SIERRA CLUB COMMENTS

STORMWATER DRAINAGE MANUAL (JUNE 2005 DRAFT ED.)

Central Ohio Sierra Club
36 West Gay Street, Ste 314; Columbus OH 43215

GENERAL REMARKS

Support Wet Weather Management Plan Goals.

Columbus Division of Sewerage and Drainage is proposing to address sewer overflows and water quality. This Stormwater Drainage Manual (SDM) will greatly affect sewers and waterways, but it does not even mention varying conditions in combined sewer areas. This manual could enhance the WWMP initiatives by:

Promoting as much separation as possible of storm and sanitary flows;

Not compromising quality controls in combined sewer areas;

Not granting exemptions or variances which will undercut WWMP efforts;

Considering requirements specific to combined areas.

Restructure for Clarity and Ease of Use.

As presented the Manual is difficult to use. Suggestions that would enhance clarity and understanding include: (See Portland Stormwater Man. Manual, Ch 1)

Summarize general requirements in the Introduction (chart, table, etc).

Include a full list of references, either for whole volume, or by section.

Define all important terms used in the Manual, see specifics below.

Add a chapter summarizing maintenance requirements.

Put technical engineering calculations in an appendix.

Index, if possible, major topics and controls.

Explain relationship of quantity and quality controls more clearly.

Highlight and Clarify Maintenance Requirements.

Maintenance requirements are scattered in Section 3.3.9 and Appendices E and F. A separate dedicated chapter in the manual should collect and highlight information. The Portland Stormwater Management Manual does a good job in Chapter 3/Operations and Maintenance: Applicability, Plan Submittal Requirements, and Enforcement. See references at the end of these comments.

We believe that there should be consequences for failure to operate and maintain. Enforcement actions are buried in the Model Maintenance Agreement in Appendix F, giving the City the right to enter, fix problems, and seek reimbursement. Maintenance requirements should cover private and public facilities. What recourse is there if the City does not keep up maintenance?

It is not clear why the City should offer to maintain privately owned stormwater facilities (Section 3.3.9). If the City takes over maintenance, a substantial fee is necessary to cover ongoing costs. The responsibility for maintaining private facilities could become a large expenditure for ratepayers.

Add Landscaping Guidelines

There is a lack of landscaping principles and guidelines: plant selection, soils, mulch, irrigation, site preparation and grading, etc. For examples, see Georgia Stormwater Management Manual; City of Portland Stormwater Management Manual; Prince George’s County Bioretention Manual in the list of references at the end of these comments. Well constructed guidelines can guide efforts, for example, even if not every plant species is on the recommended list. Plant selection guidelines are commonly for species native to eastern North America (or a state) that are adapted to site conditions and will not become invasive.

Create Lists of Suggested Plant Species for Each Control.

Appendix B (Approved Wetland List for Detention Ponds…) is a good start and could be expanded. At the very least, the list should be “Recommended Plants.” It should be clear that the list is not exclusive and other species that conform to guiding principles would be approved.

Ideally there should be separate lists for each stormwater control situation. The Portland Stormwater Manual has separate lists for ecoroof, contained planter, vegetated swale, grass swale, wet pond, etc..

Appendix B should not be used to identify streams or wetlands. Lists of riparian species would be more useful for streams in natural conditions; wetland lists for wetlands. If the site has been altered and degraded, however, a stream may exist without its expected species.

Update Stream Corridor Protection Zone.

The formula for this protection zone should be updated to the latest ODNR Rainwater and Land Development formula. Also, it should include the 100 year floodplain, wetlands, and steep slopes.

Examine Volume v. Peak Flow Calculations

The stormwater regulations are based on peak flow rates and not volumes. We support controls on calculated increase of post-development volumes.

Incoporate Stricter Quality Controls Where They Exist.

This report does not mention TMDL standards. It makes sense to incorporate them where they exist in an inclusive statement.

The Big Darby watershed will have stricter water quality controls implemented by Ohio EPA. Specific reference and inclusion should be in this ordinance, implementing any controls for Big Darby environmentally sensitive areas.

Tighten definition for Variances.

The defined terms for granting variances are loose and leave too much subjective discretion.

Adapt Engineering Practices so that Hydrology and Temperature are Protected.

The BMPs required will allow alterations of stream flow hydrology and water temperature. Adding woody plant species for shade would help maintain cooler temperatures. Maintaining water flow during dry periods might be helped by generous woodland riparian buffers.

