As Category 4 Hurricane Ian approached in late September, a “smart” retention pond on S.R. 45 near Port Tampa Bay captured 175,000 cubic feet of the polluted flow before it hit Tampa Bay. Technology in the pond continuously assesses its contents and rainfall forecasts to initiate an automatic release of partly filtered contents before a storm comes ashore. Operators can also remotely lower the water levels when a storm approaches.
Day: April 5, 2023
NST TEAM SPOTLIGHT: Meet Capt. John Ferguson, USN-Ret., President & COO
We are very proud of the rich backgrounds and experience brought to the smart stormwater industry by our team at NST. One team member in particular, NST President and COO Capt. John Ferguson (USN-Retired), was recently appointed to represent the Muscogee Creek Nation at the ship construction steel-cutting ceremony for the future USNS Muscogee Creek Nation at Bollinger Mississippi Shipbuilding in Pascagoula, Miss.
The vessel is the 10th Navajo-class Towing, Salvage and Rescue Ship (T-ATS) and the fifth T-ATS vessel being constructed by Bollinger since acquiring the program in April 2021. The Navajo-class provides oceangoing tug, salvage, and rescue capabilities to support fleet operations and are tasked with coming to the aid of stricken vessels. Their general mission capabilities include combat salvage, lifting, towing, retraction of grounded vessels, off-ship firefighting, and manned diving operations.
Named for the Muscogee Creek Nation, the ship honors the self-governed Native American tribe located in Okmulgee, Okla.
WEBINAR: New Stormwater Rule Provisions for Offsite/Compensatory Treatment
Jeff Littlejohn, Florida water expert and former Deputy Secretary of the Florida Department of Environmental Protection, will lead a webinar focused on how new stormwater rule provisions for offsite/compensatory treatment may impact you and projects you are involved in. Whether you are in engineering, development, public works, transportation, or water resources, these webinars will have something for you.
NST Announces New Webinar Series
The Florida stormwater industry is headed in a new direction, supporting needed benefits to water quality and flood resiliency, and fueled by innovations in technology and regulations. The professional staff at National Stormwater Trust will host a series of webinars over the coming months to discuss these important issues. Whether you are in engineering, development, public works, transportation, or water resources, these webinars will have something for you.
Future Webinars Will Focus On:
- Permitting CMAC/Smart Pond Best Management Practices using the Alternative Design Provisions of the Applicant’s Handbook
- Planning and permitting development using Stormwater Nutrient Credits
Be on the lookout for those forthcoming webinar dates.
ENGINEERING TIP OF THE MONTH: Incorporating Stormwater Nutrient Credits into Site Development Design
By: Mark Thomasson, P.E., Chief Stormwater Engineer
We’re often asked about how to maximize design flexibility using Stormwater Nutrient Credits (SNCs) to meet system requirements for stormwater management facilities that control both water quantity and water quality.
We recognize that land and opportunity costs constitute a majority of losses in stormwater management, and that’s why more and more civil engineers are turning to off-site stormwater treatment alternatives to optimize their designs.
To maximize design flexibility for its customers, National Stormwater Trust (NST) created the SNC market to enable public and private developers to meet a portion of their stormwater treatment requirements by purchasing credits generated in an off-site Regional Stormwater Management Systems (RSMS).
In a typical 10-acre commercial development in Orange County, the gross land cost is about $7.5 million. The cost of a conventional wet pond is about $0.5 million, including construction and the present value of 30 years of maintenance costs. The opportunity cost of the 1.2 acres occupied by the wet pond is about $0.9 million. (NOTE: The average cost of commercial real estate in Orange County is about $750,000 per acre.)
How can SNCs be applied to this scenario to benefit the development? In this example, the required water quality treatment is 0.83 ac-ft for 1” of treatment over the 10-acre site. This quantity of treatment (0.83 ac-ft or the equivalent treatment converted into pounds or kilograms of nitrogen per year) can be provided in a permitted RSMS in the same watershed. The purchase and transfer of SNCs from a regional facility to the development can result in significant cost savings to the development, while providing an equivalent amount of water quality treatment in a regional facility that is professionally maintained. In this example, the cost of the SNC would be about $625,000, and the savings to the developer would be about $800,000 (eliminating direct costs and lost land value).
