    Water Quality: Better Data and Evaluation of Urban Runoff
    Programs Needed to Assess Effectiveness (29-JUN-01, GAO-01-679).

    The Environmental Protection Agency (EPA) regards the
    contaminants in storm water runoff as a significant threat to
    water quality across the nation and considers it to be one of the
    most significant reasons that water quality standards are not
    being met nationwide. Prompted by Congress, EPA has responded
    with a variety of programs, including the National Pollutant
    Discharge Elimination System Storm Water Program, which requires
    more than 1,000 local governments to implement storm water
    management programs. Those municipalities that are currently
    involved in Phase I of the program have been attempting to reduce
    pollutants in storm water runoff for several years. It is time to
    begin evaluating these efforts. However, EPA has not established
    measurable goals for this program. In addition, the agency has
    not attempted to evaluate the effectiveness of this program in
    reducing storm water pollution or to determine its cost. The
    agency attributes this problem to inconsistent data reporting
    from municipalities, insufficient staff resources, and other
    competing priorities within the Office of Wastewater Management.
    Although Phase I municipalities report monitoring and cost data
    to EPA or state regulatory agencies annually, these agencies have
    not reviewed this information to determine whether it can be of
    use in determining the program's overall effectiveness or cost.
    GAO's analysis shows that the reported cost information will be
    difficult to analyze unless EPA and its state partners set
    guidelines designed to elicit more standardized reporting. Better
    data on costs and program effectiveness are needed--especially in
    light of the Phase II program that will involve thousands more
    municipalities in 2003. EPA's planned research grant to the
    University of Alabama and its pilot project to analyze data from
    annual reports and develop baseline indicators is a step in the
    right direction and could point the way for a more comprehensive
    approach.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-01-679
        ACCNO:   A01269
      TITLE:     Water Quality: Better Data and Evaluation of Urban Runoff
                 Programs Needed to Assess Effectiveness
         DATE:   06/29/2001
      SUBJECT:   Cost analysis
    	     Program evaluation
    	     Reporting requirements
    	     Water quality
    	     Water pollution control
    	     Performance measures
    	     Clean Water State Revolving Fund
    	     EPA National Pollutant Discharge
    	     Elimination System

    	     EPA National Pollutant Discharge
    	     Elimination System Storm Water Program

    	     EPA Total Maximum Daily Loads Program

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    GAO-01-679

    A

    Report to Congressional Requesters

    June 2001 WATER QUALITY Better Data and Evaluation of Urban Runoff Programs
    Needed to Assess Effectiveness

    GAO- 01- 679

    Letter 3 Results in Brief 4 Background 6 Volume of Urban Runoff Increases
    With the Expansion of Urban

    Development and Can Affect Water Quality 12 Local Governments Take Actions
    to Manage Urban Storm Water

    Runoff, but Information Is Limited on the Cost and Effectiveness of These
    Actions 26 Conclusions 37 Recommendation 37 Agency Comments and Our
    Evaluation 38

    Appendixes Appendix I: The Storm Water Program in Baltimore City, Maryland
    40 Appendix II: The Storm Water Program in Boston, Massachusetts 42 Appendix
    III: The Storm Water Program in Los Angeles County, California 44

    Appendix IV: The Storm Water Program in Milwaukee, Wisconsin 48 Appendix V:
    The Storm Water Program in Worcester, Massachusetts 51 Appendix VI: Comments
    From the Environmental Protection Agency 55 Appendix VII: GAO Contacts and
    Staff Acknowledgments 58

    Tables Table 1: Storm Water Pollutants in Urban Runoff, Including Sources
    and Potential Impacts 21

    Table 2: Comparative Health Outcomes for Swimming in Front of Drains Versus
    400 or More Yards Away 24 Table 3: Summary of Fiscal Resources Projected for
    Los Angeles

    County and Its Co- permittees, Fiscal Years 1997- 99 46 Table 4: City of
    Worcester?s Capital Expenditures for Storm Water

    Management 53 Figures Figure 1: Urban Runoff Flows in Different Types of
    Sewer Systems 10

    Figure 2: Increase in Urbanized Land in Selected Cities, 1960- 90 14 Figure
    3: Percentage of Paved Public Road Miles, 1945- 97 15 Figure 4: Impact of
    Impervious Surfaces on the Amount of Storm

    Water That Runs Off, Infiltrates, and Evapotranspires 17 Figure 5: Damage
    Caused by Storm Water Runoff From Urbanized

    Areas in the Gingerville Creek Subbasin 20

    Figure 6: Comparison of Town Lake PAHs and Traffic Trends 25

    Abbreviations

    BMP best management practices CSO combined sewer overflow DOT Department of
    Transportation DPW Department of Public Works EPA Environmental Protection
    Agency FHWA Federal Highway Administration MCTT Multi- Chambered Treatment
    Tank MDE Maryland Department of Environment MS4 Municipal Separate Storm
    Sewer System NPDES National Pollutant Discharge Elimination System PAH
    polycyclic aromatic hydrocarbons PCB polychlorinated biphenyls TEA- 21
    Transportation Equity Act for the 21 st Century TMDL total maximum daily
    load USGS U. S. Geological Survey WDNR Wisconsin Department of Natural
    Resources WPDES Wisconsin Pollutant Discharge Elimination System

    Lett er

    June 29, 2001 The Honorable Olympia Snowe United States Senate

    The Honorable Sherrod Brown The Honorable Martin Meehan The Honorable James
    Oberstar The Honorable Jack Quinn House of Representatives

    Nonpoint source pollution- that is, pollution from contaminants picked up
    and carried into surface water by water running over land- is known to be
    one of the leading causes of water quality problems in the United States.
    Water that runs over developed areas, including paved surfaces such as roads
    and parking lots, before reaching a water body is known as urban

    runoff and is an increasingly important category of water pollution. As
    urban areas have expanded over the past several decades, the amount of urban
    runoff has also increased. Although the overall quality of the nation?s
    waters has improved since the passage of the Clean Water Act in 1972, a
    significant number of water bodies still suffer from poor water quality.
    Because the act brought discharges from ?point sources,? such as industrial
    plants and municipal treatment plants, under control, the continuing

    pollution of these waters suggests that other sources, including urban
    runoff, are contributing to water quality problems. As a result, the
    Environmental Protection Agency (EPA) now classifies urban runoff as a

    significant cause of impairment to water quality. The Water Quality Act of
    1987, which amended the Clean Water Act, required EPA, among other things,
    to regulate as a point source urban runoff that reaches municipal sewer
    systems. EPA?s National Pollutant Discharge Elimination System Program for
    storm water requires that certain local governments take measures to control
    storm water runoff.

    Concerned about the degradation of water quality in urban areas, you asked
    us to report on (1) the amount of runoff from urban areas, particularly from
    roads, highways, and other impervious surfaces, 1 and its effects on water
    quality and (2) the programs that federal regulations require local
    governments to develop to address urban runoff, and the

    costs and effectiveness of those programs. To address these issues, we
    reviewed federal and other studies and interviewed experts on the
    relationship between the amount of paved and other impervious surfaces and
    the amount of runoff, and on the types of materials typically contained in
    urban runoff. We also reviewed studies and interviewed experts on the
    sources of these materials and any actual or potential effects on water
    quality from urban runoff. We visited five urban areas and organizations

    that are affiliated with their watersheds 2 to obtain site- specific
    information about urban runoff problems, programs these areas have
    implemented in response to federal requirements, and the costs and
    effectiveness of these programs. Finally, we reviewed studies and estimates
    of the costs and investment requirements associated with implementing storm
    water management programs. Because this report focuses on local governments?
    actions, we did not review the portions of the National Pollutant Discharge

    Elimination System Storm Water Program that address industrial facilities
    and construction sites. We performed our review from August 2000 through May
    2001 in accordance with generally accepted government auditing standards.
    Results in Brief The volume of urban storm water runoff increased throughout
    the United States in the last half of the 20 th century because of the
    growth in

    impervious surfaces that resulted from the development of urban and suburban
    areas. According to the U. S. Department of Agriculture, between 1945 and
    1997, land devoted to urban areas in the United States has increased by
    about 327 percent; according to EPA, paved road mileage has

    increased by 278 percent. Because paved surfaces are almost impervious, they
    allow little storm water to infiltrate the ground; therefore, the storm
    water runs off into creeks, rivers, and lakes. As storm water runs across
    these impervious surfaces and land, it picks up pollutants from these
    surfaces and carries them to receiving bodies of water- either directly or

    1 An impervious surface keeps water from soaking into soils. 2 A watershed
    is an area of land in which all surface water drains to a common point.

    through conveyances such as gutters, storm sewers, and culverts. EPA?s 1998
    National Water Quality Inventory Report to Congress showed that certain
    rivers, streams, lakes, and estuaries are impaired in terms of their

    ability to support such uses as aquatic life, swimming, and fish
    consumption, and concluded that urban runoff was a major source of this
    impairment. Studies have shown that urban runoff and the pollutants it
    carries can cause increases in sedimentation, water temperature, and
    pathogen levels and decreases in dissolved oxygen levels in bodies of water.
    These changes can lead to the degradation of habitat in these water bodies
    and a decline in diversity of aquatic life and can endanger public health.
    For example, metals, a pollutant typically found in urban runoff, can be
    toxic to aquatic organisms. Pathogens, such as bacteria from animal waste,
    another pollutant commonly found in urban runoff, can pose public health
    problems when present in waters used for recreational purposes.

    The magnitude and nature of these effects vary by region, depending on the
    type and concentration of pollutants in storm water, rainfall
    characteristics, land use, and other factors.

    Local governments are required to address urban runoff through EPA?s
    National Pollutant Discharge Elimination System Storm Water Program. Under
    permits that EPA and states issue through this program, over 1,000 local
    governments must meet EPA?s requirements to implement storm water management
    programs to reduce contaminants in storm water to the ?maximum extent
    practicable.? EPA recommends that these cities use ?best management
    practices? to reduce contaminants in storm water runoff. The most typical
    practices included controlling runoff through a combination of structural
    means, such as detention ponds, and nonstructural means, such as increasing
    the frequency of street sweeping and educating the public about how to
    prevent pollutants from reaching storm sewers. Cities also used specialized
    practices to address specific local runoff problems. For example, Baltimore,
    Maryland, has focused on reducing the level of nutrients, such as
    fertilizers, in its runoff because of its proximity to the Chesapeake Bay,
    which suffers from high nutrient levels.

    Neither the overall costs of implementing the storm water program nor the
    program?s effectiveness has been determined. EPA estimated in a 1996 report
    to congress that the potential need for spending on storm water runoff and
    overflows of sewage resulting from runoff was over $50 billion over 20
    years, but the agency also believes this estimate will increase when it
    issues its next report in 2002. EPA?s regulations require that permitted
    cities annually report the costs of implementing their storm water

    programs, along with the results of their monitoring of storm water runoff
    and water quality. However, in part because EPA has not established
    guidelines for reporting costs, these data have not been calculated or
    reported consistently and, therefore, are not currently useful in
    characterizing the program?s overall cost. EPA, state, and city officials
    generally believe that managing storm water runoff will reduce the volume of
    runoff and concentrations of pollutants in the runoff, as well as improve

    water quality, but no systematic effort to evaluate the program?s results
    has been started. EPA and the states have generally been unsuccessful in
    developing measurable program goals and in demonstrating program
    effectiveness through the review of water quality data reported by local

    governments. We believe it is time for EPA to begin evaluating this program,
    which is directed at one of the nation?s most significant water quality
    problems. Therefore, this report includes a recommendation to EPA to work
    with states to develop program goals, establish standards for reporting on

    program costs and effectiveness, and review reported water quality data to
    determine whether the current storm water management programs are having the
    intended effect of improving the quality of the nation?s waters and how much
    the programs cost. We provided a draft of this report to EPA and the
    Department of Transportation (DOT). EPA generally agreed

    with the report and plans to take action to implement several parts of the
    recommendation; the agency did not comment on the other parts of the
    recommendation. DOT generally agreed with the report. (See the Agency
    Comments and Our Evaluation section of this report.)

