STORMWATER MANAGEMENT

AT STOCKTON UNIVERSITY

Contributing authors to be added in the final edition (first worked on in Spring

2020 by Environmental Quality (ENSC 5202), last worked on in Fall 2020 by
Dana Kelly. Currently a draft.)

LAST UPDATED OCTOBER 2020.

STOCKTON UNIVERSITY

ENVIRONMENTAL SCIENCE AND GEOLOGY PROGRAM

Instructor: Dr. Tait Chirenje

ACKNOWLEDGEMENTS
ABSTRACT

To be added by Tait.
 TABLE OF CONTENTS

List of Tables 8

List of Figures 8

Definitions 12

1.​ ​Introduction to Stormwater 15

1.1 What Is Stormwater? What is Stormwater Management? 15

1.2 Importance of Managing Stormwater 17

1.3 Combined Sewer Outfalls 24

1.4 Separate Storm Sewer Systems 25

2. ​Stormwater Regulation 29

2.1 Introduction 29

2.2 National Regulations 32

2.3 State Regulations 40

2.4 Regional Regulations 48

2.5 Local Regulations 52

2.6 Conclusion 60

3. ​Stormwater Management Practices 62

3.1 Introduction 62

​3.2 Riparian Buffers 65

​3.3 Rainwater Harvesting - Reservoirs, Cisterns, and Rain Barrels 67

 3.4 Bioretention Areas and Bioswales 74

3.5 Detention Basins and Retention Basins 75

3.6 Rain Gardens 78

3.7 Green Roofs and Blue Roofs 80

3.8 Curb and Gutter Elimination, Downspout Disconnection, Rain Chains 84

3.9 Vegetated Filter Strips, Organic Filters 85

3.10 Constructed Wetlands, Subsurface Gravel Wetlands 86

3.11 Permeable Pavement 87

3.12 Planter Boxes, Green Streets and Alleys, Green Parking 88

3.13 Manufactured Treatment Devices 90

3.14 Urban Tree Canopy 90

3.15 Land Conservation 94

3.16 Conclusion 96

4.​ ​Stormwater Management Challenges 97

4.1 Introduction 98

4.2 Flood Impact 99

4.3 Policies and Organizational Difficulties 108

5. ​Stormwater Management at Stockton University 111

5.1 Background of Stormwater Regulation 111

5.2 Initial Steps Taken by Stockton University and Where it is Now 115

5.3 Stormwater Management at Stockton University 122

 5.4 Best Management Practices at Stockton University 126

5.5 Public Education and Outreach at Stockton University 132

5.6 Future Plans at Stockton University & Recommendations 135

Bibliography 139
 List of Tables

​ JDEP 1.25-Inch/2-Hour Stormwater Quality Design Storm

Table 2.3.​1​ N 42
Table 2.3.2​ ​Projects With Green Infrastructure Funded by
The Water Bank From FY2015 to FY2017 46
Table 2.5.1​ ​General Permits Issued by The Department 56
Table 2.6.1​ ​Applicable Stormwater Acts 58
Table 3.3.1​ ​Typical Domestic Daily per Capita Water Use 65
Table 3.3.2​ ​Typical Daily Water Use for Office Buildings and Hotels 66
Table 3.5.1​ ​The Location of 125 New Jersey Stormwater Basins 73
Table 3.7.1​ ​Examples of Green Roofing Utilized on College Campuses 81
Table 5.1.1​ ​General Overview of Public Complex Stormwater Rules 109
Table 5.3.1​ ​Stockton University SPPP Team Members 120
Table 5.3.2​ ​Previous Lake Fred Runoff
​Rates VS Runoff Rates Following Improvement Project 124

List of Figures

Figure 1.1.1​ ​Stormwater & Urbanization 15

Figure 1.2.1​ ​Impervious Coastal Towns 18
Figure 1.2.2​ ​Effects of Acid Rain on Some Aquatic Species 20
Figure 1.4.1​ ​National Map of Regulated MS4s 25
Figure 1.4.2​ ​State Environmental Officials Observing The
Separation of Sewer Systems in 1993 Saint Paul, Minnesota 26
Figure 2.1.1​ ​Southern New Jersey Dam That Flooded in 1940 28
Figure 2.1.2​ ​The Levels of Government &
​Their Place in Stormwater Regulation (New Jersey Case Study) 31
Figure 2.2.1​ ​Examples of Continued Pollution Following the FWPCA 33
Figure 2.2.2​ ​Cuyahoga River Fire of 1952 34
Figure 2.2.​3 ​How Sewage is Processed 38
Figure 2.3.1​ ​NPDES Construction General Permit (CGP) Requirement Flowchart 40
Figure 2.4.1​ ​CCMP Water Monitoring Stations as of July 1, 2020 49
Figure 2.4.2​ ​Map of Pinelands National Reserve 51
Figure 2.5.1​ ​Galloway Township Tier A Permit General Conditions 54
Figure 2.5.2​ ​SPPP General Development & Implementation Steps 55
Figure 3.1.1.​ ​EPA Examples of Green Infrastructure 63
Figure 3.2.1​ ​EPA & NJ Forest Service Riparian Buffer Recommendation 64
Figure 3.2.1​ ​Mullica River Mitigation Bank Before (left) and After (right) Restoration Project 66
Figure 3.3.2​ ​Example of a 55 Gallon Rain Barrel 71
Figure 3.3.3​.​ ​Rain Barrel Tour Map from Barnegat Bay Blitz Rain Barrel Challenge 72
Figure 3.5.1​.​ ​NJDEP BMP Example of a Surface Extended Detention Basin 76
Figure 3.6.1​ ​Camden, New Jersey Waterfront South Rain Garden (Before and After) 78
Figure 3.8.1​ ​Downspout Disconnection Method
​Example Where Runoff is Redirected From Sewer System 84
Figure 3.9.1​ ​Diagram of the layout for a simple vegetated strip (Vegetative Filters). 85
Figure 3.12.1​ ​City of Philadelphia 88
Figure 3.14.2​ ​Jersey City Tree Canopy Coverage by Ward 92
Figure 3.15.1​ ​Brightwood Park, Westfield NJ. 95
Figure 4.1.1​ ​Estimated Values of Two Homes, One in A Flood Zone and One Outside 100
Figure 4.1.2​ ​Impact on Property Value as Road Flooding Occurs 101
Figure 4.2.1​ ​Percent of Cyanobacteria Bloom Response
​Samples in New Jersey Exceeding Microcystin
​Health Advisory Guidance Level of 3 µg/L in 2017-2019 Data. 103
Figure 4.2.2​ ​Action of Water on Particles Near Streambed 105
Figure 4.2.3​ ​Terraces formed by an incising stream. 105
Figure 5.1.1​ ​Stockton University Galloway Campus Boundary Shown in
​Pinelands Management Area 113
Figure 5.2.1​ ​Aerial View of Stockton University Galloway Campus in 1930 (left) and 2017
​(right) 115
Figure 5.2.2​ ​Land Use Within Lake Fred Watershed 117
Figure 5.2.​3​ ​Stockton University (Galloway Campus) Construction
​Not Outside of a 300 ft Wetlands Buffer 118
Figure 5.3.​1​ ​Storm Drain Inlet Label Outside of Stockton
​University’s Arts & Sciences Building 123
Figure 5.​4.1​ ​Morses Mill Stream Quality 126
Figure 5.​4.2​ ​J Wing Rain Gardens 127
Figure 5.4.​3​ ​Infiltration Basin near Lot 8A 128
Figure 5.4.​4​ Ra​ in Barrels Connected to Gutter on the Stockton Farm 129
Figure 5.4.​5​ ​Stockton University’s Permeable Parking Lot 130
​ ravel Roadway Leading to Stockton Farm
Figure 5.4.​6​ G 131
Figure 5.5.1​ A ​ presentation on native plants during the 2018 short course. 132
Figure 5.5.2​ ​CRC researchers extracting a marsh core, and a water level logger installation 134
Figure 5.6.1​ ​An Example of Excessive Grass Cover at Stockton’s Galloway Campus 136
Figure 5.6.2​ ​Stream Channelization Outside of Arts & Sciences at Stockton University 137
 Definitions

Term​ …
​ definition used for the purposes of this document.

Chapter One

​ water that results from precipitation in any form and flows over land surfaces
Stormwater …
(NJDEP, 2016).

Previous surfaces​ ​ … surfaces that allow infiltration to occur.

Impervious surfaces​ ​… a surface that has been covered with a layer of material so that it is
highly resistant to infiltration by water (NJDEP, 2016).

Stormwater management …​ the means and efforts put forth to mitigate the potential issues caused
by stormwater (NJDEP, 2016).

Acid Rain​ ​… any form of precipitation with acidic components, such as sulfuric or nitric acid
that fall to the ground from the atmosphere in wet or dry forms, and can include rain, snow, fog,
hail or even dust that is acidic (EPA, 2020a).

Nonpoint source (NPS) pollution​ ​… Runoff that comes from many different sources and picks up
natural and human-made pollutants only to deposit them into lakes, rivers, wetlands, coastal
waters and ground waters (NOAA, 2020).

Total maximum daily load (TMDL)​ … identifies the maximum amount of a pollutant that a body
of water can receive while still meeting water quality standards (EPA, 2020a).

Sediment​ ​… as solid material; mineral or organic; that is either in suspension, being transported,
or has been moved from its site of origin by air, water or gravity as a product erosion (NJDEP,
2016).

Total Suspended Solids (TSS)​ … The total quantity measurement of solid material per volume of
water
Combined sewer outfalls​ … Designed to collect the rainwater runoff, sewage, and industrial
wastewater into one pipe (EPA, 2018a).
Sanitary sewer systems … ​ responsible for the transport of household, commercial and industrial
wastewater to a sewage treatment plant for treatment. The networks of pipes that make up SSSs
collect wastewater from residential, commercial, and industrial sources; sources include sinks,
showers, toilets, and other producers of sewage and wastewater (MSU Water).

Chapter Two

MS4​ … a municipal sewer system that supports a population of over 100,000 and less than
250,000 individuals, owned by a municipality, designed for stormwater conveyance/discharge
and is not combined or sectioned into a treatment plant (EPA, 2020b).
The Code​ … the codification of all rules and regulations made by the executive branch agencies
of New Jersey. ​ Each agency's statement of general applicability and continuing effect that
implements or interprets law or policy, or describes the organization, procedure or practice
requirements of any agency (NJGOV, 2020).

Major Development​ … any "development" that provides for ultimately disturbing one or more
acres of land or increasing impervious surface by one-quarter acre or more. Disturbance for the
purpose of this rule is the placement of impervious surface or exposure and/or movement of soil
or bedrock or clearing, cutting, or removing of vegetation. Projects undertaken by any
government agency which otherwise meet the definition of "major development" but which do
not require approval under the Municipal Land Use Law, N.J.S.A. 40:55D-1 et seq., are also
considered "major development." (NJDEP, 2016)

The USDA Natural Resources Conservation Service (NRCS) methodology​ … uses a hypothetical
design storm and an empirical nonlinear runoff equation to compute runoff volumes, and a
dimensionless unit hydrograph to convert the volumes into runoff hydrographs method for
computing stormwater runoff rates, volumes, and hydrographs. The key component of the NRCS
runoff equation is the NRCS Curve Number, which is based on soil permeability, surface cover,
hydrologic condition, and antecedent moisture. This method is particularly useful for comparing
pre- and post-development peak rates, volumes, and hydrographs. (Division of Watershed
Management, 2004, p. 5-27)

The Rational Method​ ​… uses an empirical linear equation to compute the peak runoff rate from a
selected period of uniform rainfall intensity. Since it is not based on a total storm duration, but
rather a period of rain that produces the peak runoff rate, the method cannot compute runoff
volumes unless the user assumes a total storm duration but continues to be useful in estimating
runoff from simple, relatively small drainage areas such as parking lots (Division of Watershed
Management, 2004, p. 5-27).

Regional Stormwater Management Planning​ ​… a water resource management strategy that

identifies and develops solutions to problems that can be managed most effectively on a regional
basis (Division of Watershed Management, 2004, p. 3-16).

Tier A​ … assigned under N.J.A.C. 7:14A-25.3(a)1, includes 462 municipalities, that are more
densely populated regions or along or near the coast addressing new and existing development
(NJDEP, 2016).

Public Complexes … ​ include a “campus of a college or university which Statewide has a

combined total of at least 1,000 employees (usually present at least six hours per day on
weekdays) or full-time students'' located partially in a municipality that is assigned to Tier A or
in a municipality that receives a waiver (NJDEP, 2016).

Tier B​ ​… includes 104 municipalities, which are in more rural and non-coastal areas focusing on
new development, redevelopment projects and public education. The renewal of NJPDES master
general permit NJ0141861 applies to Tier B Municipalities only (NJDEP, 2016).

Chapter Three
Green Infrastructure​ ​… the range of measures that use plant or soil systems, permeable
pavement or other permeable surfaces or substrates, stormwater harvest and reuse, or
landscaping to store, infiltrate, or evapotranspirate stormwater and reduce flows to sewer systems
or to surface waters (EPA, 2020c)
Riparian Buffer​ … the border of vegetation lining waterways that prevents negative impacts and
can be implemented as green-infrastructure at a landscape-scale (NJ Forest Service, 2018).
​Potable & Non-potable Water​ ​… Potable water is that that is safe to drink and has typically
undergone some form of treatment process, as is the case with municipal water from reservoirs.
Non-potable water is either untreated or treated minimally to the point that it can be used for
activities other than ingestion. This distinction is important when considering how water is
commonly used in residential and work spaces (EPA, 2020c).
Cisterns …​ are stormwater management practices used to capture, collect and reuse roof runoff
(Division of Watershed Management, 2004).
Rain Barrels​ … are smaller versions of cisterns that are usually connected to downspouts and
can typically store up to 100 gallons of water (Division of Watershed Management, 2004).
Stormwater Basins​ … Mostly as part of larger residential or commercial projects. ​In general, the
structures are used to detain and treat stormwater runoff to aid in preventing flooding, especially
flash flooding, along New Jersey’s watercourses. ​There are different types of stormwater basins
(NJDEP, 2016).
Detention Basins​ ​…​ ​or “dry ponds”,​ ​are the most basic form of stormwater basins. As the name
implies, they are designed to detain, disperse and slow the flow of stormwater before it enters a
stream. Detention basins are usually fitted with an outflow pipe at ground level that leads to a
forebay (Division of Watershed Management, 2004).
Forebay​ ​…​ ​or an artificial pool of water prior to a larger body of water.
Retention basin​ ​…​ ​or “wet pond” consists of an inflow pipe and a large, manmade depression
where stormwater runoff from paved surfaces is collected and detained. On the other end is an
outflow system with a release valve designed to allow for a “plug and pulse” control of
stormwater after rain events (Division of Watershed Management, 2004).
Rain Garden​ … an indented shallow surface depression planted with specially selected native
vegetation to treat and capture runoff. Such gardens are designed with three different layers
(NJDE, 2016).
Green Roof​ ​… also known as a vegetated roof, is a roof that has been covered with a growing
medium and vegetation and receives both sunlight and rainfall, though watering can be provided.
Vessels for holding plants are open ended, but popular options include arrays of planters, or full
garden beds laid atop an installed waterproof barrier layer. Benefits include the capture of
rainfall which thereby prevents it from becoming storm water (Division of Watershed
Management, 2004).
Downspout Disconnection​ ​… reroutes rooftop drainage pipes from draining rainwater into the
storm sewer to draining it into rain barrels, cisterns, or permeable areas. Can be used to store
stormwater and/or allow stormwater to infiltrate into the soil. Downspout disconnection could be
especially beneficial to cities with combined sewer systems (EPA, 2020c).
Planter box … ​ a form of green infrastructure where “... the range of measures that use plant or
soil systems, permeable pavements, or other permeable surfaces or substrates, stormwater
harvest and reuse, or landscaping to store, infiltrate, or evapotranspirate stormwater and reduce
flows to sewer systems or subsurface waters (EPA, 2020c).”
Chapter Four
Bank erosion​ … refers to the erosion of the banks of the waterway.
Streambed erosion​ … refers to the erosion of the bed of the waterway.
Chapter Five
Optional measures​ ​… BMPs that are not implemented as Statewide Basic Requirements or
Additional Measures but that prevent or reduce the pollution of the waters of the State
 1. Introduction to Stormwater

1.1 What Is Stormwater? What is Stormwater Management?

Following a rainfall event, precipitation can infiltrate into the soil, partake in plant
uptake and transportation, evaporate, or become runoff from pervious and impervious surfaces.
This fallen precipitation is known as stormwater, which can be defined as water that results from
precipitation in any form and flows over land surfaces (NJDEP, 2016). The fate of the
stormwater, or which of the paths from above it may follow, is ultimately determined by the
given landscape in which the precipitation falls. In landscapes that offer a natural system,
stormwater becomes runoff that’s filtered of pollutants and other debris by a variety of plants
(Greenville County Soil & Water Conservation District, 2020). Runoff then travels to nearby
water bodies or infiltrates the ground through previous surfaces, or surfaces that allow infiltration
to occur. This infiltration process is obstructed when naturally occurring landscapes are
disturbed or used for human development (Philadelphia Water Dept., 2018). Construction of
impervious surfaces; defined as a surface that has been covered with a layer of material so that it
is highly resistant to infiltration by water; such as rooftops, sidewalks, and paved or graded
roads–causes stormwater to be collected or redirected (NJDEP, 2016).

Figure 1.1.1

Stormwater & Urbanization

(Federal Interagency Stream Restoration Working Group, 2001)

 The collection and redirection of stormwater caused by the transition from natural
landscapes to urban landscapes has negative implications. ​Figure 1.1.1​ portrays a general
simulation of the relationship between stormwater and urban development; overall, urbanization
leads to increased runoff and decreased infiltration. In addition, lack of vegetation in urban areas
prevents natural filtration from occurring, allowing stormwater to accumulate contaminants that
have been released from anthropogenic sources. This polluted stormwater can then infect both
ground and surface water. Excess runoff caused by urban development can also lead to flooding
and accelerated erosion. Stormwater that is collecting contaminants, redirecting rather than
infiltrating, and running off into waterways can have wide range direct and indirect negative
impacts on people and the environment.

Therefore, stormwater management is the means and efforts put forth to mitigate the
potential issues caused by stormwater. Stormwater management can be recognized in diverse
forms, including construction of various infrastructure installations, legislation creation, and
guidelines to protect open space and limit construction activities. The physical applications of
stormwater management measures, stormwater utilities, come in a variety of functions and
applications, and new and creative technologies are continually arising to better deal with
stormwater challenges (Goldman, 2017). Parties responsible for stormwater management
include units of local, state, regional, and federal agencies, as well as conservation groups, public
utility companies, and private contractors (NJDEP, 2016).

Federal agencies include the organizations such as the Environmental Protection Agency
(EPA). These agencies have the ability to release legislation that sets overall guidelines to
follow; in regards to stormwater management The Clean Water Act, published originally in 1972
by the EPA, is an example of legislation that serves to regulate permits managing stormwater
discharge. Another example of a federal agency is the U.S Department of Agriculture, which
creates funding for community infrastructure projects. At the state level, examples include the
New Jersey Department of Environmental Protection (NJDEP) and the New Jersey
Environmental Infrastructure Trust & Environmental Infrastructure Financing Program
(NJEIFP). State level agencies focus on the protection of the state's environment as well as
in-state programs for funding and education. Regional management practices focus on
identifying the best practices for a given region. Local organizations focus on a similar goal to
regional organizations, but due to their potentially smaller range, they often work on community
engagement. Lastly, worth mentioning is the National Association of Clean Water Agencies
(NACWA), which is a nonprofit organization recognized for advocating legislation and having a
goal of creating clean water for all. This collective effort relies on science, engineering, industry,
and community involvement to meet the ultimate goals of stormwater management. Though
challenging and often in constant need of improvement, successful stormwater management has
numerous benefits for human, economic, and environmental health.
1.2 Importance of Managing Stormwater

A significant consideration within stormwater management is that of human dimensions

of the environment. Uncontrolled stormwater can threaten human safety, buildings, and heavily
relied on infrastructure. Climate analyses have estimated that heavy rainfall events have
increased over the past few decades, with many scientific projections showing this trend is likely
to continue in coming years (Kennedy, 2014). This heavy rain or snowfall that causes high
volumes of stormwater increases the risk of flooding, harm to surface water quality, and erosion
caused by runoff, thus creating a risk for all developed areas and an exceptional risk to high
density coastal regions of the U.S. (Hess et al, 2019).

In vastly developed areas like the Northeast, particularly areas of urban and coastal New
Jersey, the dangers of flooding are increasingly imminent. Developing at a rate of over 15,000
acres per year, it’s estimated New Jersey will be the first state to reach buildout sometime near
the middle of the century (Hasse and Lathrop, 2008). While rapid development has multitudes of
downsides, the creation of impervious surfaces remains one of the largest. Impermeable surfaces
cause concentrations of water collection during and after precipitation events, which leaves water
unable to naturally infiltrate into the ground or run safely to a nearby water body. This results in
pooling of water, increased velocity and increased volume of flows over the impervious surface
(Guo, 2017).

