded by the Washington State Department of Community, Trade, and Economic
Development, endeavored to identify and address barriers in order to promote “green”
projects in Vancouver and unincorporated Clark County. The results of the audit
characterized city and county codes as “outdated” and found that LID design components
that were intended to reduce impervious surfaces, such as narrower driveway widths and
a reduction in the area required to be set aside for parking, conflicted with existing county
and city codes (Cascadia Region Green Building Council, 2008, pp. 12-13)
The SARD study identified barriers that were created by existing county and
municipal codes and made recommendations for improvements. Using elements pointed
out by SARD, the Clark County Sustainable Communities (CCSC) project, funded by a
grant from Ecology (Clark County Sustainable Communities: Meeting #1, 2009, p. 2),
held a series of six meetings from October 2009 to March 2010 to “engage key
stakeholders to craft a regional strategy for fostering sustainable development across
[Clark] County” (p. Agenda). An unusual aspect of the meetings was that representatives
from a public involvement consulting firm were on hand to help facilitate productive
communication among the diverse participants. The goal was for 50 percent of the
jurisdictions in Clark County to adopt code changes and/or promote incentives to support
sustainable communities (Clark County Sustainable Communities: Meeting #3, 2009, p.
37
4). One outcome was a codified pilot program (code 40.200.090) for six sustainable
development projects called the Sustainable Communities Pilot Program (SCPP), which
includes LID elements. According to email correspondence (in conjunction with research
for this case study) with the Clark County Department of Environmental Services and a
consultant involved in the SCPP, while there have been several inquiries into the
program, no applicants have been accepted thus far; however, there is one promising
candidate in process. The main reason given for the lack of response to the program thus
far is a slowdown in development due to the economy.
In another ambitious and collaborative undertaking, the Planet Clark venture
defines itself as “a public-private outreach and education group” that provides a broad
scope of services and products to promote sustainable living (Planet Clark.com, 2013).
One of the group’s projects, the Planet Clark Emerald House, is a single-family
sustainable home built on the site of an abandoned property that was a safety concern and
a neighborhood eyesore. The home, constructed according National Green Building
Standards, is designed to manage all stormwater onsite with the goal of “zero runoff;”
LID elements include rain gardens and amended soils to promote infiltration of
stormwater that is not collected by the rain barrels attached to roof drainpipes (Planet
Clark.com, 2013). The Planet Clark team is comprised of private sector green building
specialists, the Evergreen Habitat for Humanity organization, WSU, and representatives
from Clark County’s Environmental Services and Building Services departments. The
group hopes that the innovative energy and water-efficient 1,154 square foot home will
be awarded the first “Emerald” certification in the county (ibid). The Planet Clark
project is a tangible example of sustainable residential building, which demonstrates how
38
a run-down property can be redeveloped into an asset for the community and for the
environment, while providing healthy living conditions for its occupants. Furthermore, it
is the epitome of LID design and technology in pursuit of “zero runoff,” beyond NPDES
requirements of matching pre-disturbance flows.
Stormwater management agendas in Clark County have inspired innovations of
sizable and humble magnitudes, encouraged entrepreneurism, and infused pride into
organizations as are exemplified by the previous examples and by activities at the Port of
Vancouver (PV). The port, an NPDES Phase II Municipal and an Industrial Stormwater
General Permit holder in Clark County, is a frontrunner in LID stormwater management
technology. The largest known bioretention facility of its kind was completed by PV in
2009 to treat industrial stormwater runoff for metals and turbidity prior to discharge into
the Columbia River. The unique LID facility has returned promising results based on
two years of water quality testing data that demonstrate “vastly improved removal of total
and dissolved copper, zinc, and turbidity” (Port of Vancouver USA, 2013).
Going from very large to very small stormwater treatment systems, the modest yet
highly effective Grattix device (Figure 6), invented by two PV employees, utilizes LID
technology to remove 90-95 percent of zinc from stormwater runoff captured from
galvanized metal roofs and drainpipes (Port of Vancouver USA (2), 2013). PV’s
bioretention facility and the Grattix have attracted attention from stormwater
professionals from around the nation (personal conversation on March 25, 2013).
Ecology is examining the bioretention facility for possible application on other industrial
sites and a “Build Your Own Grattix” video, featuring the unit’s inventors, is highlighted
on the WSC website
39
(www.wastormwatercenter.org). Lastly, port tenants are invited to join the Clean Water
Challenge, a program initiated by PV to promote sustainable water practices, recognize
participants’ efforts, and provide guidance for
implementing sustainable measures (Port of
Vancouver USA (2), 2013). PV stormwater
management regimes demonstrate that LID
strategies can provide valuable environmental
services in an industrial environment, and PV’s
successful LID initiatives exemplify an
organizational culture that encourages and
supports sustainability and innovation among its
www.portvanusa.com
Figure 6: The innovative Grattix
invented by PV employees removes 9095% of zinc from roof runoff and is
simple and inexpensive to build and
maintain.
employees and business partners.
Other agendas that bring LID concepts
and tools to businesses and residents include the
Green Business Program and the Stormwater Partners of Southwest Washington. The
Green Business Program, a Clark County initiative, combines outreach, education, and a
call to action by offering county businesses the opportunity to qualify for annual
certification as a Green Business. Instigated in 2011, the popular program is growing
quickly with twenty-eight certified Green Business members (Clark County
Environmental Services, 2012, p. 9) that represent a diverse cross-section of the business
community including Frito Lay, a semiconductor foundry, financial institutions, hotels,
local eateries, and an automotive repair facility. The colorful and easy-to-navigate
Stormwater Partners of Southwest Washington website offers comprehensive information
40
and tools to help private citizens, homeowners’ associations, and businesses understand
stormwater issues and properly manage private LID features
(www.stormwaterpartners.com). The product of a grant from Ecology in 2009, the
website is a collaborative endeavor by Clark County, Battle Ground, Camas, La Center,
Ridgefield, Vancouver, and Washougal. Along with stormwater information and videos,
the site includes contact information for all partnership entities and links to additional
stormwater resources.
Litigation
According to the Phase I permit, flow control must be returned to pre-disturbance
levels. When Ecology found Clark County in violation of the pre-disturbance flow
control portion of the permit, the two parties negotiated an alternative (Agreed Order
7273, January 6, 2010) that allows developers in Clark County to maintain (not cause an
increase in) existing conditions on development sites. Under the agreement, Clark
County determines the difference between existing and pre-disturbance stormwater flow
conditions and transfers the remaining mitigation to its Stormwater Capital Improvement
Program, using offsite remediation locations as needed (ibid). Despite Ecology’s
endorsement of the alternative management regime, three organizations argue that the
Agreed Order does not meet NPDES permit conditions.