    Background Nonpoint source pollution can result when water, such as
    precipitation, runs over land surfaces and into bodies of water. Significant
    nonpoint sources of pollution can include paved urban areas, agricultural
    practices,

    forestry, and mining. However, in urban and suburban areas, this runoff
    generally enters a sewer system that can be regulated as a point source of
    water pollution. For example, precipitation from rain or snowmelt may run
    into a municipal separate storm sewer system (MS4 or storm sewer) that
    eventually discharges into a body of water. The precipitation may also run
    into a combined sewer system, which carries a combination of storm water
    runoff, industrial waste, and raw sewage in a single pipe to a sewage

    treatment facility for discharge after treatment. Lastly, the precipitation
    may run off of land or paved surfaces directly into nearby receiving waters.

    EPA?s Office of Wastewater Management, which is within the Office of Water,
    implements the National Pollutant Discharge Elimination System (NPDES)
    Program. The program was created in 1972 with the passage of the Clean Water
    Act. Created to control water pollution from point sources- those sources,
    such as a factory or wastewater treatment plant, that contribute pollutants
    directly into a body of water from a pipe or other

    conveyance- the NPDES Program did not specifically address storm water
    discharges. In 1987, the Congress amended the Clean Water Act with the Water
    Quality Act, which directed EPA to also control storm water discharges that
    enter MS4s- essentially requiring EPA to treat such storm water as a point
    source. 3 MS4s are defined as those sewers that collect and

    convey storm water; are owned or operated by the federal, state, or local
    government; and are not part of a publicly owned treatment (sewage)
    facility. To regulate urban storm water runoff, EPA published regulations in
    1990 that established the NPDES Storm Water Program and described permit
    application requirements. According to EPA, the program?s objective, in
    part, is to preserve, protect, and improve water quality by, among other

    things, controlling the volume of runoff from paved surfaces and by reducing
    the level of runoff pollutants to the maximum extent practicable using best
    management practices (BMP). 4 The 1987 act also authorized

    EPA to implement a program that provides federal funds and technical
    assistance to states to develop their own nonpoint source pollution
    management programs. States can use the federal funds they receive for
    nonpoint source programs to address nonpoint sources of pollution as well as
    urban runoff.

    Currently, EPA manages NPDES Storm Water programs in six states (Alaska,
    Arizona, Idaho, Massachusetts, New Hampshire, and New Mexico) and has
    delegated authority to the remaining 44 states to manage these programs. The
    storm water program is being implemented in two phases. Local governments
    meeting the following criteria must comply with EPA?s storm water program
    regulations. First, Phase I of the program requires that municipalities with
    a population of 100,000 or more obtain a permit for their MS4 system;
    second, the program requires that entities obtain a

    3 Section 402( p) of the Clean Water Act. 4 According to EPA, a best
    management practice is a device, practice, or method for removing, reducing,
    retarding, or preventing targeted storm water runoff constituents,
    pollutants, and contaminants from reaching receiving waters.

    permit if they discharge storm water from sites with industrial activities,
    including construction activities that disturb 5 acres or more of land. In
    addition, NPDES permitting authorities may also bring other municipalities
    and industrial entities into the program if they deem it necessary.

    Municipalities that meet these conditions must submit a permit application
    to EPA or the governing regulatory state agency. In 1990, the regulations
    specifically identified 220 municipalities throughout the United States that
    were required to apply for a Phase I permit. According to EPA, as of April
    2001, about 256 Phase 1 MS4 permits had been issued and about 17 more still
    needed to be issued. Because some permits cover more than one

    municipality, these permits cover about 1, 000 medium and large
    municipalities nationwide. The final rule for Phase II of the program was
    issued in December 1999.

    Phase II extends Phase I efforts by requiring that a storm water discharge
    permit be obtained by (1) operators of all MS4s not already covered by Phase
    I of the program in urbanized areas 5 and (2) construction sites that
    disturb areas equal to or greater than 1 acre and less than 5 acres of land.

    As with Phase I of the program, permitting authorities may require
    additional small MS4s and construction sites to obtain a permit if they are
    a significant contributor of pollutants. Currently, EPA anticipates that
    about 5,000 municipalities may be subject to permitting requirements under

    Phase II of the storm water program. These municipalities are required to
    obtain permits no later than March 10, 2003.

    5 The Bureau of the Census generally defines an urbanized area as a land
    area comprising one or more places- central place( s)- and the adjacent
    densely settled surrounding area- urban fringe- that together have a
    residential population of at least 50, 000 and an overall population density
    of at least 1,000 per square mile.

    EPA also regulates combined sewer overflows (CSO) that can be caused by
    urban storm water runoff. Combined sewer systems, in which storm water
    enters pipes already carrying sewage, may overflow when rain or snowmelt
    entering the system exceeds the system?s flow capacity. In the CSO that

    results, the mixture of untreated sewage and runoff bypasses the water
    treatment facility and is diverted directly into receiving waters. (See fig.
    1 for an illustration of combined and separate sewer systems.) These
    combined systems generally serve the older parts of approximately 900 cities
    in the United States. Pipes carrying sewage and storm water separately
    generally serve newer parts of cities. EPA?s 1994 CSO policy requires
    communities with combined sewer systems to take immediate and

    long- term actions to address CSO problems. The policy contains provisions
    for developing appropriate, site- specific NPDES permit requirements for all
    combined sewer systems that overflow because of wetweather events. The Wet
    Weather Water Quality Act of 2000 requires that any permit, order, or decree
    issued for a CSO conform to the 1994 policy. Under this act, EPA is also
    required to submit a report to the Congress by September 2001 on the status
    of the program. 6

    6 Sanitary sewer overflows, which are illegal under the Clean Water Act, can
    also result from rainfall. A sanitary sewer overflow may occur when
    rainwater or snowmelt leaks into sanitary sewage pipes, thereby exceeding
    the pipes? capacity and causing them to overflow. This discharge of raw
    sewage from municipal sanitary sewer systems can release untreated sewage
    into places such as streams, basements, and streets. EPA proposed
    regulations to require municipalities to reduce the number of overflows.
    However, these regulations have been withdrawn for further review.

    Figure 1: Urban Runoff Flows in Different Types of Sewer Systems Combined
    Sewer System

    Sanitary wastewater Storm water Storm Storm drain

    drain Snowmelt Sanitary wastewater

    Wastewater treatment plant Fully treated Combined effluent sewer overflow
    Sanitary sewage/ wastewater Storm water runoff with potential contaminants

    Separate Sanitary Separate Storm

    Sewer System Sewer System Storm

    drain Sanitary wastewater

    Storm drain Storm

    Sanitary wastewater drain

    Storm water

    Erosion Storm water

    point source Lawn Care

    Nonpoint source pollution

    Source: GAO illustration based on EPA data.

    The Total Maximum Daily Load (TMDL) Program, established under the Clean
    Water Act, is intended to address water bodies that do not meet water
    quality standards because of pollutant loadings from point and nonpoint
    sources. Currently, it is unclear how and when this program will affect
    EPA?s and states? issuance of storm water permits. A TMDL is a calculation
    of the maximum amount of a pollutant that a body of water can receive and
    still meet the water quality standard set by the state. Under EPA?s
    regulations, the state is to allocate this ?pollutant load? among the point
    and nonpoint pollutant sources that flow into the water body and then take
    steps to ensure that no source exceeds its assigned load. In 1996,

    EPA issued a policy that outlined an interim approach to including water
    quality standards in storm water permits. The policy promoted the use of
    BMPs in the first 5- year term permits, followed by a tailoring of BMPs in
    the second round of permits as necessary to comply with water quality
    standards. Until recently, few TMDLs had been established, and citizen
    organizations sued EPA for its lack of action. EPA issued a new set of
    regulations for the TMDL Program in 2000, but the Congress prevented

    EPA from spending money to implement the rule in 2000 and 2001. It is
    possible that establishing a TMDL for a body of water could result in the
    application of a numeric effluent limit to outfalls 7 that release storm
    water into that body of water. Some city officials we spoke with generally
    felt that numeric effluent limits would significantly increase the cost of
    managing storm water.

    Volume of Urban Since World War II, urban runoff has increased throughout
    the United Runoff Increases With

    States. This increase is directly related to growth in the amount of
    impervious surfaces due to urban and suburban development and the the
    Expansion of

    construction of roads, highways, and other impervious surfaces. Urban
    Development

    Coinciding with this growth in impervious surfaces has been a reduction in
    and Can Affect Water wetlands and in the amount of storm water that
    infiltrates the ground to recharge aquifers. Moreover, the loss of
    vegetation due to development

    Quality and related runoff can cause major erosion. Ultimately, much of this
    runoff

    is channeled into gutters, storm drains, and paved channels, and vegetation
    and sediment removed with the runoff may end up in receiving waters. EPA has
    identified urban storm water runoff as one of the leading sources of
    pollution to the nation?s rivers, streams, lakes, and estuaries. Runoff from
    impervious surfaces picks up potentially harmful pollutants and

    7 An outfall is an outlet, such as a pipe, that allows storm water to flow
    into a river, lake, or other body of water.

    carries them into receiving waters. Studies have shown that urban runoff and
    the pollutants it carries can negatively affect water quality, aquatic life,
    and public health.

    Paved Surfaces Have According to the U. S. Department of Agriculture,
    between 1945 and 1997, Increased With Urban and

    urban land area increased by almost 327 percent, from 15 million acres to
    Suburban Expansion and

    about 64 million acres in the contiguous 48 states. From 1992 through 1997,
    Growth in Automobile Use the annual rate of development averaged about 1
    million acres per year.

    The land developed between 1945 and 1997 came primarily from forestland and
    pasture and range. 8 For example, according to the Bureau of the Census,
    between 1960 and 1990, the amount of land used for urban

    purposes in Baltimore, Maryland, and Washington, D. C., grew by about 170
    percent and 177 percent, respectively. As a result, urbanization, with its
    accompanying expansion of impervious surfaces like sidewalks , roofs,
    parking lots, and roads, has significantly increased the nation?s total
    developed land and paved surface area. 9 Figure 2 demonstrates the growth in
    the urbanized areas of Baltimore and Washington, D. C., over the last half
    of the 20 th century. 8 Agricultural Resources and Environmental Indicators,
    2000, U. S. Department of Agriculture, Economic Research Service, Resource
    Economics Division. 9 Our Built and Natural Environments, A Technical Review
    of the Interaction Between Land Use, Transportation and Environmental
    Quality, U. S. Environmental Protection Agency (EPA 231- R- 00- 005, Nov.
    2000).

    Figure 2: Increase in Urbanized Land in Selected Cities, 1960- 90

    Source: U. S. Geological Survey.

    The increase in paved surfaces has been spurred not only by urban and
    suburban development, but also by a steady increase in the use of
    automobiles, the primary mode of daily transportation for most Americans.
    Roads also play an important role in the economy of the United States,

    since trucks carry about 75 percent of the value of all goods shipped.
    According to EPA, paved road mileage in the United States increased by 278
    percent from 1945 to 1997. In 1945, 19 percent of the public roads in the
    country were paved; by 1997, that percentage had increased to 61. (See

    fig. 3.) According to a 1999 study, motor- vehicle infrastructure, such as
    roads and parking lots, accounts for close to half of the land area in U. S.
    urban cities. 10 10 Stormwater Strategies, Community Responses to Runoff
    Pollution, Natural Resources

    Defense Council (May 1999).

