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NAHB Proposes Alternatives to Limit Storm Water Runoff
To protect the nation’s waterways from storm water runoff and recognizing that most smaller building projects already do an adequate job using current practices, NAHB last week submitted an alternative proposal to the U.S. Environmental Protection Agency effluent limitation guidelines (ELGs) plan, which was published in November.
The EPA is under a court-ordered deadline to finalize ELGs for the construction and development industry by the end of this year.
EPA considered three options for home builders and developers to keep rainwater runoff from construction sites out of nearby water bodies and wetlands:
- Option 1 relies primarily on Best Management Practices (BMPs) that home builders already use — including erosion and sediment control requirements — and also mandates the use of sediment basins for certain sites.
This option recognizes that storm water controls need to be site-specific and that there is no single “one-size-fits-all” approach, NAHB said in a March letter to EPA Administrator Lisa Jackson. “Option 1 would build upon the significant environmental progress made to date by ensuring that all construction sites meet a minimum standard of excellence by adopting those erosion and sediment controls that have evolved and are now accepted across the country,” the letter said.
- Option 2 imposes all of the requirements of Option 1, plus a numeric turbidity limit and sampling and monitoring mandates for sites larger than 30 acres that have high rainfall and high clay content.
This option would be expensive for home building and other industries that disturb land, because the EPA has based its turbidity limit on the use of advanced treatment systems that use costly chemicals to treat and filter storm water discharges. While the EPA estimated that this plan would cost developers about $7,000 an acre, NAHB said the agency’s modeling is flawed and that the actual costs would be closer to $23,000 per acre.
- Option 3 expands the requirements of Option 2 to all construction sites that involve 10 or more “disturbed” acres at one time; this is the most broadly ranging and expensive of the EPA options.
Recognizing wide variations in climate, topography and soil conditions around the country, NAHB’s comments address the different kinds of situations that may confront home builders and recommends that the EPA look at five different categories in its regulation of storm water:
- For small, single lots within a larger development, individual ELGs are not necessary, nor do they make environmental sense, NAHB said. Instead, the EPA should continue to require builders to choose from accepted BMPs to prevent storm water runoff. This approach would provide a comprehensive list of BMPs that would be mandatory for the unique characteristics associated with single-lot building operations.
- Similarly, ELGs are redundant in those states or jurisdictions where Low Impact Development (LID) techniques are already mandated. Sites that are already meeting LID requirements should be exempt from ELGs, NAHB said.
- The EPA’s Option 1 is appropriate for sites where there are land disturbance activities on one to 10 acres of land, NAHB said. Requirements for settling ponds, however, should conform to state and local mandates.
- With the modifications suggested by NAHB, Option 1 is also appropriate for sites of more than 10 acres that drain to only one location.
- Recognizing that sites that disturb more than 30 acres and are located in parts of the country with high rainfall and high clay content do require additional protection, the NAHB proposal lays out a plan that requires turbidity sampling and specific responses when turbidity levels rise.
“Total current discharges from all construction sites account for less than 0.1% of all sediment discharges to receiving waters nationally,” the NAHB comments added.
“If all construction sites meet appropriate construction and development ELG standards as outlined in the NAHB proposal, construction discharges will be further reduced below this already de minimus level,” NAHB said.
For more information, e-mail Calli Schmidt, or call her at 800-368-5242 x8132.
 'Storm Water Permitting: A Guide for Builders and Developers' Available at BuilderBooks.com
“Storm Water Permitting: A Guide for Builders and Developers,” available through BuilderBooks.com, provides a starting point for builders and developers to use in locating and understanding storm water permitting requirements.
The publication has been prepared to help builders comply with the U.S. Environmental Protection Agency's storm water requirements, and includes information on state permitting programs and more than 50 of the most commonly used Best Management Practices. Also included are tips on compliance, including how to handle visits from inspectors.
To view or purchase this guide online, click here, or call 800-223-2665.
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