The Rosemere Neighborhood Association, Columbia Riverkeeper, and the
Northwest Environmental Defense Center (Rosemere) contend that Agreed Order 7273
does not meet the environmental standards of the Phase I permit. Rosemere complained
to the Pollution Control Hearings Board (PCHB), who reviewed and subsequently
41
overturned the Agreed Order. Clark County, Ecology, and the Building Industry
Association of Clark County (Clark County et al.) subsequently appealed the decision to
the State of Washington Court of Appeals, which in September of 2012 upheld the PCHB
ruling by declining to review the case. Clark County et al. then appealed the decision to
the Washington State Supreme Court, which on March 5, 2013, also declined to review
the case. In the meantime, a judicial stay was lifted that clears the way for Rosemere to
pursue the case on a federal level. Anecdotal information suggests that a federal court
will review the case and render an opinion; however, evidence of this turn of events was
not forthcoming in the course of research for this paper.
In another case, Clark County, along with other Phase I permitted Western
Washington counties filed an appeal with the PCHB regarding the Phase I permit that
takes effect in August 2013. Clark County asserts (in part) that the permit is “legally
flawed” due to excessive costs, lack of empirical evidence supporting LID, the lack of
jurisdictional control over watershed-scale planning, and that compliance with the permit
in its current form risks litigation (Clark County's Notice of Appeal of Phase I Municipal
Stormwater Permit, 2012). The cases are ongoing and it is unknown when decisions will
be rendered and whether decisions will precipitate further legal action.
42
Chapter 4
The analysis phase of the study characterizes the data, identifies barriers and
successes, and then evaluates the data using the seven criteria adapted from Roy et al.
(2008). The resulting seven barriers are then ranked according to influence on LID into
three categories: Keystone (most influential), Prominent (influential), and Moderate (least
influential). The findings also highlight common traits of successful LID initiatives.
Analysis
Analyses commenced during the initial process of compiling and scanning
literature, policy documents, and other resources. The materials were broadly
categorized by theme, and then subcategorized by connection to the research topic and
contribution to interdisciplinary perspectives (to reduce potential for bias). Further
segmentation was conducted based on relevance to LID. Relevance was generally
determined by the clear presence of LID or stormwater management elements, and
through logical inference of connections with LID. For example, the LIDTGM
(Washington St Univ; Puget Sound Partnership, 2012) obviously contains LID elements
as is stated in the title. The Clark County Economic Development Plan (TIP Strategies
Inc, 2011), while not an LID or stormwater management document, indirectly informs
the topic through discussions of county development goals.
The resulting resources were evaluated in terms of the seven criteria to reveal LID
and stormwater management barriers and successes. Lastly, the barriers were ranked by
level of influence on LID as determined by the scale of impact on LID practices and the
availability of compensatory resources. For example, in contrast to findings by Roy et al.
43
in 2008, ample training and educational opportunities are available for stormwater
managers to compensate for a lack of professional knowledge about LID. Figure 7
illustrates the analysis process.
Broad scope of source materials, literature, manuals, policies, projects, etc.
to gain interdisciplinary perspectives and mitigate potential for bias.
Establish relevance to LID/stormwater management
Evaluate material through the lens
of the seven criteria devised by
Roy et al. (2008)
Identify LID
barriers/successes
Rank barriers in order
of influence on LID
D. Dochow, June 2013
Figure 7: Analysis of data using seven barriers devised by Roy et al. (2008).
Roy et al (2008) state three assumptions that inform the analysis:
1. Sustainable urban stormwater management maintains the natural ecological
structure and function of receiving water bodies
44
2. Technologies already exist that are capable of mimicking the natural water cycle
and reading downstream transport of stormwater pollutants [underline added for
clarity]; and
3. Sustainable urban stormwater management must be planned and implemented at
the watershed scale. (p. 345).
Assumption 1 is maintained for this study and Assumption 2 is adapted as
follows: 2. Technologies already exist that are capable of mimicking natural water
cycles, thereby protecting downstream waterways from point source stormwater-borne
pollutants (underline added for clarity). However, while recognizing watershed scales as
important components of stormwater management and with the understanding that
watershed-scale planning is addressed in the Phase I permit, a thorough discussion of
Assumption 3 is beyond the scope of this study. Furthermore, based on the widely
accepted premise that connects stormwater runoff with environmental degradation
(Howie, Emmett, & Winz, 2011, p. 1; Stark, 2012; Dept of Ecology, 2011), stormwater
management strategies that promote source reduction of stormwater runoff are presumed
to provide valuable and desirable environmental services. As discussed earlier in this
section and illustrated in Figure 7, the barriers and successes that were identified through
analysis of LID materials are examined below in the context of the seven barriers.
1. Uncertainties in performance and cost (Roy, et al., 2008, p. 347):
LID initiatives have progressed rapidly since the paper by Roy et al. was
published in 2008. Large and small-scale projects within Clark County and throughout
Western Washington have incorporated LID features, providing a variety of sources of
performance and cost data. In some cases, the customized nature of LID warrants
investigation of performance and costs of individual LID elements (e.g., pervious
45
pavement, bioretention facilities) rather than looking at entire projects; however, cost
data associated with materials, installation, and maintenance are available for a number of
government and private projects that have incorporated LID facilities. For instance, the
PV in Clark County has one of the largest and arguably one of the smallest LID
bioretention features (Chapter 3), and these facilities have prompted inquiries about
performance and cost from private and public stormwater managers (personal
conversation on March 25, 2013). The City of Seattle website supplies a cost-benefit
analysis for natural (LID) drainage systems versus traditional regimes (City of Seattle,
2013), and established installations like the Pierce County Environmental Services
complex (constructed in 2004) have years of LID performance data to share. Landscape
and building professionals that specialize in sustainability are other sources of cost and
performance data. Washington State University (WSU) is a frontrunner in long-term LID
research with its LID Stormwater Research Program in Puyallup; however, regionspecific long-term performance datasets (e.g., over ten years) are not as robust.
Uncertainties in performance and cost as barriers to LID stormwater management in
Clark County are confounded by differing interpretations of NPDES mandates and by
questions posed by NPDES permit holders about the scientific validity of LID data.
Ongoing litigation on the aforementioned issues (Chapter 3) and risk management
concerns associated with the adoption of new technologies create a tentative atmosphere
about how LID will be applied in the future and whether alternatives will be allowed;
these variables directly affect cost and performance data and are discussed further in
Barrier 7.
46
2. Insufficient Engineering Standards and Guidelines (Roy, et al., 2008, p. 348):
Conflict between standard specifications and LID techniques can be prohibitive to
using LID, and professional guidance resources have yet to incorporate some LID
practices as design standards because of lack of supporting data (Roy, et al., 2008, p.