Add Incentives for Stream Restoration

There are few high quality watercourses left in the area. A policy of restoration could be advanced by this manual, providing incentives for improving hydrologic and biological functioning of streams. Generous stream corridor protection zones and upgraded hydrologic profiles would help manage urban stormwater. There need to be incentives for stream restoration. Stream restoration must have its own section in the manual. At present it is scattered under compensation for floodplain filling in Section 1.4 and Section 2.3.7.

Strengthen Protections for Wetlands

This can be accomplished by:

Clearly including adjacent wetlands in the protection zone;

Adding easements or buffers around high quality wetlands;

Adding penalties for disruption or destruction of wetlands;

Strengthen the stated goals of preserving wetland hydrology.

Encourage Reduction of Pavement De-icers

Is there any way that these regulations could move toward encouraging reduction in use of road salt and other de-icing agents? Using less road salt would do much to improve water quality in the winter/spring. See NRDC reference report Stormwater Strategies.

Examine Requirements for End Treatments

Although this manual aims to prevent erosion at outlets from storm sewer conveyances, the language may not be strong enough.

Increase Protections for Floodplains

This manual allows the continued practice of floodplain filling. Too much floodplain filling has already occurred and it should be stopped. We do not support siting stormwater control facilities or mitigation wetlands in floodplains (or stream protection zones).

SPECIFIC SUGGESTIONS

Introduction (1)

According to the Columbus Department of Public Utilities 2004 Annual Report (p. 11) Columbus had 5,486 total miles of sewers: 2,782 sanitary; 2,537 storm; and 167 combined.

Purpose (1)

A proactive purpose statement is found in the Portland SMM: “The purpose of this SMM is to provide stormwater management principles and techniques that help preserve or mimic the natural hydrologic cycle, minimize sewer system problems, and achieve water quality goals.”

Applicability (1)

The list of activities subject to the manual includes redevelopment of multi-family residential facilities “if the renovation will substantially affect storm water drainage.” Substantially should be removed as it is unclear. It might strengthen the intent to add something like “all private or public projects that add over 500 square feet of impervious surface or increase stormwater discharge off-site.”

It would be useful to have a flow chart or table summarizing which requirements apply to which type of projects: commercial, redevelopment, construction, etc.

Definitions (3-9)

Best Management Practice (4): The ODNR Rainwater and Land Development Book should be mentioned. See references. A new draft is available on the internet.

Combined Sewer and Combined Sewer Overflow

Major Stormwater Routing System (6): Give examples: open watercourses, streets, floodplain, floodway, e.g.

Stormwater Pollutants (8): Must include any substances prohibited by state law, including general “free from” requirements. Suggest adding to the end of the sentence “… or which are prohibited by state law.”

Stream (8): The proposed definition of a stream includes a surface watercourse with defined bed, bank, and high water mark. It is not the same as the definition in Appendix A, the Columbus Erosion and Sediment Pollution Control Regulation. The definition also differs from that agreed on by the Big Darby Environmental Advisory Group. The definition also differs from that in EnviroScience Environmental Planning and Zoning; Sample Environmental Zoning Tools.

We advocate removing the requirement for a high water mark, which would bring it closer to the other definitions cited. Streambank should also be defined. Specifying reference maps would enhance the definition.

If the presence of a high water mark is required for the proposed Stormwater Manual, then a reference for the definition should be included. In any case, the definition should include the distinction between Tier I and II.

Stream Corridor Protection Zone (8): A stream corridor provides protection of both quantity and quality of stormwater. This should be reflected in the definition by adding something like: “A corridor with natural vegetation also protects water quality by providing filtration of sediment and pollutants.” Further, the definition should mention that the protection zone “is left in a natural, usually vegetated, state so as to protect water resources. Prohibited activities are regulated by this ordinance.”

Terrestrial Vegetation (9): Upland terrestrial vegetation should be defined in reference to an approved complete species list, not Appendix B.

Wetland Vegetation (9): Mention of the National Wetland Plant List should be clarified with a full reference. See references for USFW list and ACOE manual. Appendix B is not a complete list of wetland vegetation and any reference to it must be removed from this definition.