    Figure 3: Percentage of Paved Public Road Miles, 1945- 97 Percent

    70 60 50 40 30

    A 20

    10 0

    1945 1955 1965 1975 1985 1997 Source: EPA.

    Increase in Impervious The increase in impervious surfaces over the past
    several decades has led

    Surfaces Leads to Increased to an increase in storm water runoff. In part,
    this has occurred because Runoff

    highways and other developments have reduced the amount of wetlands and
    other undeveloped land. Wetlands mitigate the effects of storm water runoff
    by acting as a natural form of flood control, facilitating sediment
    replenishment, and improving water quality by removing excess nutrients and
    other chemical contaminants before the contaminants can affect receiving
    waters. According to a 2000 EPA report, 11 of the 12 states that listed
    wetland losses, six reported that they had significant losses due to highway
    construction, and 10 reported that they had significant losses due to
    residential growth and development. However, the effect of road building on
    wetland loss has been reduced in recent years. According to a

    Federal Highway Administration (FHWA) official, since 1996, wetlands have
    been replaced and restored under the Federal- Aid Highway Program 11 See
    footnote 9.

    at an average rate of 2. 7 acres for every acre lost to highway building.
    Other undeveloped land with vegetation also performs some of the roles that
    wetlands play in managing runoff, although to a lesser extent.

    Furthermore, as impervious surfaces increase, less storm water is able to
    infiltrate through the soil to groundwater. Impervious areas allow only a
    very small amount of initial infiltration compared with unpaved areas whose
    infiltration capacity varies, depending on the soil type. Figure 4
    demonstrates EPA?s estimates of the impact of impervious surfaces on the
    percentages of storm water that runs off, infiltrates the ground, and is
    lost through evapotranspiration. 12 When natural ground cover is present
    over an entire site, normally 10 percent of precipitation runs off the land
    into

    nearby creeks, rivers, and lakes. In contrast, when a site is 75- to
    100percent impervious, 55 percent of the precipitation runs off into these
    receiving waters. However, according to an FHWA official, the runoff rates
    can be reduced if developers take mitigating actions to develop and
    implement BMPs to control flooding or runoff.

    12 Evapotranspiration represents water loss from evaporation and the
    absorption and eventual release into the atmosphere of water that plants and
    trees have collected. The extent to which evapotranspiration occurs is
    dependent primarily on the solar energy available to vaporize the water. As
    a result, the effect of evapotranspiration varies greatly across the
    country.

    Figure 4: Impact of Impervious Surfaces on the Amount of Storm Water That
    Runs Off, Infiltrates, and Evapotranspires

    Source: EPA.

    The decrease in storm water infiltration that accompanies urbanization also
    reduces the amount of water that is available to recharge groundwater
    supplies. For this reason, reduced infiltration may lead to problems with
    the water table in certain urban areas. For example, a Massachusetts

    Department of Environmental Protection official noted that a low recharge
    rate affects water quality because it can result in a loss of wetlands and
    adversely affect aquatic habitat as water- table levels fall during dry
    weather. 13 In addition, officials from the Charles River Watershed
    Association in Massachusetts are concerned that the lack of infiltration

    might cause some communities to run short of drinking water in the next 20
    years. Urban Runoff Has the

    Urban runoff can adversely affect the quality of the nation?s waters, and
    Potential to Impair Water

    urban storm water runoff has been identified as one of the leading sources
    of pollution to rivers, streams, lakes, and estuaries. 14 Section 305( b) of
    the Quality and Disrupt

    Clean Water Act requires states and other jurisdictions to report on the
    Biological Integrity

    quality of their waters to EPA every 2 years. The 1998 National Water
    Quality Inventory Report to Congress showed that 35 percent of assessed
    river and stream miles, 45 percent of assessed lake acres, and 44 percent of
    assessed estuarine square miles were impaired in terms of their ability to
    support uses such as aquatic life, swimming, and fish consumption. 15 The

    report identified urban storm water runoff as one of the leading sources of
    impairment to the assessed waters. 13 Dry weather is defined as a period
    when rainfall measuring at least 0.10 of an inch has not occurred for 72
    hours. 14 Other leading sources of pollution include agricultural runoff,
    municipal point sources, hydrologic modifications, and atmospheric
    deposition.

    15 Information contained in the 1998 report reflects only those waters
    assessed by states and other jurisdictions and cannot be used to
    characterize nationwide water quality. Furthermore, water quality standards
    among states are not identical, and the monitoring design used to collect
    data differed among states.

    Studies have shown that as the percentage of impervious cover increases
    within a watershed, biodiversity also declines. Research conducted by the
    Center for Watershed Protection found that, generally speaking, when a
    watershed has 10 percent or less impervious cover, the associated stream can
    be categorized as sensitive. 16 Sensitive streams are characterized as
    having high fish diversity and good water quality. Once the percentage of
    impervious cover exceeds 25 to 30 percent of the watershed, however,

    streams tend to become nonsupporting. Nonsupporting streams are highly
    unstable, have poor diversity of fish and aquatic life, and have poor water
    quality. For example, one study evaluated the relationship between the
    extent of impervious cover in watersheds to the number and diversity of fish
    populations in 47 small streams in southeastern Wisconsin between the 1970s
    and 1990s. 17 The results revealed that the number of fish species per site
    was highly variable for drainage areas that had less than 10- percent
    imperviousness. In contrast, sites that had greater than 10- percent

    imperviousness had consistently low numbers of fish species. Other studies
    have associated urban runoff with basic changes in the receiving body of
    water. Runoff can carry sediment into surface water, and this sediment can
    carry contaminants, harm aquatic plants, and smother organisms. Runoff can
    also be warmed by the impervious surfaces it flows across. When sufficient
    amounts of warmed runoff enter a water body, the

    water temperature can rise. Less oxygen is then available for aquatic
    organisms because water holds less oxygen as it becomes warmer. These
    combined factors lead to the degradation of aquatic habitat. According to
    EPA, the common effects of these types of pollution on aquatic life include
    a decline in biodiversity and an increase in invasive species.

    An increase in the volume of storm water runoff also increases the
    likelihood of erosion, which allows for transport of eroded sediment
    downstream into receiving waters. For example, during a site visit, we

    observed extensive erosion along the Gingerville Creek Subbasin in Anne
    Arundel County, Maryland, that was caused by urban runoff channeled into the
    creek. Figure 5 depicts the eroded banks and channel of this creek.

    16 ?The Importance of Imperviousness,? Watershed Protection Techniques, v.
    1: 3, Fall, 1994. The article reviews 18 studies on the relationship between
    urbanization and stream quality. 17 L. Wang and others, ?Watershed
    Urbanization and Changes in Fish Communities in

    Southeastern Wisconsin Streams,? Journal of the American Water Resources
    Association, Oct. 2000, Vol. 36, No. 5.

    Figure 5: Damage Caused by Storm Water Runoff From Urbanized Areas in the
    Gingerville Creek Subbasin

    Source: Anne Arundel County, Maryland, Department of Public Works.

    Contaminants in Urban There have been several efforts to characterize the
    chemicals and other

    Runoff Can Affect Aquatic constituents in urban runoff. The Nationwide Urban
    Runoff Program,

    Life and Human Health conducted by EPA between 1978 and 1983, examined the
    characteristics of urban runoff. Another federal effort to characterize
    urban runoff is an ongoing joint project of the U. S. Geological Survey
    (USGS) and the FHWA to evaluate guidelines for highway runoff. As table 1
    indicates, these studies and others have shown that the principal
    contaminants found in

    urban runoff include nutrients, solids, pathogens, metals, hydrocarbons,
    organics, salt, and trash. Water flowing over various surfaces, such as
    streets, parking lots, construction sites, industrial facilities, rooftops,
    and lawns, carries these pollutants to receiving waters . The contaminants
    have the potential to impair water quality, degrade aquatic ecosystems, and
    pose health risks to swimmers.

    Table 1: Storm Water Pollutants in Urban Runoff, Including Sources and
    Potential Impacts Contaminant Source Potential impact Nutrients

    Nitrogen, Animal waste, fertilizers, failing septic systems, Nutrient
    enrichment can cause an excessive growth of

    phosphorous atmospheric deposition, a CSOs algae. Nuisance levels of algae
    are associated with dissolved oxygen deficiencies leading to fish kills,
    loss of submerged aquatic vegetation that serves as a habitat for aquatic
    organisms, and loss of natural biodiversity.

    Solids

    Sediment Construction sites, other disturbed and/ or Sediment can cause
    infection and disease among fish,

    nonvegetated lands, eroding banks, road sanding scour submerged aquatic
    vegetation, prevent sunlight from reaching aquatic plants, and bury bottom-
    dwelling aquatic organisms. Pathogens

    Bacteria, viruses Animal waste, failing septic systems, illicit Pathogens
    entering waters used for recreational purposes

    connections and discharges to storm sewer can pose human health risks.

    system, CSOs

    Metals

    Lead, cadmium, Industrial processes, normal wear of automobile Metals can
    cause acute or chronic toxicity for aquatic

    copper, zinc, mercury, brake linings and tires, automobile emissions,
    organisms. chromium, aluminum,

    automobile fluid leaks, metal roofs and others

    Hydrocarbons

    Oil and grease, Industrial processes, automobile wear, automobile
    Hydrocarbons have the potential to be acutely toxic for

    polycyclic aromatic emissions, automobile fluid leaks, waste oil aquatic
    organisms and several are suspected carcinogens. hydrocarbons Organics

    Pesticides, Pesticides (herbicides, insecticides, fungicides,

    Low concentrations of some organics have the potential to polychlorinated

    rodenticides, etc.), industrial processes bioaccumulate in the food chain.
    biphenyls (PCB), synthetic chemicals

    (Continued From Previous Page)

    Contaminant Source Potential impact Salt

    Sodium Road salting and uncovered salt storage Salt can damage roadside
    vegetation, transport high levels Chlorides of chlorides to receiving
    waters, and degrade aquatic ecosystems. Chloride can be harmful to some
    species of fish.

    Trash

    Street refuse and improperly discarded waste Trash impairs water quality by
    inhibiting the growth of material aquatic vegetation and conveys nutrients,
    toxic substances,

    and other pollutants to aquatic ecosystems. a Atmospheric deposition occurs
    when pollutants in the air fall on land or water.

    Sources: Massachusetts Department of Environmental Protection Stormwater
    Policy; EPA reports and guidance, including Preliminary Data Summary of
    Urban Storm Water Best Management Practices, Combined Sewer Overflow Control
    Policy, Innovative Urban Wet- Weather Flow Management Systems,

    and the 1998 National Water Quality Inventory Report to Congress; the
    California Regional Water Quality Control Board; the Natural Resources
    Defense Council?s Stormwater Strategies: Community Responses to Runoff
    Pollution; ?Accretion of Pollutants in Roadway Snow Exposed to Urban Traffic

    and Winter Storm Maintenance Activities - Part I,? Draft; 18 and USGS?
    National Water Quality Assessment Program.

    18 J. J. Sansalone and D. W. Glenn, ?Accretion of Pollutants in Roadway Snow
    Exposed to Urban Traffic and Winter Storm Maintenance Activities Part I,?
    DRAFT.

