Percent Impervious as a Threshold Option
Wednesday, October 28th, 2009It appears that the majority of the effects on stormwater quantity and quality can be tracked either explicitly or implicitly through the measurement of the percentage of impervious area on a zoning parcel of land. In reviewing literature and studies done in this regard, a few observations may prove useful in the ordinance rewrite.
- Total Impervious Area (TIA) is often distinguished from Effective Impervious Area (EIA) when tracking impacts. EIA is the portion of the TIA that has improved drainage area. It is similar to concepts like “Directly connected Impervious Area” found in TR-55. Unfortunately, it takes quite a bit of investigation to separate EIA from TIA on a project parcel, and often generalized ratios dependent on description of the land use are used rather than direct measurement.
- An on-going challenge in stormwater Ordinance language is finding language for and descriptions of “Development” that make meaningful distinctions technically, practically and administratively. One potential way out of this on-going problem is to use the % impervious of a project as a threshold trigger for certain mitigation requirements. Here is an example:
- Define any project that is less than 10% TIA as not requiring a site runoff storage facility.
- Define projects that increase the % impervious area of a project site as requiring a site runoff storage facility to mitigate the change, if the TIA is greater than 10%.
- If a project can be shown to significantly reduce the EIA, then a site runoff storage facility may not be required.
- These are only examples, but consider something like the holdings of the Forest Preserve District, or the trend toward Low Impact Design.
- The overwhelming majority of studies show that percent impervious can be correlated with the “health” of streams, with nearly all studies beginning to register stream impairments as low as 10% impervious. While that is the “bad news”, it also tells us what is and is not likely to further degrade water quality. Many studies site the percent impervious threshold for characterization of land use as rural/undeveloped less than 10% impervious, suburban as up to 50% impervious and urban as greater than 50% impervious. Is a site that has been urban for a number of years, likely to degrade or improve conditions if a new project on the site is approved as an urban land use but at a reduced percent impervious? Certainly a trend toward a watershed scale reduction in impervious surfaces has already been recognized as a goal by the EPA and as a valid approach to meeting NPDES requirements.
- What about flooding? Don’t all developments, of any kind, increase flooding? The answer is: not necessarily if one considers that the drainage of an existing land use has often been accomplished by existing drainage infrastructure for years. Consider many of our older “downtown” areas. While localized drainage problems may exist, drainage infrastructure out of the downtown area is usually “mature” at this stage, and a new outlet or modification of the existing outlet into a stream is probably not proposed. If an urban project is discharging to the same storm sewer as the previous urban land-use, is not causing its neighbors additional damages, and has actually reduced the volume of pollutants and runoff volume, doesn’t that embody the trend we desire? Considering the current push towards denser and more intense downtown land use, Does a pond or an underground tank really sound like wise use of infrastructure dollars?
Where is this discussion going? I am wondering if we can’t eliminate the often confusing pages and pages of ordinance language with something more direct, like percent impervious, that is not only more universally recognizable but more directly associated with the impacts we wish to continue regulating. Can we replace the references to single family residential, multifamily, commercial, industrial, institutional land use with thresholds of percent impervious? Is that an improvement, or just a new complication? What do you think?