ADDITIONAL DEFINITIONS SUGGESTED

Bioretention Facility, Combined Sewer and Combined Sewer Overflow, Construction Stormwater Quality Controls, Culvert, Detention Basin: Wet and Dry, Filter Strip, First Flush, Floodway Fringe, Green Roof, Hydraulic Grade Line, Invasive Species, Level Spreader, Media Filter, Micropool, Non-Point Source of Pollution, Native Plants, NPDES, Ohio Rapid Assessment Method, Open Channel, Peak Flow, Outfall, Pollutant, Protection Zone, Sand Filter, Total Suspended Solids, Stormwater Wetland, Vegetated Swale

ADDITIONAL ACRONYMS SUGGESTED (9)

HSG-Hydrologic Soil Group (33), BDF-Basin Development Factor (35), HGL-Hydraulic Grade Line (42), WQv-Water Quality Volume (95)

Part I – Stormwater Policy and Facility Design Criteria (11)

This outline overview of stormwater conveyance and controls presents questions, especially when compared to the definitions on pages 8 and 41:

- Why does “Minor Stormwater Conveyance Systems” include certain components and not others? It is surprising that it does not include drainage swales, curbed streets, and open channels. Why does it include end treatments, outlet channel protection, and level spreaders?

- Why does “Major Stormwater Routing Systems” only include open watercourses? Why does it not include streets and floodplains?

- Why does “Stormwater Quantity Controls” not include swales, pervious pavement, filter strips, stream corridors, or natural systems to control quantity?

Section 1.1: Stream Protection Policy (13)

The change from past city policy is very good; we applaud the requirement that streams remain open with a stream corridor protection zone. See above comments on definition of protection zone: we advocate that the zone be wide enough to protect water quality, as well as erosion.

Section 1.2: Stream Identification (13)

See comments on definition of stream: we do not support the requirement for a high water mark. Intermittently flowing water in a bed and bank should be sufficient. Possible reference maps, in addition to USGS topo quads, include FEMA maps, county riparian maps, or soils maps.

Some protection is granted to streams, none to “open channels.” There is no definition of an open channel. Distinguishing between a stream and open channel can be difficult. More guidance is needed. We suggest articulating the principle that watercourses do not qualify for protection if they are constructed features and were not previously existing stream channels.

Further, there needs to be verification or check through an independent source, not just at the discretion of the Director. The Applicant carries the responsibility to identify streams, but has a strong interest to not find them. Stream identification should include the Soil and Water Conservation District.

Appendix B must not be used to identify streams. It is not an adequate or complete list of stream or wetland vegetation. A commonly accepted authoritative reference should be used: US Fish and Wildlife List of Wetland Plants is suggested since a stream will show riparian species, and not necessarily wetland plants.

Section 1.3: Stream Corridor Protection Zone (15)

Establishing stream corridor protection zones is a very positive approach. The methodology could be improved:

1) The formula should be updated to that in the latest ODNR Rainwater and Land Development Book (see reference list):

Stream setback width in feet = 129 D.A.0.43

This will lead to a wider corridor.

2) If stream is Exceptional Warmwater Habitat, formula should be more generous: Width in feet = 133 DA 0.43 See Ohio EPA, TMDL for the Big Darby Creek Watershed (May 16, 2005)

3) The Stream Corridor Protection Zone must include wetlands. This report specifies in Section 1.5 that the zone expands to include contiguous wetlands. That requirement needs to be included here for completeness. The wetlands should have protection zone buffers adequate to permanently protect flora, fauna, and hydrology.

4) The protection zone is defined as expanding to include slopes of more than 15%, up to double the protection zone. We advocate, instead, for full inclusion of all slopes 12% or more. This would prevent erosion-causing activities on steep slopes and consequent loss of sediment into watercourses.

Ideally, there would be an a setback from the top of the slope of 10 feet.

Table 1-2: Prohibited Facilities and Activities (17)

Prohibited facilities should include roads, driveways, parking lots, and man-made impervious surfaces, quarries, road salt storage, and storage tanks.

Prohibited activities could be clarified by listing dredging and filling.

Section 1.3.5: Exemptions (18)

1) Even in the downtown zoning district, there should be a protected corridor along the Scioto and Olentangy rivers.

2) The exemption involving the floodwall is not clear, but appears to not extend west of the floodwall. This exemption could be dangerously large. What about tributary streams that run west toward the Scioto?

3) We suggest incentives to reduce building in the protection zone – thus disincentives to leaving buildings in the protection zone.

Section 1.4: Floodplain (18-19)

We do not support filling or dredging in the 100 year floodplain and suggest removal of permission in this manual and from the Columbus Zoning Code Flood Plain Development. City policy should not give incentives for (more) filling of floodplains. Even if compensatory volume of space is provided for floodwaters, dumping in floodplains introduces foreign materials with possible biological and chemical contaminants and alters the hydrology. By its nature, floodplain filling and excavating greatly disturbs drainage patterns.

Filling of floodplains should not be compensated through disturbance of stream corridor protection zones or construction of upland detention basins.