This remains the case for New Jersey; from 1995 to 2002, 35,809 acres of impervious
surface were added to New Jersey’s landscape, representing an annualized rate of 5,116 acres of
impervious surface increase per year (Hasse & Dornisch , 2009). ​Figure 1.2.1​,​ ​which displays
the percentage of impervious surfaces within several coastal towns of New Jersey, acts as an
example as to how coastal towns can face the highest risk. As a result of increased populations
and increased development, these coastal towns with high percentages of impervious surfaces
now face an array of problems. Infrastructure fails when impervious surfaces create runoff it
can’t handle; in these coastal towns, when the water can’t be pushed into the bay quickly enough
by drainage systems, it remains lingering in roadways. Without much grass, sand, dirt, and other
permeable space remaining in highly developed areas, the buildup of this water can lead to
severe flooding (Zoppo, 2019) .
Figure 1.2.1

Impervious Coastal Towns

With about 130 miles of Atlantic coast, high percentages of impervious surfaces observed
in ​Figure 1.2.1,​ and dense populations, this goal of flood protection in New Jersey is especially
important (Zoppo, 2019). At the federal level, the U.S. Federal Emergency Management
Administration (FEMA) provides New Jersey with the Pre-Disaster Mitigation Grant Program
(PDM) as well as Flood Mitigation Assistance Grants. Aiming to reduce overall risk to the
population and structures from future hazard events, PDM also reduces reliance on federal
funding in future disasters (CCLR, 2018). The Flood Mitigation Assistance Grants provide
funding to plan for floods and implement measures to prevent them. At a state level, through the
review of permits issued by the Division of Land Use Regulation (DLUR), NJDEP works to
create stormwater rules that reduce flood hazard (CCLR, 2018).

Protecting human health in regard to our water supply constitutes another major goal of
managing stormwater. As mentioned, in the absence of a natural system stormwater runoff is
prone to collecting excess pollutants that can negatively impact overall water quality if not
properly controlled. Being “one of the major threats to water quality in the United States”, there
are numerous human health-related implications to improperly managed stormwater runoff
(Gaffield et al, 2003). Direct risks associated with stormwater runoff, particularly in urban
settings, include severe illness from exposure to contaminated water. Heavy metals and
pesticides can be incidentally ingested if water sources reused for domestic purposes and
drinking are contaminated by polluted stormwater (Ma et al, 2016). Dangers can also arise in
exposure to contaminated seafood or by contact through recreational activities. Indirect health
hazards arise from lack of adequate stormwater control that results in stagnant water pooling or
flooding. Harmful bacteria can proliferate in still water and pools can act as mosquito breeding
areas. Thus, effective stormwater management addressing these issues can prevent the spread of
sickness and infectious disease (Gaffield et al, 2003).

One way these issues are addressed federally is through the U.S. Department of
Agriculture’s (USDA) Office of Rural Development. This office’s Rural Utility Service offers
much needed water, stormwater, and waste treatment infrastructure to rural areas with the intent
of improving both economic and life quality. At a state level, the NJEIFP provides and
administers nine different low interest loans for water quality infrastructure projects (CCLR,
2018).

While the human dimensions of the environment are primary considerations of effective
stormwater management, conservation of aquatic and terrestrial ecosystems are important
objectives too. Natural aquatic habitats and their biological constituents can be easily degraded
by contamination, thereby leading to a variety of negative effects (Philadelphia Water Dept.,
2018). One example of contamination is acid rain, which includes any form of precipitation with
acidic components, such as sulfuric or nitric acid that fall to the ground from the atmosphere in
wet or dry forms, and can include rain, snow, fog, hail or even dust that is acidic (EPA, 2020d).
As displayed by ​Figure 1.2.2,​ it causes the acidity in lakes and streams to increase and the
amount of species that can continue to tolerate the lake or stream decreases. Another example is
that of nitrogen and phosphorus, which the EPA labels as one of the leading causes of water
quality impairment in U.S. rivers, lakes, and estuaries (EPA, 2018a). New Jersey's 2014
Integrated Water Quality Assessment Report found that 31% of all freshwaters were not
supporting aquatic life uses due to exceedances of the applicable numeric phosphorus criterion
(Berry et al., 2014)​.
Figure 1.2.2

Effects of Acid Rain on Some Aquatic Species

​ s acidity increases (and pH decreases) in lakes and streams, some species are lost.
Note. A
(Federal Interagency Stream Restoration Working Group, 2001)

A major source of contaminants is nonpoint source (NPS) pollution which is runoff that
comes from many different sources and picks up natural and human-made pollutants only to
deposit them into lakes, rivers, wetlands, coastal waters and ground waters (NOAA, 2020).
While NPS pollution can’t be directly traced, catalysts typically include things such as: excess
fertilizers, herbicides and insecticides from agricultural lands and residential areas; oil, grease
and toxic chemicals from urban runoff and energy production; sediment from improperly
managed construction sites, crop and forest lands, and eroding stream banks; salt from irrigation
practices and acid drainage from abandoned mines; bacteria and nutrients from livestock;
atmospheric deposition and hydromodification; pet wastes and faulty septic systems (EPA,
2018a). For instance, in 1981 defective and malfunctioning septic systems were becoming a
growing problem in New Jersey to the point of being referred to as, "New Jersey's Dirty Little
Secret," by the Division of Water Resources of the Department of Environmental Protection
(Carney, 1982). To better help combat this multifaceted problem, planning, designing and
maintaining such systems for housing units were the subject of a six-week course at Stockton
State College in 1982. Sponsored by the college's Center for Environmental Research, the
course was intended for engineers, planners, health officials and architects (Carney, 1982).
However, the problem is far too large for a single class to resolve the issue; in addition to the
negative effects NPS pollution has on ecosystems and natural landscapes, designated uses of
waterways can be impacted, such as fisheries or recreational uses (EPA, 2018b).

To maintain the lowest possible impact on surface water quality, the EPA established a
water quality criteria that determines the recommended maximum concentrations for pollutants
in ambient waters using values calculated using primarily laboratory data (API, 2020). A total
maximum daily load (TMDL), as defined by the U.S. Clean Water Act, identifies the maximum
amount of a pollutant that a body of water can receive while still meeting water quality standards
(EPA, 2020a). These values serve to protect most species nationally and are incorporated by state
agencies to create legally enforceable water quality standards. In New Jersey, NJDEP enforces
these standards through Surface Water Quality Standards (SWQS), N.J.A.C. 7:9 B, which
establishes the policies, stream classifications and surface water quality criteria necessary to
protect the quality of New Jersey’s surface waters.

In addition to carrying contaminants, stormwater runoff picks up soil and dust particles,
or sediment from developed and natural landscapes. Defined as solid material; mineral or
organic; that is either in suspension, being transported, or has been moved from its site of origin
by air, water or gravity as a product erosion, sediment can range in size from small, pea-sized
gravel to tiny soil particles, less than 2 millimeters in diameter and is a result of any soil that is
not protected from rainfall or runoff (NJDEP 2016). Sediment pollution can form in the water
bodies themselves as well, typically as a result of high water flow. High enough concentrations
of sediment can impact water quality by increasing Total Suspended Solids (TSS), or the total
quantity measurement of solid material per volume of water (NJDEP, 2016). Noted as one of the
main “conventional” pollutants designated by the Clean Water Act, high levels of TSS can
reduce water clarity and ultimately lead to inability to meet water quality standards (EPA,
2018a). Ultimately, one of the most dangerous aspects of sediment pollution is the advanced
erosion it causes. While natural erosion produces nearly 30 percent of the total sediment in the
United States, accelerated erosion from human use of land accounts for the remaining 70 percent
(IDEM, 2020). High velocity or flow of stormwater can also cause significant stream bank
erosion and widened stream channels, making nearby surface waters vulnerable to sediment
deposition and nearby populated areas more susceptible to flooding (NJDEP, 2016).

To prevent sediment pollution, the EPA works with construction site operators to
confirm that proper stormwater controls are in place so that construction can proceed in an
environmentally conscious manner (EPA, 2020b). To best manage effects on sediment and
erosion caused by runoff though, TMDLs are determined by the states and EPA regions and
implemented by the National Pollutant Discharge Elimination System (NPDES). In New Jersey,
the management of soil erosion and stormwater from virtually all non-agriculture,
construction-based soil disturbances is done through its adoption of the NJ Soil Erosion and
Sediment Control Act (N.J.S.A. 4:24-39 et seq). The act requires all construction activities
greater than 5,000 square feet to be developed in accordance with a plan to control erosion
during construction. The plan must also ensure that erosion will not occur once construction is
completed (NJDA, 2017). One example of erosion control occurred in Ocean City, New Jersey
only fifteen miles away from where Stockton University’s first campus opened (Warner, 1969).
As the college prepared for it’s first class, Warner (1969) wrote an article discussing how
beaches nearby were at risk of full degradation as a result of advanced erosion brought forward
by construction. This was later avoided in 1981 when the New Jersey Short Master Plan,
endorsed by Stockton Faculty, was released and set plans to restore the suffering beaches
(NJDEP, 1981).

Lastly, properly managed stormwater can promote improved groundwater recharge.

Groundwater recharge is an important step in the hydrologic cycle, as precipitation infiltrates
back into the ground to be taken up by plants or returned to subsurface aquifers (NJDEP, 2016).
Protecting natural landscapes and limiting the area of impervious surfaces can enhance
stormwater infiltration rates. Creating stormwater infrastructure, such as rain gardens and other
“green infrastructure”, can have similar positive effects. These types of management that aid
groundwater recharge help protect from flooding, and can allow water to infiltrate into soils for
uptake by plants, leading to healthier terrestrial ecosystems (NJDEP, 2016).
While there are several types of management, a pivotal component of public health and
clean water is the collection and treatment of domestic sewage and wastewater (EPA, 2018b).
There are two types of public sewer systems used in the United States for collecting and
conveying sanitary sewage, combined sewer systems (CSS) and sanitary sewer systems (SSS).
Combined sewer systems collect and convey sanitary sewage and urban runoff in a common
piping system, whereas sanitary sewer systems collect and convey sanitary sewage separately
from urban runoff. In locations where SSSs exist, urban runoff is collected and conveyed in a
separate storm sewer system. There are approximately 20,000 SSSs in the U.S. serving 147
million people and approximately 1,100 CSSs serving 43 million people (Office of Water
Programs, 2008). A majority of municipalities use two major types of sewer systems, which are
combined sewer outfalls and sanitary sewer overflows. Both collect sewage and wastewater
from homes, businesses, and industries and deliver it to wastewater treatment facilities before it
is discharged to water bodies or land, or reused (EPA, 2018b).
1.3 Combined Sewer Outfalls

Combined sewer outfalls (CSO) are those that are designed to collect the rainwater
runoff, sewage, and industrial wastewater into one pipe (EPA, 2018b). A majority of these
systems transport all of the wastewater to a sewage treatment plant, where it is treated and then
discharged into a nearby water body. Issues arise with CSOs due to their potential to overflow
during heavy rainfall or snowmelt, causing excess wastewater to be discharged directly into
nearby streams, rivers, or other water bodies. With excess water containing stormwater as well as
untreated human and industrial waste, toxic materials, and different debris, the water being
discharged from CSOs contaminates waterways with microbial pathogens, suspended solids,
chemicals, trash, and nutrients that deplete the dissolved oxygen content. (EPA, 2018b).
Approximately 850 billion gallons of untreated wastewater stormwater gets discharged into
waterways every year as a result of CSOs (Tibbetts, 2005).

When they were first introduced in the mid 1850s, combined sewer systems were
considered a major improvement to the sanitary issues in cities. Prior to their introduction, city
streets were lined with cesspool ditches that overflowed when it rained, with waste and
stormwater collected into the same pipes running underground and discharged directly into the
waterways (Tibbetts, 2005). In the early 1900s, wastewater treatments plants were erected and
cleaned the wastewater before being discharged. As described above however, these systems
easily overflow when there is too much stormwater. That has led to the CSOs becoming part of a
debate over the best way to manage stormwater runoff and sewage in older US communities
(Tibbetts, 2005).
Asymmetrically, sanitary sewer systems are standardly responsible for the transport of
household, commercial and industrial wastewater to a sewage treatment plant for treatment. The
networks of pipes that make up SSSs collect wastewater from residential, commercial, and
industrial sources; sources include sinks, showers, toilets, and other producers of sewage and
wastewater (MSU Water, 2014). SSS’s exclude most storm water drainage by having a separate
main subsurface pipe running to a treatment facility, while storm sewers transport rainwater and
melted snow and are then discharged into a waterbody (MSU Water, 2014). Combined sewer
systems are shared underground pipes responsible for directing both the sewer and stormwater
into a treatment system before being discharged into a waterway. In the majority of
municipalities these two systems are separate and serve as remnants of the early infrastructure in
the United States, mostly located in older urban areas.

In 1994, the EPA issued the CSO control policy through the NPDES. This became the
national framework for controlling CSOs (EPA, 2018b). The main purpose of this document is to
help guide compliance with the requirements of the Clean Water Act. The policy mandated that
communities should eliminate, and if not possible, reduce their CSOs. The EPA began working
with municipalities to improve their sewage systems so that they could comply with CWA goals
by offering communities that still use CSOs two options to comply - either build separate pipes
underground for sewage and stormwater or keep the existing infrastructure and somehow expand
it. By expanding the existing pipes, these towns would be able to store the overflow during heavy
rain (Tibbetts, 2005). As of 2004, there are still approximately 772 cities in 32 states that use
CSOs (EPA, 2018a). Most of these can be found in Maine, New York, Pennsylvania, West
Virginia, Ohio, Indiana, Michigan, and Illinois. The EPA found that most of the cities with CSO
problems have populations less than 10,000 people. It is believed that larger municipalities have
a more sufficient tax base and water users to be able to finance changes to the sewer systems.

Sewage collected in a sanitary sewer typically continually runs to a sewage treatment

plant, where it is filtered and treated before being released (MSU, 2014). They are not designed
to collect large amounts of stormwater runoff from precipitation events and SSS’s are usually
accompanied by a separate stormwater system, such as a municipal separate storm sewer system
(MS4) which is discussed below. These separate systems allow runoff to drain and be piped
separately from other water drainage sources, thereby reducing the amount of water to be treated
at a treatment facility. Though this load on the sewage flow is reduced, a separate stormwater
system typically directs water to a water body, and is typically untreated.

Untreated discharges from SSSs are commonly called sanitary sewer overflows, or SSOs,
and can occur at any time, during either dry or wet weather (EPA, 2018b). They can extend to
include overflows out of manholes and onto city streets, sidewalks, and other locations. Possible
causes of sanitary sewer overflows include blockages, line breaks, sewer defects, power failures,
improper sewer design, and vandalism. SSOs contamination potential for waterways can create
serious water quality problems, with an additional potential of backing into homes and causing
damage to property and public health (EPA, 2018b). The EPA has estimated that every year
there are 23,000 to 75,000 SSOs in the US (EPA, 2018b). The SSOs that reach waters of the US
are point source discharges.

1.4 Separate Storm Sewer Systems

The most common regulated separate storm sewer system is the municipal separate storm
sewer system (MS4). Although the name contains the word “municipal”, these systems can be
owned and managed by local governments, state governments, or certain other public entities
that discharge untreated stormwater into local water bodies, such as public universities (EPA,
2020b). An MS4 typically consists of a series of pipes, retention basins, ditches, and inlets that
collect stormwater from impervious surfaces (Yencha, 2020). MS4s are common throughout the
United States, and can be divided into two phases based on their location. If located in a city or
county with a population over 100,000 people, an MS4 is considered “Phase 1”. If located in a
small town or non-traditional area such as a public university, it is considered “Phase 2” (EPA,
2020b). Regulated MS4 areas account for approximately 4% of the total United States land area,
but 80% of the population (EPA, 2018c). New Jersey, in particular, contains a large quantity of
MS4s (​Figure 1.4.1)​ .
Figure 1.4.1

National Map of Regulated MS4s

(EPA, 2020b)

Because MS4s capture relatively clean stormwater and keep it separate from sanitary
sewage, the volume of wastewater needing treatment at a sewage treatment plant is greatly
reduced. The separation also provides relief during times of heavy rainfall and snowmelt, as the
resulting stormwater does not cause the overflow of sewage into water bodies, streets, and
basements associated with CSOs. It can also reduce regulatory burden, as MS4 permits are
generally simple. However, despite these advantages, there is a danger in discharging stormwater
directly to waterways. Without proper management practices, stormwater pollutants such as trace
metals, nutrients, sediment, and litter may be directly discharged in local water bodies. This can
offset the environmental benefits derived from the elimination of untreated sanitary sewage
discharges (EPA, 1999).

To combat stormwater pollutants entering water bodies, MS4s are regulated under the
NPDES. However, unlike a typical NPDES permit, an MS4 permit does not require specific
end-of-pipe effluent limits based on state-determined water quality standards or best available
treatment technology. Instead, MS4 permits require the development of a Stormwater
Management Plan and the implementation of best management practices. MS4 permitting is
discussed in detail in ​Section 2​.

There are several cities which have recently converted their combined sewer systems to
separate sanitary and storm sewers. In New Jersey for instance, the total number of CSO outfalls
was reduced more than 20% and solids and floatables controls were installed at remaining CSO
outfalls to prevent solids that are greater than one half inch from entering the waterway ​(Van Abs
et al., 2014)​. This was following individual CSO permits adopted in 2015 that maintained
commitment to working with CSO permittees and CSO communities to reduce or eliminate
CSOs. To better meet this goal, NJDEP reserves funds and provides principal forgiveness loans
for CSO abatement projects utilizing green practices such as green roofs, rain gardens, porous
pavement, and other activities that maintain and restore natural hydrology by treating stormwater
runoff through infiltration into the subsoil, treatment by vegetation or soil, or stored for reuse.
For example, the Northwest Resiliency Park in Camden County, New Jersey, is a multi-phase
project that serves a number of different purposes including but not limited to;

● on-grade stormwater detention through green infrastructure;

● on-grade public park and open space; and
● subsurface stormwater quantity and quality treatment. The subsurface stormwater storage
will be designed to receive approximately 1 million gallons of stormwater flows from a
new high-level storm sewer system designed by the North Hudson Sewerage

Continuing outside of New Jersey, Minneapolis, Saint Paul and South Saint Paul,
Minnesota completed one of the largest sewer separation projects in the 1990s. Their separation
project covered more than 21,000 acres, and involved installing 189 miles of storm sewers and
11.9 miles of sanitary sewers (​Figure 1.4)​ . Though very costly, this enormous project was
necessary—before the separation, an overflow occurred an average of once every three days
(EPA, 1999). While there are still small isolated sections of combined sewer, there were no
overflows in Minneapolis from 2010-2018. This drastic reduction allowed for the termination of
the last combined sewer overflow permit in the state (Minnesota Pollution Control Agency,
2018).

Figure 1.4.2

State Environmental Officials Observing The Separation of Sewer Systems in 1993 Saint Paul,
Minnesota

(Minnesota Pollution Control Agency, 2018)

 In addition to stormwater and pollution-related benefits of converting to a separate sewer
system, there are other infrastructure-related benefits. A variety of necessary infrastructure
updates, such as the installation of handicap ramps in sidewalks, the repaving of roads, and the
replacement of utility lines, can be more cost-effective if done in conjunction with sewer
separation. In Saint Paul, the sewer separation project allowed for cheaper street pavement,
handicap ramp installation, gas and water main installation, lead water pipe replacement, and
street light installation. However, there are drawbacks to separating sewer systems. The process
itself involves extensive construction, which results in noise and sediment pollution, erosion, and
possible disruptions in sewer service (EPA, 1999). Cities must carefully weigh the advantages
and disadvantages of a sewer separation project.
 2. Stormwater Regulation

2.1 Introduction
The concept of stormwater management and regulation is most often credited to the
Clean Water Act of 1972. In agricultural contexts however, stormwater has been considered a
resource for millennia; it’s only within urban contexts that stormwater has been considered a
waste product (Echols & Pennypacker, 2015). Prior to modern day understanding of stormwater,
one of the first ways it was managed was through the creation of dams. ​Figure 2.1.1​ shows
images of one of the earliest dams in New Jersey whereas Sadd-el-Kafara, or dam of the Pagans,
brings the history back even further; known as the first dam and estimated to have been built
around 2700-2600 BC, the goal of the dam was to prevent flooding but it was never completed as
during the building process as it was ironically destroyed by a flood (HYDRIA Project, 2009).
Still, the history of dams continued and the path for stormwater management began to be paved.

Figure 2.1.1

Southern New Jersey Dam That Flooded in 1940

​ lood damage occurred from Millville to Clemton (NJDEP).