    In our visits to cities with Phase I permits and their watersheds, we
    identified specific instances in which these contaminants had affected water
    quality. The Chesapeake Bay, for example, has been polluted with the
    nutrients nitrogen and phosphorus and with excess sediment caused, in part,
    by urban runoff. The excess nutrients cause algae blooms that block

    sunlight from reaching bay grasses- which are a source of food, shelter, and
    nursery grounds for many aquatic species. In an effort to control nutrient
    pollution in the Chesapeake Bay, the Executive Council of the Chesapeake Bay
    Program 19 established a goal to reduce the nitrogen and phosphorus entering
    the Chesapeake Bay by 40 percent, including through control of runoff from
    urban areas. In addition, an assessment of the status of chemical
    contaminant effects on living resources in the bay?s tidal rivers found ?hot
    spots? of contaminated sediment. As a result, the Baltimore Harbor and the
    Patapsco River in Maryland; the Anacostia River in Washington, D. C.; and
    the Elizabeth River in Virginia were designated as

    ?regions of concern.? Urban storm water runoff is a significant source of
    contaminants in the three regions. The Chesapeake Executive Council has
    committed to reduce by 30 percent the chemicals of concern in the regions of
    concern by 2010 through pollution prevention measures and other voluntary
    means. 20

    Pathogens such as bacteria and viruses, which are often present in urban
    runoff, can pose public health problems. For example, the Santa Monica Bay
    Restoration Project conducted a study to identify adverse health effects of
    untreated urban runoff by surveying over 13,000 swimmers at three bay
    beaches. 21 The study established a positive association between

    an increased risk of illness and swimming near flowing storm- drain outlets.
    Table 2 explains health outcome measures at various distances from storm
    drains. For example, the study found a 1- in- 14 chance of fever for
    swimmers in front of the drain versus a 1- in- 22 chance at 400 or more
    yards away.

    19 The Chesapeake Executive Council includes the governors of Maryland,
    Pennsylvania, and Virginia; the Administrator of the U. S. Environmental
    Protection Agency; the mayor of the District of Columbia; and the chair of
    the Chesapeake Bay Commission.

    20 Chesapeake Bay Program Office, Toxics 2000 Strategy: A Chesapeake Bay
    Watershed Strategy for Chemical Contaminant Reduction, Prevention, and
    Assessment, Dec. 2000. 21 R. W. Haile and others, ?The Health Effects of
    Swimming in Ocean Water Contaminated by Storm Drain Runoff,? Epidemiology,
    July 1999, Vol. 10, No. 4.

    Table 2: Comparative Health Outcomes for Swimming in Front of Drains Versus
    400 or More Yards Away

    400 or Health outcomes 0 yards more yards

    Fever 1: 14 1: 22 Chills 1: 26 1: 42 Ear discharge 1: 68 1: 143 Coughing
    with phlegm 1: 20 1: 33 Significant respiratory disease (fever and

    1: 12 1: 22 nasal congestion, fever and sore throat, and cough with phlegm)

    Note: This table includes the statistically significant health outcomes.
    Source: GAO analysis of data from ?The Health Effects of Swimming in Ocean
    Water Contaminated by Storm Drain Runoff,? Epidemiology, July 1999, Vol. 10,
    No. 4.

    Metals and polycyclic aromatic hydrocarbons (PAH) in urban runoff can
    present a threat to aquatic life. Studies have found the following:

     Storm water runoff from an urban area proved to be toxic to sea urchin
    fertilization in the Santa Monica Bay, and dissolved zinc and copper were
    determined to be contributors to this toxicity. 22  Brown bullheads (a
    bottom- dwelling catfish) in the Anacostia River developed tumors that were
    believed to be caused by PAHs associated in part with urban runoff. 23
    High PAH and heavy metal concentrations were found in crayfish tissue

    samples from several urban streams in Milwaukee. The study associated these
    contaminants with storm water runoff. 24

    22 Southern California Coastal Water Research Project, Study of the Impact
    of Stormwater Discharge on Santa Monica Bay Executive Summary, Nov. 1, 1999.
    23 Chesapeake Bay Program Office. 24 J. P. Masterson and R. T. Bannerman,
    ?Impacts of Stormwater Runoff on Urban Streams in Milwaukee County,
    Wisconsin,? National Symposium on Water Quality, American Water Resources
    Association, Nov. 1994.

    In addition, USGS tracked trends in the concentrations of PAHs found in
    sediment in 10 lakes and reservoirs in six metropolitan areas over the last
    several decades. This study found that PAH concentrations in developed
    watersheds are increasing and that these increases may be linked to the
    amount of urban development and vehicle traffic in urban and suburban

    areas. 25 For example, from 1982 to 1996, PAH concentrations in the sediment
    core in Town Lake (Austin, Texas) and total miles driven in greater Austin
    both increased by about 2.5 times. Figure 6 illustrates this correlation.
    Figure 6: Comparison of Town Lake PAHs and Traffic Trends

    Total miles driven on PAHs detected in sampled core sediments

    Austin roads (micrograms per kilogram)

    (in thousands)

    12, 000 14, 000

    10, 000 12, 000

    10, 000 8,000

    A 8,000

    6,000 6,000

    4,000 4,000

    2,000 2,000

    0 0 1960

    1962 1963

    1964 1966

    1972 1978

    1982 1984

    1986 1990

    1992 1994

    1995 1996

    1997 1998

    Date

    Note: According to USGS, irregularities in the date pattern are due to
    intervals at which sediment samples were collected. Source: USGS National
    Water Quality Assessment Reconstructed Trends Program.

    25 P. Van Metre, B. Mahler, and E. Furlong, ?Urban Sprawl Leaves Its PAH
    Signature,? Environmental Science and Technology, Vol. 34, No. 19, 2000.

    Although the studies we reviewed show that certain contaminants are likely
    to be present in urban runoff, factors such as land development practices,
    climate conditions, atmospheric deposition, and traffic characteristics all
    can affect the characteristics of runoff from a particular area. Therefore,
    given the diffuse nature of many storm water discharges and the variability
    of other contributing factors, characterizing the

    concentrations of pollutants contained in storm water runoff has been
    challenging. Recent USGS reports also suggest that improvements are needed
    in the methods used to analyze sediment and metals in runoff. 26 Local
    Governments

    To comply with federal and state storm water management for Phase I Take
    Actions to

    permitting requirements, permitted municipalities must create and implement
    storm water management programs. The three primary Manage Urban Storm

    activities used in these programs include efforts to characterize storm
    Water Runoff, but

    water runoff; BMPs aimed at reducing pollutants in storm water runoff to
    Information Is Limited the maximum extent practicable; and reporting program
    activities, monitoring results, and costs of implementing the program. Some
    BMPs on the Cost and are structural- meaning that they are designed to trap
    and detain runoff

    Effectiveness of These until constituents settle or are filtered out. Other
    BMPs are nonstructural- meaning that they are designed to prevent
    contaminants Actions

    from entering storm water through actions like street sweeping and
    inspections. Many permitted municipalities use specialized BMPs tailored to
    address particular runoff problems in their locations. Over 1,000 cities are
    undertaking these efforts under the NPDES Storm Water Program, but
    information on the overall costs of managing urban runoff and the
    effectiveness of the actions taken is limited. EPA?s attempts to forecast
    costs have not encompassed the entire program or are out of date. In
    addition, the permitted municipal agencies we visited estimated their

    annual storm water management costs and reported them to state agencies or
    EPA, but the approaches they used to calculate these estimates varied
    considerably, making it difficult to draw any conclusions. Although EPA and
    state agencies believe that the program will be effective in improving water
    quality, EPA has not made a systematic effort to evaluate the

    program. Without such an effort, EPA cannot tell what effect the program is
    having on water quality nationally.

    26 The USGS reports indicate that certain methods used to analyze sediment
    and metals samples can be unreliable. For example, sample collection and
    processing methods can have an effect on measured concentrations of metals.

    Municipalities Comply With The NPDES Storm Water Program requires
    municipalities operating under

    Federal and State a Phase I MS4 permit to characterize and monitor storm
    water runoff,

    Requirements Through implement BMPs to reduce pollutants to the maximum
    extent practicable, Monitoring, Best

    and report costs and monitoring results to the permitting authorities.
    Because of these requirements, local governments have generally shifted
    Management Practices, and

    the focus of their storm water management from water quantity control or
    Reporting

    flood management to water quality concerns. Besides following the basic
    federal requirements, municipalities must follow any additional regulations
    developed by states that have been delegated the authority to manage the
    NPDES Storm Water Program. For example, Wisconsin?s Department of Natural
    Resources broadened the

    requirements for determining which municipalities must get permits. The
    state requires local governments with storm sewer systems in priority
    watersheds (based on the significance of storm water runoff as a pollutant
    source) that serve a populace of 50,000 or more 27 to obtain a permit with
    requirements similar to those for a Phase I permit. Wisconsin?s Department
    of Natural Resources also requires municipalities that are located in one of
    the state?s five Great Lakes Areas of Concern 28 to obtain a state permit.
    Furthermore, in line with specific criteria in Wisconsin?s Administrative
    Code, the state requires other municipalities to obtain a permit if the

    municipality is found to significantly contribute storm water pollutants to
    waters of the state. These various requirements increased the number of
    municipalities that must get permits from the two under federal requirements
    to over 70 under the states? requirements.

    The local governments we reviewed were undertaking three primary activities
    when applying for permits and implementing their storm water management
    programs. Specifically, these activities were (1) characterizing storm water
    runoff; (2) developing BMPs to reduce discharges of pollutants to the
    maximum extent practicable; and (3) reporting program activities, monitoring
    results, and reporting program

    costs. First, to characterize runoff, applicants are to provide quantitative
    data that describe the volume and quality of discharges from municipal storm

    27 For example, we visited West Allis, Wisconsin, which has a permit even
    though its population is under 100,000. 28 Areas of concern have persistent
    water quality problems, which impair beneficial uses.

    sewers. For example, cities must map all storm sewer outfalls- an
    undertaking that one group representing cities described as significant.
    After the permit application is approved, additional monitoring is required
    throughout the life of the permit to facilitate the design of effective
    storm water management programs and to document the nature of the storm
    water. The local governments we visited were all monitoring for a variety of
    purposes, including characterizing runoff from different types of land

    use in order to target their BMPs, testing the effectiveness of a particular
    BMP, or establishing a baseline for their storm water quality evaluations.

    Second, the storm water management programs that local governments develop
    focus on implementing BMPs. While active treatment, such as sending storm
    water through a treatment facility, is a possible BMP, the cities we visited
    were generally not using active treatment. EPA?s February 2000 report 29 on
    the Phase I program described the program as based on the ?use of low- cost,
    common- sense solutions.? The five cities we visited were generally using
    similar types of structural and nonstructural BMPs, as follows:  Structural
    BMPs are designed to separate contaminants from storm

    water. For example, detention ponds temporarily hold storm water runoff to
    allow solids and other constituents in the runoff to settle before the water
    is released at a predetermined rate into receiving waters. In addition,
    catch- basin inserts, placed in a storm drain, catch trash and other debris,
    and particle separators, placed beneath the surface of an impervious area
    such as a parking lot, separate oils from runoff and allow sediment and
    debris to settle. Structural devices such as these require regular
    maintenance to function properly and remain effective.  Nonstructural BMPs
    are primarily designed to minimize the

    contaminants that enter storm water. These nonstructural BMPs include
    ?good housekeeping? practices by the local government, such as oil
    collection and recycling, spill response, household and hazardous

    waste collection, pesticide controls, flood control management, and street
    sweeping; 29 Report to Congress on the Phase I Storm Water Regulations, U.
    S. Environmental Protection Agency, February 2000. This report includes
    information on the program for local governments, industries, and
    construction sites.

     public education programs, such as storm- drain stenciling, to remind the
    public that trash, motor oil, and other pollutants thrown into storm drains
    end up in nearby receiving waters; 30

     new ordinances to control pollution sources, such as prohibiting the
    disposal of lawn clippings in storm drains and requiring pet owners to clean
    up after their pets; 31  requirements that developers comply with storm
    water regulations

    and incorporate erosion and sediment controls at all new development sites;
     requirements that runoff from properties owned or activities

    sponsored by the municipality be properly controlled; and  efforts to
    identify and eliminate illicit connections and illegal

    discharges to the storm sewer systems, such as those from pipes carrying
    sewage.