We question the need to have stream restoration plans designed and signed by a professional engineer. Restoration specialists and landscape architects know stream restoration better. Stream restoration should have its own section and not be lumped under compensation for floodplain filling.

Section 1.5: Wetland Protection (21)

We support the policy of protecting wetlands through delineation and inclusion on the plan and report, extending the stream corridor protection zone to include wetlands, and mitigation as close as possible.

We do not support allowing constructed mitigation projects in the stream corridor protection zone.

Protected wetlands should have additional protection through buffer setbacks adequate to permanently protect flora, fauna, and hydrology.

Language in this section would be clarified by specifically requiring:

-preserve pre-development quantity and quality of wetland stormwater

-don’t use existing wetlands to treat development stormwater

-post-development flow to wetland should not be increased

There should be penalties or consequences for violating wetlands. As written, the rules are aspirational and offer no incentive to truly protect existing wetlands from the altered hydrology of development.

Section 2.1: Stormwater Conveyance (23-24)

Controls seem to require that offsite and onsite runoff will not increase peak stormwater rates - not increasing downstream peak water surface elevation?

Section 2.1.4 Agricultural Field Tile Systems (25)

This section is not clear. Is it a typo or intended that runoff from a proposed development plus offsite flows shall be “not less than the development’s fair share.” Should that be not more than?

Section 2.1.5: Stormwater Diversion (25-26)

The process of approval and criteria is unclear. The requirement for diversion from one catchment to another is low and the decision discretionary. We suggest setting the bar higher and making requirements more specific.

Section 2.2: Hydrology Requirements (26-40)

Tables and calculations should be in an appendix. Include as much necessary information as possible: e.g. Table 16 soil chart (33).

Section 2.2.4: Acceptable Runoff Hydrograph Development Methods (38)

The “common engineering computer software” should be in the reference list with more complete information on authors or sources. It would be much clearer if the manual relied on one hydrograph method and included the necessary information. See Portland Stormwater Management Manual Appendix B, Santa Barbara Urban Hydrograph Method.

Section 2.3.7: Open Watercourses (74-74)

What is an open watercourse? It is not in the definitions. The text suggests that it includes both open channels and restored streams. This will increase the danger of confusion noted above distinguishing between streams and open channels. We suggest adding the definitions suggested and splitting this section into two, one “Open Channels,” and one “Stream Restoration.”

We suggest discouraging alteration of streams, other than for restoration purposes. There are more references than the USDA handbooks. Please include requirements for native, non-invasive vegetation in stream restorations.

The guidance documents should be in the reference list with more complete information on sources, including web addresses.

 

Section 2.3.4 – 2.3.6: End Treatments (66-74)

This section combines with the following two covering protection from erosion at outlets and outfalls. This section should state explicitly that stormwater conveyances should not discharge in such a way as to accelerate erosion. Ideally, end treatments would include biological systems as well as engineered physical structures.

In Section 2.3.5 requiring channel protection, it is not clear if this is the channel of the receiving stream.

Section 2.4: Design of Major Stormwater Routing Systems (78-79)

It seems odd that the section on Minor Stormwater Conveyance would be 37 pages while Major Stormwater Routing would only have 1 page. The definitions of major and minor drainage systems on page 6 are excellent and could be summarized in the text. They suggest that minor systems generally carry up to 5 year storms?

Section 3.1.2: General Criteria for Stormwater Control Facilities (81-82)

2) We do not support siting of control facilities in the floodplain.

4) Language should be strengthened to protect existing wetlands, with penalties or disincentives for disturbance and alteration of hydrology. “Wetland hydrology shall be sustained to the extent possible” is too weak.

Section 3.2.1: Stormwater Quantity Control Exemptions (82)

Three: The existing facility should be functioning up to the level required by these regulations.

It is confusing to have these important requirements buried on page 82. They should be summarized in the Introduction.

Section 3.2.2: Hydrologic Requirements (82-83)

Quantity control calculations are based on the Critical Storm Method, referenced to Mid-Ohio Regional Planning Commission in 1977. Although this will provide protection from peak flows, there will be much longer periods of the maximum flow allowed. Is there not another more recent method developed since 1977?

Typo: Table 2-1 should be Table 2-3

Stormwater quantity controls should, in our view, have controls or limits on increase in runoff volumes – with disincentives to increase runoff volume over pre-development conditions.

Section 3.2.4.1: General Requirements for All Detention Basins (84-86)

Why is woody vegetation not permitted? With no shade, basins will increase water temperatures. What about maintenance?