Note. F

Dams first made their mark on the United States in the 1800s with the Ohio River being
the predominant focus for potential improvement. Spanning 981 miles and through several states,
the Ohio River could be relied on for early transportation methods of both tools and people
(Billington, Jackson, & Melosi, 2005). During this time period, steamboats were an increasingly
popular choice for this transportation but due to a variety of factors, journeys taken on them were
often unsafe and came with high risk. When populations continued to increase and the river
being navigable became a priority, dams were seen as the answer to this risk. This led to one of
the first instances of federal involvement when in the 1820s, when under the guidance of the
U.S. Army Corps of Engineers dams were set to be constructed throughout the Ohio River
(Billington, Jackson, & Melosi, 2005).
While the Ohio River relied on federal funding and assistance early on, other areas were
still requesting federal funding and assistance. In March 1824, a court case known as Gibbons V
Ogden occurred as a result of these frustrations, and it was ruled that interstate river navigation
fell under the authority of congress and not individual states ​Gibbons v. Ogden. (n.d.) ​ This
ruling opened the door for further federal involvement, and a month later the General Survey Act
of 1824 was passed. This act allotted $75,000 to improve navigation on the Ohio and Mississippi
river through the removal of sandbars, snags, and other obstacles (Glass, 2017). By 1826, the
first version of the Rivers and Harbors Act was passed. While the 1826 Rivers and Harbors act
still didn’t acknowledge the environmental effects it would have, the act was one of the first of
it’s kind as it combined both planning and construction and served as a model for the U.S. Army
Corps for future work involving flood control and navigation improvement (Glass, 2017).
By the second half of the 19th century, predominantly due to the gold rush, California
was another state with a rapidly growing population. This growing population led to dam
construction with the goal of diverting water for mining operations and creating irrigation for
personal properties (Winzenread & Okada, 1999). New Jersey wasn’t blind to the uprising of
dam construction either; despite being located outside of the Delaware River’s basin, the need
for a dam was promoted by the state (Billington, Jackson, & Melosi, 2005). This initial form of
management was quickly becoming a widespread plague for the waterways of America as issues
with dam construction and new transportation abilities quickly arose. General problems for
waterways included excessive sediment deposits, poor fishery health, and overall poor water
quality. In California, excess water was often sent to mines to be used for hydraulic mining, a
practice that caused severe erosion, environmental degradation and excess sediment in rivers
(Winzenread & Okada, 1999). In Minnesota, construction of the Lake Winnibigoshish and Leech
Lake Dams required taking a substantial amount of timber from an area that belonged to
approximately 1,300 Chippewa Indians, (Billington, Jackson, & Melosi, 2005). The dam New
Jersey had promoted ended up in the midst of these realizations and was met by an abundance of
environmentalists who didn’t want it’s construction to occur (Janson, 1975).
While the dams themselves were creating controversy and complications, the increasing
populations that led to the “dam trend” brought their own array of environmental issues as well.
These include sewage and industrial pollutants, urban and agricultural runoff, dredging,
canalizing (Winzenread & Okada, 1999). Transporting lumber by water, an increased practice as
a result of government assistance in creating navigable waters, created significant water pollution
along the upper Mississippi. As the detrimental effects of water pollution were becoming
apparent, the need for pollution prevention was becoming apparent as well. In the 1880s and
1890s, congress began instructing the U.S. Army Corps to prevent dumping and filling in
harbors. In 1893 for example, one Ohio community was forced to build an incinerator and burn
refuse rather than dump the garbage into the river where it obstructed navigation (​US Army
Corps of Engineers, n.d.​). However, environmental regulation had yet to officially exist.
 To give the corps proper authority to prevent further degradation of waterways, the first
piece of environmental legislation, known as the 1899 Rivers and Harbors act, was passed to
prevent dumping of refuse off of boats (FWS, 2013). The most commonly used aspects at the
time of the 1899 Rivers and Harbors act were sections 9 and 10; section 10 prohibits the
unauthorized obstruction or alteration of any navigable water of the United States, and section 9
prohibits the construction of any bridge, dam, dike or causeway over or in navigable waterways
of the U.S. without congressional approval (FWS, 2013). Introducing environmental regulation
to the United States was a huge step, however, environmental agencies were still mostly absent
when the 1899 Rivers and Harbors act was passed. Agencies are a significant part of the
regulation process, and during this time period the U.S. Army Corps were essentially the only
agency enforcing environmental regulation. The need for further enforcement brought upon by
newfound pollution issues is what led to the current system, which operates on three general
levels of governing: federal, state, and local. While there were many smaller steps throughout the
timeline, it was in 1971 that the EPA was founded and the Clean Water Act of 1972 that is used
today came shortly after. As one of the first documents to acknowledge stormwater, the CWA is
the primary federal law in the United States governing water pollution and is regulated by the
EPA.
To gain a better understanding as to how each level of government is involved, ​Figure
2.1.2​ includes examples of current agencies and their ability to enforce regulation. As mentioned,
there’s a large gap of development that occurred between the 1899 Rivers and Harbors Act and
the 1972 Clean Water Act. However, with the context of regulation foundation, the timeline and
effects these regulations have on individual levels of government can be better understood.
Figure 2.1.2

The Levels of Government & Their Place in Stormwater Regulation (New Jersey Case Study)

2.2 National Regulations

With the precedent set by the first form of environmental regulation, the 1899 Rivers and
Harbors Act, the United States began further expanding federal involvement into the quality of
it’s waterways. While the U.S. The Army Corps worked to prevent the negligent dumping of
refuse into waterways, simultaneously the USDA, established in 1862, was working on the state
of agriculture and the U.S. The Department of Interior, established in 1849, was working to
manage natural resources and protect cultural heritage (USDA, 2020). Still, the nation’s
waterways were suffering; though the Rivers and Harbors act prevented dumping of refuse, the
priority was maintaining navigable waters, not healthy ones (FWS, 2013).
As a result, water bodies were still seen as available areas for waste. In 1945, it was
reported that over 3,500 communities pumped 2.5 billion tons of raw sewage into streams, lakes,
and coastal waters everyday (Powers, 2020). The results of this weren’t going unnoticed; at the
time Manhattan was described as “an island in New York surrounded by sewage,” fish were
dying at rapid rates, and water bodies across the nation were unfit for swimming (LA Tech
University, 1999). More progress had been made with environmental regulation, as the U.S. Fish
and Wildlife Service, established in 1940, served to oversee wildlife management and The
National Park Service, established in 1916, conserved national parks and monuments (USDA,
2020). Municipalities and states had begun attempting to address water pollution on their own at
this time, with one example being the Interstate Commission on The Delaware River Basin
(INCODEL) that was formed in 1936. Including input from New York, New Jersey, and
Pennsylvania, the goal was to create policy and pollution control for the Delaware River Basin
(Patrick, Douglass, Palavage, & Stewart, 2016). However, the steps taken by states and
municipalities across the country were overshadowed by production needs and it was becoming
increasingly apparent that federal involvement was also required to best aide water quality
(Powers, 2020). The U.S. Surgeon General of this era, who was in charge of delivering scientific
information regarding the nation’s health and wellbeing, warned that over half of the U.S.
population relied on drinking water supplies of doubtful purity (Powers, 2020).
Stemming from the uprising concern, the 1948 Federal Water Pollution Control Act
(FWPCA) was enacted by congress in an attempt to alleviate these environmental stressors and
heal the quality of the nation's water bodies. The 1948 FWPCA’s ​Declaration of Goals and
Policy​ directly states, “The objective of this Act is to restore and maintain the chemical, physical,
and biological integrity of the Nation’s waters.” This was the first federal act that addressed
water pollution in regards to environmental health and while this factor may have paved the way
for regulation far more productive than the 1899 Rivers and Harbors act, the Rivers and Harbors
Act was at least regulated by the U.S. Army Corps while the FWPCA allotted most
responsibility to individual states. The FWPCA did allow the U.S. Surgeon General to sue states
which polluted a water body that crossed state boundaries, but there were no federally required
goals, objectives, limits, or guidelines (Stets, 2015). The only federal involvement came when
permission to assess water pollution was granted from the state or when assistance was needed
and requested from the state, and congress often failed to provide sufficient funding (LA Tech
University, 1999). Consequently, as seen through the examples in ​Figure 2.2.1​, water pollution
levels remained the same and even rose in some areas despite the FWPCA as states had little
motivation or reason to implement real change (Powers, 2020). There had been future
amendments in attempts to strengthen the program; however, what was required was a complete
overhaul of the FWPCA for its initial policy goals to hold any effect (Digest of Federal Resource
Laws of Interest, n.d.).
Figure 2.2.1

Examples of Continued Pollution Following the FWPCA

Note.​ Image left shows Bayonne, New Jersey, where raw and partially digested sewage can be
seen darkening the water. Image right shows the Edison Power Plant in Manhattan, which is
estimated to have dumped 6 million gallons of coal into the New York/ New Jersey Bright. (EPA
Archives)

The environmental movement that began in the 60s drastically increased tension with
federal agencies regarding hazardous substances and public health perception on chemical
dumping. Social pressures began forming a strong opposition towards unregulated chemical
companies. Rachael Carson’s 1962 release, ​Silent Spring,​ became a culturally accepted
environmental science epitome, coincidentally creating a new moral standard from Americans
(Lear, 2015). The state of the environment was becoming more political, and during President
Lyndon B. Johnson’s State of Union address in 1965 he said, “Every major river system is now
polluted,” and called for the federal government to set effective water quality standards,
combined with effective enforcement procedures (​The Association of Centers for the Study of
Congress, n.d.). That same year, the 1965 Water Quality Act, which required states to set
pollution standards and created the Federal Water Pollution Control Administration, was
enacted.
Still, the ladder of the 1960s was known less for the environmental movement and more
for the environmental crisis. Despite the 1965 amendment, disaster was striking across the
nation. In January of 1969, an oil spill known as the Santa Barbara Oil Spill covered more than
35 miles of Southern California coastline and had a catastrophic ecological impact (Stets, 2015).
Lake Erie had become polluted to the point that it’s oxygen was nearly depleted as a result of
algae blooms and dead fish had littered the shore; at the time, the lake was declared dead
(Rotman, 2020). One of the most public crises was that of the Cuyahoga River fire. The residents
of Cleveland passed a $100 million bond initiative to clean up the river in 1968, and in 1969 the
Cuyahoga River fire occurred when sparks from a passing train reached oil in the river (Rotman,
2019). This wasn’t the first time the river had caught on fire either, there were several instances
with one being the 1952 fire seen in ​Figure 2.2.2​. While no photographs were captured of the
1969 fire, Time Magazine still covered it, instead opting to use a photograph of the 1952 fire.

Figure 2.2.2

Cuyahoga River Fire of 1952

(The Cleveland Press Collection)

With the coverage in Time Magazine leading to nationwide concern, The Cuyahoga
River fire soon became known as a figurehead for the countries piling environmental issues
(Latson, 2015). Though it wasn’t the first river fire, it was set to be the last when ​the resultant
reform of federal regulations established the 1972 milestone of water stewardship known as the
1972 Clean Water Act (CWA). With the EPA having been established the year prior, the 1972
CWA amended the previously aforementioned FWPCA with one of the largest improvements
being federal regulations that would now be enforced by an agency (Schumm, 2012).
 The CWA’s objectives were to neither dissolve nor dilute the prior regulation, but extend
the FWPCA. The 1972 CWA enactment had given the EPA the authority to create and enforce
new water quality standards in a way that a federal agency hadn’t before (Schumm, 2012). As a
result, individual states were no longer relied as heavily upon, especially due to a new permitting
program called the National Pollution Discharge Elimination System, or NPDES within Sect.
402. The NPDES permitting program’s purpose was to limit point source pollution by targeting
susceptible industries, e.g. construction, through regulation of required technologies and
treatment efforts in discharge mitigation (Schumm, 2012). This was achieved by making the
discharging of pollutants into American waterways illegal unless permitted through the NPDES
program. While primary emphasis in the Clean Water Act was municipal and industrial point
sources, no mechanisms for control of nonpoint sources were implemented by the Act, and no
incentives for complying with pollution abatement programs were specified for these sources.
Nonetheless, the enactment of a land-use planning process in the development of management
plans stood as the first formal recognition that regulation of only point sources would not be
adequate in combating the rising pollution problem (Stets, Kelly, Broussard, Smith, & Crawford,
2012).
Stormwater regulation was first introduced to the CWA in 1973, when the EPA noted the
early known detrimental effects of runoff (EPA, 2018a). However, the suggestions made weren’t
regulated by the EPA as at the time it was assumed they would be best handled at local levels.
The EPA justified this decision by suggesting that the enormous numbers of individual permits
that the agency would have to issue would be administratively burdensome and divert resources
from addressing industrial process wastewater and municipal sewage discharges, which
presented more identifiable problems (Stets, Kelly, Broussard, Smith, & Crawford, 2012). This
decision was met with reluctance, resulting in 1977 amendments to the CWA that further
addressed nonpoint source pollution through the Rural Clean Water Program (Schumm, 2012).
The program supported implementation of best management practices for controlling pollution
from nonpoint sources and required individual permits for stormwater discharges from industrial
or commercial activity, or where the stormwater discharge was designated by the permitting
authority to be a significant contributor of pollutants (EPA, 2018a).
At this time, attention was also directed towards agricultural contributions which are now
a well known source of polluted stormwater runoff. By 1972, agricultural runoff accounted for
the erosion of 2.25 billion tons of soil as well as large amounts of phosphorus and nitrogen
deposited in waters (Spellman & Drinan, 2003). The Department of Agriculture offered guidance
on developing measures to control agriculturally related pollution. In addition, recognizing that
there may be an impact to farms and wetlands, the federal government established the first
wetland mitigation banks around 1983 in partnership with the US Fish and Wildlife Service
(USDA, 2020). The US Soil and Water Conservation Service began specific programs with
farmers to reduce the impact of farming on waters of the US during this period as well.
As urbanization continued, the 1987 CWA amendment 33 U.S.C. § 1342(p) further
expanded upon the NPDES program by including specificities on regulated entities to include
municipal sewer systems. Permits covered industrial activities, general purpose and individual
purpose based on activity levels and population size. Municipal sewer systems now harboring a
population of 100,000-250,000 would require a permit for discharge through the NPDES permit
program (Howard, 1987). Additionally, a combined sewer overflow (CSO) policy had also been
established within the 1987 CWA amendment to further regulate municipal water quality
standards (Howard, 1987). Industrial activities were required to adhere to permittance
requirements as of the 1987 CWA amendment including construction activities. The 1987 CWA
Stormwater amendment had laid a framework of incentive for state and municipal agencies to
control discharges as section C of 3 U.S. Code § 1342 NPDES states federal suspension upon
submission of state programming. This framework increased state side power and consequently,
more municipal control of discharge point source pollution (Howard, 1987).
The federal government recognized the importance of gradual implementation for
continued state/municipal cooperation in continued stormwater management and NPDES permit
compliance. Phase I of a two phased program was enacted in the 1990 amendments of the Clean
Water Act. The most important aspect of the Phase I amendment in relevance to federal
stormwater regulations was it’s establishment of the municipal sewer system MS4 program. An
MS4 had been denoted as a municipal sewer system that supports a population of over 100,000
and less than 250,000 individuals, owned by a municipality, designed for stormwater
conveyance/discharge and is not combined or sectioned into a treatment plant (EPA, 2020b).
Additionally, municipalities must create a separate stormwater management programs, or
SWMP, in order to acquire their MS4 NPDES permit. Municipal cooperation led to 855 different
MS4’s being in compliance under 250 individual permits in accordance with the 1990 CWA
Phase I enactment (EPA, 2020b).
While progress was being made, it was recorded that nearing the end of the 20th century
50% of receiving water bodies were not meeting the water-quality goals established by the CWA
and multiple lawsuits were filed against the EPA as a result (Stets, Kelly, Broussard, Smith, &
Crawford, 2012). The outcome of this was section 303(d) of the CWA, which overall requires
states to identify waters that are impaired by pollution, even after application of pollution
controls. This section added established TMDLs of pollutants to ensure that water quality
standards can be attained.
Unfortunately, smaller municipalities had not been covered under Phase I
implementation. Congruently, a high majority of central locations for large population flux, e.g.
public universities, are also commonly designed with their own sewer discharge systems similar
to municipal sewer systems. The 1999 CWA amendments sought to alleviate sewer discharge
pollution from such systems by also including them into federal regulation. The Phase II
regulations annotated area’s defined as “urbanized areas” under the U.S. Census Bureau to apply
for MS4 NPDES permits for sewer discharges. In addition to smaller municipalities, other
smaller entities such as institutions, public universities, hospitals and prisons are also defined as
MS4’s; therefore, also requiring MS4 NPDES permits (EPA, 2020b). With polluted stormwater
runoff commonly being transported through MS4s, this phase is a large key in stormwater
management. Most of the 6,695 Phase II MS4s are covered by statewide General Permits,
however some states use individual permits. ​Figure 1.4.1 ​displays these areas.
Today, the CWA has been in place for several decades with noticeable effects, one being
about twice as many waters being fishable and swimmable in comparison to the 70s and another
being a 12% increase in waters suitable for fishing (Wiszniewski, 2020). The introduction of
wastewater treatment, specifically Section 106 of the CWA which authorizes EPA to provide
financial assistance to states and eligible interstate agencies for the creation and improvement of
municipal wastewater plants and sewer systems, has had the most documentable effect. Much
like Lake Erie, parts of the Delaware River below Trenton, NJ were considered “dead zones”
after microbes and bacteria thrived on the organic material from pollution and as a result,
consumed all the oxygen, leaving none for the fish (Phillips, 2019). The biggest source of
pollution along the Delaware River at the time was waste water being dumped directly into the
river. As a result of the CWA, these parts of the Delaware River now not only contain fish, but
have also left the reputation of being “dead” behind (Phillips, 2019).
Referencing both ​Figure 1.4.1 ​ and ​Figure 2.2.4​ offers context to the progress made by
the Delaware River. As observed in ​Figure 1.4.1​, states the river flows through are mostly
regulated MS4 areas. As observed in ​Figure 2.2.4, ​the treatment of sewage post Phase I and
Phase II was a major improvement as previously waste water was dumped directly into water
bodies. Since the introduction of industry-specific discharge standards, such as 33 U.S.C. §1251
of the CWA, more than 700 billion pounds of toxic pollutants every year are prevented from
being dumped into the nation’s waters (Devine, 2017).
Figure 2.2.4

How Sewage is Processed

Note.​ Infographic created based on information from CWA amendments.

2.3 State Regulations

New Jersey Regulation. ​Using New Jersey as the main case study for state level
regulations, the predominant agency within the state set to enforce the CWA is the New Jersey
Department of Environmental Protection (NJDEP). In addition to enforcing CWA standards,
NJDEP oversees seven different program areas, which include

● air quality,
● energy and sustainability,
● water resource management,
● land use management,
● climate and flood resilience,
● compliance and enforcement,
● natural and historic resources,
● site remediation, and
● water management (NJGOV, 2020).

After its creation in 1970, the NJDEP concentrated most of the state's water resource protection
efforts on sewage treatment plants, industrial discharges and other major point sources of
pollution. However, as these sources of pollution have been reduced, it’s become clear that one
of New Jersey's largest pollution problems is now nonpoint source pollution. For instance, 586
NJ water bodies that were assessed as not supporting general aquatic life found nonpoint source
pollution from urban runoff and agriculture land uses was the most predominant potential cause
(NJDEP, 2012). With considerations of New Jersey’s population density and the increase of
impervious surfaces this has caused, runoff being a major contributor to water quality harm is far
from shocking, but requires regulation to prevent excess harm (NJDEP, 2012).

While other states and the Federal government generally refer to their rules as
regulations, New Jersey instead uses the word “code.” The New Jersey Administrative Code
(N.J.A.C.), also known as the Code, is the codification of all rules and regulations made by the
executive branch agencies of New Jersey (NJDOE, 2020). Rules from NJDEP are codified in
Title 7 of the Code. New Jersey’s Stormwater Management rules specifically, codified under
N.J.A.C. 7:8, are implemented by the NJDEP through the review of permits issued by the
Division of Land Use Regulation (DLUR) as well as local authorities through the Municipal
Land Use Law (MLUL) and the Residential Site Improvement Standards (RSIS).

In New Jersey, EPA has delegated authority to issue NPDES permits to the NJDEP. As a
result, the first set of rules are the Phase II New Jersey Pollutant Discharge Elimination System
Stormwater Regulation Program (NJPDES) rules (EPA, 2015). As part of NJDEP’s Water
Pollution Control Act, codified as N.J.A.C 7:14, The NJPDES addresses and reduces pollutants
associated with existing stormwater runoff and establishes a regulatory program for existing
stormwater discharges as required under the CWA (EPA, 2015). ​Figure 2.3.1 ​gives a
generalized idea as to when these permits are utilized. The second set of rules are known as the
Stormwater Management rules, codified as N.J.A.C. 7:8, which set forth the required
components of regional and municipal stormwater management plans and establish the
stormwater management design and performance standards for proposed development. The
design and performance standards for new development include groundwater recharge, runoff
quantity controls, and runoff quality controls (NJDEP, 2020b). The New Jersey Stormwater Best
Management Practices Manual provides guidance to address the standards in the Stormwater
Management Rules.
Figure 2.3.1:

NPDES Construction General Permit (CGP) Requirement Flowchart

(EPA, 2017)

Last amended in June 2016, N.J.A.C 7:8 Stormwater Management Rules discuss the
general provisions of stormwater management which include general requirements, regional and
municipal stormwater management planning within the state, design and performance standards
for stormwater management measures, and safety standards for stormwater management basins
(NJDEP, 2020b). These provisions are regulated by The Bureau of Nonpoint Pollution Control
under the NJDEP’s Division of Water Quality (DWQ), which maintains a mission statement to
“protect New Jersey’s surface and ground waters from pollution caused by improperly treated
wastewater, residuals, and stormwater” (Division of Water Quality, 2019). The stormwater
management planning goals stated in the N.J.A.C 7:8 should be designed to “reduce flood
damage, minimize an increase in stormwater runoff from new developments, reduce soil erosion,
assure the adequacy of existing and proposed culverts and bridges, maintain groundwater
recharge, prevent an increase in non-point pollution, maintain the integrity of stream channels for
their biological functions, minimize pollutants in stormwater runoff, and to protect public safety
through proper design and operations” (NJDEP, 2016). A plan must include structural and
nonstructural stormwater management strategies, safety standards for stormwater basins,
consideration of physical and ecological characteristics of the planning area, and any ordinance
must be coordinated with other management areas in the same river basin.

