The stormwater ordinance, and some questions raised by basic arithmetic


Until now, the rain that’s fallen on Harrisonburg’s impervious bits – roofs, roads, parking lots, etc. – has found its quiet way down the storm drains, into our friendly local creeks, and on around the bend. But it’s soon going to demand a lot more attention by trickling into the checkbooks of all of us friendly local property owners by way of the city’s new stormwater utility fee.

This new fee will cost the average city homeowner somewhere in the range of $50 per year, and is being put in place to help the city meet some pretty stiff requirements to make the water flowing quietly down our storm drains a lot less polluted.

The fine print involves a frightening mess of acronyms – TMDL, MS4, WIP (phases I, II & III), etc. – and is surrounded by the monumental chaos of various bureaucracies trying to enact an extremely costly and controversial bit of public policy. (Here’s as good a place as any to start with a broad overview; here’s a previous OSH article about this issue as it pertains to Harrisonburg).

For now, suffice it to say that this new fee is part of the bigger regional effort to clean up the Chesapeake Bay. That’s been going on for decades, but it’s gotten a lot more serious now. Under threat of fines and other sanctions, the federal government is requiring Virginia to make its water a lot cleaner. And thus is the Va. Dept. of Environmental Quality requiring, under the threat of fines and other sanctions, cities to make their stormwater a lot cleaner. And thus did city council unanimously adopt the stormwater ordinance this week. (The matter will be up for a second reading and final passage next month).

If you own a home in Harrisonburg, as of July 1, you’ll owe a few dozen more bucks to city, which will use it to do things like build a “regenerative stormwater conveyance” in the median of East Market St. And I think that’s a good thing. Blacks Run and downstream should benefit. Lord knows Blacks Run needs it, and that sort of thing doesn’t happen for free.

Each property owner’s fee will be based on that property’s impervious surface area, as calculated by the city’s analysis of aerial imagery. According to public works, my place on Collicello Street – it’s a pretty standard c. 2,000-sq-ft, two-story deal, plus a little backyard shed, plus a little patio that they hopefully didn’t count since it’s dry-laid brick and therefore entirely permeable – has 1,116 square feet of impermeable surface. That’ll cost me $21.00/year. If I want, I could reduce that fee by up to 50 percent if I get intense about mitigation with “best management practices” like rain barrels and conservation landscaping and etc. To be honest, I’ll probably just hold the course with my own “not too shabby management practices” and pay the extra $21. (For more detail on how the fees are calculated and how you, too, can best manage your stormwater, lots of detail in this document.)

Assuming the ordinance takes full effect next month, the city will launch a GIS website that will allow property owners to check out their specific situations. In the meantime, if you call and ask nicely, they’ll probably tell you. In total, public works projects to raise close to $2 million per year with the new fee.

Back now to the basic premise of all this: cleaner runoff into Blacks Run, with specific state-mandated targets for reduction nitrogen, phosphorous and sediment.



The basic unit here is reduced pounds per year. I.e., by 2018, the entirety of stormwater running off of land within city limits each year will contain 347 fewer pounds of nitrogen, 34 fewer pounds of phosphorous and 37,978 fewer pounds of sediment than compared to a 2009 baseline. As you can see, things start easy and get a whole lot harder.

The first big project that’s planned is the regenerative stormwater conveyance along East Market Street. Public works staff described it at the city council meeting as a low-hanging fruit sort of project that will treat water running off 96 acres in one of the city’s highly impervious commercial areas. At a cost of $606,000, it will remove 18.6 pounds of phosphorous per year from the city’s total discharge (its nitrogen and sediment reductions haven’t been calculated yet; since it’s impractical to actually sample runoff as it’s running off, the city’s progress toward its stormwater goals will be measured by engineers’ on-paper calculations of a given project’s effect.)

On the plus side, the East Market thing gets the city more than half the way to its 2018 target for 34 pounds of phosphorous reduction . At the same time, this low-hanging fruit deal gets the city just 2.7 percent of the way to the 2028 end goal of 673 fewer pounds of stormwater phosphorous.

The math here works out to about $33,000 per pound of phosphorous removed. At that rate, achieving the full 2028 reduction will cost $22 million. But that’s the low-hanging fruit rate. You can certainly bet the final total will be much higher. Maybe much, much higher, though no one really seems to know how much.

One other math thing. The East Market St. project will nab low-hanging pollution fruit on 96 acres. That’s getting close to 1 percent of the total land area of the city, (c. 11,200 acres) and the total phosphorous reductions aren’t even going to reach 3 percent of what the state is ultimately asking for. Given that that 96-acre area is parking lot- and roof-intensive, and that big swaths of the remainder of the city aren’t, it’s kind of hard to imagine how this will even be possible, regardless of final cost (and assuming that nitrogen and sediment reductions are no more difficult to come by than phosphorous).

There was some talk at the council meeting about nutrient trading, which might help, but it felt very vague. Fuzzy math, vagueness and confusion have been a huge gorilla in the room when it comes to improving water quality from farm runoff in the area, and that seems to be the case here too. That’s not to say the intentions aren’t good, nor to cast aspersions on the East Market regenerative stormwater conveyance, nor to suggest that nothing should be done. It’s just… well, hopefully, for the sake of clean water and public budgets, there’s a lot more low-hanging stormwater fruit out there for the city to pick.