348). As mentioned in Barrier 1 above, LID initiatives have progressed since 2008 and
engineering standards and guidelines are still evolving. Ecology, WSC, stormwater
management groups, and early adopter jurisdictions (e.g., City of Seattle) can help cities
and counties incorporate LID into engineering standards and guidelines. Assistance is
also available from free online documents like the SWMMWW (Dept of Ecology, 2012)
and the LIDTGM (Washington St Univ; Puget Sound Partnership, 2012). Contrary to
dissent over some aspects of the Phase I permit that takes effect in August 2013, Clark
County is currently working on stormwater code revisions that are “flexible and tailored
to multiple project types” and that (per permit requirements) identify LID as the
“preferred approach” for stormwater management (Clark County, 2013). Once code
revisions are drafted, stakeholders, the Clark County Board of Commissioners, and
finally Ecology will have opportunities for review and comment (ibid).
3. Fragmented Responsibilities (Roy, et al., 2008, p. 348):
Fragmentation of responsibilities on a local level speaks to the broad spectrum of
resources and people involved in stormwater management and the potential for a lack of
synchronization among these entities. Clark County addresses this barrier with an
integrated organizational model and through a network of public outreach ventures in
collaboration with several Clark County cities to provide consistent stormwater
47
information to local businesses and to the public (Chapter 3). Phase I permit compliance
mechanisms in Clark County utilize an integrated organizational approach that promotes
collaboration among various departments (Clark County, 2012, p. 6). The NPDES
Compliance section of the Department of Environmental Services Clean Water Program
(CWP) acts as a hub for permit-related activities (Figure 8). Among other
responsibilities, the CWP generates NPDES permit-related reports and provides
engineering guidance (Clark County, 2012, p. 4).
Monitoring
-DES Clean Water
-GIS
Outreach & Public
Involvement
-DES Clean Water
-DES Sustainability
& Outreach
Regulation
-DES Clean Water
-PW Dev Review
-PW Dev Inspection
-CD Building Dept
-PA Civil Division
Operations &
Maintenance
-DES Clean Water
-DES Legacy Lands
-DES Vegetation Mgmt
-DES Endangered Species
-PW Operations
-General Services
-Parks Department
NPDES Compliance
DES Clean Water
Program
Administration &
Coordination
-DES Clean Water
-DES Admin
-Treasurer
-PA Civil Division
CD = Community Development Dept
DES = Dept of Environmental Services
PW = Public Works
Source Control & IDDE
-DES Clean Water
-PW Dev Inspection
-PW Operations
-Public Health Dept
Inventory
-DES Clean Water
-GIS
Capital
-DES Clean Water
-DES Legacy Lands
-DES Enviro Permitting
-DES Vegetation Mgmt
-PW Engineering
-PW Operations
GIS = Geographic Information Systems Dept
PA = Prosecuting Attorney
IDDE = Illicit Discharges Detection & Elimination
Adapted from Clark County Stormwater Management Plan 2012, p. 6
Figure 8: Clark County’s integrated approach to NPDES permit responsibilities
combats fragmentation by involving staff from many different departments in
stormwater management activities.
48
Interdisciplinary collaboration with stormwater management is one benefit of an
integrated approach. Another advantage is that working relationships established through
stormwater management activities can also serve as a platform for county departments to
share information and cooperate on other projects. On another front, Clark County is
actively engaged in collective efforts to gather and disseminate consistent information
about LID and stormwater, and to provide resources to private stormwater managers and
the public as is evidenced by the Stormwater Partners of Southwest Washington website
(Chapter 3).
4. Lack of Institutional Capacity (Roy, et al., 2008, p. 349):
Institutional capacity refers to human and fiscal resources, guidance, and
education for stormwater professionals. Expanding upon the definition from Roy et al.
(2008), institutional capacity also depends not only on education, but also on the
availability of resources (e.g., training materials and qualified trainers) to meet
professional training needs. In the case of Clark County, institutional capacity is
intertwined with Barrier 3 (fragmented responsibilities) in that the collaborative
endeavors undertaken by Clark County and its partners have positively influenced
institutional capacity. For example, the integrated NPDES compliance organizational
model illustrated in Figure 8 involves a number of departments, which helps educate staff
not normally involved with LID practices and stormwater management, and cultivates
intra-organizational partnerships that can enhance institutional capacity. Clark County
further reinforces institutional capacity for LID through related research and
implementing programs that gather and disseminate information about and provide
49
assistance with LID practices (Chapter 3). SNAP researches and devises strategies for
NPDES compliance in addition to recommending and prioritizing capital stormwater
projects. SARD identifies institutional protocols as potential barriers to sustainable
development. The follow-up to SARD, the CCSC project engages with government
agencies within and outside of Clark County, with the Building Industry Association of
Clark County, and with WSU to explore the integration of sustainable development
projects on an institutional level (Cascadia Region Green Bldg Council, 2008, p. 19).
Ongoing collaborative efforts by WSU, WSC, scientists, and stormwater
professionals combine with networking among municipalities and other NPDES permit
holders to create strong networks and support systems for Western Washington
stormwater managers. Guidance documents are available at no cost including the
SWMMWW (Dept of Ecology, 2012) and the LIDTGM (Wash. St. University & Puget
Sound Partnership, 2012), along with abundant online resources on the EPA and Ecology
websites. Furthermore, Ecology recently instigated free LID training workshops
developed for specific audiences including realtors, building industry professionals,
landscapers and nurseries, compost manufacturers and retailers, elected officials,
planning and land use decision makers, and maintenance and operations personnel (Dept
of Ecology, 2013). When Roy et al. published their research in 2008, these schemes were
not in place; thus, substantial progress is demonstrated in the availability of resources and
training for stormwater managers.
50
5. Lack of Legislative Mandate (Roy, et al., 2008, p. 349):
Lack of legislative mandate, as defined by Roy et al. (2008), looks at how the
absence of comprehensive national stormwater directives creates a mosaic of
disconnected local authorities and interferes with consistent LID implementation. In
contrast to categorizing the absence of national mandates as a barrier, however, Clark
County (along with Pierce, Snohomish, and King Counties) asserts that the presence of
NPDES federal mandates as administered by Ecology actually creates barriers by
exercising excessive control over local conditions (Clark County's Notice of Appeal of
Phase I Municipal Stormwater Permit, 2012). Particular points of contention are limited
local input in the selection of watersheds, interference in land use planning, and claims
that some NPDES mandates conflict with state law and local codes (e.g., vestment rights)
(ibid). Consequently, the barrier is not a lack of legislative mandates, but instead a need
for clarification of NPDES legislative mandates.
The following example illustrates differing interpretations of NPDES mandates,
which confuse the local application of national directives. Clark County Code Section
40.385.020 I(2)(a) states, “The pre-developed condition to be matched shall be the land
cover condition existing at the time of the development application” [underline added for
clarity] or as identified in an approved basin plan (retrieved on March 2, 2013).
Conversely, the SWMMWW Volume I (Dept of Ecology, 2012), a document that
provides minimum NPDES compliance guidance in Washington State, defines predeveloped condition as:
The native vegetation and soils that existed at a site prior to the influence
of Euro-American settlement [underline added for clarity]. The predeveloped condition shall be assumed to be forested land cover unless
51
reasonable, historic information is provided that indicates the site was
prairie prior to settlement (2012, p. G34).