General requirements of NJ stormwater regulation.​ The Stormwater Management

rules apply to all major developments, which can be defined as all developments that are part of
a common plan of development or sale that collectively or individually meet any one or more of
conditions listed by the NJDEP. These conditions are

● The disturbance of one or more acres of land since February 2, 2004;

● The creation of one-quarter acre or more of “regulated impervious surface” since
February 2, 2004;
● The creation of one-quarter acre or more of “regulated motor vehicle surface” since
March 2,2021; or
● A combination of 2 and 3 above that totals an area of one-quarter acre or more. The same
surface shall not be counted twice when determining if the combination area equals one
quarter acre or more (NJDEP, 2016).

Within the N.J.A.C 7:8-5, design and performance standards discuss measures that should be
taken for major developments, structural and nonstructural stormwater management strategies,
erosion control, groundwater recharge and runoff quantity standards, and stormwater runoff
quality standards. Major developments within the state have the most standards to abide by
having to meet the standards for all components mentioned previously and should be focused on
minimal impact to the surrounding environment including surface water and groundwater
quality, habitat for threatened and endangered species, and land use management. As of October
25, 2019, NJDEP adopted amendments to N.J.A.C. 7:8 “to replace the current requirement that
major developments incorporate nonstructural stormwater management strategies to the
‘maximum extent practicable’ to meet groundwater recharge standards, stormwater runoff
quantity standards, and stormwater runoff quality standards, with a requirement that green
infrastructure be utilized to meet these same standards” (NJDEP, 2019).

NJ stormwater runoff standards. ​The runoff quantity standards at N.J.A.C. 7:8-5.4(a)3

are applicable to major development if 0.25-acre or 1-acre of new impervious surface is added or
exceeded, unless the receiving waterbody is tidal and existing structures will not be subject to
increased flood damages by increases in runoff (NJDEP, 2016). As described in the Stormwater
Management Rules, the NJDEP has specified that one of two general runoff computation
methods be used to compute runoff rates and volumes. The first and most commonly used
method is The USDA Natural Resources Conservation Service (NRCS) methodology, which
uses a hypothetical design storm and an empirical nonlinear runoff equation to compute runoff
volumes, and a dimensionless unit hydrograph to convert the volumes into runoff hydrographs
method for computing stormwater runoff rates, volumes, and hydrographs (Division of
Watershed Management, 2004, p. 5-27). The key component of the NRCS runoff equation is the
NRCS Curve Number, which is based on soil permeability, surface cover, hydrologic condition,
and antecedent moisture. This method is particularly useful for comparing pre- and
post-development peak rates, volumes, and hydrographs. The second method is The Rational
Method, which uses an empirical linear equation to compute the peak runoff rate from a selected
period of uniform rainfall intensity. Since it is not based on a total storm duration, but rather a
period of rain that produces the peak runoff rate, the method cannot compute runoff volumes
unless the user assumes a total storm duration but continues to be useful in estimating runoff
from simple, relatively small drainage areas such as parking lots (Division of Watershed
Management, 2004, p. 5-27).

For stormwater runoff quantity standards, one of the three following designs should be
completed using the assumptions of stormwater runoff calculations. In general, all runoff
computation methods are, to some degree, mathematical expressions of the hydrologic cycle.
One, to demonstrate that runoff leaving the site post-construction does not exceed
pre-construction runoff for two, 10, and 100-year storm events. Following, to demonstrate
through hydrologic and hydraulic analysis there is no increase compared to pre-construction, in
peak runoff rates leaving the site for two, 10 and 100-year storm events and if there is an
increase in runoff does not negatively impact property at or downstream of the site. Post
construction stormwater management designs should have runoff rates for two, 10, and 100-year
storm events that are 50%, 75%, and 80%, respectively of pre-construction rates. Stormwater
runoff quality standards (N.J.A.C 7:8-5.5) are based on design measures to reduce
post-construction load of total suspended solids (TSS). ​Table 2.3.1​ below describes the time
interval from time 0 to 2 hours and the amount of cumulative rainfall in inches used to determine
these water quality calculations. As an aspect of New Jersey’s BMP, it contains cumulative and
incremental rainfall values for the stormwater quality design storm in five minute increments that
can be used in computer programs such that contain the NRCS methodology and allow
user-specified rainfalls.
Table 2.3.1

NJDEP 1.25-Inch/2-Hour Stormwater Quality Design Storm

(Division of Watershed Management, 2004, p. 5-27)

Overall, in accordance with NJDEP stormwater management measures should be

designed to reduce the post-construction nutrient load from the developed site in stormwater
runoff generated from the water quality design storm to the maximum extent feasible. In
achieving reduction of nutrients to the maximum extent feasible, the design of the site shall
include nonstructural strategies and structural measures that optimize nutrient removal while still
achieving the performance standards in N.J.A.C. 7:8-5.4 and 5.5. In addition, if a waterbody or
waterbody segment in the regional stormwater management planning area is on the Department's
list prepared to comply with CWA, Section 303(d) (33 U.S.C. § 1313(d), for one or more
designated uses by stormwater runoff, then drainage area objectives would be included to
address the pollutants which left the waterbody threatened or impaired.
Besides issuing permits, Rain Tax, S-1073 was introduced in New Jersey to help
manage stormwater, stating, “Any county, municipality, or authority that collects a stormwater
utility fee under the bill would be required to remit to the State Treasurer annually an amount
equal to five percent of all such fees collected by the stormwater utility, or $50,000 (Peterson &
Haines III, 2019).” The Bill allows counties and municipalities to create stormwater management
utilities dedicated to reducing flood risk and cutting back on the amount of pollution that washes
into Garden State waterways. The utilities are funded by fees assessed to property owners based
on the number of impervious surfaces, like roads, roofs and parking lots, they have on their
property (Peterson & Haines III, 2019).
Plus the agencies mentioned above, the New Jersey Department of Agriculture (NJDA)
aids in lowering pollutants resulting from stormwater runoff as well. One way is through the
Animal Waste Management rules, adopted by the NJDA in 2009 and codified as N.J.A.C. 2:91.
These rules “set forth the requirements for the development of Animal Waste Management Plans
(AWMPs) or Comprehensive Nutrient Management Plans (CNMPs) for farms which generate,
handle or receive animal waste (NJDA, 2016).” The rules contain criteria and standards for
animal waste management on all agricultural animal operations not requiring a New Jersey
Pollutant Discharge Elimination System (NJPDES) permit, including animal feeding operations,
all of which can pollute stormwater runoff (NJDA, 2016).
Moreso, along with the NJDEP, the NJDA is a co-sponsor for The Conservation Reserve
Enhancement Program (CREP) which is a joint State-Federal conservation program targeted to
address environmental impacts related to agricultural practices. Under NJ CREP, farmers receive
financial incentives from FSA and NJDA to voluntarily remove marginal pastureland or
cropland from agricultural production and convert the land to native grasses, trees and other
vegetation ​(Land Use Management & Division of Watershed Management, 2008, p. 35-40.)​. The
vegetation can then serve as a buffer to filter or contain agricultural runoff and prevent polluted
stormwater runoff generated by farms from reaching neighboring water bodies. The $100 million
NJ CREP proposal seeks to enroll 30,000 acres of agricultural lands into the program and
provides a 10-year enrollment period and targets the installation of riparian buffers, filter strips,
contour buffer strips and grass waterways ​(Land Use Management & Division of Watershed
Management, 2008, p. 35-40.)​.
 NJ groundwater recharge standards.​ Within N.J.A.C 7:8-5:4, minimal design and
performance for groundwater recharge standards are established. These standards abide by those
of the Soil Erosion and Sediment Control Act, N.J.A.C. 4:24-39, with the minimum design and
performance standards for erosion control established by the act. Standards for groundwater
recharge in areas of urban development use calculations and factors to either demonstrate
through hydrologic and hydraulic analysis that a site and its stormwater management strategy
maintains 100% of its annual average groundwater recharge prior to construction or that there is
an increase in runoff volume from prior to post construction (Division of Watershed
Management, 2004, p. 6-29). Specifically, groundwater recharge is calculated using “The New
Jersey Geological Survey Report GSR-32 A Method for Evaluating Groundwater-Recharge
Areas in New Jersey.” An important component to groundwater recharge is that the design
assesses the impact on the groundwater table to avoid adverse hydraulic impacts. Potential
adverse hydraulic impacts include a naturally or seasonally high water table so as to cause
surficial ponding, flooding of basements, or interference with the proper operation of subsurface
sewage disposal systems and other subsurface structures in the vicinity or downgradient of the
groundwater recharge area (Division of Watershed Management, 2004, p. 6-29). The exception
is that of stormwater from a high pollutant area, which should not be recharged.

On March 2, 2020, amendments to the SWMR were adopted. Most significantly, the
amendments require major developments to utilize green infrastructure to meet the groundwater
recharge and stormwater runoff quantity and quality standards, replacing the previous
requirement to incorporate nonstructural stormwater management strategies to the “maximum
extent practicable (Riker Danzig Scherer Hyland & Perretti LLP & Haus, 2020).” Water
quantity, quality, and groundwater recharge standards must be met in each drainage area on-site
and a groundwater mounding analysis is required for all infiltration BMPs, not just for recharge.
According to the NJDEP, the amendments to the SWMR will more effectively reduce
stormwater volume, reduce erosion, encourage stormwater infiltration and groundwater recharge,
and minimize the discharge of stormwater-related pollutants into the environment (Johnson,
2019). Even with these amendments, FEMA still recommended the state consider adding a
requirement that nutrients, such as fertilizer, be reduced in runoff water as currently there are no
specific regulations regarding these nutrients that prevent excess use of them (Johnson, 2019) .

NJ Stormwater Structure and Infrastructure.​ In N.J.A.C 7:8-6, the safety standards

set forth are to protect the public through proper design and operation (NJDEP, 2016). The
purpose for trash racks, overflow grates and any escape provisions follow as such: design to
catch debris and prevent clogging out outlet structures; to prevent obstruction of overflow
structure; and provisions for stormwater management basins. Some requirements for each
include being designed to not adversely affect outlet pipes and be removable in emergency and
maintenance cases, constructed to be durable and corrosive resistant and withstand a live load of
300 lbs./ft sq (Division of Watershed Management, 2004, p.22).
 The New Jersey Statewide Nonpoint Source Program is responsible for administering the
federal Section 319(h) Grant Program, in which sources are the EPA pass-through grants issued
under Section 319(h) of the CWA and other federal and State funds that may be available for
NPS-related water quality restoration activities (Division of Water Monitoring and Standards,
2020a). On top of the Nonpoint Source Program, The New Jersey Water Bank, a partnership
between the NJDEP and the New Jersey Infrastructure Bank (I-Bank), provides low-cost loans
and other funding for a variety of environmental infrastructure projects that provide a water
quality benefit as well (New Jersey Future, 2018). Eligible projects include bioswales,
stormwater pump-outs, porous asphalt or concrete, green roofs, cisterns, and street tree trenches;
Table 2.3.2​ contains examples of already implemented projects as well as their purpose.

Table 2.3.2

​Projects With Green Infrastructure Funded by The Water Bank From FY2015 to FY2017

(New Jersey Future, 2018, p. 3)

2.4 Regional Regulations

Regional stormwater management planning is a water resource management strategy that

identifies and develops solutions to problems that can be managed most effectively on a regional
basis (Division of Watershed Management, 2004, p. 3-16). The regional stormwater management
plan (RSWMP) under N.JA.C 7:8 covers individual properties, neighborhoods, municipalities,
and even county borders. The goal of the plan is to address any existing water quantity issues
such as water quality issues, like excess pollutant loading, or issues of water quantity and quality
for future development on existing land uses in regional bases, which the planning area should
consider one or more continuous drainage areas. Under N.J.A.C 7:8-3, the regulations require the
formation of a broadly representative regional planning committee, then the committee will lead
a planning agency to plan out technical and administrative resources to develop and implement a
regional plan. Doing so requires sources from

● state and FEMA floodplain maps,

● hydraulic analysis and stream cross section data from stream encroachment
permits,
● topographic data from aerial photos with two-foot contours,
● water quality data from New Jersey Pollution Discharge Elimination System
(NJPDES) permits or intake waters from local water treatment facilities, and
● monitoring data from the U.S. Geological Survey, the Environmental Protection
Agency’s STORET database, the NJDEP, local health departments,
environmental commissions, or watershed associations (Division of Watershed
Management, 2004, p. 3-16).

While the benefits include improved water resources for years to come, creating a
suitable, well-organized, high-quality Regional Stormwater Management Plan takes a substantial
amount of effort. In addition to requiring great effort, budgets for developing RSWMPs typically
exceed $100,000 as they often require extensive collection and complex analysis of field data
(Division of Watershed Management, 2004, p. 3-16). Once created, the plan should have the
following components, existing land uses; projected lands; soil mapping units from the U.S
Department of Agriculture; Topography from U.S Geological Survey Topographic Map; Water
bodies map from both the U.S Department of Agriculture and U.S Geological Survey
Topographic Map; Coastal wetlands map from the Wetlands Act of 1970, 13:9A-1 et seq and
freshwater wetlands maps from the Department under the Freshwater Wetlands Protection Act,
13:9B-1 et seq; Flood hazard areas listed from the Flood Hazard Area Control Act, 58:16A-50 et
seq; Groundwater recharge areas from NJDEP; Environmentally constrained and critical areas;
River areas from the New Jersey Wild and Scenic Rivers Act, 13:8-45 et seq., or the Federal
Wild and Scenic Rivers Act, (Division of Watershed Management, 2004, p. 3-16). Nonetheless,
as a state containing both a vast coastline and vast forest, New Jersey has had to create some
regional level management. While as of 2019 no Regional Stormwater Management Plans had
been created in New Jersey, some regions maintain their own management plans that incorporate
individualized stormwater management plans.
In regards to the state's beaches, NJDEP administers the New Jersey Cooperative Coastal
Monitoring Program (CCMP). During the bathing beach season, ocean and bay stations that can
be located in​ Figure 2.4.1 ​are monitored on a weekly basis for bacteria. Once an impaired area is
identified, existing data and information is researched, reviewed, and analyzed to identify gaps
and develop targeted monitoring studies and sanitary surveys (CCMP, 2020). Stormwater runoff
has a significant impact on water quality at public recreational beaches and as a result elevated
bacteria levels and subsequent beach closure often occur following rainfall. Though these are
often only temporary fluctuations, many beaches face consequences from not just stormwater
runoff runoff but stormwater outfalls as well that convey stormwater from our streets to oceans,
bays and rivers. Following the identification of an impaired area, if the DEP then identifies
persistent water quality problems at a recreational bathing beach, the CCMP will implement a
source track down strategy in partnership with the Division’s Bureau of Marine Water
Monitoring, the local health agency. The New Jersey Water Bank can be used as a resource to
repair and replace problematic and antiquated infrastructure and offers 50% principal forgiveness
for capital improvement projects that will eliminate, prevent or reduce occurrences of beach
closings due to the presence of pathogens (New Jersey Future, 2018). Funding has the potential
to be applied to projects that would eliminate potential sources such as leaking or broken sanitary
sewers and illegal cross connections between storm sewers and sanitary sewers (New Jersey
Future, 2018).

Figure 2.4.1:

CCMP Water Monitoring Stations as of July 1, 2020

(CCMP 2020)

Another regional focus of New Jersey is that of the pinelands; in 1978 the US Congress
passed legislation creating the New Jersey Pinelands National Reserve, seen in ​Figure 2.4.2​, to
protect the area's ecology and aquifer, which serves the large metropolitan region (Pinelands
Preservation Alliance, 2020). The aquifer in question, also seen in ​Figure 2.4.2​, is the
Kirkwood-Cohansey aquifer and contains some 17 trillion gallons of fresh water. Due to how
shallow it is the aquifer is easily polluted by fertilizers, herbicides, pesticides and chemicals that
are spread or spilled on the ground’s surface (South Jersey Water Savers, 2020). Following the
reservation of the land, the 1979 Pinelands Protection Act was created, establishing a regional
plan (the Pinelands Comprehensive Management Plan, or CMP) and governance structure (the
Pinelands Commission) that restricted development in environmentally sensitive areas in order to
preserve natural and cultural resources. The Stormwater Management rules do not supersede the
Pinelands CMP, putting relevant municipalities in the unique position of having to implement
stormwater management ordinances that comply with both DEP and Pinelands regulations.
Additionally, in conjunction with NJDEP the Pinelands Commission created a Stormwater
Control Model Ordinance for Pinelands municipalities in 2004 using $15,000 of NJDEP funds
(Rapa, 2004). Some variances between the general rules and those followed in the pinelands
include that in Pinelands, groundwater accounts for more than 90 percent of stream flow
(Pinelands Preservation Alliance, 2020). Consequently, the pinelands require groundwater
recharge levels that are higher than that of other New Jersey areas. Another difference is that in
comparison to other areas, as a result of the porous soils in the Pinelands the amount of runoff is
low.
Figure 2.4.2:

Map of Pinelands National Reserve

(Pinelands Preservation Alliance, 2020)

2.5 Local Regulations

New Jersey’s Stormwater Management Rules are implemented by local authorities

through the Municipal Land Use Law (MLUL) and the Residential Site Improvement Standards
(RSIS). MLUL is how municipalities in NJ obtain their authority to identify, evaluate, designate,
and regulate historic resources, enabling legislation for municipal land use and development
planning, zoning, and historic preservation zoning (NJDEP, 2016). Under MLUL, a utility
service plan element analyzing the need for and showing the future general location of water
supply and distribution facilities, drainage and flood control facilities, sewerage and waste
treatment, solid waste disposal and provision for other related utilities, and including any storm
water management plan is required. Through the RSIS, the Stormwater rules are activated
whenever a municipality requires the control of runoff from a site that is the subject of a site or
subdivision application (NJDEP, 2016). Therefore, with its duly adopted ordinances, a
municipality may require compliance with the Stormwater rules through the RSIS whether or not
a development is a major development. The rule clarification and interpretation are consistent
with the current application of the Stormwater rules by the Department and don’t supersede local
authority under the MLUL. Most recently, a bill known as the “rain tax” by some and “flood
defense” by others let's municipalities and counties create their own local stormwater utility that
could then charge property owners a fee based on "a fair and equitable approximation" of how
much runoff is generated from their property (Peterson & Haines III, 2019). Property owners
could get their fees reduced by installing rain barrels, rain gardens and other naturally based
systems that reduce runoff rates.

The Municipal Stormwater Regulation program from the NJDEP, codified as NJAC
7:14A-25.1, was developed in December 1999 corresponding to the U.S. Environmental
Protection Agency’s Phase II rules. As defined by MLUL, established municipalities must meet
requirements set for regulating discharges to surface water and groundwater of stormwater from
large, medium, and small municipal separate storm sewer systems (NJDEP, 2016). NJDEP
delivered the confirmed stormwater rules and four permits on February 2, 2004. The four
renewal permits referred to as MS4 according to 4&41, authorized stormwater discharges from
Tier A and Tier B municipalities, public complexes, and highway agencies that discharge
stormwater from municipal separate storm sewers. These general permits address stormwater
quality issues associated with new development, redevelopment and existing development.

Tier A, assigned under N.J.A.C. 7:14A-25.3(a)1, includes 462 municipalities, that are
more densely populated regions or along or near the coast addressing new and existing
development (NJDEP, 2016). The renewal of NJPDES master general permit NJ0141852 applies
to Tier A municipalities only and also regulates privately owned streets, basins and storm drains,
any stormwater facilities owned by commercial interests or by homeowner associations.
According to N.J.A.C. 7:14A-25, the regulation of stormwater for Tier A MS4 NJDEP permit is
planned to deliver significant water quality benefits and prevent increased flooding and erosion,
regulatory mechanism which addresses stormwater quality and quantity issues related to public
works operations, new development, redevelopment, and existing developed areas by requiring
existing Tier A Municipalities to continue to implement stormwater programs (NJDEP, 2020b).
In 2018, NJDEP added new permit conditions since most permit conditions are from the 2009
Tier A MS4 master general permit, which include:
 · Upgraded maintenance language intended to ensure better function of
stormwater facilities; prioritizing maintenance; to ensure proper maintenance of
privately owned and operated stormwater facilities at developments approved by
the municipality; and to specify that any inspection and maintenance logs include
specific information including the location of the facility inspected.

· Greater flexibility in the frequency of storm drain inlet and catch basin
inspection and cleaning to maintain the integrity and functionality of the MS4.

· Clarified, improved and additional stormwater management conditions to better

reflect activities that generally occur at the municipal maintenance yard such as
vehicle washing, yard trimmings and wood waste management.

· Best practices for the use of herbicides in municipal roadside operations

· Greater flexibility for employee training with new training resources to

expand knowledge and skills.

