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Stormwater Testing and Evaluation: Improving Water Quality
The Stormwater Testing and Evaluation for Products and Practices (STEPP) Initiative seeks to improve water quality in the United States with the implementation and adoption of innovative stormwater management technologies and by removing current barriers to innovation, creating regulatory confidence, minimizing duplicative performance evaluation efforts, and establishing a common framework for testing and evaluating both public domain and proprietary stormwater control measures.
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As stormwater-related pollution has increased, regulatory programs have been established at the state and federal levels to address the effects of stormwater runoff. Various stormwater control measures (SCMs), such as proprietary products and public domain practices, have been developed and have evolved to address runoff issues.
As the diversity and complexity of SCMs has grown, the need to develop a process to test, categorize, review, evaluate, verify, and certify/approve stormwater runoff controls became evident. This process ensures that the efficacy of products and practices meets performance expectations, which often are tied to permit requirements. Some programs to test and evaluate SCMs have arisen at the state, regional, and national levels, but these have had mixed results.
Beginning of the Initiative
The STEPP initiative was triggered, in part, by the end of the only national evaluation program for stormwater technologies, the U.S. Environmental Protection Agency (EPA)
environmental technology verification (ETV) program. The STEPP program was created from a 2012 meeting of interested parties representing the product manufacturing, consulting, and regulatory sectors. The Water Environment Federation (WEF) volunteered to investigate the need for a national testing and evaluation program for stormwater products and practices, and formed a STEPP workgroup.
A white paper was released (2014, WEF) that summarized the findings of the workgroup. The report noted that a national SCM testing and evaluation program would be beneficial to multiple stakeholders (regulators, municipalities, technology providers, consumers, etc.). The result of this 2014 investigation was that agreement existed on the feasibility and the need for a national program.
With support from EPA to move beyond the investigatory phase, a STEPP steering/ advisory committee was assembled. It became part of the WEF Stormwater Institute in 2015, which morphed the steering committee into a work team.
This second phase sought to develop a report to recommend the scale, scope, architecture, funding, and leadership for a national program. The committee used five stormwater and nonstormwater technology evaluation programs as models for the potential design components to be considered for the STEPP program. Additionally, two informal surveys of states and municipal separate storm sewer system (MS4) permitees assessed their needs and how they might use such a program.
A feasibility report was released in 2016 that laid out the potential framework and policy options for the STEPP program (WERF, 2016). Findings from this document include: S Enhance and further implement recruitment strategies through partnerships with stakeholder groups.
These include individual states, MS4 permittees, EPA, academic researchers, the development community, nongovernmental organizations, and others. S Promote the adoption of a flexible
“cafeteria plan” approach for a national program that is envisioned to evolve continually over time. A cafeteria plan option allows both technology proponents and regulatory entities to have flexibility in designing a SCM study and determining how to meet specific state and local regulatory requirements.
Individual program features that were explored included mission and objectives, program services, organizational relationships, operational structure, governance, funding, stakeholder engagement and transparency, testing purpose and scope, the setting for testing, and reciprocity. Continued on page 6
Initiative Participants Selected and Meetings Held
The STEPP program continued to evolve. In the summer of 2017, WEF hosted a meeting to consider the potential of a multiorganizational partnership to work together by leveraging the respective strengths of each organization to further the goals of the STEPP concept (June 2017, meeting synthesis). The result is the STEPP consortium group, which is led by WEF and includes the following participants: S American Society for Testing Materials (ASTM International) S Interstate Technology and Regulatory
Council (ITRC) S Water Research Foundation S Washington State Department of Ecology,
University of Washington – Washington
Stormwater Center, Technology
Assessment Protocol – Ecology (TAPE) S New Jersey Corporation for Advanced
Technology (NJCAT)/New Jersey
Department of Environmental Protection (NJDEP)
These organizations have worked
Figure 1. Stormwater Testing and Evaluation for Products and Practices Consortium Group Partners
Figure 2. Stormwater Testing and Evaluation for Products and Practices Consortium Group Partners Proposed Tasks together to articulate an initial understanding of their respective roles as STEPP matures into an independent program, which is outlined in the document, “Stormwater Testing and Evaluation of Products and Practices (STEPP) Consortium Overview.” The work team and the consortium met and reviewed this document with no major disagreements, which suggests that the work team supports the members of the consortium, as well as their roles as outlined in the document. This document formed an initial basis of understanding regarding the various roles that the consortium group members would play as STEPP continues its work.