Clark County’s site remediation goals are less restrictive, with requirements tied to the
date of development application versus pre-disturbance conditions (prior to EuroAmerican settlement) as defined in SWMMWW (Dept of Ecology, 2012, p. G34). When
existing site conditions are similar to pre-disturbance conditions, the difference in levels
of onsite remediation is negligible; however, in the instance of severely degraded sites
where the disparity between existing and pre-disturbance is substantial, the impacts of
policy differences are more pronounced. As mentioned in Chapter 3, Clark County and
Ecology are appealing the PCHB decision that requires mitigation to pre-disturbance
conditions, based on the Agreed Order (Chapter 3) between the county and state that
allows partial offsite mitigation to account for differences in existing and pre-disturbance
condition.
Beyond the legal challenges Roy et al. (2008) cite the absence of “national, legal
mandates” as the cause of “inconsistent management policies across jurisdictions” (p.
349). However, given hydrologic, soil composition, climate, and myriad other
differences among U.S. localities, it is difficult to imagine that national directives could
adequately and equitably address regional and site variations, especially if the expected
outcomes are consistent LID implementation and cohesion among state and local
authorities. A more practical approach is reflected in the current regime; overarching
minimum national mandates, administered by state agencies (e.g., Ecology in
Washington State) that work closely with local governments to devise localized strategies
that meet or exceed national and state minimum requirements.
52
Protests aside, LID stormwater management successes including the PV’s
bioretention facility and the Grattix, Clark County’s Green Business Program, the Planet
Clark sustainable home (Chapter 3), and other initiatives demonstrate that collaborative
interdisciplinary efforts can successfully implement LID in local jurisdictions, while
inspiring innovation and contributing to LID technology.
6. Lack of Sufficient Funding and Effective Market Incentives (Roy, et al., 2008, p.
349):
As mentioned in Chapter 3, stormwater fees are a common source of revenue in
NPDES permitted cities and counties. Clark County Clean Water fees are dedicated to
stormwater management, maintenance, and capital improvement projects (Clark County,
2012, p. 5). In tandem with the financial benefits of spreading costs among residents and
businesses, the act of paying stormwater fees raises public awareness about price tags
associated with stormwater management. Stormwater fees generate about $4.9 million
per year from 65,000 ratepayers in unincorporated Clark County, which is augmented by
funds received from other county sources and from grants (Clark County, 2012, p. 4).
However, escalating capital projects and other stormwater-related costs are taking a toll
on the county’s stormwater budget (ibid).
With regard to incentives, the findings of the 2008 SARD study state that,
“Opportunities to increase requirements or incentives for LID practices . . . could be
explored by both the City and County to optimize adoption of standards that match
current research and technologies” (Cascadia Region Green Bldg Council, 2008, p. 13).
The study also indicates that in 2008 the City of Vancouver and Clark County were in the
53
process of revising outdated stormwater codes to allow credit for LID practices, although
a review of county code archives in the course of research for this paper failed to reveal
evidence of such revisions. However, pursuant to upcoming NPDES requirements to
codify preferences for LID, Clark County stormwater codes are currently under review, a
process that is slated for completion in 2015.
The disputed Agreed Order between Clark County and Ecology (Chapter 3)
equates to a cap-and-trade market incentive for development. Instead of meeting predisturbance stormwater outflow conditions through onsite LID strategies as prescribed in
the Phase I permit, onsite mitigation is capped at the site condition existing “at the time
of the development application” (retrieved on March 2, 2013). Developers can then
transfer (trade) the calculated difference between existing and pre-disturbance flow
conditions to the county’s Stormwater Capital Improvements Program. As demonstrated
by ongoing litigation in response to the Agreed Order, a remedy intended to provide
incentives (or remove disincentives) for developers creates a new set of problems, which
Roy et al. (2008) describe as challenges in defining parameters and enforcement, and
garnering a broad base of support (p. 350).
Clark County is also looking to incentivize development through streamlined
permitting processes and fee waivers; although similar incentives were previously in
place, further measures are planned. In 2012, a resolution was adopted for a pilot project
that allows developers (under certain conditions) to self-certify in place of a final review
by county engineering staff, thereby foregoing the cost and time involved in a final
review (BOCC Meeting Minutes, 2012). A county staff report (August 21, 2012)
expresses concerns over the construction quality of transportation and stormwater
54
elements under this arrangement and the ability to address violations after developments
are completed (p. 1). In another move the Clark County Board of Commissioners held a
public hearing on May 7, 2013 to discuss temporary waivers of “all fees associated with
the permitting, development and inspection of commercial or industrial subdivisions, and
site plan approvals” and other fees related to building and traffic impacts (Notice of
Public Hearing, 2013). Fees waivers would apply only to for-profit commercial and
industrial developments (ibid). A video of the meeting shows that a decision was
postponed pending further investigation in light of concerns raised during three hours of
public comments. No mention of incentives attached specifically to LID or other
sustainable development practices was uncovered in the research for this study.
According to the Clark County Sustainability and Outreach Coordinator, Clark
County does not offer financial incentives for LID, however, the county contracts with
consultants to assist property owners with LID guidance (email correspondence May 6,
2013). The City of Vancouver, Clark County’s largest city, offers up to 50 percent credit
in stormwater fees for qualifying properties that meet or exceed prescribed stormwater
management strategies (Vancouver City Code Section 14.09.100), but these incentives
apply only within incorporated city boundaries. Marketing incentives also take the form
of projects that demonstrate LID elements; the Planet Clark Emerald House sustainable
home project mentioned in Chapter 3 is an example of such an incentive. Navigating
county codes for the design and construction of model projects can point out code
deficiencies and can assist developers to quantify permit costs for sustainable
development. Model homes provide tangible examples of materials, costs, and
performance associated with sustainable building practices (see Barrier 1); and visiting a
55
model home brings sustainable concepts to life, which can educate prospective
homebuyers and generate market demand for sustainable features (e.g., LID).
The Green Business Program (Chapter 3), a recent county initiative, rewards
businesses for LID and other sustainable practices by providing marketing incentives that
include the use of a Green Business logo, a company profile in the Green Business
Directory and on the user-friendly Green Business website, recognition for achievements,
and county support for training and green initiatives. Twenty-eight annually certified
Green Businesses representing a diverse cross-section of the business sector participate in
the popular Clark County Green Business Program.
7. Resistance to Change (Roy, et al., 2008, p. 350):
In addition to creating obstacles to adopting LID regimes, Barriers 1 through 6
represent potential motives for resistance: performance and cost, engineering standards,
fragmented responsibilities, institutional capacity, legislative mandates, and funding and
market incentives. The following examples illustrate the complexity of resistance to
change and the role this barrier plays in legislative mandates, marketing incentives, and
institutional capacity.