Section 3.2.4.2:Additional Layout Requirements for Dry Detention Basins (87-88)

There should be guidelines and a list of recommended species for dry detention basins. Guidelines could include native vegetation that can survive 48 hours saturation and species could include grasses and sedges. As written, there is not sufficient guidance on what the City finds “suitable.”

Section 3.2.4.3: Additional Requirements for Wet Detention Basins (88-90)

Three: The manual should say that plantings may be selected from Appendix B, and that other native non-invasive shallow emergents may work.

Five: Should say that species may be selected from Appendix B, but that other native non-invasive species that can withstand inundation may work. There needs to be guidance on what the City considers “suitable.”

Six: What other alternatives are suggested near airports? This regulation will prohibit wet basins from almost two miles of airports.

Section 3.2.7: Green Roof Technologies (91)

The requirements for green roofs are much stricter than other stormwater controls; this will not encourage their adoption and use. For instance, there should be system components and maintenance requirements for other controls that are as precise and strict: written maintenance requirements for inspection, aesthetics, debris and litter, and vegetation for basins, filters, etc.

We do not understand or support the requirement for retaining at least 50% of precipitation per year. Such a requirement seems arbitrary. If the requirement is retained, green roofs meeting the regulations should get a corresponding stormwater fee reduction.

There should be a list of green roof suggested species and guidelines; see Portland Stormwater Management Manual.

Section 3.3: Stormwater Quality Controls (94)

Section 3.2 lists stormwater quantity exemptions first and then requirements. It would be more consistent to have the same order in sections 3.2 and 3.3.

This section should list pollutants of concern. There are no performance standards that must be attained. We suggest at least limits on sediment and oil and grease. See Dane County Wisconsin Stormwater Control Plan and Portland Stormwater Management Manual.

Requirements are not clearly stated in the General Requirements section.

Section 3.3.1.1: Stormwater Quality Control Exemptions (95)

Existing BMPs or management facilities must be functioning to provide the level of control required if they are to have an exemption.

Section 3.3.1.2: Stormwater Quality Control Redevelopment Variance (95)

Because redevelopment will occur in the combined sewer area, it is disturbing to reduce quality controls. Pollution reduction should be stricter, not more lenient, when there is potential for untreated discharges.

This category could include any existing developed parcel in the City. The regulations are not clear but seem to suggest extensive variance availability. At a minimum, quantity controls should not be waived. And, to repeat, pollution reduction is more important on sites in the combined sewer areas.

Section 3.3.2: Water Quality Volume Determination (96)

WQv should be in the list of acronyms; TND should be in the list of acronyms and probably definitions as well.

Section 3.3.4.2: Extended Wet Detention Basins (106-110)

Five: The requirements suggest using salt tolerant plants. Why is this a factor for extended wet detention basins but not for quantity controls? Presumably, they would get as much road salt.

Appendix B species do not seem to be selected for salt tolerance. There should be a list of salt-tolerant species.

There should be an accommodation for woody species as well.

Section 3.3.4.3: Stormwater Wetlands (111-114)

There should be a provision allowing for woody species, trees and shrubs, in wetlands.

Most submittal sites will be less than 20 acres. Is it permissible to allow offsite stormwater into a constructed wetland to meet the requirement for 20 acres of drainage? We hope so: it will reduce total stormwater volumes and allow wetlands to be used in more situations.

Same comments on Appendix B: there should be separate dedicated list of recommended plant species for this and each BMP.

Section 3.3.5: Group 2 – Media Filters (114-123))

Media Filters is a confusing title; why not Bioretention Facilities and Sand Filters? Bioretention Facility is an offputting name, how about “Vegetated Filter?” We applaud that the Bioretention basins allow grasses as well as trees and shrubs.

Table 3-8 is a good list, although taken from Maryland (and Georgia) manuals. However, for consistency, we suggest that a list for bioretention facilities be put in Appendix B with lists for other controls. Each list should be carefully constructed to include plants native to eastern North America that will thrive in the particular soil and hydrology conditions but not become invasive.

Section 3.3.6: Vegetated Swales and Filter Strips (124-129)

We strongly object to the recommendation of reed canary grass (127) (Phalaris arundinacea). It has become a dangerous invasive plant of wetlands throughout eastern America. It is on many state lists of invasive species as a plant to be controlled before wetland restoration. It absolutely should not be promoted for constructing stormwater facilities. Reed canary grass was number 1 species of concern on the Invasive Plant Association of Wisconsin survey (www.ipaw.org).

There should be a dedicated list in Appendix B of recommended plants, along with clear guidelines. Although the suggestion here is for fine, close-growing, water-resistant grasses redtop and reed canary grass are both tall.

