York County WIP – IWRP and CBPRPs

A key strategy, supported by PA DEP, that is worthy of specific mention is the preparation of a County or Regional Chesapeake Bay Pollution Reduction Plan (CBPRP). All MS4 municipalities will be required to submit a CBPRP to PA DEP within one (1) year of receiving their MS4 Permit. Through an intergovernmental cooperative effort, a single Plan could be prepared at a lesser cost than multiple individual Plans. This cost savings could then be directed to implementing the BMPs. Additionally, this effort would enable participating municipalities to contribute to potentially larger structural BMP projects that would result in greater strides toward meeting the County targets. Likewise, they would receive credit for contributing to such projects, regardless of whether they were located in their MS4 urbanized area. The premise is that successful implementation of large projects identified in a County or Regional CBPRP could result in the reduction of more pollutants that an abundance of smaller projects listed in individual municipal CBPRPs.

Another notable strategy is using the York County Integrated Water Resources Plan (IWRP) Flowchart Tool. This web-enabled tool (www.paiwrp.com) integrates many of the solutions identified by this WIP into an overall process, addressing water related issues in a holistic manner. The development of a methodology by which municipalities could incorporate the Flowchart Tool into regulations, policies and/or procedures, would facilitate implementation of the County’s WIP, largely by addressing its identified solutions.

York County WIP – Strategies

The solutions identified in Section IV of this Plan are effective at reducing pollutants only if implemented. The focus of this Section is to establish viable strategies by which identified solutions will be implemented throughout York County. These strategies relate solely to the solutions recommended in this Plan.

Additionally, it is important to reiterate that these strategies are intended to not only clean up York County waters and assist the County with meeting its Draft Planning Targets, but also to aid Pennsylvania in meeting its target allocations. Through implementation of the strategies noted in this Plan, strides can also be made in helping the County to not be subjected to potential US EPA backstops in the future. 

This Plan is a start for municipal action. It did some up front thinking to identify priority areas and priority tools that make sense. A countywide or regional approach to implementation may realize an increased chance of success. 

It is apparent that local governments will need to use coordination, cooperation and communication to carry out many of the strategies recommended in this Plan. This includes, but is not limited to, engaging citizens, environmental organizations, non-profit groups, and public/private foundations. Often times, these groups will gladly volunteer to support local initiatives that restore and protect local waters when they understand the threats to those waters. Additionally, financial resources and technical assistance will likely be needed.

Rather than just listing strategies, a table is being used to set forth the strategies to implement the solutions. The table (See pages 24 and 25) sets forth not only implementation strategies for each of the four (4) solutions, but also notes the recommended time frame for implementation, the lead and/or partner agencies responsible for implementation of the strategy, and tasks that the Coalition for Clean Waters could carry out to assist with implementation. This format is often referred to as a “crosswalk.”

The “Lead Agency” refers to the entity that would take primary responsibility for implementing the strategy, while “Partner(s)” refers to entities that would assist the Lead Agency with implementing the strategy. The time frames for implementation are described as follows:

• Ongoing - Tasks that are initiated as the opportunity arises and should continue. 
•  Immediate - Tasks that should be undertaken as soon as possible following completion of the Plan. 
•  Short-Term - Tasks that should be implemented within years one (1) through four (4) following completion of the Plan. This reflects implementation by US EPAs 2017 milestone, which has a target of meeting 60% of the pollutant reductions. 
•  Long-Term - Tasks that will be implemented in year five (5) or longer following completion of the Plan.

York County WIP – Criteria for Evaluating Solutions

Cost versus effectiveness is the ultimate bottom line when considering solutions; how to get the proverbial “biggest bang for the buck.” The effectiveness of each solution would be based upon the size of the pollutant load that is cleaned up by a particular remedy and the time it takes to accomplish it. The catch is that many factors come into play when calculating both the “bang” and the “buck.”

Among the factors are geographic considerations, such as outfall location, headwater areas and confluences. In addition to location within the watershed, environmental factors, such as soils, geology, impaired streams (see Appendix B) and species of concern; operation/maintenance; and sustainability need to be analyzed when contemplating the most effective solution to reduce nutrient/sediment pollution. The cost of implementing the solution also needs to be considered, in conjunction with effectiveness, to ensure practicality, as well as getting the most pollutant reduction for each dollar spent. At times, site restraints may prevent the use of the most effective and/or the least expensive solution. Among the common restraints are location of solutions, pollutant sources, population centers, types of land use, landowners, and funding sources.

When calculating financial costs for a particular solution, the achievement of multiple objectives should likewise be considered. York County has many plans, assessments, and reports concerning the County’s water resources, all with recommendations, goals, and objectives. For example, if a particular pollutant reduction solution also reduces an environmental hazard and/or provides an identified recreational need, achievement of multiple benefits may turn an otherwise economically impractical solution into the most cost effective remedy. Established TMDLs, Watershed/Rivers Conservation Plans, MS4 permits, County land preservation programs, and County/municipal comprehensive plans are some examples of environmental planning efforts throughout the County that should be consulted when establishing project priorities for this Plan.

The criteria presented above for evaluating solutions can be summarized as follows:

• Pollutant source/type
• Target impaired waters
• BMP efficiency (cost/benefit)
• Secondary benefits
• Cooperative partners
• Public vs. private projects
• MS4 compatibility
• Funding availability

York County WIP - BMPs Not in the Current Bay Model

The current Chesapeake Bay Model has limitations, which results in certain types of pollutant reduction activities (BMPs) not being considered for credit. These limitations may exist for various reasons; however, it is worth examining the potential to revise the Model to credit such activities. A process exists by which new technologies, unthoughtof reductions, or intentionally not included BMPs may be included/reconsidered in the Model. Municipal leaf pick-up programs and surface water supplier sediment filtration processes may be examples of such activities. Awareness of such activities or BMPs that reduce nutrients and/or sediment is the first step for credit to be acknowledged in the Model.