    We found that the NPDES Program?s requirements allowed local governments to
    tailor their storm water management efforts to prioritize local concerns,
    such as a particular type of contaminant, a particular climatic condition,
    or a particular body of water. Some cities also

    developed specialized BMPs to address these concerns. The following
    information highlights specific storm water- related concerns in the five
    cities we visited and the specialized BMPs these municipalities have
    developed to address these particular concerns. (See apps. I to V for
    additional information on these cities? storm water management programs.)

    30 Other public education programs we observed included in- school education
    programs, partnerships with grassroots organizations concerned with water
    quality issues, and the identification of commercial businesses and
    industries to educate owners on methods to control storm water runoff.

    31 According to Worcester, Massachusetts? April 2000 City of Worcester DPW
    Stormwater Management Program Annual Report, the city has proposed
    ordinances that prohibit the disposal of lawn clippings and other yard waste
    in catch basins and that require pet owners to clean up after their pets. As
    of April 2001, neither ordinance had been implemented.

    In Baltimore, Maryland, excessive levels of nutrients, particularly
    phosphorus and nitrogen, are among the city?s major water quality concerns
    because of the city?s participation in the Chesapeake Bay Program. Baltimore
    City agreed to assist the state in reaching the Chesapeake Bay Program?s
    goal to reduce nutrients discharged to the bay by 40 percent by the year
    2000. According to a Chesapeake Bay Program Office representative, 32 as of
    March 2001, the program has not met this goal but expects to reach it within
    the next several years. In Boston, Massachusetts, the Boston Water and
    Sewer Commission,

    which holds the permit for Boston?s storm sewer system, is concerned about
    runoff from roadways, especially runoff containing salt and sand used in the
    winter months and dissolved metals (copper and zinc) from automobiles. In
    September 2000, the commission began a 3- year program to develop and
    implement a citywide catch- basin inspection, cleaning, and preventive
    maintenance program. The program will also include the development of a
    database and map that can be linked to the commission?s Geographic
    Information System.  Los Angeles County, California, is responding to a
    TMDL for trash in

    the Los Angeles River Watershed that will require the county, over a 10year
    period, to eliminate trash in runoff. The county is testing a variety of
    devices that remove trash from runoff and specialized catch- basin devices
    that are designed to prevent trash from ever reaching the storm

    sewers.  Milwaukee, Wisconsin, changed its monitoring and public education

    activities in its recent permit to test the effectiveness of a BMP targeting
    public education efforts to a specific community. The new permit also
    requires a monitoring program aimed at the community, its associated

    watershed, and city employees who work in the area.  Worcester,
    Massachusetts, had a significant problem with illicit

    connections to its storm sewers and with flow in these sewers during dry
    weather. Worcester?s Department of Public Works (DPW) screened 71 of its
    storm water outfalls and determined that 32 of them had drainage areas that
    carried both sanitary sewage and storm drainage in separate conduits through
    common manholes. DPW has retrofitted over 65 percent of the manholes to
    prevent sewage from mixing with storm

    water. 32 The Chesapeake Bay Program Office, U. S. EPA Region III, was
    founded in 1983 with the formation of the Chesapeake Bay Program. The
    program is a voluntary regional partnership that leads and directs
    restoration of the Chesapeake Bay. Members of the Chesapeake Bay Program
    include Maryland, Pennsylvania, Virginia, the District of Columbia, the
    Chesapeake Bay Commission (a tristate legislative body), EPA, and
    participating citizen advisory groups .

    Third, local governments participating in the Phase I program are required
    to report annually to EPA or the state regulatory agency on their storm
    water programs. These reports are to include a status report on the program;
    a summary of data, including monitoring results collected during the
    reporting year; information on annual expenditures on the program and

    a budget for the coming year; and a description of any water quality
    improvements or degradation.

    Information on the Costs of Good information about the cost of implementing
    federal storm water Addressing Storm Water requirements is limited. EPA
    conducted a survey to estimate the nation?s

    Runoff Is Limited future water infrastructure needs over a 20- year period-
    from 1996 to 2016.

    In its 1996 report, 33 EPA estimated that states would require over $50
    billion to meet their current (as of 1996) water infrastructure needs. The
    estimate consists of storm water management needs (at $7.4 billion) and CSO
    needs (at $44.7 billion). 34 EPA noted, however, that estimated storm water
    management needs are likely too low and could increase following an

    analysis of data collected to prepare the agency?s 2000 clean water needs
    survey- to be released in 2002. According to EPA, many cities have
    implemented the Phase I program since EPA reported to the Congress in 1996,
    and municipalities should now be better able to provide documented cost
    data. As a result, EPA will need to rely less on modeled storm water needs
    than it did in the 1996 needs survey. EPA did not project the costs

    and benefits of the program when it was initiated; therefore, no initial
    cost estimates are available. When EPA promulgated the Phase I program
    regulations in 1990, the agency decided that the storm water program did not
    meet the requirements for preparing a benefit/ cost analysis.

    33 1996 Clean Water Needs Survey Report to Congress, U. S. Environmental
    Protection Agency (Sept. 1997). EPA?s estimate represents the estimated
    capital costs for water quality projects eligible for state revolving fund
    support. 34 EPA also estimates that $81.9 billion of its 20- year water
    infrastructure needs cost can be attributed to sanitary sewer overflows.
    These overflows may occur when rainwater or snowmelt leaks into sanitary
    sewage pipes, exceeding the pipes? capacity and causing them to overflow.
    This overflow can release untreated sewage from municipal sanitary sewer
    systems into streams, basements, and streets.

    The costs to local governments of complying with the Phase I program have
    generally been portrayed as high. However, because of inconsistencies in
    cost accounting and reporting practices, we could not determine the cost of
    the program to several of the cities we visited. Although municipalities are
    required to provide information on the expenditures that they anticipate
    will be needed to implement their storm

    water management programs for each fiscal year covered by the permit, EPA
    has not issued any cost reporting guidelines. Consequently, while the
    reported fiscal year 1999 total cost to manage and treat storm water runoff
    across the five municipalities in our review ranged from less than $1
    million (Milwaukee) to $135 million (Los Angeles County), 35 these numbers
    are not comparable because the municipalities did not have consistent cost
    accounting and reporting practices and did not fully express storm water

    management costs. 36 For example, some cities reported only the costs of
    activities that were funded by the city department that held the permit.
    Significant activities funded by other city departments were not reported,
    even if they were important components of the storm water program. Officials
    in the Milwaukee Department of Infrastructure Services and the Boston Water
    and Sewer Commission told us that other city departments perform and fund
    activities such as street sweeping and flood control. The costs of these
    activities are not reported as storm water program costs because the
    activities serve other purposes besides preventing storm water

    pollution. In addition, according to some city officials, these activities
    were in place before the permit was issued and, therefore, cannot be
    characterized solely as storm water costs. The cost of street sweeping can
    be significant- for fiscal year 1999, Baltimore City and Worcester, which
    did include streetsweeping costs in their storm water program?s cost
    estimate, stated that their street- sweeping expenses totaled about $9.5
    million and $1. 2 million,

    respectively. Similarly, Milwaukee did not report the cost of a significant
    project related to storm water runoff because it was mostly funded by the
    state of Wisconsin.

    35 Los Angeles County?s cost was projected by the municipal permit holder
    and represents the cost of the 85 cities covered by the permit. 36 We were
    unable to obtain comprehensive information on the total cost to the Boston
    Water and Sewer Commission of managing storm water, so their fiscal year
    1999 costs could not be included in this range.

    An EPA official told us that the agency had not yet made a national effort
    to analyze the information that Phase I permittees submitted on the costs of
    their storm water programs. This official cited the inconsistent formats of
    the annual reports as a reason that the information was not readily

    available at the national level and also indicated that adequate staff are
    not available to analyze the data. In addition, other EPA officials informed
    us that the Office of Wastewater Management must divide its resources among

    a number of issues that will challenge the agency?s water program over the
    next decade. Several officials in the cities we visited said that their
    annual costs are likely to increase. A number of factors could affect the
    costs. For example, a Baltimore City official explained that the
    anticipated, future program costs depend on several factors, including (1)
    requirements in watershedmanagement plans currently being developed, (2)
    pollution- reduction goals the city will be required to achieve, (3)
    requirements of the state regulatory agency in future permits, and (4)
    requirements the city may have to meet if TMDLs or numeric effluent limits
    are incorporated into NPDES storm

    water permits. Other city officials also expressed concern about the extent
    to which TMDLs could affect their future costs. These city officials are
    concerned that when and if TMDLs are established, their future storm water
    permits may require that storm water runoff meet specific water quality
    standards. For example, Los Angeles County?s trash TMDL could potentially
    drive the county?s storm water management costs upward, and the county
    expects additional TMDLs to be imposed. On the other hand,

    Worcester officials estimated that their future storm water costs would be
    about the same as they were at the time of our review- about $4.5 million
    per year. In a separate analysis, EPA estimated in 1999 that it will cost
    Phase II municipalities about $848 million to $981 million per year (in 1998
    dollars) to manage storm water runoff. Because Phase II permits have not
    been

    issued as of May 2001, we did not gather any cost information on them from
    these cities. Funding for Managing The five cities we visited had not
    generally obtained federal funds for their Storm Water Runoff Is

    storm water management efforts. They used local sources, including Available
    From Local and general revenues, bonds, revenue from specifically created
    storm water

    Federal Sources utilities, state grants, and inspection and permit fees.

    While several sections of the Clean Water Act provide funding that can be
    used for municipal storm water control, relatively few federal funds have
    been directed to these types of projects. The most significant source of
    funds is the state revolving loan funds administered by states. 37 These
    revolving loan funds provide loans for eligible storm water control
    projects. In some cases, nonpoint source projects may also qualify for
    funding when storm water permits are not required or issued. However,
    municipal storm water management is generally a low priority in these

    programs. Specifically, in the year 2000, revolving fund loans were made in
    the ?storm sewers? category in the amount of $38.76 million for 44 different
    projects. These funds represented less than 1 percent of the amounts loaned
    from these revolving funds that year. Activities eligible for revolving fund
    loans include constructing BMPs to control runoff, but support for ongoing
    operations and maintenance is not eligible. Revolving fund loans can also be
    used for eligible CSO control projects. In 2000, Clean Water State Revolving
    Fund Program loans were made in the ?CSO Correction? category of a national
    EPA database in the amount of $411.3

    million for 69 different projects and could have been used for CSO or
    sanitary sewer overflow projects. This amount represented about 9 percent of
    the funds loaned in 2000. According to EPA, the agency also issues grants to
    universities and other research institutions to help implement the storm
    water program. Some of these grants provide training and guidance to Phase I
    permittees on

    watershed protection and the proper selection of BMPs. Other sources of
    funding may be available to local governments beginning in 2002. In December
    2000, the Congress authorized programs for fiscal years 2002 through 2004 to
    provide grants to local governments for (1) pilot projects for managing
    municipal CSOs, sanitary sewer overflows, and storm water discharges on a
    watershed basis and for testing BMPs and (2) controlling pollutants from
    MS4s to demonstrate and determine costeffective,

    innovative technologies for reducing pollutants from storm water discharge.
    EPA?s proposed budget does not request funds for these programs. In
    addition, the Congress authorized programs for fiscal years

    2002 and 2003 to provide grants to local governments for planning,
    designing, and constructing treatment works to intercept, transport, 37
    Under the Clean Water State Revolving Fund Program, the federal government
    provides grants to capitalize states? funds. States provide loans to local
    governments for wastewater projects.

    control, or treat municipal CSOs and sanitary sewer overflows. EPA?s
    proposed budget requested $450 million for this program.

