Green infrastructure (GI) is entering a “make it or break it” phase; certain communities, with support from federal and state agencies, are now willing to invest broadly in GI, such as vegetated bioswales or green roofs, as a way to manage urban stormwater. These forward-thinking communities, many of whom see the challenge of wet weather control through the lens of combined sewer overflow and stormwater control requirements, are now increasingly willing to opt for “green” rather than traditional “gray” pollution control approaches. This is in large part because of the effective advocacy and outreach that key activist organizations, like the Natural Resources Defense Council (NRDC), have successfully conducted on behalf of GI.
Environmental groups have spent tremendous resources in recent years promoting and encouraging GI approaches to stormwater/wet weather management. Pioneering publications like NRDC’s own Rooftops to Rivers report helped open the door to GI as a solution to wet weather challenges not simply as a cosmetic addition to gray infrastructure techniques but potentially as a substitute. NACWA saw the value of the NGO groups’, including NRDC’s and the Low Impact Development Center’s (LIDC), effort to support GI and joined in signing a collaborative Statement of Intent in 2007 with the U.S. Environmental Protection Agency (EPA), LIDC, the Association of Clean Water Administrators (ACWA), and NRDC.
As a result of all these efforts, EPA has supported GI conceptually and through practical implementation, approving its inclusion as a core component of consent decree settlements including a recent partnership with Philadelphia. Today EPA released a software tool that allows users to determine how GI can be one of the most cost-effective ways to curb stormwater runoff. Additionally, last year, the Agency released its Integrated Planning Framework, which emphasizes sustainable stormwater management. GI is one tool a community has to control wet weather and NACWA believes the site-specific circumstances of a community should determine how narrowly or broadly it should be used. NRDC recently blogged that “EPA … knows that green infrastructure is a cost-effective, multi-benefit set of strategies that prevents rainfall from becoming polluted runoff.” Simply put, GI is now a vibrant component of EPA’s core water program. The bottom line is that we are quite close to the Statement of Intent’s GI vision being realized and at this vital juncture we must now strengthen our collaboration not step back from it.
The only way to fully realize the potential of GI is through large-scale pilot projects. Philadelphia is a good start. But the question must be asked: at a time when such robust pilot programs are necessary to lay a foundation for GI as an implementable city-wide approach, why has NRDC reacted skeptically and so publicly to news of DC Water’s intention to develop GI pilot projects as a key component of its Long Term Control Plan (LTCP)?
NRDC’s recent Op-Ed in The Washington Times seems to imply a certain amount of buyer’s remorse on GI. On the one hand the NRDC Op-Ed reads:
Contrary to the article’s implication [see June 2 article in the Washington Times], NRDC strongly supports Integrating smart 21st-century innovations into municipal water-restoration initiatives in Washington and across the nation. “Green infrastructure” techniques often can solve the same flooding and pollution problems as effectively as gray approaches, but with additional benefits such as cost savings and healthier communities.
Yet in the same article, NRDC states that:
Because green infrastructure competes well with other stormwater-management techniques and because sewage overflows threaten public health, weakening sewage-overflow protections to accommodate green infrastructure is unnecessary and irresponsible.
If GI competes well with other techniques and can solve the same flooding and pollution problems as effectively as gray — coupled with the fact that if any plan that governs the implementation of a GI program to control wet weather would have the same force of law as a gray infrastructure approach —, why is there a presumption that moving in the direction of green rather than gray would “threaten public health” or somehow weaken “sewage overflow protection”?
NRDC has been a leader on GI but it cannot have its cake and eat it too. It cannot declare that the time for GI is now, but then retreat into a position that its implementation should only be additive to gray. Nor is it fair to support one plan but back away from others that are equally deserving. Neither is it consistent to advance and tout a new approach only to withhold support from communities that are already under agreements -especially if there is a window of opportunity to adopt a smarter way to protect the environment. The prime mover of a vision for a new paradigm cannot then disavow it when the time comes to put it to the test.
Rather than support a collaborative initiative that will invest in distributed GI projects, lead to cost savings for stressed rate-payers, and address the most pressing wet weather challenges, NRDC, a staunch GI supporter in many respects, seems to be resistant to GI piloting efforts. NRDC and other groups need to make their message to the public consistent. Entities willing to spend the necessary funds on large-scale GI projects which must meet benchmarks and are subject to legal assurances, should receive their unwavering support. On behalf of our clean water utility members, we call on NRDC and the environmental community to maintain their historically consistent position on GI and work with the utility community to promote and ensure the success of viable GI programs.
Again, at this critical juncture we must now strengthen our collaboration not step back from it.