To help move the STEPP initiative forward, the meeting focused on two areas. First, the roles outlined in the consortium document needed to be developed in greater detail. Second, the activities and schedule associated with the STEPP initiative over an estimated six to 12 months needed to be fleshed out. These two proposed and preliminary focus areas underpin the development of memoranda of understanding (MOUs) that needed to be created to formalize the relationships among the consortium group partners, and to the program overall.
The next meeting, held July 2018 and hosted by WEF, again brought the organizations together, along with the WEF Stormwater Institute STEPP work team, to refine the roles each organization could play in the STEPP program, consider more detailed policies, and identify initial coordinating activities among the consortium group partners (July 2018, meeting summary).
The focus for discussion was on SCM verification programs and issues, with a specific focus on the STEPP program initiative. Objectives for the discussion included: S Provide an overview of the STEPP consortium group. S Develop a more detailed/enhanced understanding of the roles of consortium group members in the STEPP program. S Identify and discuss key areas of focus that will enable the STEPP program to progress. S Develop a list of near-term activities for consortium group members, along with a schedule for activities. S Discuss the nature of the MOUs, along with proposed MOU elements, articulating the relationship of consortium group members with the STEPP program initiative, and the contributing products and/or activities that each member can provide toward the further development of the STEPP program. Continued on page 8
Continued from page 6 S Develop a list of areas for further and deeper understanding and research. S Develop a list of next steps in the STEPP program initiative for work team and consortium group members.
Another topic discussed at length during the meeting focused on the number of storm events needed for statistical significance and/or confidence in product or practice performance. A related issue that was discussed was the concept of developing a single standard for data collection associated with field testing and evaluation, rather than a series of standards based upon geographic, physiographic, or ecographic regions.
Related to this would be the concept of a base level of data collection required in a verification effort, with no prescriptive information related to certification at all, as STEPP will only be a testing and verification program. Certification will be done at the state and local levels, with testing information based on standard verification protocol.
An area of agreement on this topic was the need for research funding to develop a deeper understanding of the relationship between data sample size for storm events and the statistically defined level of confidence associated with product or practice performance.
It was suggested that the STEPP program could develop guidance based upon this type of research, which could be referenced in an ASTM standard on the issue of data collection for field testing and evaluation. The significance of this issue is related to the cost and time required for stormwater product or practice testing and evaluation.
A central tenant of the STEPP initiative is the need to reduce testing/evaluation time and costs in order to drive further innovation in the sector, as well as providing greater opportunities to responsibly drive new and emerging technologies to the market and into implementation.
Associated with further partner engagement is the need to interact with the states. The STEPP program has been working closely with the Association of Clean Water Administrators (ACWA), which represents state regulatory staff for the wastewater and stormwater sector. In a survey of ACWA stormwater committee members, over 95 percent of those who responded did so favorably when asked about support for STEPP.
It was recognized that some states may be more interested than others to actively engage in and support the STEPP program. Those involved groups most closely aligned with state regulators suggested that an outreach strategy should be developed to target those states that would be most supportive in order to gain support of a critical mass in a moreefficient manner.
The bottom line is that states that are not supportive of STEPP and will not certify products or practices based upon STEPP verification results will undermine the potential success of the program; therefore, it was recognized that gaining support from a critical mass of state regulatory programs is likely needed to show value in terms of market size for product manufacturers.
Letters of Support From Other Organizations
The STEPP group has received unsolicited letters of support from several jurisdictions, states, and organizations, such as: S Associated General Contractors of
America S International Council of Shopping
Centers S Leading Builders of America S National Apartment Association S National Association of Home Builders S National Multifamily Housing Council S National Association of Realtors S Retail Industry Leaders Association
These groups are pleased to support the development of a STEPP program, as outlined in the recent report, “Framework for a National Testing and Evaluation Program Based Upon the STEPP Initiative.”
Other groups and entities offering support include: S The Michigan Department of
Environmental Quality (MDEQ),
Water Resources Division, supports the recommendations of the national STEPP workgroup steering committee. Letters of support from other states have been received as well. S It’s the understanding of NJDEP that WEF is determining the feasibility of creating a national protocol for the testing and evaluation of manufactured treatment devices. The department fully supports the development of such a protocol and applauds WEF’s leadership and efforts in this matter. S The Washington State chapter of the
American Public Works Association’s
Stormwater Managers Committee expresses its support for developing a national testing and evaluation program for stormwater products and practices. S The State of Washington Department of
Ecology supports the idea of a national program that provides a level of detail comparable to its program and that addresses its concerns.