There is evidence to indicate that some York County pollution reductions are resulting from a practice that is not recognized in the Model. These pollution reductions should not be overlooked. The merit of working with PA DEP to incorporate such pollution reductions into the Bay Model needs to be determined. Nevertheless, due to the complexities of the Model, potential difficulty in calculating pollutant reductions, and ecological factors that influence reductions, obtaining credit may be a lengthy process, if possible at all.

Success of this solution will be contingent upon availability of necessary data to document the pollution reduction and cooperation from regulatory agencies. There is potential for supporting documentation to exist on pollutant reductions resulting from some activities, such as municipal
leaf/yard waste pick-up programs and sediment removal from surface water supplier intakes. For example, municipalities may track tonnage of waste picked up, while water treatment plants
may track the tonnage of sediment removed from their source water. This data, as well as additional information, would likely be needed to obtain credit retroactively, and annually into the future,
for these types of activities. As stated previously, US EPA and the Chesapeake Bay Program are in the process of developing guidance that will be beneficial to the data collection effort. It is also
important to note that for BMPs to be credited under this solution, they must have been implemented on or after January 1, 2006.

Public Misperception of Quiescent Mill Ponds

Sunday's York Daily News contained an excellent article "Fix PA's Killer Dams", by Scott Fisher, Editor, about the dangers.

However, one reader commented that "The dam appeals to me, recalling a recent kayak paddle miles upstream and saying he has caught large fish in the pools created by the dam. If the dam(s) were removed, we'd end up with a shallow, rocky creek that would be useless for such activities."

The public maintains the misperception that these quiescent mill pond settings are both normal and healthy ecosystems. I argue they are not. Dams of all sizes are the direct result of the loss of migrating American shad, Atlantic eels, numerous freshwater shellfish, and other migratory species.

Impoundments behind dams often have poor water quality and may not have the quantity and diversity of aquatic species often found in a free-flowing river. Typically, the tail-water runs approximately one to two miles upstream of these dams.

Removing dams brings different ecological benefits, including restoring free-flowing rivers, enabling unobstructed fish passage, and improving water quality (Scruton et al., 1998; Bednarek, 2001). Bednarek (2001) reviewed the long-term and short-term ecological impacts of dam removal based on 16 dams. She concluded that biotic diversity could increase by removing the dams and that the increased sediment load was a short-term effect. Scruton et al. (1998) showed an 18-fold increase in biomass of juvenile salmon and trout, a result of a 62% habitat increase after removing some dams.

Removing these dams in York County have shown immediate improvements in water quality and diversity of aquatic species often found in a free-flowing river, as well as eliminating a public health and safety hazard.

Ways to Achieve and Account for Pollution Reductions - Best Management Practices

Best Management Practice (BMP) solutions consist of two (2) general types: structural BMPs and non-structural BMPs. Both types will need to be an integral component of York County’s Watershed Implementation Plan (WIP) strategy. Moreover, the sustainability of York County’s water resources will depend upon incorporating BMPs into all aspects of our communities and lives. The Pennsylvania Stormwater BMP Manual identifies and describes both structural and non-structural BMPs and, in addition, provides design/construction criteria for structural BMPs. Nevertheless, a brief overview of each type is provided below.

Non-structural BMPs: Non-structural BMPs are practices that incorporate techniques and behaviors that do not involve physical construction. Education, outreach, planning, ordinance provisions, and land preservation are types of non-structural BMPs.

This WIP, however, focuses on provisions that could be adopted by a municipality, either through a standalone ordinance or incorporated into an existing zoning or subdivision/land development ordinance, and, when put into practice, would ultimately help to reduce stream pollution.

These provisions include, but are not limited to, the following:

• Urban Nutrient Management
• Conservation by Design/Low Impact Development (LID)
• Green Infrastructure
• IWRP Flowchart Tool
• On-lot Septic System Management
• Protection of Sensitive Environmental Areas

Structural BMPs: Structural BMPs are those practices that use physical structures features to improve water quality.

Although PA DEP provided the County with a scenario of pollution reduction actions (BMPs) to meet the Draft Planning Targets, a primary purpose of this Plan, as previously stated, is to modify that scenario in an effort to make it better suited to York County, yet still meet the targets.

The Recommended Pollutant Reduction Actions Scenario Table (see Appendix D) includes an array of urban and agricultural BMPs to improve streams throughout the County, regardless of whether they are on the Impaired Waters List (see Appendix B), in an effort to be of benefit to both MS4 and non-MS4 municipalities.

Furthermore, BMPs that yield the most efficiency for the least amount of cost or “biggest bang for the buck” are highlighted on the Table.

With regard to recommended urban BMPs, four (4) of the BMPs are highlighted for having high efficiency and low cost in achieving reductions in two (2) out of the three (3) pollutants.

The Actions Opportunity Table (see Appendix E) notes the impaired streams by municipality and the amount of land available in the watershed to implement the Recommended Pollutant Reduction Actions or BMPs.

Both the Recommended Pollutant Reduction Actions and Actions Opportunity Tables were developed by local stakeholders, with specialized knowledge. They represent an attempt to produce a more efficient, less expensive, and more “implementable” means for York County and its municipalities to meet the Draft Planning Targets. However, the average efficiency, median lifecycle costs, and impaired waterway BMP lineal feet/acreage calculations should be used for general information and planning purposes only. Their accuracy cannot be guaranteed as there are many variables and costs are constantly changing.

The Tables can be used separately or in conjunction with one another. While all of the BMPs listed in the Recommended Actions Table are beneficial, their applicability on a watershed or municipal basis may vary.