This entry was posted in The Burg Abides. Bookmark the permalink. Trackbacks are closed, but you can post a comment.


  1. Jared Stoltzfus says:

    I was the Stream Health Coordinator for 2 years (06-08) and am now a PhD candidate in the School of Sustainability at Arizona State University. I hope to return home, and try to keep up to date on happenings in the burg, (and Blacks Run especially) so I was excited to follow the Stormwater Regulations. I’ll be the first to agree that $606K to get us 2% of our way to our final goal is not encouraging, but wanted to share my thoughts too… In 96 acres of commercial development, I wouldn’t expect to see a lot of P, N, or sediments in the runoff because there’s virtually no soil there! The high cost comes from trying to put a strainer (to catch VERY dilute nutrients) at the end of a firehose… if the 96 acres had been layed out to disperse rainwater to various raingardens, bioretention basins, or just more outlets to the stream it wouldn’t have cost $606K. Years ago we put a raingarden in place at Westover to treat ~1 acre of parking lot. Total cost of that project was around $1000. With enough small, cheap systems in place throughout the city (which includes projects done by homeowners) I think the numbers will quickly add up. If I remember correctly, the Quarry on Waterman Ave was permitted to discharge about 40,000 lbs of sediment per year into a drainage ditch that flows into Blacks Run. Revoke that permit (ie, make them clean their own water) and we’re set through 2018… How many other commercial/industrial facilities are contributing large volumes? Those won’t be (or shouldn’t be) taxpayer expenses…

    • Andrew says:

      Interesting point about there being little N, P or sediment running off of parking lots and the mall roof – I hadn’t thought about that. How do you square that with this being the city’s first low-hanging fruit project?
      The $606k cost is actually being split 50-50 between the city and a state grant, so the state has also seemed to decide that the E. Market project amounts to a few hundred grand well spent on stormwater mitigation.
      I think large, sudden volumes of stormwater runoff, polluted or not, are bad since they cause floods & bank erosion downstream. Right? So would just slowing down the water running off those impervious areas have a big net positive effect on sediment and nutrient pollution further downstream?

      • N and P are not the only pollutants. We can hope that some of the others, in this case associated with automobiles and commercial roofs might bioremediate. Polycyclic aromatic hydrocarbon (PAH) will not. But at least they will not get to the watershed. PAH is a major problem that we really should be working on next. The Chesapeake Bay act provides authority for that regulation and City Council has enacted it. It just needs to be applied to the major source: coal tar parking lot sealant. The area in question here is not affected yet, as far as I have seen. Most of the low income shopping centers, however, have been coated with coal tar parking lot sealant in the last year or so as the product is being banned around the country.

        The E. Market project being considered low hanging fruit may highlight the fact that credits are based on models rather than measurements. If you build to a certain engineering specification, you get credit according the the model. It might be work looking into the assumptions, now that we have a concert example in mind. Soon we will have the raw GIS files from the city so the public can look at this in free software such as QGIS or R.

        It was pointed out by a water expert from the public at one SWAC meeting that if we were serious about reducing pollution, the easiest thing would be to stop purchasing and dumping N and P on our lawns.

        This project is a major positive development that could contribute tremendously to the future prosperity of the city, but more on that later.

      • Jared Stoltzfus says:

        Reducing downstream erosion will certainly have a large impact on N and P (plus sediment) reductions, so maybe that’s the main purpose? The comment below also says the credits are based on models, and this model probably says X gallons of water ‘treated’ = X amount of N and P. It may also be one of the only sites where 1 project treats such a large volume of water, and that’s why it’s considered low-hanging fruit… To hit 2% of the goals for the whole city in 1 project may prove fairly significant, though I’m still concerned about the cost for the rest of the projects.

      • Jared Stoltzfus says:

        In a conversation with a homeowner whose property I’m familiar with, I started to wonder how exactly the ‘impervious surfaces’ would be calculated to assess stormwater fees on each property. The property we were discussing is roughly 25% impervious between the paved driveway, house, and sidewalks. However, the driveway runoff flows into the back yard landscaping where it always soaks into the ground, and the gutters on the house also direct water into the yard. If the city actually looks at stormwater discharged from this property, there isn’t any- so will there still be a fee?
        The way this gets calculated is critical because there are many ways for homeowners to harvest the rainwater that falls on their property: rain barrels, rain gardens, or just diverting downspouts into the yard (assuming you don’t have compacted, clay soils). Recognizing these practices and reducing the stormwater fees accordingly would be enough incentive for many homeowners to act… I’d personally put a small bump on my sloped driveway in order to direct all the water into the yard if it would reduce my stormwater fee!

Post a Comment

Comments Policy

This is a thoughtful blog about Harrisonburg for thoughtful adults who care about Harrisonburg. Unfounded personal attacks, off-topic ranting and general internet pettiness, meanness, vulgarity or stupidity do not have a place here. And we’ll be the judge of that.

Your email is never published nor shared. Required fields are marked *