· A Major Development Stormwater Summary form

· Training requirements for design engineers, municipal engineers, and other

individuals that review stormwater management design for development and
redevelopment projects on behalf of a municipality.

· Training requirements for members of municipal boards and councils that

review and approve applications for development and redevelopment projects on
behalf of a municipality.

· Annual review of Total Maximum Daily Load (TMDL) reports (Division of

Water Quality, 2004).

Further, if a Tier A Municipality meets the requirement, it does not require any new local
ordinances to renew but instead is required to submit an annual report and certification under the
new MSA4 Tier A permit. Galloway Township is an example of a Tier A Municipality and
maintains a Municipal Stormwater Management Plan, as mandated by NJAC 7:14:A-25, that
addresses all requirements in 7:8 Stormwater Management Rules (GTNJ, 2017).​ Figure 2.5.1
displays the general requirements from Galloway’s Tier A permit as well as the codes that
regulate them. The town is a Municipal Blue Star Recipient, meaning it has partaken in The
Municipal Blue Star program that combines the visionary Sustainable Jersey Program with Clean
Ocean Action’s focus on water quality protection. The program works on a point basis and
Galloway Township exceeded the necessary 150 points needed to attain certification by
completing 234 points through things such as their water conservation education program and a
rain garden in the town (GTNJ, 2017). The Office of Sustainability in Galloway is in charge of
the towns stormwater management and overall water quality.

Figure 2.5.1:

Galloway Township Tier A Permit General Conditions

(GTNJ, 2017)

Public complexes can include a “campus of a college or university which Statewide has a
combined total of at least 1,000 employees (usually present at least six hours per day on
weekdays) or full-time students'' located partially in a municipality that is assigned to Tier A or
in a municipality that receives a waiver (NJDEP, 2016). The Public Complex Permit, which
regulates discharge from large public complexes such as universities, hospitals and prison,
requires that each Public Complex develop, implement, and enforce a stormwater program that
shows how the public complex will implement each permit requirement. Under the permit, an
Annual Report and Certification must be submitted each year on or before July 1, which need to
be maintained for at least five years and signed and dated by the university (EPA, 2007). A
Stormwater Pollution Prevention Plan (SPPP) form is also required for the permit which can be
created by the public complex, however it is not required to submit the plan as the Department
will review the SPPP during inspections. The steps taken to create a SPPP can be seen in ​Figure
2.5.2. ​Another reason submission isn’t mandated is the plan is meant to serve as a dynamic
document that is never fully completed; each year, with the submission of an Annual Report and
Certification, complexes should analyze and assess BMPs and potential management
improvements (NJDEP, 2016). ​Figure 2.5.3 ​displays an example of how municipal stormwater
programs, SPPP, Statewide Basic Requirements (SBRs) and other permit requirements
(Additional Measures and Optional Measures) all relate to one another, offering context as to
how the different levels of regulation coincide.
Figure 2.5.2

SPPP General Development & Implementation Steps

(EPA, 2007)

Figure 2.5.3
How Municipal Stormwater Programs, SPPP, Statewide Basic Requirements (SBRs) and Other
Permit Requirements (Additional Measures and Optional Measures) Relate to One Another

(Division of Water Quality, 2004, p.5)

An example of a public complex is Stockton University, which implemented one of their

first master plans in 1990 that states that the area is within the NJ pinelands area that’s covered
under NJSA 13:18A-1 and NJAC 7:50-1 through 8 (Stockton University, 2020b). The 2010
master plan addressed miscalculations from the initial plan and introduced stormwater
management. Now with a Stormwater Pollution Prevention Team consisting of 12 team members
who are involved with other important directories within Stockton, the school aims to reach
stormwater prevention goals by sharing the responsibility of keeping common pollutants out of
the water and making small but impactful changes within the community.

Tier B includes 104 municipalities, which are in more rural and non-coastal areas
focusing on new development, redevelopment projects and public education. The renewal of
NJPDES master general permit NJ0141861 applies to Tier B Municipalities only (NJDEP,
2016). Tier B apply on Statewide Basic Requirements (SBR), which includes local public
education and outreach, post-construction stormwater management in new development and
redevelopment. There is no renewal fee for both Tier A Tier B permits, but it does charge Tier A
from $600 to $9000 and Tier B for $500 annually. Both Tier A and Tier B permit is related to
N.J.A.C. 7:8 under the authority of Municipal Land Use Law and the Residential Site
Improvement Standards where both need to meet the standards (NJDEP, 2016).
 The Highway Agency Stormwater Permit regulates the discharge of stormwater from
highways or roads for the NJ Department of Transportation, NJ Turnpike Authority, and the
South Jersey Transportation Authority. There are different regulatory mechanisms which are all
under legation within most New Jersey counties, which are pet waste control, improper waste
disposal control, wildlife feeding control and prohibiting illicit connections. All regulatory
mechanisms need to meet the minimum standard for the permit. In addition to the MS4s, there
are many general permits that are issued by the department to regulate stormwater discharge that
can be seen in​ Table 2.5.1.

Table 2.5.1:

General Permits Issued by The Department

Permit Area of Use

The Sand and Gravel Activity permit (RSG) Involved in sand and gravel mining or
quarrying processes

The Vehicle Recycling General Permit vehicle recycling

(RVR)

Dental Amalgam General Permit (K2) for new or existing dental facilities.

The Concrete Products Manufacturing Permit for facilities that manufacture concrete or
(CPM) concrete products.

Basic Industrial Stormwater Permit (5G2) for facilities being eliminated or eliminated
within 6 months of authorization, any
exposure materials will need to be covered or
moved indoor.
The Concentrated Animal Feeding Operation for regulating animal feeding discharge under
Permit(R8) N.J.A.C. 7:14A-2.13.

The Construction Activities Permit(5G3) where construction parties need to develop a

soil erosion and sediment plan and the permit
is given by the Local Soil Conservation
Districts.

.The Scrap Metal Permit (SM) recycling business, including vehicle parts.

The Hot Mix Asphalt Producers Permit (R4) aims for any manufacture on hot mix asphalt

Mining and Quarrying Activities Permit for mining and quarry activates under the
(R13) Standard Industrial Classification (SIC) 1411,
1423, 1429, 1442, 1446, 1459 and the North
American Industry Classification System
(NAICS) 212311, 212313, 212319, 212321,
212322, 212325, 212319, 212399

permit for Newark Airport (R5) regulates any aircraft, vehicles and equipment
activates related to stormwater discharge

The Lined Surface Impoundments Permit for unlined surface impoundments, basins or
(LSI) infiltration or percolation creeks.

The Basin Discharges at Sanitary Landfills for sanitary landfills on stormwater discharge
Permit (l1) toward basins. Sanitary Subsurface Disposal
Permit (T1) which allows discharge of
sanitary sewage with a design volume in
 addition to 2,000 gross domestic product
(GPD)

The Potable Water Treatment Plants discharge of filter backwash and clarifier
Permit(I2) water from potable water treatment plants to
basins, this permit also involved drinking
quality standards on removal of metals.

The Wood Recyclers General Permit (R7) for wood recycling facility operations that are
classified as Solid Waste Class B Wood
Recyclers.

(NJDEP, 2016)

2.6 Conclusion

The United States have come a long way in their efforts to protect the nation’s waterways
in the last 70 years. From the first federal regulation of the FWPCA in 1948 to the CWA of 1972
with constant adoptions and amendments being added throughout the years. Within the United
States, states have their own authority based on the federal regulations to either abide by or make
stricter laws in the battle to protect our waterways. ​Table 2.6.1​ lists applicable Stormwater acts,
rules, regulations and manuals that have played a significant role in protecting the chemical,
physical, and biological integrity of the nation’s waters.
Table 2.6.1

Applicable Stormwater Acts

Federal Regional

Federal Water Pollution Control Act of 1948 Regional Stormwater Management Plan under
N.J.A.C 7:8-3

Clean Water Act of 1972 NJ Stormwater Best Management Practices

1987 Stormwater Amendment Manual
National Pollution Discharge Chapter 3
Elimination System
1990 Phase I Amendment
1999 Phase II Amendment

State (NJDEP) Local

Stormwater Management Rules N.J.A.C 7:8 N.J.A.C 7:8-4

as of 2016
Adoptions to N.J.A.C 7:8 as of late 2019

NJ Stormwater Best Management Practices Municipal Stormwater Regulation

Manual General permits for Tier A & B
Municipalities, Public
Complex & Highway Agencies
Guidance Document

Rain Tax Bill S-1073 Municipal Land Use Law

Water Pollution Management Element

New Jersey Pollutant Discharge
Elimination System

Table 2.5.1 Stormwater acts, rules, regulations and manuals for federal, state, regional, and
local use
 3. Stormwater Management Practices

3.1 Introduction
Within ​2. Stormwater Regulations, ​the agencies responsible for implementing
stormwater management practices as well as specific regulations were reviewed at all levels. It’s
historically observed that lack of federal oversight led to the downfall of various acts that aimed
to repair the quality of the nations water bodies, due mostly to poor funding and poor incentive
for states to implement management practices among other factors. However, with the CWA
implementation following those failures an easy conclusion to draw may be that the issue of poor
regulation has dissipated along with the country’s water pollution issues. For example, a specific
case study reviewed in ​2. Stormwater Regulation​ was that of the Delaware River, which faced
potentially irreversible effects of pollution up until the implementation of the CWA, at which
point the river began to recover. Much like the Delaware River, water bodies across the country
were given a chance to heal from the ample dumping of waste that had occurred prior. Some
water bodies, on the other hand, continue to suffer.
Lake Eerie, another case study discussed in ​2. Stormwater Regulation, ​still contains
dead zones to this day mostly due to algae blooms. Dangerous levels of one algal toxin in August
2014 led to the shut down of Toledo, Ohio’s drinking water supply for three days (Rotman,
2020). Moreover, Lake Eerie only saw it’s largest algae bloom in 2012 as a result of a record low
flow that year that left the lake unable to handle the pollution it received. Researchers found that
both of Lake Erie's environmental problems are ultimately caused by agricultural runoff and
human activity, which result in too much phosphorus entering the lake (Rotman, 2020). New
Jersey’s largest lake, Lake Hopatcong, faced the same issue with algae blooms shutting down all
recreational uses over summer 2020 only a year after the previous case was resolved. Stormwater
infrastructure upgrades and p​hosphorus-controlling technologies ​were determined to be a
long-term solution, but don’t account for the algae blooms already present (Comstock, 2020).
These aren’t isolated examples either. The 2012 National Lakes Assessment found that 35% of
lakes assessed had excess nitrogen, 40% had excess phosphorus and 31% of lakes have degraded
benthic macroinvertebrate communities, which include small aquatic creatures like snails and
mayflies (EPA, 2016c). The 2008/2009 Rivers and Streams Assessment found that only 28% of
rivers and streams were in good condition and 46% were in poor condition, with more than 40%
of rivers and streams containing excess nutrients (EPA, 2016a). In the 2011 National Wetland
Condition Assessment, fewer than 50% percent of wetlands were in good biological condition
and 32% were in poor condition (EPA, 2016b).
In a statement to Circle of Blue, the EPA said, “Many of these problems will require
expanded treatment of sewage and industrial discharges. But the majority of pollution problems
are caused by runoff from agricultural sites, city streets, rural areas, and other diffuse sources
(​Kozacek, 2015)​.” While this statement acknowledges the detrimental effects of runoff, much
like the CWA it doesn’t follow up with an answer to the effects. To aid in the crisis of NPS
pollution, new technologies continue to be developed to make stormwater management
inexpensive and eco-friendly. As society has reached a greater understanding of the effects that
runoff can have on native ecosystems, green infrastructure has been developed, radically
changing how we cope with stormwater. Section 502 of the Clean Water Act defines green
infrastructure as, "...the range of measures that use plant or soil systems, permeable pavement or
other permeable surfaces or substrates, stormwater harvest and reuse, or landscaping to store,
infiltrate, or evapotranspirate stormwater and reduce flows to sewer systems or to surface waters
(EPA, 2020c)."
Green infrastructure can be used on different scales, from the house or building level, to
the broader landscape level. On the smaller end of the scale, i.e local level projects, green
infrastructure practices include rain gardens, permeable pavements, green roofs, infiltration
planters, trees and tree boxes, and rainwater harvesting systems. At the largest scale, the
preservation and restoration of natural landscapes, such as forests, floodplains and wetlands, are
critical components of green infrastructure (EPA, 2020c). Nevertheless, there are many
communities in the United States that still rely on “gray infrastructure” to manage stormwater,
which generally involves a system of gutters, downspouts, pipes, and stormwater drains that
channel stormwater into Combined Sewer Systems, which can be reviewed in ​Section 1.3.
Alternatively, other towns have channels and storm drains that direct stormwater directly into
local water bodies. Most communities still using gray infrastructure are located in the
Mid-atlantic and New England regions, which can be attributed to the fact these cities are some
of the oldest in the country; population expansion and development occurred too rapidly for city
planners to predict the types of issues that would occur with Combined Sewer Overflows (EPA,
2020c). The costs of retrofitting and replacing these systems can be prohibitive, but many cities
and towns are working to implement green infrastructure as much as possible in new
developments to offset negative impacts of Combined Sewer Outfalls.
Generally, where gray infrastructure ultimately discharges untreated stormwater into a
local water body, green stormwater infrastructure is instead designed to mimic nature and
capture rainwater where it falls. Through mimicking the natural hydrological processes and using
natural elements such as soil and plants to turn rainfall into a resource instead of a waste, GI
increases the quality and quantity of local water supplies and provides myriad other
environmental, economic, and health benefits—often in nature-starved urban areas (EPA,
2020c). In addition and often in conjunction with innovative green infrastructure techniques,
there is an effort to allow naturally occurring ecosystem services to take care of the problem of
stormwater runoff on their own - as is the case when rehabilitating riparian buffers.
As of October 25, 2019, NJDEP adopted amendments to N.J.A.C. 7:8 “to replace the
current requirement that major developments incorporate nonstructural stormwater management
strategies to the ‘maximum extent practicable’ to meet groundwater recharge standards,
stormwater runoff quantity standards, and stormwater runoff quality standards, with a
requirement that green infrastructure be utilized to meet these same standards (Adoptions
Amendments, 2020).” The New Jersey Stormwater Best Management Practices Manual lists
types of GI and their applicable uses in New Jersey, as well as how to implement them. The New
Jersey Water Bank, a partnership between the NJDEP and the New Jersey Infrastructure Bank
(I-Bank), provides low-cost loans and other funding for a variety of environmental infrastructure
projects that provide a water quality benefit as well. Eligible projects include bioswales,
stormwater pump-outs, porous asphalt or concrete, green roofs, cisterns, and street tree trenches
(New Jersey Future, 2018). NJ Water Savers offers rain barrel workshops and is a great resource
for other green infrastructure information. While there are many types of GI practices, the most
relevant types are discussed below, with ​Figure 3.1.1​ showing examples. It’s important to recall
that before humans began fundamentally altering the landscape, stormwater management was not
an issue. Storms are a natural part of any ecosystem, and ecosystems were generally able to
handle the occasional load of extra water they bring. It is the removal of native plant
communities and addition of impermeable surfaces that causes runoff from storm events to
become such a major problem. With this in mind, one of the greatest tools in stormwater
management is the restoration of naturally occurring plant communities.

Figure 3.1.1.

EPA Examples of Green Infrastructure

(EPA, 2020c)
3.2 Riparian Buffers
A riparian buffer is the border of vegetation lining waterways that prevents negative
impacts and can be implemented as green-infrastructure at a landscape-scale (NJ Forest Service,
2018). Standing as a protective vegetated wall around waterways, riparian buffers serve two
crucial purposes related to stormwater. First, the trees themselves take up water, reducing the
amount of overground flow that will actually reach the waterway. Second, their roots anchor the
soil lining the waterway, resulting in significantly less erosion than a bare streambank. ​Figure
3.2.1 ​displays the EPA and NJ Forest Service recommendations for an effective riparian buffer.
Given the important ecological functions that a healthy riparian buffer provides, adequately
preserving them is essential to protecting New Jersey's natural resources and water supply.

Figure 3.2.1

EPA & NJ Forest Service Riparian Buffer Recommendation

(NJ Forest Service, 2018)

When water bodies lose the protection natural riparian buffers offer, they’re risks of
exposure to contaminated stormwater, accelerated erosion, and flooding are increased as a result.
Unfortunately, in many urban areas, riparian buffers are destroyed as the area becomes more
developed . NJDEP sees importance in the need for construction to sometimes be located within
the riparian zones and the criteria for said construction within a riparian zone are contained at
N.J.A.C. 7:13-11.2. A riparian zone per N.J.A.C. 7:13-4.1. can be 50, 150, or 300-ft wide along
both sides of a waterway, depending on how the waterway is classified, and with a few
exceptions, every waterway that collects runoff from at least 50 acres of land possesses a riparian
zone (NJDEP, 2016). Also, any naturally occurring stream that has a discernible channel
possesses a riparian zone, no matter how small the area that drains into the stream.
The construction permitted within riparian zones, however, is often heavily regulated due
to their importance to a healthy ecosystem. In fact, restoration projects are becoming far more
common in New Jersey in comparison to construction projects. For example, a major focus of
the Pinelands wetlands program is “the establishment of upland-buffer zones to minimize the
adverse effects of development occurring adjacent to wetlands(Pinelands Commission, 2020).”
This focus includes protecting already existing buffer zones. Other instances also include the
over 1,900 native trees and shrubs utilized in five different riparian restoration projects in the NJ
Highlands Region (Neff, 2017). Supplied by New Jersey Audubon (NJA) as part of the Delaware
River Watershed Initiative (DRWI), these five restoration projects in total accounted for over 1
mile of stream bank stabilization and buffer areas to two major water courses in the region. The
plantings benefit water quality, soil health and floodplain function, as well as significantly
enhance habitats for bird species, trout and other aquatic species, as well as threatened and
endangered species (Neff, 2017).
Further, on the Mullica River, also home to Stockton University’s research center within
Jacques Cousteau National Estuarine Research Reserve, The Mullica River Mitigation Bank was
created. With an intent to provide compensation for impacts to wetlands, transition areas,
riparian zones, and critical wildlife habitats, the project restored 34 acres of a highly functioning
forested wetland/upland complex and reestablished over 1,600 linear feet of historic headwater
stream channels (Mullica River Mitigation Bank, 2020). This included a restored 33.89 acre
parcel of land in the New Jersey Pinelands Region that was heavily impaired by historic and
intensive site manipulation, yet still contained no less than four state listed species, one of which
was the endangered timber rattlesnake. The entire stream reach has fully formed and has been
stable since the end of the 2014 growing season, which has allowed the State Threatened Pine
Barrens Tree Frog to breed in the newly restored area (Mullica River Mitigation Bank, 2020).
Figure 3.2.1 ​displays this area prior to and after the restoration project, with the vernal pools that
allow the tree frog to increase breeding rates visible.
Figure 3.2.1

Mullica River Mitigation Bank Before (left) and After (right) Restoration Project

(Mullica River Mitigation Bank, 2020)

3.3 Rainwater Harvesting - Reservoirs, Cisterns, and Rain Barrels

Humans have been harvesting rainwater in reservoirs for centuries, particularly in arid
areas that are prone to drought. While historical examples of rainwater harvesting are mostly
through the use of dams, modern day knowledge has created more sustainable methods for rain
harvesting that benefit ecosystems. Harvested water can be divided into 2 categories: potable,
and non-potable. Potable water refers to water that is safe to drink and has typically undergone
some form of treatment process, as is the case with municipal water from reservoirs. Non-potable
water is either untreated or treated minimally to the point that it can be used for activities other
than ingestion (EPA, 2020c). This distinction is important when considering how water is
commonly used in residential and work spaces.
A study conducted by the Water Research Foundation gathered information on the
residential end uses of water and percentages of water use for different activities. ​Table 3.3.1
and ​Table 3.3.2 ​below summarize some of the study’s findings, with one of the key takeaways
from the study was that we use potable water for a majority of activities that could be achieved
with non-potable water (Kloss, 2008). Even Stockton University is guilty of this; potable water is
used to spray several fields on campus. Since the original study, high-efficiency appliances and
more strict regulations have helped to lower the amount of potable water used for everyday
activities, but there are still uses for non-potable water that are being neglected (DeOrea, 2016).
This is where cisterns and rain barrels can make a big difference.