    EPA, States, and Local EPA, state, and municipal officials generally believe
    that the NPDES Storm Governments Believe the Water Program will improve
    water quality. These officials believe that the NPDES Storm Water program
    will result in more bodies of water that meet water quality Program Is
    Effective, but It

    standards, improved aesthetic conditions, reduced risk from bacterial
    contamination, and improvements attributable to the discovery and Has Not
    Been Evaluated management of pollutants in storm water that otherwise would
    have gone unnoticed. EPA attempted to put a dollar value on these benefits
    in its benefit/ cost analysis prepared for the Phase II storm water
    regulations,

    estimating that such benefits could range from $672 million to $1. 1 billion
    per year (in 1998 dollars). 38 However, little information is currently
    available on the benefits of the storm water program or its general
    effectiveness. There is no doubt that it will take time for the results of
    the Phase I program to be demonstrated. As EPA notes in its February 2000
    report to the Congress, pollution control efforts under water quality
    management programs produce long- term

    changes, and the agency expects water quality improvements attributable to
    the Phase I program to become evident in the future, as the program matures.
    In this report, EPA concluded that the program has improved

    storm water management at the local level, improved water quality, and
    decreased pollutant loads in storm water. However, EPA relied on a survey of
    only nine Phase I cities in making these conclusions and, therefore, also

    reported that the agency could not provide national estimates on water
    quality protection and improvements generated by Phase I of the program. To
    evaluate the entire program, EPA would have to establish goals for the

    program that are based on its mission; obtain information about the
    program?s results; compare the results with the goals; and make changes to
    the program, if warranted, to get closer to achieving the agency?s goals.
    EPA and the states also have not taken advantage of information that is

    available to evaluate the program. Each city we visited was regularly
    monitoring its storm water to establish baseline information on pollutant
    levels and was reporting this information to EPA or the regulatory state

    agency each year. Although cities with Phase I permits are required to
    report on their storm water monitoring results and changes in water

    38 Using another method, EPA estimated the benefits at $1. 6 billion per
    year.

    quality, overall, EPA and the states have not successfully developed
    measurable goals for the program or demonstrated its effectiveness through
    the review of municipal reports. An EPA official said that some states had
    requested funding to analyze program data because they did not have the
    resources to do so, and that EPA had provided the funding in a few cases.
    EPA also has not established any guidelines for how these data should be
    reported. Therefore, the reports may be as variable as the cost information
    we obtained in our five site visits.

    EPA has not yet taken any of these data- analysis steps because, according
    to EPA officials, other program challenges within the Office of Wastewater
    Management compete with storm water management efforts for priority. For
    example, EPA officials stressed that available resources within the office
    must address other significant wet- weather pollution problems, such as CSOs
    and sanitary sewer overflows, and nonpoint source pollution

    problems, such as agricultural practices, forestry, and mining. One agency
    official noted that the highest priority is addressing needs that the agency
    and local governments have identified for improving wastewater
    infrastructure, such as sewage treatment facilities. The program also has
    relatively few staff assigned- about five in the headquarters office and
    about 10 in the regional offices- for the municipal, industrial, and

    construction portions of the program. In a program plan recently prepared
    for the storm water program, EPA estimated that nine to 10 staff would be
    needed in EPA headquarters to evaluate the program and implement other

    program requirements. EPA officials described two efforts that may be the
    first steps in developing better information about the program. First, EPA
    intends to issue a grant to the University of Alabama in June 2001 to
    evaluate monitoring data submitted by a sample of municipalities with Phase
    I permits. This effort will (1) determine the different types of monitoring
    being conducted by

    Phase I municipalities, (2) assess water quality in and around permitted
    municipalities and determine any correlation between program implementation
    and impacts on water quality, and (3) recommend approaches for improving the
    effectiveness of municipal storm water monitoring programs. EPA expects the
    results of this study in 2003. Second, an EPA official stated that the
    agency would like to establish a system for analyzing program findings,
    incorporating necessary changes that are based on these findings, and
    evaluating the program?s effectiveness. The agency plans to implement a
    pilot project in 2001 in the agency?s Atlanta Region IV office for analyzing
    data reported in annual

    reports and developing key indicators for the program. If this project is
    successful and resources are available, the project could be expanded.

    Conclusions EPA regards urban runoff as a significant threat to water
    quality across the nation and considers it to be one of the most significant
    reasons that water

    quality standards are not being met nationwide. Prompted by the Congress,
    EPA has responded with a variety of programs, including the NPDES Storm
    Water Program, which requires more than 1, 000 local governments to
    implement storm water management programs. Those municipalities that are
    currently involved in Phase I of the program have been attempting to reduce
    pollutants in storm water runoff for several years. It is time to begin
    evaluating these efforts. However, EPA has not

    established measurable goals for this program. In addition, the agency has
    not attempted to evaluate the effectiveness of this program in reducing
    storm water pollution or to determine its cost. The agency attributes this
    problem to inconsistent data reporting from permitted municipalities,

    insufficient staff resources, and other competing priorities within the
    Office of Wastewater Management. Although Phase I municipalities report
    monitoring and cost data to EPA or state regulatory agencies annually, these
    agencies have not reviewed this information to determine whether it can be
    of use in determining the program?s overall effectiveness or cost.

    Our analysis shows that the reported cost information will be difficult to
    analyze unless EPA and its state partners set guidelines designed to elicit
    more standardized reporting. Better data on costs and program effectiveness
    are needed- especially in light of the Phase II program that will involve
    thousands more municipalities in 2003. EPA?s planned research grant to the
    University of Alabama and its pilot project in the agency?s Region IV to
    analyze data from annual reports and develop baseline indicators is a step
    in the right direction and could point the way for a more

    comprehensive approach. Recommendation To determine the extent to which
    activities undertaken through the NPDES

    Storm Water Program are reducing pollutants in urban runoff and improving
    water quality, and the costs of this program to local governments, we
    recommend that the Administrator, EPA, direct the Assistant Administrator
    for the Office of Water to  establish measurable goals for the program;

     establish guidelines for obtaining consistent and reliable data from local
    governments with Phase I permits, including data on the effects of the
    program and the costs to these governments;  review the data submitted by
    these permittees to determine whether

    program goals are being met and to identify the costs of the program; and
    assess whether the agency has allocated sufficient resources to oversee and
    monitor the program.

    Agency Comments and We provided a draft of this report to EPA and DOT for
    their review and

    Our Evaluation comment. EPA generally agreed with the report and with the
    recommendation, although it did not explicitly comment on all parts of it.

    (EPA?s comments appear in app. VI.) In response to our recommendation that
    EPA set measurable goals for the storm water program, EPA stated that under
    the second phase of the program, local governments will establish their own
    goals. Although this is an important activity, EPA will have difficulty
    evaluating the program?s effectiveness at a national level without setting
    goals that reflect the program?s mission of improving water

    quality. The agency (1) agreed that it should establish guidelines for
    obtaining consistent and reliable data from local governments about their
    programs and (2) plans to award grants to two universities for reviews of
    monitoring data reported by local governments. EPA did not comment on
    whether local governments should report on the costs of their programs. EPA
    also agreed that it and its state partners should review data reported by
    local governments to determine whether the program?s goals are being met. In
    April 2001, EPA officials told us that the agency planned to undertake a
    project in the Region IV (Atlanta) office to evaluate the

    methods local governments are using to control storm water. EPA?s letter
    indicates that the agency now plans to implement this project in three
    regional offices and 10 states. EPA did not comment on the part of our
    recommendation that the agency review the level of resources devoted to
    overseeing and monitoring the program. EPA also provided technical

    comments that we incorporated where appropriate. DOT generally agreed with
    the draft report and provided technical comments that we incorporated where
    appropriate. In particular, DOT suggested that we revise several references
    in the draft report to paved surface area and its relationship to increases
    in urban runoff, to emphasize that impervious surfaces, of which paved
    surfaces are a significant subset, cause increases in runoff. We revised the
    language in these places.

    As agreed with your offices, unless you publicly announce its contents
    earlier, we plan no further distribution of this report until 7 days after
    the date of this report. At that time, we will send copies of this report to
    the Administrator, Environmental Protection Agency, and the Secretary of
    Transportation. We will make copies available to others on request. If you

    or your staff have any questions about this report, please call me at (202)
    512- 2834. Key contributors to this report are listed in appendix VII. Peter
    F. Guerrero

    Director, Physical Infrastructure Issues

    Appendi xes The Storm Water Program in Baltimore City,

    Appendi x I

    Maryland Baltimore City?s municipal separate storm sewer system (MS4) is
    regulated by the Maryland Department of Environment (MDE) and, according to
    a city official, services the entire city. The city is currently
    implementing its second, 5- year National Pollutant Discharge Elimination
    System (NPDES) permit, issued on February 8, 1999. Before obtaining the
    first NPDES

    storm water permit in 1993, Baltimore City addressed the adverse affects of
    storm water runoff by implementing Maryland?s Storm Water Management Program
    and Erosion and Sediment Control Program. According to the 2000 census,
    Baltimore City?s population is about 651, 000. Urban Runoff

    Baltimore City?s urban runoff discharges to four major areas- Gwynns
    Problems in Baltimore Falls, Jones Falls, Herring Run, and the Patapsco
    River- and then ultimately to the Chesapeake Bay. In 1990, the Environmental
    Protection City

    Agency?s (EPA) 319( a) report 1 implicated urban runoff as the main source
    of pollution in these waters. Moreover, Baltimore City was one of the areas
    studied in EPA?s Nationwide Urban Runoff Program in the 1980s. This study
    reported that urban runoff contributed over 60 percent of the total
    nitrogen, phosphorus, and organic carbon; over 70 percent of the chemical
    oxygen demand; and over 80 percent of the total suspended solids, lead,

    and zinc in local water bodies. An MDE official told us that nutrients,
    zinc, and suspended solids are among the constituents most commonly found in
    urban runoff, but the quantitative contribution to water quality impairment
    in the state?s waters was not known. Also, in 1996, the Chesapeake Executive
    Council designated the Baltimore Harbor as one of three toxic regions of
    concern in the Chesapeake Bay. The harbor suffers from sediment contaminated
    by banned substances (such as the termiticide chlordane) and contaminants
    currently being released (such as metals and organics). Furthermore,

    according to the Chesapeake Bay Program Office, data collected from Phase I
    permittees indicate that storm water runoff can be a significant source of
    metals and organics in the harbor. A Baltimore City official told us that
    some portions of Maryland?s waters are impaired because of unacceptable
    levels of nutrients, metals,

    1 Section 319( a) of the Clean Water Act requires, among other things, that
    states identify and report to EPA the navigable waters that cannot
    reasonably be expected to maintain water quality standards (e. g.,
    established water body uses) without additional action to control nonpoint
    source pollution.

    suspended sediments, and chlordane. Moreover, this official noted that the
    state does not consider data that municipalities collect under their NPDES
    storm water permits during the 303( d) listing process. Therefore, he
    believes that streams in Maryland are much more impaired than indicated by
    the listing process. Baltimore City?s Use of Like other NPDES storm water
    permit holders, Baltimore City uses a Best Management

    variety of best management practices (BMP) to reduce the amount of
    pollutants in runoff to the maximum extent practicable. These BMPs Practices

    include detention ponds, shallow marshes (which use the biological and
    naturally occurring chemical processes in water and plants to remove
    pollutants), sand filter devices, public education programs, and the
    identification of illicit discharges to the MS4 system. Furthermore,

    Baltimore City participates in Maryland?s effort to reduce nutrient levels
    in the Chesapeake Bay. Refer to the section of this report describing local
    government efforts to manage storm water for details concerning this
    nutrient- reduction goal. One other BMP includes the following:

     Baltimore City has incorporated the 2000 Maryland Storm Water Design
    Manual?s management policies, principles, methods, and practices into its
    current NPDES storm water discharge permit. The purpose of the design manual
    is to (1) protect the waters of the state from the adverse effects of urban
    storm water runoff; (2) provide design guidance on the most effective
    structural and nonstructural BMPs for

    development sites; and (3) improve the quality of BMPs that are constructed
    in the state, with particular attention to their performance, longevity,
    safety, ease of maintenance, community acceptance, and environmental
    benefit. Costs Associated With

    We were not able to obtain comprehensive information on the total cost to
    Managing Storm Water Baltimore City of managing storm water. Therefore, we
    do not present that information here.