The text is very confusing in that it seems to recommend planting according to CMSC Section 659 and later says that those same lists should not be used. The remarks for Vegetated Filter Strips are not any more helpful.

Section 3.3.7: Controls for Commercial Activity Areas and Redev. (129-133)

Many redevelopment sites may be located in areas of combined sewage pipes. Precipitation can and should be directed to sanitary sewers if runoff collects substances requiring wastewater treatment. Other than that situation, we support keeping stormwater and sanitary sewage isolated and separate as much as possible. Public sewer pipes may be separated and the wastewater systems onsite should be designed to fit with a separate public system. It is not clear from the text as written whether 3.3.7.1 will achieve separate on-site systems or not.

Of course, we support pre-treatment and control of contaminating substances.

Section 3.3.7.2: Controls for Redevelopment (133)

In Section 3.3.1.2 the manual outlines variances for stormwater quality controls. It does not make clear there or here in 3.3.7.2 whether stormwater quantity controls are still required. We would urge making explicit that stormwater quantity controls are still required.

It might be helpful to add references for information on identifying high-risk pollutant sources, etc.

Section 3.3.8: Applicant-Proposed Stormwater Controls (134-137)

This section appears to offer the possibility of using other control technologies. It would be useful to include suggestions of references or sources of information.

Calculations of peak post-development runoff are to be caculated the same way as vegetated swales. Swales, however, in 3.3.6 are only recommended for areas less than five acres. What if the drainage area is larger?

The proof required for manufactured controls is pretty high, especially if it must be from a third party.

Section 3.3.9: Stormwater Control Facility Maintenance Requirements (137-138)

The City offers to take over maintenance of eligible detention basins and constructed wetlands. This responsibility will be costly over many years; we believe that there should be a substantial fee paid to the City for relieving owners of this responsibility.

Maintenance requirements for City-maintained facilities needs to be addressed. Are they the same as private facilities? What if the City does not maintain the facilities? What recourse then?

Information on operations and maintenance is very important. We believe that it should be in a separate dedicated chapter. See Portland SDM.

Section 3.3.10: Stormwater Control Facility Easement and Access (138)

The requirement for constructing and maintaining vehicular access will not be environmentally beneficial. This manual should include a model easement.

Section 3.5: Construction Stormwater Quality Controls (139)

It is good to include the actual regulations, but we suggest that the regulations be updated to be consistent with this manual, which has stricter limits.

Section 5.1: Stormwater Plan Requirements (147-148)

Nine: The stream corridor protection zone as shown on the plan should include adjacent wetlands, floodplains; and we suggest all slopes steeper than 12%.

The text here should mention the plan shows all utility lines on the site.

The plan should show amount and location of impervious surface proposed.

Section 5.2.1: Stream Corridor Protection Calculations (149)

See above

Section 5.2.2: Compensatory Floodplain Fill (149)

We do not support further filling of the floodplain and believe it should be discouraged.

Section 5.2.3: Storm Sewer Calculations (149-150)

Two: Make sure these acronyms are included in the list at the beginning

Tailwater: define at beginning

Four: Why not write out requirements, as they are short.

Five: Does this mean spacing of inlets? It is not clear.

Section 5.2.7: Stormwater Detention Calculations (151)

One: We believe that there should be controls on increase in runoff volume and disincentives to increase it.

Two: If the constructed open watercourse is designed to convey a 5 year storm (150), but the maximum release rate is for a 10 year storm, won’t erosion result?

Section 5.4: Compensatory Floodplain Restoration Plan Requirements (153)

We do not support filling of the floodplain.

 

Appendix A: Columbus Erosion and Sediment Pollution Control Regulations

For clarity, these regulations should be updated to be consistent with the manual.

Appendix B: Approved Vegetation List for Extended Wet Detention Ponds, Stormwater Wetlands, and Bioretention Basins

Good list but restricted, could be expanded. A planting list of recommended species for each control is recommended, see Portland Stormwater Management Manual.

Should not be exclusive list; other species could be used.

Articulate guidelines, for instance: utilize site-adapted natives and not alien/introduced species; do not use invasives. See Portland Manual.

Include more references.

We hope that more woody species of trees and shrubs can be added.

Appendix B lists plants for 3 environments: mudflats, shallow water, and open water. How do these correlate with the controls? The list would be more useful if it said clearly, for example, that shallow water emergents can be sited on the aquatic bench of a wet detention basin or that mudflat species can be used in a wet detention basin above the permanent pool.