Table 3.3.1

Typical Domestic Daily per Capita Water Use

Use Gallons per Capita % Daily Total

● Showers 11.6 7.0%

● Dishwashers 1.0 0.6%
● Baths 1.2 0.8%
● Faucets 10.9 6.6%
● Other uses, leaks 11.2 6.7%

Subtotal 35.8 21.7%

Non-potable indoor uses

● Clothes washers 15.0 9.1%
● Toilets 18.5 11.2%

Subtotal 33.5 20.3%

Outdoor uses 95.7 58.0%

(Kloss 2008)

Table 3.3.2

Typical Daily Water Use for Office Buildings and Hotels

Use Office Buildings % of Daily Hotels % of Daily Total

Total

Potable Indoor Uses

● Showers --- 27%
● Faucets 1% 1%
 ● Kitchen 3% 10%
● Other Uses 10% 19%

Subtotal 14% 57%

Non-potable indoor uses

● Toilets/urinals 25% 9%
● Laundry --- 14%
● Cooling 23% 10%

Subtotal 48% 33%

Outdoor uses 38% 10%

(Kloss, 2008, p. 2)

Cisterns are stormwater management practices used to capture, collect and reuse roof
runoff (Division of Watershed Management, 2004). Some underground cisterns can hold up to
10,000 gallons, while above-ground cisterns typically max out at 5,000 gallons (Division of
Watershed Management, 2004). They can be connected to drinking water systems, plumbing
systems, or other means of distribution depending on the level of filtration and treatment the
rainwater is subject to and greatly reduce the amount of potable water a residence or building
draws from municipal supplies. A convenient aspect of cisterns is their extremely versatile
nature, as they may be used on a variety of sites ranging from small-scale residential sites to
large scale industrial or commercial sites. Further, they may be placed either indoors or outdoors
and above, at, or below grade and they can be used in various shapes and sizes. The only
requirement is that cisterns must be designed based upon on-site water needs; an under-sized
cistern may not store sufficient water for site demands, and an oversized cistern may remain full
or near-full most of the time, and thus be unable to provide storage during rain events.
To prevent malfunctioning cisterns in New Jersey, pursuant to N.J.A.C.
7:8 – 5.3(a), the design of a cistern must assist in maximizing stormwater management strategies.
This includes minimizing impervious surfaces and breaking up or disconnecting the flow of
runoff over impervious surfaces (Division of Watershed Management, 2004). Continuing, the
Division of Watershed Management (2004) states, “cisterns may be designed to reduce the
volume of stormwater discharged to downstream facilities and/or to reduce peak runoff rates
when designed as an on-line system in combination with an extended detention basin; however,
regardless of the design storm chosen, all discharges must be designed for stability and in
accordance with the Standards or Soil Erosion and Sediment Control in New Jersey.”
Regulations include mandated design criteria, with standards such as;
● The use of a cistern is limited to the collection of clean, roof runoff and is prohibited in
areas where high pollutant or sediment loading is anticipated;
 ● Any overflow of clean roof runoff that mixes with runoff that is subject to the stormwater
quality standards pursuant to N.J.A.C. 7:8-5.5 must be treated in a downstream facility;
● The cistern must have sufficient storage volume to contain the Water Quality Design
Storm (WQDS) runoff volume without overflow;
● The maximum inflow drainage area is based upon the demand for water reuse at the site;
● No standing water may remain in the cistern 72 hours after a rain event in order to allow
for sufficient storage for the next rain event; and
● Various other design criteria to assure runoff rates aren’t negatively affected by overflow
(Division of Watershed Management, 2004).

Should a cistern be found to be an adequate measure of stormwater management for an

NJ area, regular and effective maintenance is required. Any cistern used to meet a state
requirement is required to have a maintenance plan. Once a cistern is in place though, it reduces
stormwater runoff contamination by instead capturing it, reduces erosion, and reduces a facility's
overall water consumption through the re-utilization of stormwater. To amplify the simplicity of
such a useful system, the 29th Annual Pinelands Short Course hosted by Stockton University
included a segment that taught participants how to incorporate cisterns, among other GI, within
the design of their own homes and gardens.

Figure 3.3.1.

NJDEP BMP Example of A Subsurface Cistern

(Division of Watershed Management, 2004)
Rain Barrels are smaller versions of cisterns that are usually connected to downspouts
and can typically store up to 100 gallons of water (Division of Watershed Management, 2004).
Water running off of the downspout of a roof is often diverted away from the home and runs
rapidly into storm drains. Rain barrels capture the water directly from the downspout and store it.
Figure 3.3.2

Example of a 55 Gallon Rain Barrel

(NJDEP, 2015c)
Water in rain barrels is most commonly used for small-scale irrigation of gardens with
potential to save most homeowners about 1,300 gallons of water during the peak summer
months. Many municipalities and non-profit organizations have created partnerships and
programs to offer rain barrels to residents for free or at reduced cost. New Jersey Water Savers, a
collaboration between Rutgers Cooperative Extension, NJDEP, and the EPA, offers rain barrel
workshops and is a great resource for other green infrastructure information (EPA, 2020c).
Additionally, there’s The Barnegat Bay Rain Barrel Challenge, a competition that engages
schools and youth groups located in the Barnegat Bay watershed to learn about the importance of
the Bay and how people can help protect its water quality and natural resources, utilizes rain
barrels extensively throughout NJ (NJDEP, 2015c). After the students learn about the
complexity of keeping waters clean, they work together to design rain barrels that address the
given theme with each school or group able to enter one designed barrel to compete in this
challenge. With 36 rain barrels completed in only one challenge year, ​Figure 3.3.3​ displays the
reach of this project.
 Figure 3.3.3.

Rain Barrel Tour Map from Barnegat Bay Blitz Rain Barrel Challenge

Note.​ Each water drop represents a barrel on the tour. (NJDEP, 2015c)
3.4 Bioretention Areas and Bioswales
A bioretention area can be an in-line system, such as a retention basin, that allows water
to move through slowly and drain into a waterway (Division of Watershed Management, 2004).
It can also be something smaller, like rain gardens discussed in Section 3.6, that hold water until
it eventually permeates into the ground. The key component in a bioretention area is the addition
of plants and soil designed to enhance pollution control and uptake (Division of Watershed
Management, 2004). Vegetation can be aquatic, woody, or herbaceous plants, usually native
species that are flood-tolerant. Often, plants are selected that can enhance an ecosystem by
providing wildflowers for pollinators, and habitat for birds, reptiles, amphibians, and other forms
of wildlife.

Figure 3.5.1

Bioretention Basin Schematic Example

(NJDEP, 2018)

Bioswales, like bioretention basins, are depressions lined with vegetation to slow and
sequester pollutants. The main difference is that bioswales are designed to capture and convey
water in a linear direction. They are commonly used along roads and parking lots and can be
easily created by simply adding improvements to existing natural drainage channels. However,
they are most effective in small rain events; in areas with large rain events, bioswales may be
fitted with an underdrain to prevent overflow and erosion due to heavier volumes of water.

3.5 Detention Basins and Retention Basins

Stormwater basins are essential to collect and slow the flow of stormwater runoff in areas
with a high percentage of impervious surface, mostly as part of larger residential or commercial
projects. ​In general, the structures are used to detain and treat stormwater runoff to aid in
preventing flooding, especially flash flooding, along New Jersey’s watercourses (NJDEP, 2016).
Before retention basins became a requirement for large developments, stormwater was channeled
through storm drains into the sewer or local bodies of water, and unintended flooding of
surrounding lands could be a major issue. There are different types of stormwater basins.
Generally, both types are located near areas with ample impervious surfaces due to the specific
benefits they offer. For example, ​Table 3.5.1​ displays the location of 125 stormwater basins with
numbers for those located along the Garden State Parkway and Route 70 most abundant; being
the most heavily traveled road in the most densely populated state, the need for stormwater
basins becomes clear (New Jersey Department of Transportation, 2008). Another example is
Stockton University, where all but one of five basins on campus are adjacent to parking lots, with
the last being located next to the athletic field (Stockton University, 2016).

Table 3.5.1

The Location of 125 New Jersey Stormwater Basins

Location Number of Basins

Bay Head Rail Yard 1

Garden State Parkway 30

I-95 11

NJ Route 37 14

NJ Route 70 63

NJ Route 72 4

NJ Route 88 1

U.S. 9 1
(New Jersey Department of Transportation, 2014, p. 2)
 Detention Basins​, ​or “dry ponds”,​ ​are the most basic form of stormwater basins. As the
name implies, they are designed to detain, disperse and slow the flow of stormwater before it
enters a stream (Division of Watershed Management, 2004). Detention basins are usually fitted
with an outflow pipe at ground level that leads to a forebay, or an artificial pool of water prior to
a larger body of water. This is to cause them to dry out over time, as opposed to holding water
permanently. Ideally, a detention basin will dry out within 72 hours of a storm event. Some will
have a “low flow” channel to help move remaining water out of the pond and prevent mosquito
breeding (Division of Watershed Management, 2004)
The benefit of allowing a detention basin to dry out as opposed to holding water
permanently begins first with the reduction of runoff in nearby water bodies. By creating a
middle body to slow runoff rates, water bodies become responsible for lower rates of stormwater.
The biggest benefit though is that of the TSS removal rate experienced as a result of the dry-out
process; when designed in accordance with the BMP, such as the basin in ​Figure 3.4.1​, the total
suspended solids (TSS) removal rate is 40 -60%, depending on the duration of runoff detention.
It is to be noted that while the benefits of this mock-natural system are undeniable, the adopted
TSS removal rates for extended detention basins is less than the 80% TSS removal rate typically
required in the Stormwater Management rules at N.J.A.C. 7:8 (Division of Watershed
Management, 2004). Therefore, it may be necessary to use a series of BMPs to achieve the
required TSS removal.
Figure 3.5.1​.

NJDEP BMP Example of a Surface Extended Detention Basin

(Division of Watershed Management, 2004)

A​ retention basin ​or “wet pond” consists of an inflow pipe and a large, manmade
depression where stormwater runoff from paved surfaces is collected and detained. On the other
end is an outflow system with a release valve designed to allow for a “plug and pulse” control of
stormwater after rain events (Division of Watershed Management, 2004). Where detention
basins serve to allow collected water to dry out, retention basins hold at least a small level of
water permanently. The permanent pool serves to slow and spread the influx of pollutants for
treatment through chemical and physical reactions.

Figure 3.5.3
Example of a Wet Pond - Plan View.
(Division of Watershed Management, 2004)

Wet ponds can become more complex depending on their size, location, and the functional
possibilities within the surrounding community. As discussed, retention areas can be
supplemented with certain plants to create wildlife habitat and more efficient pollution treatment.

3.6 Rain Gardens

A rain garden is an indented shallow surface depression planted with specially selected
native vegetation to treat and capture runoff. Such gardens are designed with three different
layers (NJDE, 2016). On top, and the only layer visible above ground, is the bowl, or ponding
area. This, as the name implies, is the initial collection area for water, and where the actual plant
life is located. Beneath this is the filter bed, which is composed of sandy fill, and is intended to
act as a natural filter for the water as it seeps into the ground. At the bottom is the underdrain
level, composed of larger pieces of gravel, which will feed the water into a storm drain (Scott,
2013). Whether or not this layer is necessary will be dictated by the quality of surrounding soil.
If the soil has a high enough rate of infiltration, the bottom layer and storm drain can be
eliminated, allowing the stormwater to seep into the ground after it passes through the sandy fill
(Scott, 2013).
 In addition to being simple and cost effective, a benefit of rain gardens is their range with
use applicable to homeowners, municipalities, and schools. As infrastructure that reduces
stormwater runoff, improves groundwater recharge, and traps nonpoint source pollutants before
they reach waterways the ability to install them on all scales creates more opportunities for better
practices in virtually all areas (Obropta et al., 2015). The main difference between a standard
garden and a rain garden comes with the root system; where non-native plants will grow for a
season before potentially disappearing, native plants create long root systems that allow for
enhanced filtration. Further, established native plants require very little maintenance as they
typically do not require irrigation or the application of pesticides or fertilizers (Obropta et al.,
2015). A true testament to rain garden’s versatility can be found in Camden New Jersey, seen in
Figure 3.6.1​, where the gardens are designed to manage as much as one million gallons of
stormwater and aid in the control of local flooding and reduce stormwater runoff flowing to the
Delaware River or to the local sewage treatment plant. Prior to the planting of the garden, a gas
station that’d been abandoned nearly 20 years was a focus of remediation efforts involving the
removal of 12 underground storage tanks, 1,850 tons of contaminated soil and treatment of
contaminated groundwater (NJDEP, 2015b). Today the landscape provides habitats for both
birds and butterflies, and is designed with green walking paths that serve as gateways into the
Camden Waterfront South community.

Figure 3.6.1

Camden, New Jersey Waterfront South Rain Garden (Before and After)
Note. I​ mage left shows site prior to the implementation of the rain garden with the abandoned
gas station. Image right shows the site with the implementation of the rain garden (NJDEP,
2015b).

3.7 Green Roofs and Blue Roofs

Green and blue roofs are forms of stormwater management best suited for buildings
with flat, accessible tops that have the purpose of reducing site runoff. A green roof, also known
as a vegetated roof, is a roof that has been covered with a growing medium and vegetation and
receives both sunlight and rainfall, though watering can be provided. Vessels for holding plants
are open ended, but popular options include arrays of planters, or full garden beds laid atop an
installed waterproof barrier layer. Benefits include the capture of rainfall which thereby prevents
it from becoming storm water (Division of Watershed Management, 2004). Instead the water is
utilized for feeding plants, which eventfully release the water as evapotranspiration.
Additionally, green roofs utilize solar radiation, lowering the temperature of the building,
providing a habitat for wildlife, improving air quality, and even extending the lifetime of the
roof. Though they are most commonly seen in urban areas without room for traditional gardens,
green roofs are a good option for any building that meets the criteria.
Figure 3.7.1

Green Roof That Incorporates a Variety of Plants

(Division of Watershed Management, 2004)

Blue roofs follow a similar concept but rather than vegetation cover, systems that are
designed to provide stormwater detention are installed on the roof. The lack of vegetation adds
accessibility to GI for those who wish to avoid the upkeep of a garden and for areas that are less
accessible or don't receive sunlight (Division of Watershed Management, 2004). Water
collecting vessels can be shallow trays filled with rock that are placed on top of the roof. The
water collected can be utilized for personal use, or slowly drained directly into the sewer, which
circumvents some of the issues caused by stormwater. The speed that the water drains is up to
the owner, but a common goal is to retain the water in the vessels for a while, so that some of it
may evaporate directly back into the atmosphere. Major benefits of blue roofs are that they
reduce stormwater, harvest usable water, and can reduce the temperature of the roof of the
building.
Figure 3.7.2

Blue Roof With Partitions Example

(Division of Watershed Management, 2004)

Overall, the benefits of GI roofing are minimizing the decrease of time it takes for runoff
to travel from the hydraulically most distant point of the drainage area to the point of interest
within a watershed from pre to post construction and minimizing impervious surfaces thereby
disconnecting the flow of runoff over impervious surface (Division of Watershed Management,
2004). Their design makes them especially convenient for sites where a lot of cover comes in the
form of buildings, such as cities and college campuses, as infrastructure on the ground may be
less plausible due to space (Handorf, 2017). Further, due to less materials blue roofs are less
costly making them an even easier option. Several colleges have already taken advantage of this
as well as the learning opportunities, with ​Table 3.7.1 ​showing a few.
Table 3.7.1

Examples of Green Roofing Utilized on College Campuses

College/University About

University of Illinois, The campus has two buildings on campus that are employing green
Chicago roof technology to save energy, extend the life of the roof, and retain
rainwater. Students can currently enjoy heading out onto a green roof
at the school’s Behavioral Sciences Building or the Education,
Performing Arts, and Social Work Building. Additional green roofs
may be popping up in the future as the school aims to help Chicago
maintain its reputation as a green roof leader.

Princeton University, Butler College complex contains dormitories where the rooftop is
New Jersey planted with several different varieties of sedum and serves not only
as an environmentally friendly addition to the dorm but also a
working laboratory in environmental science for students. The
rooftop is rigged to collect data about a variety of energy and
water-related factors, helping maximize the benefits of this roof and
others that may be brought to campus in the future to fulfill the
university’s sustainability plan.

Swarthmore College, Thus far, Swarthmore has three green roofs that together make up
Pennsylvania nearly 14,300 square feet. With more green roofs than most
campuses, Swarthmore has plans to add additional green roofs in the
future as it aims to lower energy, water, and resource usage on
campus.

University of The roof of UPenn’s School of Nursing is just one of several green
Pennsylvania roofs on campus. So far, the school has added green roofs to The
Radian apartment complex, Steinberg Hall, the Erdman Center, and
the Perelman Center for Advanced Medicine.

Colorado State Colorado State University has an extensive green roof program. The
University school not only builds green roofs but also uses them in its
environmental and agricultural studies programs, which are working
to determine which plants are best for their region and what soil
 mixes are most productive. Their research has been instrumental in
helping green roofs all over the nation maximize their benefits.
While the campus does have a small, 400-square-foot green roof on
site, they’re planning much larger green roof projects in the future.
(Handorf, 2017)

3.8 Curb and Gutter Elimination, Downspout Disconnection, Rain Chains

In urban and semi-urban areas, it is typical for gutter downspouts to drain directly into the
sewage system, turning precipitation to stormwater immediately, and denying the groundwater a
chance to recharge. The concept behind downspout disconnection is simple; break the path from
your gutter to the curb, and instead direct the rainwater to a location where it can either be of use
to you, such as a garden, or into an open planted space where the ground can take it back in
(Division of Watershed Management, 2004). Specifically, downspout disconnections reroute
rooftop drainage pipes from draining rainwater into the storm sewer to draining it into rain
barrels, cisterns, or permeable areas. With the ability to be used to store stormwater and/or allow
stormwater to infiltrate into the soil, downspout disconnection could be especially beneficial to
cities with combined sewer systems (EPA, 2020c).
In compact cities, downspouts can be utilized to direct water into rain barrels or like
devices, thereby removing the space needs of things like rain gardens. Homeowners can opt to
reposition their gutters to release into hedges which normally require supplemental watering.
Whichever method of reconnection is chosen the result is the same; runoff rates are reduced and
storm sewers are less likely to be overwhelmed. ​Figure 3.8.1 ​shows an example of a downspout
that was previously connected to a sewer system and how easily it was switched to a rain barrel
connection. An easier at-home solution is to drill holes in the bottom of your gutter where you
would like water to be released below, and then to attach rain chains to direct the flowing water
appropriately. Rain chains can be simple or ornate, but the concept is the same regardless of
design, the waterflow simply runs down the chain as it would a pipe (Water Environment
Research Foundation, 2009).
Figure 3.8.1

Downspout Disconnection Method Example Where Runoff is Redirected From Sewer System

(DC Water, 2020)

3.9 Vegetated Filter Strips, Organic Filters

Many areas of large impermeable surfaces, such as roads and parking lots, drain
directly downhill into a waterway along with any contaminants picked up on the journey.
Vegetated and organic filters like sand are ideal for removing these pollutants and suspended
solids including nutrients, hydrocarbons, and heavy metals from these locations as gravity pulls
the water flow downhill in a sheet. They reduce the amount of sediment that washes into the
water body by employing sedimentation, absorption, biological uptake, filtration, infiltration, and
microbial activity, and with these, mitigate much of the issue caused by this runoff. This practice
employs the natural filtration of different types of vegetation and soils to filter runoff before it
reaches the water. Likewise, it is ideal for runoff to pass over a larger distance of filter strip as
opposed to a small one before reaching the water. To employ vegetated filtration, all one has to
do is consider which types of plants will be most effective in their are​a. Figure 3.9.1​ displays an
example of a vegetated strip, for which it is known that turf grass is effective at removing 60% of
total suspended solids, native grasses and planted woods will remove 70%, and the indigenous
woods remove 80% (Division of Watershed Management, 2004). In addition to being the most
effective for water filtration, incorporating indigenous woods creates wildlife habitat, and natural
detritus to the location. The diagram below shows an example of how the land next to an
impermeable lot can gradually turn to indigenous woods to filter runoff appropriately.

Figure 3.9.1

Diagram of the layout for a simple vegetated strip (Vegetative Filters).

(Division of Watershed Management, 2004)

3.10 Constructed Wetlands, Subsurface Gravel Wetlands

Constructed wetlands and subsurface gravel wetlands are artificial wetlands that are
created with the purpose of dealing with stormwater and improving overall water quality. Where
naturally occurring wetlands provide vital ecological services such as water filtration, artificial
wetlands accomplish this same goal with intentionally built retention ponds. Wastewater is piped
into these wetlands, where it passes through the soil and plant roots. Suspended solids in the
water are filtered out by the soil, and the water is further purified as it is taken up into the
wetlands plants, which can either transform toxins into insoluble compounds, or otherwise
deactivate them. Plants also take up excess nutrients from fertilizers that have runoff into the
wetlands, preventing them from causing algal blooms in other waterways. Wetlands also foster a
community of microorganisms that will further purify wastewater (EPA, 2004). Subsurface
gravel wetlands are a form of constructed wetlands that also has a layer of crushed stone
extending for several feet underground, which further aids in purification and filtration efforts
(University of New Hampshire Stormwater Center, 2016).
Figure 3.10.1

Two Different Design Options for Constructed Wetlands

(EPA, 2004; UNH Stormwater Center, 2016)

Another benefit of constructed wetlands is that they don’t have to be simply a water
purification system. They provide most or all of the same benefits a naturally occurring wetlands
would, including providing habitat for many species. Often constructed in areas that are either
significantly inland, urbanized, or both, these wetlands often provide habitat that would
otherwise not exist in that region, acting as both a permanent residence for species, as well as a
critical migratory stopover for others.

3.11 Permeable Pavement

Permeable pavement seeks to solve the problem of impermeable surfaces in a fairly
straightforward way: making previously impermeable surfaces permeable. While still not as
permeable as an undisturbed forest floor, the surfaces, which are constructed of pervious
concrete, porous asphalt, or permeable interlocking paving stones, allow for a much greater rate
of infiltration than standard blacktop or concrete. The general construction of these surfaces has
the permeable pavement itself on top, with a large stone reservoir beneath to collect stormwater
and allow it to gradually subside into the ground below. This also allows for the stormwater to be
filtered through the stones, rather than washed directly into a storm drain.
3.11.1

The structure of a typical permeable pavement.