Resistance to LID stormwater management strategies in Clark County is
exemplified by the county’s appeals for alternatives and relief from NPDES mandates
that are discussed Chapter 3 and mentioned again in Barriers 1, 2, and 5 in this Analysis
section. The underlying conflict surrounding these ongoing legal actions is a product of
incongruent interpretations of NPDES permit language, disagreement that the Agreed
Order is an equal or similar alternative to LID, and contradictory views on the use of pre-
56
disturbance site conditions as the stormwater flow benchmark. In contrast, resistance to
change, in these instances through legal means, will ultimately clarify the intent and
language of NPDES mandates and promote consistent interpretation and application of
NPDES policies. Roy et al. (2008) suggest that managing risk causes resistance to
change (p. 350); however, resistance to change can also reduce risk. Assuming that
uniform policy interpretation promotes consistent standards of operation, and that
standardized operating procedures result in lower risk exposures, then policy
clarifications stemming from resistance to change (e.g., NPDES mandates) provide a
positive outcome with regard to risk management.
Aside from legal challenges Clark County offers a number of resources that
address resistance to change on a community level through education, guidance, and
support. The Stormwater Partners of Southwest Washington and Clark County websites
offer LID installation and maintenance guidance, along with information about
sustainability research and pilot projects (e.g., the Plant Clark project). Other tools
available to county citizens and businesses are LID consulting services for homeowners
and businesses, and innovative outreach initiatives such as the popular Green Business
Program (Chapter 3 and Barrier 6). An example of forethought in addressing resistance
to change was demonstrated in the CCSC meetings where professional facilitators were
on hand to foster effective communication among diverse participants (Chapter 3).
57
Findings
The analysis process described in the first section of this chapter categorized the
seven barriers by level of influence on LID as determined by the scale of impact on LID
practices and the availability of compensatory resources. Table A lists the results.
Keystone
Barrier
No.
7
Barrier Name
Resistance to change
(most influential)
5
Clarification of legislative mandates
Prominent
1
Uncertainties in performance and cost
6
Lack of sufficient funding & market incentives
2
Insufficient engineering standards and
guidelines
4
Lack of institutional capacity
3
Fragmented responsibilities
Barrier Category
(influential)
Moderate
(least influential)
Table A: Barriers 1 through 7 ranked according to influence on LID.
The most influential barriers are labeled as Keystones because like the central
structural component of a stone arch the litigation and efforts to clarify mandates that
define these two barriers represent central (keystone) stormwater management policies
and standards. The outcomes of the legal actions will determine the structural integrity of
LID initiatives in Clark County and establish precedents that will affect other Phase I
jurisdictions. While Prominent barriers are not as pivotal to LID strategies as their
Keystone counterparts, these barriers are important in that they directly influence the
ability to quantify resources and performance outcomes, in addition to stimulating market
58
demand. In the case of Moderate barriers, progress is evident in Clark County,
especially with regard to fragmented responsibilities. Although somewhat dependent on
legal outcomes, the remaining issues can be largely addressed on a county level, as
myriad resources are available to assist Clark County in defining standards and building
capacity over time.
In addition to examining barriers, the analyses drew attention to characteristics of
ventures that successfully incorporate LID elements including the Planet Clark Emerald
House, the Green Business Program, and initiatives at the PV (Chapter 3). All
enterprises involve a number of collaborators and partnerships, representation from
diverse professional backgrounds, strong community connections and/or participation,
and innovation. Additionally, the PV exhibits an entrepreneurial spirit and pride in
accomplishment as is evidenced by the Clean Water Challenge program for port tenants
(including an annual awards breakfast) and an attempt to enter the port’s huge
technologically advanced bioretention facility into the Guinness Book of World Records
(professional discussion. March 25, 2013). Unfortunately, the efforts were met with
disappointment as the Guinness organization currently has no categories to recognize
green projects (ibid). Gaining an understanding of the barriers to LID strategies and
identifying traits of successful endeavors provides insights into the nature of barriers and
the potential for success that informs socio-technical improvements for future LID
implementation.
59
Chapter 5
Conclusion
Peter Gleick (2009) warns that, by necessity, the way humans use water is rapidly
changing: sustainability, adaptability, and creativity will shape the future of water
management (pp. 197-198). The clear connection between traditional stormwater
management regimes, water pollution, and other environmental consequences means that
the path to the future must take a different route. Transforming tradition is not easy,
especially when new regimes are markedly different from established methods, as is the
case with LID and conventional stormwater management.
The study has examined stormwater management in Clark County to assess
barriers to LID strategies. Seven barriers adapted from Australian researchers Roy et al.
(2008) provided a framework for review of the literature and for the analysis. The
findings identified Keystone barriers to LID strategies as resistance to change and
clarification of legislative mandates. The chief manifestation of these barriers is
litigation, the outcomes of which will either solidify or dilute NPDES LID mandates.
Other barriers, such as uncertainties in performance and cost and lack of institutional
capacity, present varying degrees of difficulty and success in adopting LID strategies.
Analysis of the barriers demonstrates Clark County’s dichotomous relationship
with LID. In the midst of ongoing litigation over LID mandates, the county at the same
time promotes LID through a number of stormwater and LID-related programs that
encourage community participation and collaboration, educate the public, and provide
resources for urban and rural areas within the county. These disparities concur with
Meadows’ (2008) premise that resistance to change “arises when goals of subsystems are
60
different from and inconsistent with each other” (p. 113). Given that LID initiatives such
as public involvement, outreach and education, and coordination among county
departments are mandated by the Phase I permit (Dept of Ecology, 2012, pp. 11-31), it is
reasonable to conclude that Phase I permit requirements have at least in part if not fully
prompted some LID programs in Clark County. If this assumption is correct, then certain
LID initiatives stem from permit compliance procedures rather than from county
aspirations to embrace LID concepts. Nevertheless, an examination through the lens of
the seven barriers presented by Roy et al. (2008) shows positive results for internal
coordination mechanisms, community involvement, innovation, and entrepreneurial
endeavors in Clark County. The data suggest that professional interdisciplinarity,
community cohesion, and innovation are common characteristics of successful LID
ventures. A pragmatic worldview provides further insights into stormwater management
concerns.
James (1907) asserts that a pragmatist “turns away from abstraction and
insufficiency [and] . . . turns towards concreteness and adequacy, towards facts, towards
action” (pp. 22, Location 384). Flooding is a direct consequence of excess surface water
and point source water pollution is a consequence of the manner in which surface water is
managed. From a pragmatic perspective, stormwater is not the problem; rather
stormwater is a consequence of anthropogenic interference (site disturbance) with natural
water cycles. Breaking it down further, problems associated with stormwater runoff
(e.g., flooding and water pollution) are an amalgamation of consequences (abstractions)
stemming from countless individual actions: one rooftop, plus one driveway, plus one
parking lot, plus one vehicle leaking oil, plus one factory, and so on. The results of this
61
study demonstrate that barriers to stormwater management represent barriers to
developing mitigation mechanisms that sustainably address the consequences of an
immense collection of highly diverse individual actions. Pragmatically the challenge is
how to manage site disturbance activities to minimize the disruption of natural water
cycles (the core problem), instead of focusing on schemes to deal with stormwater runoff
(consequences).