    Funding Sources Baltimore City funds its storm water management control
    efforts with city water and sewer user fees and with state funds.

    The Storm Water Program in Boston,

    Appendi x II

    Massachusetts The Boston Water and Sewer Commission received a NPDES storm
    water permit in October 1999. The commission is a separate entity from the
    city of Boston and, therefore, does not manage some storm water controls
    that are common in Phase I permits, such as street sweeping, winter deicing,
    and many of the urban runoff controls required for new developments. Boston
    has combined sewer systems as well as separate sanitary sewers and storm
    drains. The commission maintains 206 storm water outfalls and

    serves approximately 33 percent of the city through its separate MS4 system.
    In addition to the resident population of about 589,000, this system also
    almost daily serves 340,000 commuting workers; 70, 000 shoppers, tourists,
    and business people; and 75,000 commuting students. The commission?s
    sanitary and combined flows are transported to the

    Massachusetts Water Resources Authority at Deer Island. The commission is
    also the permittee for EPA?s Combined Sewer Overflow Program.

    Urban Runoff The commission considers the identification and elimination of
    illegal Problems in Boston

    sanitary sewer connections as the most effective means of improving water
    quality and protecting public health . It is also concerned with the washoff
    of animal wastes from residential and open land, which is another major
    contributor to the impairment of water quality because it can cause an
    increase in coliform levels in the storm water discharges to the receiving
    waters.

    The commission has contracted for various studies to determine the impact of
    storm water runoff. The following two studies identified sources of
    bacterial contamination and characterized the quality of storm water
    discharged from different types of land uses. The studies included metering
    storm water flows, collecting and analyzing the storm water and receiving
    water quality samples, and identifying and remediating illegal sewer
    connections. Observations from the studies include the following:

     A 1996 study determined that pet waste, rather than sanitary sewage, was a
    key contributor of bacteria to the storm drain system that had possibly led
    to beach closings in the area.  A 1998 study identified several illegal
    connections to the storm drain

    system. Furthermore, the study showed that deicing and sanding efforts
    resulted in levels of sodium, chloride, total dissolved solids, and cyanide
    that exceeded EPA?s acute (high dose) toxicity levels.

    Boston?s Use of Best To meet the NPDES permit?s requirements, the
    commission, like other Management Practices

    permittees, continued BMPs, such as identifying illegal connections, and
    implemented new BMPs aimed at preventing the discharge of pollutants to
    storm drains and receiving waters. Refer to the section of this report

    describing local government efforts to manage storm water for details
    describing the commission?s citywide catch- basin inspection cleaning and
    preventative maintenance program. Other efforts include the following:

     The commission has placed particle separators, which remove oil, grease,
    and sediments from storm water flows, throughout the city. The commission
    requires particle separators to be installed by developers on all newly
    constructed storm drains that serve outdoor parking areas. Fuel- dispensing
    areas not covered by a canopy or other type of roof enclosure must also have
    a particle separator.

     The commission requires developers to consider on- site retention of storm
    water for all new projects, wherever feasible. On- site retention aids in
    controlling the rate, volume, and quality of storm water

    discharged to the commission?s storm drainage system. Costs Associated With

    We were not able to obtain comprehensive information on the total cost to
    Managing Storm Water the commission of managing storm water because the
    commission does not separate the cost of its storm water program from the
    cost of its sewer operations. Therefore, we do not present that information
    here.

    Funding Sources The commission funds its storm water management control
    efforts primarily with city water and sewer user fees and bond proceeds.

    The Storm Water Program in Los Angeles

    Appendi x II I County, California Under the NPDES Storm Water Program, the
    Los Angeles Regional Water Quality Control Board issues 5- year permits to
    Los Angeles County for its municipal storm water program. The Los Angeles
    County permit, issued in July 1996, is the county?s second storm water
    permit. This permit includes Los Angeles County as the principal permittee
    and 85 cities as permittees. According to the 2000 census, Los Angeles
    County?s population is about 9.5 million.

    Urban Runoff The effects of urban runoff on the ocean are of particular
    concern in Problems in Los southern California. Contaminated sediments,
    impaired natural resources, and potential human illness could threaten the
    county?s tourism economy, Angeles County

    estimated to be about $2 billion a year. The following three studies have
    shown that urban runoff can pose health risks to swimmers near storm drains
    and contribute toxic metals to receiving water sediments:  The Santa Monica
    Bay Restoration Project conducted a study to assess the possible adverse
    health effects of swimming in waters contaminated by urban runoff. 1 This
    study revealed that there is an increased risk of illness associated with
    swimming near flowing storm drain outlets and

    an increased risk of illness associated with swimming in areas with high
    concentrations of bacteria indicators. Furthermore, illnesses were reported
    more frequently on days when the samples were positive for enteric viruses.
    Refer to the section of this report describing the effects

    of runoff on aquatic life and human health for more details.  he Southern
    California Coastal Water Research Project coordinated a

    study that assessed microbiological water quality and found that the
    majority of shoreline waters exceeded water quality standards during wet-
    weather conditions. Furthermore, the ocean waters near storm

    water outlets demonstrated the worst water quality regardless of the
    weather. 2  The Southern California Coastal Water Research Project also
    compared the runoff from an urban area and a nonurban area in the Santa
    Monica

    1 R. W. Haile and others, ?The Health Effects of Swimming in Ocean Water
    Contaminated by Storm Drain Runoff,? Epidemiology, July 1999, Vol. 10, No.
    4. 2 Southern California Coastal Water Research Project, Southern California
    Bight 1998 Regional Monitoring Program, Volume 3: Storm Event Shoreline
    Microbiology, 2000.

    Bay Watershed. 3 The results of the study indicated that storm water plumes
    extended up to several miles offshore and persisted for a few days.
    Furthermore, the runoff from the urban area proved to be toxic to sea urchin
    fertilization, and dissolved zinc and copper were determined to be
    contributors to the toxicity. The study also found that in urban areas,
    sediments offshore generally had higher concentrations of contaminants such
    as lead and zinc.

    Los Angeles County?s As in the other sites we visited, the county is
    managing its runoff through

    Use of Best the use of conventional BMPs. These BMPs include the elimination
    of illicit connections and discharges to the storm sewer system,
    construction

    Management Practices control measures, routine inspections, staff training,
    pollution prevention

    plans for public vehicle maintenance and material storage facilities,
    sweeping and cleaning public parking facilities, street sweeping, catchbasin
    cleaning, and public education.

    The Los Angeles Regional Water Quality Control Board recently adopted a
    Total Maximum Daily Load (TMDL) Program to reduce trash loads to the Los
    Angeles River. As a result, the county is exploring a number of trash

    reduction BMPs, which are discussed in the section of this report describing
    local government efforts to manage storm water. Costs Associated With

    Table 3 indicates that the county and the other permittees have allocated
    significant funding for storm water management activities over the years.
    Managing Storm Water

    For example, for fiscal year 1999, 4 projected funding for storm water
    management activities for the county and the other permittees amounted to
    over $134 million. 5 The largest projections for both went toward public
    agency activities. For example, during fiscal year 1999, the principal
    permittee and the permittees together projected almost 67 percent of storm
    water management funds to public agency activities. The activities in this 3
    Southern California Coastal Water Research Project, Study of the Impact of
    Stormwater Discharge on Santa Monica Bay Executive Summary, Nov. 1, 1999.

    4 The county?s fiscal year begins July 1 and ends June 30. 5 According to an
    official with the Los Angeles Regional Water Quality Control Board, this
    figure may also include activities that are outside the scope of the permit
    .

    program include staff training, inspections of construction projects, street
    sweeping, and catch- basin cleaning.

    Table 3: Summary of Fiscal Resources Projected for Los Angeles County and
    Its Co- permittees, Fiscal Years 1997- 99

    (Dollars in thousands) a

    Fiscal year 1997 Fiscal year 1998 Fiscal year 1999 Activity County Others b
    County Others b County Others

    Program $2, 225 $6, 195 $1, 856 $4,874 $1, 466 $6, 187

    Management Illicit 1, 620 3, 515 1,017 3, 075 764 2, 901 Connection, Illicit
    Discharge Program

    Development 784 6, 208 1,300 3, 769 1, 452 5, 743

    planning and construction

    Public agency 38, 544 40, 915 40, 256 31,992 43, 316 46, 657

    activities Public 2, 840 5, 538 4,360 3, 856 4, 629 6, 177 information and
    participation

    Monitoring 2, 018 619 1,768 729 1, 598 737 Other 187 13, 991 490 8, 656
    1,318 11, 834

    Total $48, 218 $76,981 $51, 048 $56,950 $54,543 $80, 237

    a Totals may not add up because of rounding. b Does not include 17
    permittees for fiscal year 1998 and 13 permittees for fiscal year 1997 for
    the following reasons: The permittee operated on a different budget cycle,
    the final document was not available at the time of the annual report, or
    the information submitted by the permittee was not complete.

    Source: GAO?s analysis of cost data provided by the Los Angeles County
    Department of Public Works.

    As shown in table 3, the county maintains primary responsibility for
    monitoring activities, having projected over $2 million for storm water
    monitoring activities in fiscal year 1997, almost $2 million in fiscal year
    1998, and over $1.5 million in fiscal year 1999. Conversely, the permittees?

    projected funding levels for monitoring activities amounted to only $619,000
    in fiscal year 1997, $729,000 in fiscal year 1998, and $737,000 in fiscal
    year 1999. According to an official with the Los Angeles Regional Water
    Quality Control Board, the County has consistently maintained

    primary responsibility for monitoring activities required under the permit.

    Funding Sources The primary source of funds for the county?s storm water
    program is flood control assessments collected throughout the district.
    Although the county has not applied for any state revolving funds, it has
    applied for and received

    approval for federal funds through the Transportation Equity Act for the 21
    st Century (TEA- 21) for a pilot study of an engineering device that would
    remove trash from storm water. Additionally, the county has received partial
    funding through Proposition A of the Safe Neighborhood Parks of 1992 and
    1996 6 for two Vortex Separation Systems- a Continuous

    Deflective Separation unit and a Stormceptor unit. Additionally, the county
    received grant money from the Metropolitan Transit Authority, which
    partially funded catch- basin screens, a Continuous Deflective Separation
    unit, and 120 catch- basin inserts. 7

    6 The Los Angeles County Regional Park and Open Spaces District (a district
    within the Parks Department) received this funding from Proposition A and,
    in turn, made grants to the Los Angeles County Department of Public Works
    for the BMP devices.

    7 The Metropolitan Transit Authority receives TEA- 21 funds from the
    California Department of Transportation.

    The Storm Water Program in Milwaukee,

    Appendi x I V

    Wisconsin The Wisconsin Department of Natural Resources (WDNR) has the
    authority to regulate the discharge of storm water from municipalities,
    construction sites, and industries under Natural Resources Code 216 . This
    rule identifies Wisconsin municipalities that are required to obtain a storm
    water discharge permit under the Wisconsin Pollutant Discharge Elimination
    System (WPDES). Milwaukee completed its application process in 1994, and
    WDNR issued a WPDES permit to the city in October 1994. This was the first
    municipal storm water permit issued to a

    municipality in EPA?s Region 5 covering the midwest. In July 2000, WDNR
    reissued Milwaukee?s storm water permit. According to the 2000 census,
    Milwaukee?s population is about 597,000.