(US Department of Transportation, 2015)

Permeable pavements are most useful in urban areas, where space is at a premium. In
these areas, it’s often not practical to try to install a whole constructed wetland, and other,
smaller techniques like planter boxes are unlikely to take enough of a load of the stormwater off.
It is very useful to have a certain level of stormwater subsiding into the ground, even if it is a
relatively diminished amount (Harrison, 2011). Permeable surfaces serve many purposes and
show promising benefits. Permeable surfaces allow water through. These surfaces are porous.
One of the major differences between a permeable surface and non permeable surface is the
consequences of water retaining in those pores. On asphalt, cement, and other non permeable
surfaces, water getting into the pores can cause cracks, leaks, and other serious consequences.
Permeable surfaces will be less likely to crack and will not have to be replaced or remade as
often (Harrison, 2011).
3.12 Planter Boxes, Green Streets and Alleys, Green Parking

A planter box, defined in in section 502 of the Clean Water Act, is a form of green
infrastructure where “... the range of measures that use plant or soil systems, permeable
pavements, or other permeable surfaces or substrates, stormwater harvest and reuse, or
landscaping to store, infiltrate, or evapotranspirate stormwater and reduce flows to sewer systems
or subsurface waters (EPA, 2020c).” Planter boxes can be placed all over a city to help filter
water and reduce flows into our sew system. It also allows for more oxygen, decrease of carbon
dioxide in cities, as well as increasing visual appeal. These planter boxes replace large sidewalks,
asphalt, and impermeable surfaces that have extra space in which part of the space can be
converted. These types of infrastructures can be seen throughout the city of Philadelphia and
Michigan Avenue in Chicago; more importantly, any individual can create a planter box. It does
not require permission of the city unless it is on city property. This is one way individuals can
make a difference in cities.

Figure 3.12.1

City of Philadelphia

(Philagov, 2015)

Green streets and alleys are another form of stormwater management within a city. These
types of structures are created by incorporating many different types of infrastructures within a
street or alley in order to store, infiltrate and evapotranspire storm water. Types of structures that
are included are bioswales, planter boxes, trees, and permeable pavements. Unlike planter boxes,
this cannot be completed by individuals. A city must give permission for this to be completed.
The following cities/states have incorporated these street designs; Seattle, Syracuse, Los
Angeles, and Chicago. More and more cities are incorporating these techniques into their city
design as individuals are being educated on the importance of stormwater management (EPA,
2020c).
Green Parking incorporates many aspects of stormwater management. Removing regular
asphalt/pavement and replacing it with permeable pavements/lots plays a huge role in these
parking lots and creates the biggest difference in water runoff. This allows water to directly filter
through the pavement instead of running off the roads. Other stormwater management activities
that are seen include rain gardens and bioswales. Rain gardens will be created to take in the
displaced water from buildings and parking lots. Bioswalles will remove the stormwater, as well
as remove debris and pollutants. Two places currently using these techniques include
Wilmington, MA and Toronto (EPA, 2020c).

3.13 Manufactured Treatment Devices

The main purpose of creating manufactured treatment devices is to capture sediments,
pollutants, floatables, hydrocarbons, and metals before they get transmitted into our sewer
system (Division of Watershed Management, 2004). Many sewer systems currently run off into a
body of ocean whereas this type of device will prevent the contamination of our oceans and fresh
waters. This manufacturer's device uses settling, absorption/adsorption materials, vegetative
components, vortex separation, filtration and many other different types of materials/ structures
to remove the pollutants from the storm water. This treatment device is best in small areas of
impermeable service that contribute large amounts of hydrocarbons and sediments. Areas such as
parking lots or gas stations are great candidates for these devices while larger areas may need
more than one to treat the run off. Most of the time, these devices are used to treat the water
before it hits another storm water management infrastructure such as a rain garden. When
building these types of devices, there are design criteria NJ looks considers; Pollutant Removal
Rates, Flow Rates and Storage Volumes, Overflows, Subsurface Devices, On-line and Off-line
Devices Division of Watershed Management, 2004).
Benefits of using treatment devices include filtering our water before it hits our
stormwater management systems which lead to bodies of water such as lakes, rivers, or the
ocean. These management devices do not require pressure and can be used for passive filtration.
Using these treatment devices prior to a storm management system ultimately limits the amount
of water being wasted. Areas with little to no electricity, can benefit due the fact these devices do
not require much energy.
3.14 Urban Tree Canopy
Urban forests consist of trees in parks, our yards, public spaces, and tracing streets.
Though many individuals do not look to them as forests they do have some major benefits,
including cleaning air and filtering water. Urban forests also increase the value of properties and
ultimately make that property have a nice curb appeal; these mini forests replace grassland that
might otherwise be present if trees were cut down. Further, the trees often seen surrounding
major highways play a major role in stormwater management for roadways. An urban tree
canopy consists of a layer of leaves, branche, and stems when looking at the ground from above.

Figure 3.14.1

How Urban Forests Can Interact With Stormwater

(Federal Interagency Stream Restoration Working Group, 2001)

 During a one-inch rainfall, one acre of urban forest will release just 750 gallons of
runoff, while a parking lot will release 27,000 gallons ​(Jersey City Environmental Commission
et al., 2015)​. In Jersey City, New Jersey these benefits are being examined extensively and it was
found that between 95 million and 155 million gallons of rainwater are currently intercepted
annually by Jersey City’s tree canopy and prevented from entering the stormwater system during
initial rainfall runoff. Increasing the tree canopy by just three percent to 20 percent total coverage
would potentially reduce that runoff by a further 15-25 million gallons, and a 25 percent tree
canopy across the city would potentially reduce runoff by between 150-230 million gallons,
which would significantly reduce the burden on the city’s overstrained stormwater and sanitary
system ​(Jersey City Environmental Commission et al., 2015)​. ​Figure 3.14.2​ shows the feasibility
of this; most areas in Jersey City have under 20% of urban tree canopy, but the results are
already apparent proving that the 3% raise would be realistic.
Figure 3.14.2

Jersey City Tree Canopy Coverage by Ward

(Jersey City Environmental Commission et al., 2015, p. 7)

On the other side of the coin, urban tree canopies are also suffering in favor of
development. It was mentioned earlier that the NJ Department of Transportation (2008) found
the Garden State Parkway to be the most heavily traveled road in New Jersey, yet a project in
2011 removed more than 34 miles of oak, maple, cedar and pine trees that line the parkway.
This was done with the intent of starting a $900 million widening of the parkway from milepost
30 in Somers Point to milepost 80 in Toms River (Borgdan, 2020). Port Republic Mayor Gary
Giberson said of the project, “This has completely ruined the drainage system. Runoff is going to
go right into homeowners’ backyards, and it will be their problem and the city’s problem...This
was a terribly engineered design that we’ve been left to deal with (Borgdan, 2020).” Further,
right off the Garden State Parkway, Atlantic County freeholders on Tuesday approved a $3.7
million contract for a widening project on Jimmie Leeds Road in Galloway Township from the
Garden State Parkway to Stockton University as a result of ample traffic from students and
faculty alike creating ample traffic (Brunetti, 2019). The removal of urban tree canopies shows
just how difficult it can be for some areas to truly maintain a balance of natural and urban
ecosystems; while runoff is a significant aspect, it’s sometimes not seen as the most important.
Figure 3.14.3

Visual of Tree Buffer Along the Garden State Parkway

3.15 Land Conservation

Perhaps the most obvious and yet most complex form of stormwater management is land
conservation. Land uses change over time, and as areas are developed and re-developed,
stormwater flow may be altered. New Jersey is an excellent example of the issues that can arise
when a state approaches “build-out”, or the point at which there is no space left for new
development. This tenuous balance highlights the importance of conserving lands that are
integral to the natural hydrology and control mechanisms in any watershed. Trees, fields,
meadows, wetlands, and marshes are all essential for absorbing stormwater and filtering
pollutants. If the scale is tipped too far to the side of urban development and impervious surfaces,
it will become increasingly difficult to mitigate stormwater pollution, despite any man-made
green infrastructure in place.

In addition to state and federal acquisition of lands for national parks, state forests, and
wildlife refuges, the need for creating and conserving green space on the community scale has
become evident. One example of how this need is being addressed is the New Jersey
Department of Environmental Protection’s Green Acres program, which provides grants and
other forms of assistance to municipalities to purchase conservation easements and create parks
and green spaces (NJDEP 2019).
Without land preservation, local biodiversity declines and brings developed areas further
away from their natural state. For instance, on Stockton University’s campus the initial 1971
plans for construction included a recommendation to incorporate as much native biodiversity as
possible. However, instead ornamental trees and grass cover were implemented across the
campus for aesthetic purposes and as a result local biodiversity has been found to decline
(Cromartie, 2011). This has negative implications such as lowering stormwater filtration and
increasing runoff.
Figure 3.15.1

Brightwood Park, Westfield NJ.

​ he park land was preserved through the NJDEP Green Acres program. (Kofsky, 2011)
Note. T

3.16 Conclusion
Different regions will have different stormwater needs - from an urban center where
virtually all surfaces are impervious, to a suburban neighborhood with relatively low impervious
surfaces. In some instances, one stormwater drainage solution is all that is required, but it is very
common for communities to need to implement several solutions, working in conjunction with
each other. It is necessary to consider a wide array of potential issues when constructing a
community’s stormwater system: which pollutants runoff is likely to pick up, areas that are likely
to flood, permeability of the local soil, and many others. Using this complex overlay of factors, it
is possible to find the stormwater solution that is right for each community.
 4. Stormwater Management Challenges
As discussed within ​Section 3.​, in spite of the abundance of amendments that led up to
the modern CWA, the issue of NPS pollution continues to affect many of the nation's water
bodies today. The source of this problem echoes those of the past; while point-source pollution
is federally regulated, non-point source pollution remains almost in limbo. This can partly be
attributed to the roadblocks met with focusing on point source pollution; the U.S. did not come
close to meeting the Clean Water Act’s goal of having every plant install secondary treatment by
1977, and by 1978 nearly a third of all plants lacked secondary treatment (Keiser & Shapiro,
2019). However, long after initial amendments, the CWA still has yet to improve non-point
source pollution such as runoff. The lack of rigorous end-of pipe monitoring, coupled with
EPA’s failure to use flow or alternative measures for regulating stormwater, make it difficult for
EPA to develop enforceable requirements for stormwater discharges.
The NPDES permit program is designed to prevent stormwater runoff from washing
harmful pollutants into local surface waters, but lacks the needed federal involvement. Most
states are authorized to implement the stormwater NPDES permitting program and the EPA
remains the permitting authority only in a few states, territories, and on most land in Indian
Country (EPA, 2020b). The issue with this lays within the lack of funding provided when
responsibility is handed to individual states. State and local governments don’t have adequate
financial support to implement the stormwater program in a rigorous way, and the agency has
traditionally directed funds to focus on the reissuance of NPDES wastewater permits. However,
the present need is to advance the NPDES stormwater program as NPDES stormwater permittees
outnumber wastewater permittees more than five fold, and the contribution of diffuse sources of
pollution to degradation of the nation’s waterbodies continues to increase (National Research
Council, 2008).
In addition to lack of funding, states also lack enforcement of regulations, leading to low
motivation levels in regards to stormwater management. Currently, EPA does not apparently
utilize its existing licensing authority to regulate products that increase stormwater pollution,
such as de-icing chemicals, materials used in brake linings, motor fuels, asphalt sealants, or
fertilizers, in a way that minimizes their contribution to stormwater contamination (National
Research Council, 2008). The effects of this are stark, with pesticides detected in 97% of urban
stream water samples across the United States (USGS, 2006) . Additionally, urban development
was responsible for almost 39% percent of freshwater wetland loss nationally between 1998 and
2004 and the direct impact of stormwater runoff in degrading wetland quality is predicted to
affect an even greater acreage (Wright et al., 2006).
Wherever grasslands and forest are replaced by urban development in general, and
impervious surfaces in particular, the movement of water across the landscape is radically
altered. This makes regulation more difficult than that of point-source pollution; NPS pollution
like runoff is everywhere while still remaining mostly under the radar. This isn’t to suggest that
regulation is impossible. For perspective, the Clean Air Act of 1966 is a federal law designed to
control air pollution on a national level. The Clean Air Act contains performance standards,
including the standards of performance that apply to new stationary sources, 42 U.S.C. § 7411
(2006), and the nationally uniform standards for controlling motor vehicle emissions, id. §
7521(a). These standards of performance provide some protection in the event that state
implementation plans fail to achieve the national ambient air quality standards by the designated
statutory deadlines. The CWA, unlike the Clean Air Act adopted in 1970, relies on
technology-based discharge controls as its first line of defense against pollution, instead of on the
achievement of ambient quality standards (Glicksman & Batzel, 2010). Under the CWA,
individual states set standards so long as they meet standards set by regulation with precedent.
In essence, the Clean Air Act covers virtually all major sources of pollution with high benefits,
while the CWA lacks regulation in regards to many aspects of water quality such as water
pollution from agriculture (Glicksman & Batzel, 2010).
With federal involvement discrepancies being the motivation to create further regulation
of many antecedent acts of the CWA, the controversy surrounding the acts regulation of
nonpoint pollution may one day be what leads to new amendments. Currently, however, the
CWA is still what guides states and local governments in regards to regulating water quality.

4.1 Introduction

NJ Department of Environmental Protection Commissioner Lisa P. Jackson said in a

2008 meeting, “Stormwater runoff is the biggest threat to (New Jersey) surface waters,
accounting for 60 percent of the pollution in our lakes, rivers and streams (Makatura & Hajna,
2008).” To emphasize the issue, sublists 4 and 5 of New Jersey’s 2014 Integrated List of Waters,
which identify the sources of New Jersey’s water quality impairments, list “Urban Runoff/Storm
Sewers” as a source of impairment for 942 of the total 2,560 assessment unit/pollutant
combinations identified on that list (NJDEP, 2015a). Urban runoff and stormwater pollution are
contributing sources to over one-third of New Jersey’s impairments. However, only 1,895 of the
2,560 assessment unit/pollutant combinations on the list have any source identified at all,
meaning that approximately one-half (942 out of 1,895) of attributed impairments are caused by
stormwater (NJDEP, 2015a). The problem hasn’t diminished since New Jersey’s Stormwater
Management implementation either; 117 of the assessment unit/pollutant combinations identified
as impaired by stormwater were added to the list since 2008. With this considered, it’s clear that
New Jersey’s current stormwater regulations for development sites are not strong enough to
prevent polluted runoff from degrading water quality.

However, this assessment is only the tip of the iceberg. Beyond pollution, poorly
managed stormwater in New Jersey plays a part in increased erosion and flood rates, early
infrastructure failure, and a myriad of other issues. Continuing, the resulting environmental
degradation leads to negative impacts to the economy, recreation, and ecology of affected areas.
Throughout this paper, evidence as to why efficient stormwater management is important to New
Jersey has been brought forward. To review briefly, New Jersey is a state that’s almost reached
its maximum potential development, has over one hundred miles of Atlantic Coast, is home to
the unique Pine Barrens, and has the highest population density out of all American states.

These factors create a myriad of potential stormwater related issues for New Jersey.
FEMA, the state’s chief partner in controlling runoff, assessed New Jersey regulation and said
that it failed to “consider future conditions of increasingly intense precipitation that is expected
with climate change (Johnson, 2019).” As an agency that’s spent hundreds of millions improving
New Jersey watersheds, and billions on relief after disastrous storms, the failure to include a
volume-based stormwater management standard was seen as a critical flaw that would have poor
consequences in NJ. FEMA also recommended the state consider adding a requirement that
nutrients, such as fertilizer, be reduced in runoff water, but the major component of concern is
that of increased flood risk. In high intensity storms common to New Jersey, such as nor’easters
and hurricanes, flooding can threaten homes, businesses, and human lives. Dangers from coastal
flooding alone cause hundreds of millions of dollars in damage every year in New Jersey (Hess
et al, 2019). Coupled with rising sea levels and projected increased frequency of strong storms,
these risks are increasing. Consequently, flood protection is one of the most significant goals in
stormwater management, and continues to present challenges as we adapt to changing
environmental conditions.

4.2 Flood Impact

Risk Increase Impact.​ Flooding is arguably one of the most extreme examples of
stormwater impact on urban areas. Nevertheless, it’s a common consequence that is only
anticipated to get worse; it’s projected that the average 100-year floodplain is going to increase
45 percent by the year 2100, while the annual damages from flooding are predicted to increase
by $750 million (EPA, 2014). Though there are various types of flooding that hold no correlation
to rainfall; such as global sea level rise which is caused by a change in the volume of the world’s
oceans due to expansion as the oceans warm; with heavy downpours increasing in frequency and
intensity worldwide over the last 50 years it’s anticipated that the issue of runoff caused flooding
will quickly become dire. Catalysts include increase in impervious surfaces, stressed
infrastructure, and severe storms.

To review briefly, impervious surfaces cause rainwater to redirect and leaves them little
place to go. Referencing back to ​Figure 1.2.1​, it’s known that 81% of the Jersey Shore is paved,
thus impermeable. This brought forward interest in the faculty of Stockton University, who
began working with the New Jersey Coastal Coalition. The researchers from Stockton’s Coastal
Research Center installed $300 cigar-sized sensors on the underside of 13 storm drains in Avalon
and seven in Longport, in areas identified by local authorities as hot spots to gather hard data and
determine their practical applications (Shaw, 2019). Findings included 51 flooding events in
Avalon and 235 in Longport from Aug. 28, 2017, to Feb. 25, 2019 (Shaw, 2019). This example
ties the concept of impervious surfaces and failing infrastructure together.
 When an excessive amount of stormwater runoff overwhelms stormwater management
systems, such as these storm sewers studied by Stockton University, stormwater runoff floods
roads and properties surrounding the inundated sewer drains. CSOs are another example of
infrastructure that can lead to damages. For example, more than 27 billion gallons of raw sewage
and polluted stormwater discharge out of 460 CSOs into New York Harbor alone each year
(Dietrich, 2017). Further, combined sewer systems can often reach capacity and the mixed water,
containing stormwater runoff and wastewater, is simply discharged before treatment. In more
extreme scenarios, should a CSS get backed up enough, the runoff will begin to flood the nearby
area.

Economic impact.​ According to the New Jersey League of Conservation voters, for all
of New Jersey’s water infrastructure, there’s at least a $40 billion investment needed over the
next 20 years, with stormwater requiring $16 billion (Potosnak et al., 2020). Knowing that
federal funding is scarce for these projects, the onus is on states and local governments to raise
the revenue to improve these essential systems. However, with FEMA warning that NJ
regulation isn’t strong enough to adequately protect areas from flooding, the price tag on the
infrastructure can look like a bargain in comparison to the potential cost of flood damages. In
fact, FEMA said it has invested $275 million around the state’s rivers and urban watershed
post-disaster (Johnson, 2019).

In addition to these assumed fees of infrastructure and post-disaster, neighborhoods

experiencing frequent flooding are swimming in the side effects. The longer overflow issues
persist, the more remnants are left behind; stormwater carries anything in its path ranging from
litter along the streets and walkways, debris and sediment from neighboring properties and
structures, and other materials found in its path. Flooded stormwater picks up surrounding
chemical pollutants, animal feces, and unwanted materials, causing the water to become dirty
and unappealing (National Oceanic and Atmospheric Administration, n.d.). This water can
produce a foul odor from sitting out and from picking up these undesirable waste products. These
factors destroy the aesthetic of the community or neighborhood and in result can even reduce the
value of the properties in that area due to the poor, undesirable conditions of the affected
properties (National Oceanic and Atmospheric Administration, n.d.). Areas with high flood rates,
due to indundated stormwater management systems, have reduced property values as well
(Eberlin, 2019). ​Figure 4.1.1​ shows an example of this occurrence, with two hours beginning at
similar costs that change as a result of flood impact.
Figure 4.1.1

Estimated Values of Two Homes, One in A Flood Zone and One Outside

(Cassin, 2020)

An area feeling the strain of flooding in Atlantic City, New Jersey as the proportion of
the city’s streets and homes affected by flooding is projected to quickly rise. Within about 30
years, the typical length of a mortgage, one out of three homes in Atlantic City could be
inundated in a typical year (Upton, 2017). The U.S. Army Corps of Engineers are spending tens
of millions of dollars building a seawall to reduce storm surge and flooding risks for Atlantic
City’s downtown and its towering casinos and a few miles in the other direction, it’s preparing to
spend tens of millions more on sand dunes to protect million-dollar oceanfront homes (Upton,
2017). ​Figure 4.1.2​ takes these effects into account; while F​igure 4.1.1​ considers flood impact
to the home itself, ​Figure 4.1.2​ shows how even nearby road flooding can affect a property
value.
Figure 4.1.2

Impact on Property Value as Road Flooding Occurs

(Cassin, 2020)

Public health impact. ​The importance placed on flooding is partly due to the risk of
individuals and animals drowning in flood waters. Even in flood water levels of six inches,
fast-moving flood water can knock individuals over and make it extremely difficult to regain
control of their body’s balance. Two feet of rushing water can move vehicles the size of pickup
trucks and SUVs (Office of Insurance and Safety Fire Commission, n.d.). The toll this can take
on an individual is severe. Further, it’s been emphasized that runoff carries an array of
contaminants, as well as sediment. Floods carry these things as well. However, these are more-so
characteristics of stormwater runoff in general so while flooding can increase these aspects,
they’re present in excess runoff irregardless of a flood event.