An important difference between traditional stormwater management and LID is
the perception of the problem, which as is shown above, differs markedly between the
two regimes. While traditional stormwater management deals with water after it leaves a
site, LID promotes strategies that manage precipitation onsite. Therefore, it is not
surprising that solutions also differ, and with different solutions come different actors and
different ways of acting. Brown, Sharp, and Ashley (2006) introduce the term
technocratic expertise as “a series of technologies with little consideration of . . . sociopolitical strategies needed to enable political relevance and need within the
community” (p. 420). Sustainable stormwater management is a community need; yet
addressing traditionally defined stormwater problems with technocratic solutions
exemplifies a mono-disciplinary approach. Conversely, given the vast diversity of
contributors and stakeholders that are connected to stormwater issues, LID necessarily
injects a pragmatic interdisciplinary approach into stormwater management by focusing
on the actual problem (site disturbance) and offering customizable strategies (actions) for
sustainable stormwater management.
Five years have passed since Roy et al. introduced the seven barriers in 2008.
This case study updates the successes and challenges encountered by stormwater water
62
managers through an assessment of the seven barriers to LID strategies. Revisiting the
topic in five years (2018) will further illuminate the seven barriers and provide insights
into the progress of LID over the course of a decade that has thus far seen major changes
in stormwater management. Other suggestions for future research include a focus on
potential solutions to each barrier, exploring connections between LID strategies and
economic agendas (e.g., commercial development), and comparing the environmental
services provided by in situ LID strategies versus offsite mitigation alternatives (as
proposed in the Agreed Order).
Environmental problems associated with traditional stormwater management
schemes prohibit the continuation of conventional methods. As NPDES regulations are
phased in, LID is gaining a foothold in cities and counties; and if current plans remain in
place, mandates for LID will become more stringent with time. Identifying barriers and
collectively devising LID strategies for stormwater management will inform efforts and
enhance outcomes. Most importantly, as traditional stormwater management practices
transform into more sustainable LID regimes, point source pollution from stormwater
runoff will become the exception and not the rule.
63
Bibliography
BOCC Meeting Minutes. (2012, August 21). Clark County Board of Commissioners.
Clark County.
(2013, May 25). Retrieved from Washington Stormwater Center:
http://www.wastormwatercenter.org/home
A Low Impact Development (LID) Model Ordinance and Guidance Document. (2013,
April 24). Retrieved from American Society of Civil Engineers:
http://cedb.asce.org/cgi/WWWdisplay.cgi?264681
Agreed Order No. 7273, CL 09-122 (Dept of Ecology December 31, 2009).
Allen, S. C., Moorman, C. E., Peterson, M. N., Hess, G. R., & Moore, S. E. (2012).
Overcoming socio-economic barriers to conservation subdividsions: A case-study
of four successful communities. Landscape and Urban Planning, Vol 106, 244252.
Allen, S., Moorman, C., Peterson, M. N., Hess, G., & Moore, S. (2013). Predicting
success incorporating conservation subdivisions into land use planning. Land Use
Policy, Vol 33, 31-35.
Barbosa, A. E., Jernandes, J., & David, L. (2012). Key issues for sustainable urban
stormwater management. Water Research, Vol 46, 6787-6798.
Booth, D. B. (2006). Damages and Costs of Stormwater Runoff in the Puget Sound
Region. Seattle: University of Washington.
Booth, D., Crawford, C., Derry, B., Hinman, C., Horner, R., May, C., . . . Wulkan, B.
(2007, June 27). Stormwater Runoff and Puget Sound: Problems, Issues and
Analyses Needed.
64
Bowman, T., & Thompson, J. (2009). Barriers to implementation of low-impact and
conservation subdivision design: Developer perceptions and resident demand.
Landscape and Urban Planning, Vol. 92, 96-105.
Bowman, T., Thompson, J., & Tyndall, J. (2012). Resident, developer, and city staff
perceptions of LID and CSD subdivision design approaches. Landscape and
Urban Planning, Vol 107, 43-54.
Bowman, T., Tyndall, J. C., Thompson, J., Kliebenstein, J., & Colletti, J. P. (2012).
Multiple approaches to valuation of conservation design and low-impact
development features in residential subdivisions. Journal of Environmental
Management, 101-113.
Braden, J. B., & Johnston, D. M. (2004). Downstream Economic Benefits from StormWater Management. Journal of Water Resources Planning and Management,
498-505.
Brown, R. R., Sharp, L., & Ashley, R. (2006, Vol. 54, No. 6). Implementation
impediments to institutionalising the practice of sustainable urban water
management. Water Science & Technology, pp. 415-422.
Brown, R., & Farrelly, M. (2009). Challenges ahead: social and institutional factors
influencing sustainable urban stormwater management in Australia. Water
Science & Technology, 653-660.
Building Industry Association of Clark County. (2013, April 8). Retrieved from Building
Industry Association of Clark County: http://biaofclarkcounty.org
65
Burns, M. J., Fletcher, T. D., Walsh, C. J., Ladson, A. R., & Hatt, B. E. (2012).
Hydrologic shortcomings of conventional urban stormwater management and
opportunities for reform. Landscape and Urban Planning, Vol. 105 (3), 230-240.
Cascadia Region Green Building Council. (2008). Report #1: Findings: Code Barriers
for Sustainable, Affordable, Residential Development. Cascadia.
Cherryholmes, C. H. (1994). More Notes on Pragmatism. Educational Researcher, Vol
23, No. 1, 16-18.
City of Battleground. (n.d.). Comments on NPDES Phase II Municipal Stormwater
Permit Preliminary Draft.
City of Seattle. (2013, May 26). Completed GSI Projects. Retrieved from Seattle Public
Utilities: http://www.seattle.gov/util/MyServices/DrainageSewer/
Projects/GreenStormwaterInfrastructure/CompletedGSIProjects/index.htm
Clark Co. Notice of Appeal of Ph I Municipal Stormwater Permit (St of Wash Pollution
Control Hearings Board August 31, 2012).
Clark Co. Environmental Services. (n.d.). Frequently Asked Questions about the Clean
Water Service Fee.
Clark County. (2007). Stormwater Needs Assessment Program Summary. Clark County.
Clark County. (2009, November). Clark County Stormwater Manual. Washington: Clark
County.
Clark County. (2011). 20-Year Comprehensive Growth Managment Plan: 2004-2024.
Clark County.
Clark County. (2011). Clark County Stormwater Management Plan 2011. Clark County.
Clark County. (2012). Clark County Stormwater Management Plan 2012. Clark County.
66
Clark County. (2013, March 13). Stormwater code and manual update. Retrieved from
Clark County Washington: http://www.clark.wa.gov/water-resources/SWMP/
sw%20ordinance%20update.html
Clark County Environmental Services. (2012). 2012 Annual Report. Vancouver: Clark
County.