    Urban Runoff Milwaukee has a combined sewer system as well as a separate
    sanitary

    Problems in Milwaukee sewer system. The Milwaukee Metropolitan Sewerage
    District implemented a rehabilitation program that cost over $2 billion to
    reduce the number of combined sewer overflow (CSO) events each year. The

    rehabilitation program involved the construction of deep tunnels to store
    untreated wastewater and rainwater for later treatment at a wastewater
    treatment plant. Since 1996, the deep tunnels have significantly reduced the
    number of overflow events from an average of 50 to 60 per year before

    the construction to an average of two per year afterwards . Urban runoff has
    been identified as a leading source of pollution to the Milwaukee River
    basin?s streams, lakes, and wetlands and the Milwaukee River estuary. To
    address pollution from urban runoff, WDNR issues storm

    water permits to municipalities with MS4s serving areas with populations of
    100, 000 or more, municipalities in Great Lakes ?areas of concern? where
    water quality has been identified as a serious problem, municipalities with
    populations of 50,000 or more that are located in priority watershed

    planning areas, and designated municipalities that contribute to the
    violation of a water- quality standard or are significant contributors of
    pollutants to state waters.

    Milwaukee?s Use of In addition to BMPs such as the elimination of illicit
    connections and

    Best Management discharges to the storm sewer system, the reduction of
    pollutants in storm

    water runoff from construction sites, public education, catch- basin
    Practices cleaning, street sweeping, and the use of detention basins,
    Milwaukee has explored the use of innovative BMPs. Refer to the section of
    this report describing local government efforts to manage storm water for
    more

    details about an educational campaign directed at a specific watershed.
    Additional BMPs include the following:

     An innovative storm water control device was installed in a parking lot at
    a heavily used municipal public works yard that was found to discharge
    significant amounts of storm water pollutants. Termed the Multi- Chambered
    Treatment Tank (MCTT), this device is suitable for areas with limited space,
    cleans up polluted runoff close to its source, removes pollutants that are
    not susceptible to other treatment methods, and is hidden from view. The
    MCTT consists of a catch basin, a settling chamber, and a filter. Although
    the results of the monitoring studies have revealed that the device has a
    positive effect on water quality, officials with the Department of Public
    Works explained that it is costprohibitive

    and suitable only for sites with limited space.  The permittee has also
    been working with WDNR, the Department of Transportation, the U. S.
    Geological Survey, and a neighborhood

    association in a joint effort to develop a storm water monitoring assessment
    program consisting of two innovative storm water treatment devices. One
    device removes grit, contaminated sediments, heavy metals, and oily floating
    pollutants from surface runoff. The other device removes a broad range of
    pollutants from runoff, such as bacteria, heavy metals, nutrients, petroleum
    hydrocarbons, and

    suspended solids. The devices are to be installed along a new reach of the
    Milwaukee Riverwalk through the third ward of Milwaukee. Costs Associated
    With

    Reliable data on the total cost to manage storm water in Milwaukee were
    Managing Storm Water not available and cannot be presented here because
    certain activities are not reported as program costs in the city?s annual
    report. These activities include street sweeping; leaf collection; catch-
    basin and inlet cleaning; maintenance of public boulevards, parks, and
    public green spaces; and the recycling of waste oil and antifreeze.
    Therefore, the program costs reflected in the annual report do not take into
    account many of the nonstructural BMPs employed by the city nor do the
    totals include activities funded through grants. The storm water management
    activities that were included in the city?s 2000 budget request were
    estimated to cost $460,000. Funding Sources Milwaukee?s storm water program
    is primarily funded through the city?s sewer maintenance fund. Unlike the
    general revenue account, which is

    based on property taxes, the sewer maintenance fund is based on water
    consumption. The city has also received supplemental funding from the
    Wisconsin Nonpoint Source Water Pollution Abatement Program in the form of
    WDNR grants. The city has received over $1 million since 1991 for a wide
    variety of storm water management activities.

    The Storm Water Program in Worcester, Appendi x V

    Massachusetts Worcester?s Department of Public Works (DPW) received a NPDES
    permit on November 1, 1998. The Sewer Operations Division, within the DPW,
    is directly responsible for operating and maintaining the city?s separate
    storm sewer system, along with the sanitary and combined sewer system. Since
    1993, the Sewer Operations Division has had a full- time storm water
    coordinator, reflecting Worcester?s increased emphasis on meeting NPDES
    program requirements. Worcester has a population of about 173 , 000. Its
    water system covers an extensive area, including 371 miles of sanitary
    sewers, 340 miles of storm sewers, 56 miles of combined sewers, 27,000

    manholes, over 14,000 catch basins, and 263 outfalls. Worcester?s separate
    storm drain systems consist of 93 main drainage areas covering approximately
    6,680 acres.

    Urban Runoff The constituents that are typically found in urban runoff in
    Worcester are

    Problems in Worcester the same as those normally found in urban runoff in
    older cities. Because virtually all of the paved surfaces in the Worcester
    area are devoted to the

    city?s transportation infrastructure, the constituents generated include
    automobile- related petroleum products, such as total petroleum
    hydrocarbons, oil and grease, along with total suspended solids. Also,
    coliform, silt, and sediment have been identified in the city?s runoff.

    Worcester?s Use of Best Like other permittees, the DPW has implemented BMPs
    under the major

    Management Practices areas of education outreach, pollution prevention and
    source controls,

    storm- drainage system maintenance, regulatory efforts, and storm- drainage
    system infrastructure. Additionally, to reduce storm water pollution , the
    DPW has retrofitted a number of twin manholes in the city as discussed

    below. BMPs that are specific to Worcester include the following:  The DPW
    implemented a demonstration project to determine the effectiveness of an oil
    and grit separator installed on a street drain. The drain is a major surface
    sewer main that services approximately 226 acres of heavily urbanized area
    with a typical mix of residential, commercial, and industrial use. The drain
    discharges into Lake

    Quinsigamond, which is a large lake used for recreational purposes such as
    swimming and boating. In its April 2000 annual plan submitted to EPA, the
    DPW noted that because of drought conditions, it currently did

    not have sufficient sampling data to determine the effectiveness of the
    project.

     The DPW has embarked on a comprehensive program to minimize the
    possibility that sewage and storm water will be mixed in its twin invert
    manholes. Since the program began, the DPW has installed hold- down devices
    on over 1, 680 of the approximately 2, 580 twin invert manholes in the city.
    The DPW expects to continue the program until all of the

    manholes have been retrofitted.  The DPW is also working closely with the
    Massachusetts Department of

    Environmental Protection in its ongoing tracking efforts to ensure that
    industries in Worcester are doing their part to reduce storm water
    pollution.  To improve its storm- drainage infrastructure, the city has
    established a voluntary plan to reduce the number of unpaved private roads.
    The dirt from these roads, especially after rain storms, causes sediment to
    build

    up in the drainage system. The DPW has developed a plan to pave the streets
    at a lower grade than would be necessary to meet the legal requirements for
    a public street. Under this plan, residents would not have to pay the
    additional betterment taxes that are now required to cover the costs of
    sediment removal and less sediment would be

    transported in runoff. Costs Associated With Since 1993, the DPW has
    allocated significant funding from the water and Managing Storm Water

    sewer utility fees it collects for controlling the effects of runoff,
    especially through catch- basin cleaning, street sweeping, and correcting
    illegal connections. For example, its fiscal year 1993 budget for storm
    water programs included about $1.6 million for specific programs and another
    $1 million for capital improvement programs, such as inflow/ infiltration
    and flood control. The DPW also spent $500,000 to develop and submit its
    permit application. Furthermore, as shown in table 4, Worcester made
    extensive capital expenditures during fiscal years 1994 through 1999 on
    pertinent storm water projects to improve the quality of storm water runoff
    emanating from the city?s storm water sewer system.

    Table 4: City of Worcester?s Capital Expenditures for Storm Water Management

    (Dollars in thousands)

    Fiscal year Activity 1994 1995 1996 1997 1998 1999

    Sewer construction $0 $500 $500 $300 $300 $300 Infiltration control 0 400
    400 100 100 100 Pump station

    200 200 200 200 200 200 rehabilitation Sewer rehabilitation 300 750 300 750
    750 1, 500

    Landfill closeout 150 1, 200 200 500 0 0 Belmont Drainage 0 100 600 100 0 0
    project Beaver Brook 0 500 100 100 300 100

    Culvert project Surface drain control 40 150 200 200 200 200 Geographic 0 0
    0 125 125 125 Information System Other 0 70 10 0 0 0

    Total $690 $3,870 $2,510 $2,375 $1,975 $2, 525

    Note: The Belmont Drainage project involved enlarging the drain to eliminate
    surcharging and siltation and moving the outfall to eliminate stagnation.
    The Beaver Brook Culvert project involved repairing the culvert and
    conducting a study that included a detailed hydraulic analysis of the
    drainage basin.

    Source: Worcester Department of Public Works.

    Furthermore, during fiscal year 1999, the DPW spent approximately another
    $2. 1 million to operate and maintain storm water activities. Key
    expenditures included about $1. 2 million for street sweeping, about
    $617,000 for catch- basin maintenance, $52,000 for root control, and another
    $48,000 for street paving. Also included was $40,000 per year for sampling
    five outfalls around the city three times per year as required by the
    permit. According to a DPW official, in previous fiscal years, the DPW
    funded the

    same or similar operation and maintenance activities to help control storm
    water runoff. As a result, the costs since 1994 were similar to those for
    1999, except for annual adjustments for inflation. Therefore, the annual

    operation and maintenance expenditures ranged from about $1.7 million for
    1994 to about $2. 1 million for 1999.

    According to a DPW official, the department expects to spend from $3 million
    to $4. 5 million annually over the next several years on storm water

    related activities. The amount of the cost increase will depend on whether
    EPA asks the city to increase its spending.

    Funding Sources The DPW funds its storm water management controls effort
    from the water and sewer user fees it assesses to homes and businesses.

    Comments From the Environmental

    Appendi x VI Protection Agency

    Appendi x VII

    GAO Contacts and Staff Acknowledgments GAO Contacts Peter Guerrero (202)
    512- 2834 Katherine Siggerud (202) 512- 2834 Staff

    In addition to those named above, Jennifer Clayborne, Richard LaMore,
    Acknowledgments

    Sally Coburn, Elizabeth McNally, Charles Bausell, and Timothy Guinane made
    key contributions to this report. (348248) Lett er

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    GAO United States General Accounting Office

    Page 1 GAO- 01- 679 Water Quality: Urban Runoff Programs

    Contents

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    Page 3 GAO- 01- 679 Water Quality: Urban Runoff Programs United States
    General Accounting Office

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    Appendix I

    Appendix I The Storm Water Program in Baltimore City, Maryland

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    Appendix II

    Appendix II The Storm Water Program in Boston, Massachusetts

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    Appendix III

    Appendix III The Storm Water Program in Los Angeles County, California

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    Appendix III The Storm Water Program in Los Angeles County, California

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    Appendix III The Storm Water Program in Los Angeles County, California

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    Appendix IV

    Appendix IV The Storm Water Program in Milwaukee, Wisconsin

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    Appendix IV The Storm Water Program in Milwaukee, Wisconsin

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    Appendix V

    Appendix V The Storm Water Program in Worcester, Massachusetts

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    Appendix V The Storm Water Program in Worcester, Massachusetts

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    Appendix V The Storm Water Program in Worcester, Massachusetts

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    Appendix VI

    Appendix VI Comments From the Environmental Protection Agency

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    Appendix VI Comments From the Environmental Protection Agency

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    Appendix VII

    United States General Accounting Office Washington, D. C. 20548- 0001

    Official Business Penalty for Private Use $300

    Address Correction Requested Presorted Standard

    Postage & Fees Paid GAO Permit No. GI00
    *** End of document. ***