Controlling Stormwater from Federal Facilities

Hamid KarimiDistrict Department of the Environment

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Impervious and Total Land Use Areas in D.C. by Category

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34%

1%1%

20%11%

7%

28%

1%

% of Billed Impervious Area by Category

Commercial

DCHA

EX

Federal

Multifamily

Muncipial

Residential

WASA

Source: DC Water

23%

6%

11%

31%

27%

2%

Land Use by Category

Residential

Multifamily

Commercial

Municipal

Federal

Vacant

Source: Office of Planning, December 2006

D.C. Has a Unique Relationship with Federal Facilities

• Federal facilities are the second largest landholder in the District

• Federal facilities don’t pay taxes• Some federal facilities lie in areas partially outside of the

MS4 area referred to as “other areas” where they discharge stormwater directly to the Anacostia and Potomac Rivers.

• Because of the large amount of land they occupy and their physical location close to the rivers and streams, D.C. must find a way for them to contribute to the obligations of the Bay TMDL and D.C. WIP

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D.C.’s Approach to Working with Federal Facilities

DDOE has had a long standing working relationship with federal facilities regardless of regulatory requirements– DDOE held a meeting in March of 2009 to discuss the

implementation of section 438 of EISA– EISA states that: Federal projects shall retain the 95th Percentile

Rainfall Event (1.7” in the District), or Replicate the pre-development hydrology of the site

– DDOE has held follow up meetings with DoD and GSA discussing EISA requirements and even for a specific GSA project

During the development of the District’s WIP, DDOE reached out to nearly all federal facilities in the District; ensuring that all initiatives by federal facilities were accounted for in the WIP6

Challenges• D.C.’s relationship with the federal facilities is very

straightforward where the MS4 Permit is concerned• Good intentions are often expressed, but budget

constraints stand in the way of firm commitments on any projects that are not somehow regulated

• D.C. has limited regulatory authority and little recourse

• Logistical constraints exist due to the scattered nature and sheer number of federal facilities located in D.C.

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Future Initiatives• DDOE plans to hold a meeting with federal facility

partners once the District’s new MS4 permit is issued and the District’s new stormwater regulations have gone out for public comment– This meeting will focus on the expectations of federal

facilities to comply with the WIP. Complying with the WIP will also bring the federal facilities into compliance with the TMDL,Executive Order #13508, EISA, DC MS4 Permit, and District stormwater regulations.

• DDOE plans to help federal facilities write their own 2 year milestones that will complement and inform the District’s 2012 two year milestones 8

Questions

Hamid KarimiDeputy Director Office of Natural Resources

District Department of the Environment202-535-1660

hamid.karimi@dc.gov

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