Clark County Environmental Services. (2012, February). Clark County's Clean Water
Program. Clark County.
Clark County Environmental Services. (2012, February). How Our Fees Compare. Clark
County's Clean Water Program. Vancouver, Washington: Clark County.
Clark County QuickFacts. (2013, February 3). Retrieved February 20, 2013, from U.S.
Census Bureau: http://quickfacts.census.gov/qfd/states/53/53011.html
Clark County Sustainable Communities: Meeting #1. (2009, October 22). Meeting
Minutes. Battle Ground, WA.
Clark County Sustainable Communities: Meeting #3. (2009, November 19). Meeting
Minutes. Vancouver, WA.
Clark County Sustainable Communities: Meeting #5. (2010, February 10). Meeting
Minutes. Vancouver, WA.
Clark County's Notice of Appeal of Phase I Municipal Stormwater Permit. (2012, August
31). Vancouver, Washington.
Columbia River Pilots. (2009). Retrieved from Ship Types:
http://www.colrip.com/pages/Ships.aspx
CREDC Economic Development. (2013). Retrieved from http://www.credc.org
67
Creswell, J. (2009). Research Design: Qualitative, Quantitative, and Mixed Methods
Approaches. Sage: Thousand Oaks.
Davis, A. P., Hunt, W. F., Traver, R. G., & Clar, M. (2009). Bioretention Technology:
Overview of Current Practice and Future Needs. Journal of Environmental
Engineering, 109-117.
Dept of Ecology. (2008). Making Mitigation Work. Olympia: State of Wash.
Dept of Ecology. (2010, March). NPDES 101. Olympia, Washington: Dept of Ecology.
Dept of Ecology. (2011). Stormwater Technicial Resource Center: 2011 Report to the
Legislature. Olympia: Dept of Ecology.
Dept of Ecology. (2011). Too Much Water in the Neighborhood. Olympia: Dept of
Ecology.
Dept of Ecology. (2012, August). Phase I Muncipal Stormwater Permit. Olympia,
Washington.
Dept of Ecology. (2012, August). Stormwater Management Manual for Western
Washington: Vol. I. Dept of Ecology.
Dept of Ecology. (2012, August). Stormwater Management Manual for Western
Washington: Vol. V. Dept of Ecology.
Dept of Ecology. (2013, June 1). Municipal Stormwater. Retrieved from Dept of
Ecology: http://www.ecy.wa.gov/programs/wq/stormwater/municipal/LID/
TRAINING/index.html
Dept of Ecology. (2013, August). Phase I Municipal Stormwater Permit. Olympia,
Washington.
68
Dept of Ecology. (2013, April 9). Supplemental Statewide Stormwater Grant Program.
Retrieved from Dept of Ecology: http://www.ecy.wa.gov/programs/wq/funding/
FundingPrograms/OtherFundingPrograms/StWa12a/FY12aStWa.html
Dept of Ecology. (2013, March). Who's Covered Under the Municipal Stormwater
Permits? Retrieved January 29, 2013, from Dept of Ecology: http://
www.ecy.wa.gov/programs/wq/stormwater/municipal/MuniStrmWtrPermList.html
Dietz, M. E., & Clausen, J. C. (2008). Stormwater runoff and export changes with
development in a traditional and low impact subdivision. Journal of
Environmental Management, Vol 87, 560-566.
Dong, H., & Gliebe, J. (2012). Assessing the Impacts of Smart Growth Policies on Home
Developers in a Bi-state Metropolitan Area: Evidence from the Portland
Metropolitan Area. Urban Studies, Vol. 49 Issue 10, 2219-2235.
ECONorthwest. (2007). The Economics of Low-Impact Development: A Literature
Review. Portland: ECONorthwest.
Elected Officials. (2013, May 10). Retrieved from Clark County Washington:
http://www.clark.wa.gov/aboutcc/governs/elected.html
FEMA. (2011, December 13). Tested and Proven Success: Stormwater Improvement
System. Retrieved from FEMA: http://www.fema.gov/mitigationbp/
bestPracticeDetail.do;jsessionid=8FCFD5AC0F2931D34D5539322CC120D5.Wo
rkerPublic3?mitssId=9111
Ferguson, B. C., Brown, R. R., & Deletic, A. (2013). Diagnosing transformative change
in urban water systems: Theories and frameworks. Global Environmental
Change, Vol 23, 264-280.
69
Findings of Fact, Conclusions of Law, and Order, PCHB No. 10-013 (Pollution Control
Hearings Board January 5, 2011).
Fiscal Year 2012 Stormwater Grant Programs. (n.d.). Retrieved from Dept of Ecology:
http://www.ecy.wa.gov/programs/wq/funding/FundingPrograms/OtherFundingPr
ograms/StWa12a/FY12aStWa.html
Girling, C., & Kellett, R. (2002). Comparing stormwater impacts and costs on three
neighborhood plan types. Landscape Journal 21:1-02, pp. 100-109.
Gleick, P. H. (2009). Water Soft Path Thinking in the United States. In D. B. Brooks, O.
M. Brandes, & S. Gurman, Making the Most of the Water We Have (pp. 197-206).
Washington, D.C.: Earthscan.
Graf, T. (2013, May 7). County officials delay decision on fees: Testimony focuses on
effect to budget. Retrieved from The Columbian: http://www.columbian.com/
news/2013/may/07/county-officials-delay-decision-on-fees/
Hinman, C. (2012, May 17). LID Technical Workshop Series: Sediment and Erosion
Control. Puyallup, Washington: Wash. State University.
Howie, D. C., Emmett, K., & Winz, J. (2011). Stormwater Technical Resource Center:
Report to the Legislature. Olympia: Dept. of Ecology.
Jackson, P. L., & Kimerling, A. J. (2003). Atlas of the Pacific Northwest. Corvallis:
Oregon State University Press.
James, W. (1907). Pragmatism: A New Name for Some Old Ways of Thinking. Kindle
book.
70
Johnston, D. M., & Braden, J. B. (2006). Downstream Economic Benefits of
Conservation Development. Journal of Water Resources Planning and
Management, 35-43.
Juergensmeyer, J. C., & Roberts, T. E. (2007). Land Use Planning & Development
Regulation Law. St. Paul: Thomson/West.
Kingsolver, B. (2010, April). Everyday wonders reflect the primacy of water. National
Geographic, pp. 44-49.
Langeveld, J., Liefting, H., & Boogaard, F. (2012). Uncertainties of stormwater
characteristics and removal rates of stormwater treatment facilities: Implications
for stormwater handling. Water Research, Vol 46, 6868-6880.
Meadows, D. H. (2008). Thinking in Systems. White River Junction: Chelsea Green
Publishing Company.
Monash University. (2012, September 12). Retrieved January 2013, from Prof Rebekah
Brown - Researcher Profile: http://www.monash.edu.au/research/profiles/
profile.html?sid=6069&pid=3828
Moura, P., Barraud, S., Baptista, M., & Malard, F. (2011). Multicriteria decision-aid
method to evaluate the performance of stormwater infiltration systems over the
time. Water & Science Technology, Vol. 64, Issue 10, pp. 1993-2000.