It would be useful to suggest wetland status for each grouping, e.g.: mudflats mostly facultative and facultative wetland species; shallow water facultative wetland and obligate wetland species; open water obligate wetland species. See USFW Wetland manual; Floristic Quality Index for Ohio.

Taxonomic corrections:

Alisma plantago-aquatica: replaced by A. triviale

Carex lanuginosa: remove, not found in Ohio

Could add Carex lacustris and C. crinita, others sp. possible

Cornus sericea: northern species, not best for Franklin County, could replace

with Cornus amomum

Cyperus esculentus: remove, this is a weedy species

Eleocharis smallii: not listed in Ohio, could replace with E. erythropoda

Hordeum jubatum: not native, needs dry conditions, remove

Panicum virgatum: not a wetland species

Polygonum: possible species is amphibium

Ratibida columnifera: not a wetland species

Silene regia: not a wetland species

Solidago gigantea: spelling

Verbena hastata: spelling

Vernonia fasciculata: spelling

Acorus calamus: not native

Cyperus esculentus: remove this weedy species, could replace with C. strigosus

Eleocharis: possible species are erythropoda, E. obtusa

Juncus effusus: spelling

Scirpus tabernaemontani: has been renamed Shoenoplectus tabernaemontani

S. validus: folded into Schoenoplectus tabernaemontani

Verbena hastata: spelling

Zizania aquatica: will not thrive in these conditions

Appendix E: Operation and Maintenance Inspection Report Checklists

Will the City maintain facilities at the same level? What happens if the City does not maintain stormwater facilities?

The lists should be more explicit about vigilant removal of invasive weeds/nuisance/noxious vegetation.

Appendix F: Model Maintenance Agreement

The agreement could mention that maintenance will prevent accumulations of invasive weeds.

What happens ten years after the agreement? Is there still the right of entry and reimbursement?

 

A FEW COMMERCIAL SOURCES OF WETLAND PLANTS AND/OR SEEDS

Envirotech Consultants, Inc.; 5380 Township 143 NE; Somerset, OH 43783

www.envirotechcon.com

Ernst Conservation Seeds; 9006 Mercer Pike; Meadville, PA 16335

New Moon Nursery, LLC; 1492 Kirkwood Pike; Kirkwood, PA 17536

www.NewMoonNursery.com

Octoraro Native Plant Nursery; 6126 Street Road; Kirkwood, PA 17536

www.octoraro.com

Ohio Prairie Nursery; PO Box 174; Hiram, OH  44234

www.ohioprairienursery.com

Pinelands Nursery and Supply; 323 Island Road; Columbus, NJ 08022

www.pinelandsnursery.com

Prairie Nursery; PO Box 306; Westfield, WI 53964

www.prairienursery.com

Spence Restoration Nursery; PO Box 546; 2220 E. Fuson Road; Muncie IN 47308

www.spencenursery.com

 

REFERENCES

AMEC Earth and Environmental, et al. 2001. Georgia Stormwater Management Manual, Volume 2: Technical Handbook. Atlanta Regional Commission. Available at: http://www.georgiastormwater.com

Andreas, Barbara K., John J. Mack, and James S. McCormac. 2004. Floristic Quality Assessment Index (FQAI) for vascular plants and mosses for the State of Ohio. Ohio Environmental Protection Agency, Division of Surface Water, Weland Ecology Group, Columbus, Ohio. 219 p. available at: http://www.epa.state.oh.us/dsw/welands/weland_bioassess.html

Braun, E.L. 1961. The Woody Plants of Ohio. Hafner Publishing Co., New York.

Braun, E.L. 1967. The Monocotyledoneae of Ohio. Cattails to Orchids. The Ohio State University Press; Columbus, Ohio.

Center for Watershed Protection and Maryland Department of the Environment. 2000. Maryland Stormwater Design Manual Volumes I & II. Available at: http://www.mde.state.md.us/Programs/WaterPrograms/SedimentandStormwater/stormwater_design/index.asp

City of Portland, Bureau of Environmental Services. 2004. Stormwater Management Manual. www.portlandonline.com/bes

Cooperrider, T.S. 1995. The Dicotyledoneae of Ohio. Part 2. Linaceae through Campanulaceae. Ohio State University Press, Columbus, Ohio.

Cooperrider, T.S, A.W. Cusick and J.T. Kartesz, Eds. 2001. Seventh Catalog of the Vascular Plants of Ohio. The Ohio State University Press; Columbus, Ohio.

Dane County, Wisconsin. Stormwater Control.

Dilley, Clyde H. 2004. Central Ohio Native Plants, A Partial List with Sources and Bibliography.