Here’s how the permitting works: To use an SNC, you must secure a reservation in a permitted regional facility with available credits and provide evidence of the availability of the credit to your permit reviewer. The more convenient way to do that is to request a Credit Reservation Letter from NST. In that letter, NST will outline the quantity reserved (in acre-feet or pounds/year), and the permitted facility where the SNC is being generated. This documentation provides reasonable assurance to your permit reviewer and simplifies your permit process. Simply put, the Reservation Letter replaces the on-site water quality treatment in your permit.
Prior to the start of construction, NST will transfer the SNC to your permit through a letter modification to its regional facility. Evidence of that permitted transfer will be provided to complete the purchase.
If this sounds similar to using a wetland mitigation credit in lieu of permittee-responsible mitigation, that’s because this program is designed to work the same way. It’s a one-time purchase, and the stormwater treatment requirement is transferred from your development to an NST-operated regional treatment facility.
NST will proactively manage the collection, storage, and discharge of stormwater in its facilities. NST-managed stormwater facilities use Continuously Monitored and Adaptive Control (CMAC) technology to improve treatment performance and reduce flooding by controlling water levels and increasing the storage capacity of the facilities by drawing down water levels prior to forecasted rainfall. NST’s Smart Ponds are about 50 percent more effective in treating stormwater than conventional facilities and enable verification of water treatment performance in real time.
NST Has Access to 2,600+ FDOT Stormwater Ponds
Through an agreement with the Florida Department of Transportation, NST converts conventional FDOT stormwater ponds into regional Smart Ponds that generate Florida government-approved SNCs.
NST offers its SNC customers the one-stop convenience of long-term stormwater compliance and the knowledge that NST is providing state-of-the-art stormwater technology and scientific and financial resources to provide green infrastructure solutions to Florida.
Will New Stormwater Rule Be Ratified by Lawmakers?
On March 22, the Florida Department of Environmental Protection (FDEP) hosted a Public Hearing on its Proposed Rule where it discussed four Lower Cost Regulatory Alternatives and listened to about two and half hours of public testimony. On Friday, March 24, the FDEP issued a Notice of Change to the rule. Along with some minor edits, the Notice of Change included two key modifications that warrant discussion.
First, the FDEP expanded the “grandfathering provisions” of the Proposed Rule to allow projects with existing Conceptual ERPs to continue to rely on current stormwater requirements through the remaining phases of construction. This approach is consistent with prior revisions of stormwater regulations, including the most recent change to the Statewide ERP in 2013.
Second, the FDEP modified the post-development treatment requirements in Section 8.3 of the Applicant’s Handbook Volume I. Specifically, the “baseline” post-development treatment performance standard of 80% TN annual average load reduction was changed to 55%. For OFWs, the 95% TN standard was changed to 80%, and the 95% TP standard was changed to 90%. For impaired waters, non-OFW and OFW waters were split into different performance categories. The new post-development treatment performance standards for impaired/non-OFW waters are 80% TN and 80% TP. For impaired/OFW waters, the standards are 95% TN and 95% TP. The remaining performance standards were unchanged, including the “pre-post” development loading standards and the application of basin-specific performance criteria from adopted TMDLs.
The Notice of Change started a new 21-day public comment period, which expires April 14. After the public comment period closes, the proposed rule will still require legislative ratification prior to it becoming effective. The Statement of Estimated Regulatory Cost appears to be largely unchanged. Unless there is a rule challenge, there is still potentially a path to completion this session.
National Stormwater Trust, Inc. appreciates all of the hard work that FDEP staff, the TAC members, and all stakeholders have invested in this rule over the last two years.
For additional updates, please follow National Stormwater Trust on LinkedIn. For details about the Proposed Rule and how it might impact your current or future project, contact Mark Thomasson, P.E., LEED AP or Jeff Littlejohn, P.E. at NST.