National Park Service. (2013, April 19). Fort Vancouver. Retrieved from National Park
Service: http://www.nps.gov/fova/index.htm
Notice of Public Hearing. (2013, April 22). Washington: Clark County.
Office of Wastewater Management. (2013, May 18). NPDES Permit Program Basics.
Retrieved from US EPA: http://cfpub.epa.gov/npdes/home.cfm?program_id=45
71
Pejchar, L., Morgan, P. M., Caldwell, M. R., Palmer, C., & Daily, G. C. (2007).
Evaluating the Potential for Conservation Development: Biophysical, Economic,
and Institutional Perspectives. Conservation Biology, Vol 21, No. 1, 69-78.
Peterson, M. N., & Liu, J. (2008). Property rights and landscape planning in the
intermountain west: The Teton Valley case. Landscape and Urban Planning, Vol.
86, 126-133.
Planet Clark.com. (2013, April 15). Retrieved from Planet Clark.com:
http://planetclark.com/
Port of Vancouver USA (2). (2013, May 4). Retrieved from Enviornmental Services:
http://www.portvanusa.com/environmental-services/water-quality/
Port of Vancouver USA. (2013, May 11). Retrieved from Largest Bio-retention Facility in
World Calls Port of Vancouver Home: http://www.portvanusa.com/environment/
largest-stormwater-bio-retention-facility-in-world-calls-port-of-vancouver-home/
Promising Future. (2012, December 6). Retrieved from Clark County, Washington:
http://www.clark.wa.gov/aboutcc/future.html
Proud Past. (2013, March 1). Retrieved from Clark County, Washington:
http://www.clark.wa.gov/aboutcc/proud_past/theCounty.html
Published Opinion: Rosemere Neighborhood Assn, Columbia Riverkeeper, & NW
Environmental Defense Cntr v. Clark Co., Bldg Industry Assn of Clark Co., Dept.
of Ecology, 41833-9-II (Court of Appeals, St. of Wash., Div II September 25,
2012).
Robins, L. (2007). Perspectives on capacity building to guide policy and program
development and delivery. Environmental Science & Policy, Vol. II, 687-701.
72
Roy, A. H., Wenger, S. J., Fletcher, T. D., Walsh, C. J., Ladson, A. R., Shuster, W. D., . .
. Brown, R. R. (2008). Impediments and Solutions to Sustainable, WatershedScale Urban Stormwater Management: Lessons from Australia and the United
States. Environmental Management, 344-359.
Snohomish Co Appeal of the 2013-2018 Ph. I Municipal Stormwater Permit (St of Wash
Pollution Control Hearings Board August 30, 2012).
Stark, D. J. (2012). Managing Stormwater One Parking Lot at a Time. Retrieved
September 6, 2012, from Water World: http://www.waterworld.com/articles/print/
volume-28/issue-8/urban-water-management/managing-stormwater-one-parkinglot-at-a-time.html
State & County Quick Facts. (2013, January 10). Retrieved February 3, 2013, from US
Census Bureau: http://quickfacts.census.gov/qfd/states/53/53011.html
Stiffler, L. (2012). The Promise of Permeable Pavement. Seattle: Sightline Institute.
Stormwater funding boosts water security. (2012, August 10). Stock Journal. Australia.
Thayer, H., & Rosenthal, S. B. (2013, May 23). Pragmatism. Retrieved from
Encyclopædia Britannica Online: http://www.britannica.com/EBchecked/
topic/473717/pragmatism
TIP Strategies Inc. (2011). Clark County Economic Development Plan. Austin: TIP
Strategies.
US Census Bureau. (2012, September). Technical Documentation: 2010 Census
Summary File 1. US Census Bureau.
US Census Bureau. (2013). Clark County Washington. Retrieved from Census 2010
Browser: http://gis.clark.wa.gov/gishome/Census/2010/
73
US EPA. (2008). Evaluating the Effectiveness of Municipal Stormwater Programs. US
EPA.
US EPA. (2008, January). Funding Stormwater Programs. Washington D.C.: US EPA.
US EPA. (2009). Incorporating Environmentally Sensitive Development Into Municipal
Stormwater Programs. US EPA: 833-F-07-011.
US EPA. (2012, March 9). A Brief Summary of the History of NPDES. Retrieved from
US EPA: http://www.epa.gov/region1/npdes/history.html
US EPA. (2012, March). Benefits of Low Impact Development. Washington D.C.: US
EPA.
US EPA. (2012, October). Effectiveness of Low Impact Development. Washington D.C.:
US EPA.
US EPA. (2012, December). Encouraging Low Impact Development. Washington D.C.:
US EPA.
US EPA. (2012, July 30). National Menu of Stormwater Best Management Practices.
Retrieved from NPDES: http://cfpub.epa.gov/npdes/stormwater/
menuofbmps/index.cfm
US EPA. (2012, March 12). National Pollutant Discharge Elimination System (NPDES).
Retrieved from USS EPA: URL:http://cfpub.epa.gov/npdes/index.cfm
US EPA. (2012, March 20). Stormwater Basic Information. Retrieved September 2012,
from National Pollution Discharge Elimination System (NPDES):
http://cfpub.epa.gov/npdes/stormwater/swbasicinfo.cfm
US EPA. (2012, March). Terminology of Low Impact Development. Washington D.C.:
US EPA.
74
US EPA. (2013, January 17). Low Impact Development (LID) "Barrier Busters" Fact
Sheet Series. Retrieved from US EPA: http://water.epa.gov/polwaste/
green/bbfs.cfm
Wash. St. University & Puget Sound Partnership. (2012, December). Low Impact
Development Technical Guidance Manual for Puget Sound. Tacoma,
Washington.
Washington St Univ; Puget Sound Partnership. (2012, December). Low Impact
Development Technical Guidance Manual for Puget Sound. Tacoma,
Washington.
WE CAN! Task Force. (2011). 2011 Sustainability Report. Vancouver: Port of
Vancouver.
Willard, R., & Toppi, J. (2012, October). Complete agreement: City of Denver executes
thorough storm-water response. Roads & Bridges, pp. 44-49.
Williams-Derry, C. (2012). Rural Sprawl in Metropolitan Portland: A comparison of
growth management in Oregon and Washington. Seattle: Sightline Institute.
Woltemade, C. J. (2010, August). Impact of residential soil disturbance on infiltration
rate and stormwater runoff. Journal of the American Water Resources Assn., Vol.
46, No. 4, 700-711.
Xue, J. (2012, April). Potentials for decoupling housing-related environmental impacts
from economic growth. Environmental Development, pp. 18-35.
Zaccai, E. (2012). Over two decades in pursuit of sustainable development: Influence,
transformations, limits. Environmental Development, 79-90.
75
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