EnviroScience, Inc. and Poggemeyer Design Group. July 2005. Natural Resource Zoning Models. EnviroScience, Inc. 3781 Darrow Rodad; Stow, OH 44334-4035. www.enviroscienceinc.com

Federal Interagency Stream Restoration Working Group. Revised 2001. Stream Corridor Restoration: Principles, Processes, and Practices. FISRWG (15 federal agencies of the US gov’t). GPO Item No. 0120-A; SuDocs No. A 57.6/2:EN3/PT.653. available at: http://www.nres.usda.gov/technical/stream_restoration

Gleason, H.A. and A. Cronquist. 1991. Manual of the Vascular Plants of Northeaster United States and Adjacent Canada, 2d ed. New York Botanical Garden; Bronx, N.Y.

FMSM Engineers. November 2004. Environmentally Sensitive Development Area External Advisory Group Recommendations. Prepared for Ohio EPA and City of Columbus Public Utilities. available at: www.bigdarby.org

Hightshoe, Gary. 1987. Native Trees, Shrubs, and Vines for Urban and Rural America. Van Nostrand. New York, NY.

Lowden, Richard M. 1997. A Central Ohio Flora, Manual of the Vascular Plants of Franklin County. The Ohio State Herbarium; Columbus, Ohio.

Mack, J.J. 2001. Ohio Rapid Assessment Method for Wetlands v. 5.0, User’s Manual and Scoring Forms. Ohio EPA Technical Report WET/2001-1. Ohio Environmental Protection Agency, Division of Surface Water; Columbus, OH. Available at: http://www.epa.state.oh.us/dsw/401

Natural Resources Defense Council. 2001. Stormwater Strategies: Community Responses to Runoff Pollution. Available at http://www.nrdc.org/water/pollution/storm/stoinx.asp

Ohio Department of Natural Resources, Division of Natural Areas and Preserves. 2003. Invasive Species Information. Available at http://www.odnr.com/dnap/invasive/default.htm

Ohio Department of Natural Resources, Division of Natural Areas and Preserves. 2005. Native Ohio Tree Species Suitable for Planting Within 1,000 Feet of State Wild, Scenic, and Recreational Rivers. Bob Gable;

Ohio Department of Natural Resources, Division of Soil and Water Conservation. May 18, 2005. Rainwater and Land Development Book, Draft. available at: http://www.dnr.state.oh.us/soilandwater

Ohio Environmental Protection Agency, Division of Surface Water. May 16, 2005. Total Maximum Daily Loads for the Big Darby Creek Watershed, Draft Report for Public Review. Available at: www.epa.state.oh.us/dsw/tmd/DarbyTMDL

http://www.darbycreek.org

Prince George’s County Maryland. 2001. Bioretention Manual. Department of Environmental Resources. http://www.goprincegeorgescounty.com/government/agencyindex/der/esd/bioretention/bioretention.asp

Reed, P.B., Jr. 1997. Revision of the National List of Plant Species That Occur in Wetlands. Department of the Interior, U.S. Fish and Wildlife Service; Washington, D.C.

Reed, P.B., Jr. 1988. National List of Plant Species That Occur in Wetlands. Department of the Interior, U.S. Fish and Wildlife Service; Washington, D.C.

Schueler, Thomas R and Heather K. Holland, eds. 2000. The Practice of Watershed Protection. Center for Watershed Protection.

Soil Conservation Service. Soil Survey of Franklin County. 1980. United States Department of Agriculture. . www.frnklinswcd.org/Soil/soilmain.htm

Tiner, Ralph W. 2002. In Search of Swampland. Rutgers University Press.

Tiner, Ralph W. Jr. 1988. Field Guide to Nontidal Wetland Identification. Maryland Dept. of Natural Resources and U.S. Department of the Interior.

U.S. Army Corps of Engineers (ACOE). 1987. Corps of Engineers Wetlands Delineation Manual. Technical Report Y-87-1. U.S. Army Corps of Engineers, Waterways Experiment Station; Vicksburg, MS.

USDA, NRCS. 2002. The PLANTS Database Version 3.5. National Plant Data Center; Baton Rouge, LA 70874-4490. Available at: http://plants.usda.gov

Ward, Andy et al. 2002. Sizing Stream Setbacks to Help Maintain Stream Stability. American Society of Agricultural Engineers Paper Number 022239.

Wenger, Seth. 1999. A Review of the Scientific Literature on Riparian Buffer Width, Extent and Vegetation. Institute of Ecology, University of Georgia; Athens, GA 30602-2202.