4.2 Contaminated and Excess Runoff Impact

Contamination risk increase impact. ​Stormwater often carries with it compounds that
are found on the surface. This is not too much of a problem in places where there is little
development but problems arise when an area is highly developed. Humans make use of many
chemicals that can end up on the soil surface and then washed away during or after a
precipitation event; for example, fertilizers from a lawn or a garden. Stormwater will also pick
up compounds released by vehicles, including fuels (petrol, diesel), motor oil, transmission fluid,
antifreeze, and brake fluid. Within fuels are many chemicals used as anti-knocking agents, which
make engines perform better. These chemicals : benzene, toluene, ethyl benzene, and xylene (​o​,
m,​ ​p)​ , are collectively known as BTEX. The BTEX compounds pose a long-term threat, as they
tend to persist in the environment for long periods of time. They are also light non-aqueous
phase liquids (LNAPLs) and float on the water’s surface, increasing their mobility. All of these
compounds are toxic to both marine life and humans. Benzene is the most toxic of these
compounds, being a Group 1 carcinogen that is known to cause liver, kidney, and bone cancers.
It also is known to cause cardiovascular diseases. Since BTEX constituents are volatile or semi
volatile, they often vaporize if they remain on the surface. However, they can remain in the
environment if they are deposited beneath the soil, or in groundwater.

Fertilizers contain chemicals that often lead to a large increase in nitrate and phosphate in
the water. With these normally limiting nutrients now in the water, especially phosphorus,
organisms like algae will begin to increase in population. This eutrophication leads to algal
blooms, as have occurred in Lake Erie and Lake Hopatcong to devastating levels. When this
occurs, fish will die off and the thick layer of algae at the water’s surface can cause aquatic
plants to die due to lack of light. In 2019, over 40 lakes in New Jersey were devastated by toxic,
hazardous algal blooms caused by polluted stormwater runoff (Potosnak et al., 2020). Adverse
health effects from blooms can include;

● allergic- like reactions (e.g.’ rhinitis, asthmas, eczema, and conjunctivitis),

● flu-like symptoms,
● gastroenteritis,
● respiratory irritation,
● skin rashes,
● and eye irritation (Division of Water Monitoring and Standards, 2020b).

That isn’t all though; more serious adverse health effects may include liver toxicity and
neurological effects with studies in laboratory animals suggesting the possible involvement of
some cyanotoxins in tumor formation (Division of Water Monitoring and Standards, 2020b).
With this information in mine, ​Figure 4.2.1​’s percentages of Cyanobacteria Bloom become more
daunting.
Figure 4.2.1

Percent of Cyanobacteria Bloom Response Samples in New Jersey Exceeding Microcystin

Health Advisory Guidance Level of 3 µg/L in 2017-2019 Data.

(Division of Water Monitoring and Standards, 2020b)

While algae blooms are an intense example of contamination, it occurs on all scales. In
Section 2.4​, regional stormwater management in New Jersey was discussed and it was clarified
that while regional management is present to an extent, the state maintains no official regional
stormwater management plans. However, in spite of the current practices, some of these defining
New Jersey areas have faced a multitude of degradation as a result of stormwater related causes,
including contamination. In the Pinelands an ample amount of construction occurred prior to any
regulation leading to construction that wouldn't meet today's standards. Specifically, Stockton
University’s Galloway campus had initial construction completed for nearly a decade before the
Pinelands CMP had been released (Stockton University, 2020b). As a result, some aspects
became ‘grandfathered in’ and still affect the ecosystem in a way they wouldn’t if the limeline
occurred differently. Examples include that of runoff on campus entering Lake Fred and
surrounding watersheds almost directly from parking lots, as well as from a stream converted
into a drainage ditch prior to new methods came around (​Cromartie, 2011)​.

Atlantic White Cedar trees, located throughout the pine barrens as well as on the
Stockton University campus, are one aspect affected by this runoff. ​Ehrenfeld, & Schneider
(1994) found that cedar wetlands directly influenced by stormwater runoff were much more
strongly altered than all other wetland sites. This is due to changes in water chemistry and the
enrichment of surface waters due to stormwater runoff and wastewater discharges leading to the
loss of characteristic swamp plant species and permitting the influx of non-native species.
Sphagnum mosses, the most common substrate on which cedar reproduction generally occurs,
hold a large reservoir of buried viable seed but are especially sensitive to chloride, elevated
nitrogen concentrations, hydrological changes, trampling, and other consequences of suburban
development that often result from improperly managed stormwater (​Ehrenfeld, & Schneider,
1994)​. Therefore, not only is the tree itself suffering, but new populations struggle to come forth.
While Lake Fred may not contain excessive algae blooms or clear signs of degradation, the
runoff running directly into it impacts the nearby ecosystem in this way. Sensitive species begin
to suffer until excessive algae blooms and clear signs of degradation as a result of contamination
are present.

Erosion impact. ​As is carrying contaminants wasn’t enough, runoff also maintains
sediment and occasionally high flows. As a result, stormwater can cause significant bank and
streambed erosion of waterways. This is especially true in developed areas where surface runoff
is often discharged into a stream. Bank erosion refers to the erosion of the banks of the
waterway. Streambed erosion refers to the erosion of the bed of the waterway. Both forms of
erosion can be problematic as the sediment that is eroded away must be deposited somewhere
eventually, and often they end up being deposited in larger bodies of water, like a lake. When
this occurs, the volume of the sediment will reduce the volume of water the lake can hold. This
can lead to lake shallowing, flooding, and the loss of biodiversity. Organisms reliant on nutrients
found one the lake bed will die off, and fish will have a harder time surviving in the shallower
water. Flooding will likely occur as well since the lake can no longer hold as much water as it
once did. Bank erosion can cause the flood plain of a stream to widen, creating a greater flood
hazard. Streambed erosion can lead to serious damage to bridges that have supports that were
built at the old streambed level. In addition, streambed erosion usually leads to bank erosion
eventually.
Figure 4.2.2

Action of Water on Particles Near Streambed

(​Federal Interagency Stream Restoration Working Group, 2001)

Figure 4.2.3

Terraces formed by an incising stream.

 ​ erraces are formed in response to new patterns of streamflow or sediment load in the
Note. T
​ ederal Interagency Stream Restoration Working Group, 2001)
watershed.​ (F

A major issue that comes with erosion is that remediation methods are rarely stand alone
answers. Lake Fred faced severe beach erosion, most likely as a result of runoff. Through the
addition of sand, students worked on a replenishment project that restored the lost beach
(Stockton University, 2019). However, replenishments can't combat future erosion and only
aides in the offset past erosion, essentially beginning an endless cycle without additional forms
of management. Another good example of streambed erosion can be found in the ditch across
the road (across Vera King).

The erosion of waterways can also lead to the decreased value of property. This is due to
the flooding hazards that come with channel erosion. Not only will water eat away at the land on
the banks of the waterway, but will also flood more frequently. People will not want to buy
houses that have an eroding stream in their backyard, and people will likely be deterred if a
house is in a flood zone. With extreme precipitation events occurring more frequently, flooding
can be expected a lot more often.

Economy and recreation impact. ​Recreational uses can also be limited by the runoff of
stormwater. Pet waste, as well as septic tanks that are leaking, can be washed into lakes and bays
nearby (Department of Energy & Environment, n.d.). This is from the bacteria and parasites that
are contained in biological waste (Department of Energy & Environment, n.d.). Runoff can also
indirectly cause biological waste to enter waterways when local infrastructure is overwhelmed by
high amounts of rain, the sewage overflows (American Rivers, 2019). Drinking water and
swimming areas are affected by this overflow from the pathogens that the sewage carries. The
dead zones created by the stormwater runoff affect fishing as well (Stalter, 2018). The fish leave
the area of the dead zones unusable for recreational or commercial fishing (Stalter, 2018).
Sediment can also build up with runoff and the buildup of sediment makes it more unmanageable
for boats to navigate which reduces the recreational value of the water way (Statler, 2018.
Swimming may be prohibited due to disease-causing bacteria (fecal and total coliform), but even
when it is not, the water may look undesirable. Water that is not aesthetically pleasing will cause
people to not want to swim in the water and potentially not even look at.

Many recreational uses that are impaired can tie into the economic impacts from
stormwater runoff. Poor quality of water forces higher levels of treatment, which in the end, is
passed onto the consumer or residents of the area (University of Kentucky, n.d.). These issues
are most related to communities that rely on surface water as their primary source of drinking
water (University of Kentucky, n.d.). Some water resources pull in tourism, which can be a
major part of some communities' economies (University of Kentucky, n.d.). This can suffer if
poor water quality eliminates the ability for swimming and other water related activities. The
aesthetics can affect this by becoming more green rather than their beautiful blue, which causes
people to want to use it less (Stalter, 2018). Beach closures are also a potential economic loss to
a community (Strassler et al., 2019.). Areas that suffer from the stormwater runoff can see their
beach closures impede the development of the economy (Strassler et al., 2019). Fisheries and
shellfish industries are also impacted by the runoff (Strassler et al., 2019). Contamination of
shellfish beds from bacteria can cause them to be closed as they are a public health threat
(Strassler et al., 2019). These closures not only affect the fishing industry, but they also harm the
local economy as well (Strassler et al., 2019). In order to be most cost effective and maintain
compliance with the Clean Water Act, it is best to protect the local waters from future
stormwater impacts. When a community enacts good stormwater management practices, they
can see economic gain. New businesses would almost always prefer locations that have higher
quality water bodies.

The cost to maintain clean water increases with ineffective stormwater plans in place
(Hydro International, 2017). Stormwater runoff brings increased sediment, nutrients, and other
pollutants (Hydro International, 2017). This puts the drinking sources in harm's way and
complicates the water treatment processes (Department of Energy & Environment, n.d.). With
increased intensity, stormwater overwhelms the combined stormwater and wastewater treatment
plants and causes overflows into waterways (Strassler et al., 2019).These overflows reduce water
quality and make it harder to meet water quality standards (Hydro International, 2017). In order
to curb expenses, it is best to treat the stormwater prior to it reaching the environment (Hydro
International, 2017). It can be hard to remove once it reaches the environment (Hydro
International, 2017).

4.3 Policies and Organizational Difficulties

Stormwater permits must be secured by “municipalities, certain public complexes such as

universities and hospitals, and state, interstate and federal agencies that operate or maintain
highways” in the state of New Jersey. New Jersey requires that certain requirements are taken
into account to ensure compliance with the program. They include: “the adoption of ordinances
(litter control, pet waste, wildlife feeding, proper waste disposal, etc.); the development of a
municipal stormwater management plan and implementing ordinance(s); requiring certain
maintenance activities (such as street sweeping and catch basin cleaning); implementing solids
and floatables control; locating discharge points and stenciling catch basins; and a public
education component (NJDEP, 2018)”. Homeowners are not the primary party for maintaining a
stormwater management best practice (NJDEP, 2018). That does not alleviate them from
responsibility, however (NJDEP, 2018).. Organizations, like a homeowner’s association, can
enforce the practices on the homeowner but the organization is the one responsible to ensure that
it is properly maintained (NJDEP, 2018).
In New Jersey, there are several possible authorities who can act as a regional stormwater
management planning agency. According to the NJDEP, itself, “a municipality, a county, a
county water resources agency or association, a designated planning agency under N.J.A.C. 7:15,
a Soil Conservation District when in coordination with the State Soil Conservation Committee,
The Delaware River Basin Commission, The Pinelands Commission, The Delaware and Raritan
Canal Commission, The New Jersey Meadowlands Commission, or Other regional, State or
interstate agencies” may act as one of these agencies” (NJDEP, 2016). Difficulties may occur
while planning a regional stormwater management plan due to the number of organizations that
are involved in the process.
The state of New Jersey was given the authority to enforce the Clean Water Act by the
Federal EPA. New Jersey has given the responsibility of ensuring that the soil runoff is managed
and not discharged into open waters to its soil conservation districts. However, this has not been
strongly enforced in the past but is now being enforced more heavily by the EPA. Construction
sites are seeing an increase in oversight. The EPA requires weekly detailed records in order to
ensure that the stormwater management plan is being followed and that any violations are being
corrected. The fine for not keeping records is hefty as the fines are no lower than $15,000 if there
are no other violations. If onsite soil erosion is occurring in combination with no proper
documentation, the fines can reach much higher levels (NJDEP, 2016). In order to prevent the
fines, companies must be precise and on top of their sites. More difficulties that have arised due
to new laws being passed can be demonstrated from the National Pollutant Discharge
Elimination System (NPDES) requirements that revised rules for the NPDES Phase II permit.
While they expected increased health and recreational benefits, the costs to do so were high for
municipalities and developers. It increased the demand of innovation from the stormwater
industry as well.
Most municipalities operate under the MS4 permit (Nastu, 2018). A video describing
what a MS4 is can be found ​here​ (Penn State Extension, April 2018). Despite laws being enacted
decades ago, the pollution we see from stormwater is growing (Nastu, 2018). In fact, the only
growing issue in water pollution is stormwater (Nastu, 2018). The failure comes from many
different challenges that communities may face (Nastu, 2018). Most communities do not have
the proper funding or adequate staff to execute plans and do not have a way to get that funding
(Nastu, 2018). With more and more regulatory requirements developing, assistance, guidance,
and support are needed by many of the managers (Nastu, 2018). They also face the challenge of
gaining public and political support (Nastu, 2018). The outreach done to this point has created
some progress, but it has not had the effect that is needed (Nastu, 2018).
Other challenges occur as well. For example, with increased urbanization and climate
change, not all systems can keep up to continue to protect community health (Nastu, 2018).
Additionally, urbanization poses significant concerns as more research is needed to examine the
effectiveness of stormwater management plans in urban areas (Nastu, 2018). More research,
along with better monitoring, is needed to see the impact that these programs have on our
waterways (Nastu, 2018). What has been found is that a more combined effort is needed to
protect waterways (Nastu, 2018). MS4s need watershed-wide collaboration to ensure that their
efforts are making a positive change, and many of the plans that involve multiple communities
have been favored by the states (Nastu, 2018). Wide-scale monitoring ensures that the watershed
is effective as a whole, not just at the local level (Nastu, 2018).
Colleges too face the challenges of stormwater management since they are often limited
by the amount of land they have (Howard, 2019). Looking to expand, they often do not pay
attention to the needs of stormwater (Howard, 2019). Instead of creating it as an afterthought,
colleges can face less expenses for management (Howard, 2019). Additionally, permitting
becomes easier when the stormwater management has already been addressed (Howard, 2019).
 5. Stormwater Management at Stockton University

5.1 Background of Stormwater Regulation

Stockton University is located in New Jersey, composed of the main campus in the Pine
Barrens of Galloway Township, a beach adjacent campus in Atlantic City, a smaller
Manahawkin campus, and several off-site educational labs and offices. New Jersey’s Stormwater
Management rules are implemented by the NJDEP through the review of permits issued by the
DLUR as well as by local authorities through the MLUL and the RSIS, and the University must
abide by these rules (NJDEP, 2020b). Galloway Township is determined to be a Tier A
municipality, making the University considered a public complex as per New Jersey’s
Stormwater Management rules (GTNJ, 2017). ​Table 5.1.1​ displays regulations on public
complexes, and thereby Stockton University, must abide by to meet requirements as per the
rules.

Table 5.1.1

General Overview of Public Complex Stormwater Rules

Name About

Stormwater Pollution
Prevention Plan
● The Public Complex Permit requires that each Public Complex
develop, implement, and enforce a stormwater program.
● The SPPP describes how your Public Complex will implement
each permit requirement and it provides a place for record
keeping, documenting when you met the permit requirements.
● Forms include but are not limited to; Form 1, Stormwater
Pollution Prevention Team; Form 2, Public Notice; Form 3, Post
Construction Program; Form 4, Local Education Program; Form 5,
Storm Drain Inlet Labeling; and Form 6, MS4 Outfall Pipe
Mapping

Public Notice ● Public Complexes must comply with any applicable State and
local public notice requirements when a public
involvement/participation program is being implemented in regard
to the Public Complex’s stormwater program. The permit requires
the Public Complex to comply with requirements for public notice
 that are already in effect under law.

Post-Construction ● To prevent or minimize water quality impacts, the Public Complex

Stormwater shall develop, implement, and enforce a program to address
Management in New stormwater runoff from new development and redevelopment
Development and projects at the Public Complex that disturb one acre or more,
Redevelopment including projects less than one acre that are part of a larger
common plan of development or sale, that discharge into the
Public Complex’s small MS4.
● This includes ensuring adequate long-term operation and
maintenance of BMPs at the Public Complex.

Local Public Education ● The Local Public Education Program component of this SBR
requires certain Public Complexes to educate their users and/or
residents on the impact of their day to day activities on stormwater
quality. Topics include things such as proper use and disposal of
fertilizers and pesticides, using native or well adapted vegetation
that requires little or no fertilization, and properly disposing of pet
wastes, used motor oil and household hazardous wastes.

Improper Disposal of ● Public Complexes shall adopt and enforce an appropriate

Waste regulatory mechanism that requires pet owners or their keepers to
immediately and properly dispose of their pet's solid waste
deposited on property operated by the Public Complex or shall
prohibit pets (other than disability assistance animals) from being
allowed at the Public Complex.

Solids and Floatable ● Public Complexes shall sweep all parking lots and curbed streets
Control (including roads or highways) owned or operated by the Public
Complex with storm drains that have a posted speed limit of 35
mph or less (excluding all entrance and exit ramps) at a minimum
of once per month, weather and street surface conditions
permitting.

Maintenance Yard ● Public Complexes shall certify annually that they have met the
Operations De-icing Material Storage minimum standard.

Employee Training ● Public Complexes shall develop and conduct an annual employee
training program for appropriate employees on appropriate topics.
● Topics include waste disposal, control measures, vegetatitve
waste, and street sweeping
Additional Measures ● Additional Measures (AMs) are measures (non-numeric or
numeric effluent limitations) that are expressly required to be
included in the stormwater program by an area wide or Statewide
Water Quality Management Plan (WQM plan). AMs may modify
or be in addition to SBRs.
● Often they are used to compensate for areas that don’t otherwise
meet standards

Annual Report ● Public Complexes shall complete an Annual Report (on a form
provided by the Department below) summarizing the status of
compliance with this permit including measurable goals and the
status of the implementation of each SBR contained in Part I,
Section F of the permit.
● This report shall include a certification that the Public Complex is
in compliance with its stormwater program, SPPP and this permit,
except for any incidents of noncompliance.
(NJDEP, 2004)

Beyond what’s required of public complexes, optional measures; which are BMPs that
are not implemented as Statewide Basic Requirements or Additional Measures but that prevent
or reduce the pollution of the waters of the State; can be implemented by public complexes too
(NJDEP, 2004). Optional measures can include a wide array of things, such as green
infrastructure practices, wildlife management, and road de-icing. Overall, Public Complexes
must comply with applicable design and performance standards in N.J.A.C. 7:8 for their own
“new development and redevelopment projects (NJDEP, 2004).”
Nevertheless, the Stormwater Management rules do not supersede the Pinelands CMP
and both sets of requirements must be addressed where applicable. This includes the area of
Stockton University which as seen in ​Figure 5.1.1​ sits within the Pinelands management areas of
Atlantic County. One large difference between other areas of New Jersey and the Pinelands is
that of groundwater, which accounts for more than 90 percent of stream flow in the Pinelands
(​Pinelands Preservation Alliance, 2020). Due to the heavy reliance on groundwater specifically
in Pinelands areas, recharge standards are higher; reducing nutrient loads to surface and
groundwater supplies by 90% for sites with over 2 acres of disturbance in the area, whereas New
Jersey’s general stormwater rules state that that 100% percent of the site’s average annual
pre-developed groundwater recharge volume be maintained after development without restricting
contamination ​(​Pinelands Preservation Alliance, 2020). Additionally, The Pinelands gets about
44 inches of precipitation a year but the amount of runoff is comparatively low because
Pinelands soils are porous. About 17 to 19 inches of the 44 inches works its way into the shallow
aquifer (Pinelands Preservation Alliance, 2020).
Figure 5.1.1

Stockton University Galloway Campus Boundary Shown in Pinelands Management Area

Above all else, the Pinelands CMP states, “Regional Growth Areas are areas of existing
growth or lands immediately adjacent thereto which are capable of accommodating regional
growth influences while protecting the essential character and environment of the Pinelands.
(Pinelands Commission, 1981).” This statement leads to the true differential between New
Jersey’s Stormwater Management Rules and the Pinelands CMP; whereas New Jersey’s rules
serve to best protect the state, the Pinelands CMP serves to best protect a unique ecosystem with
specific threats.

5.2 Initial Steps Taken by Stockton University and Where it is Now

Pre-Pinelands Commission Background. ​When Stockton University was first
introduced to Galloway Township, New Jersey the surrounding area and school itself were
almost unrecognizable in comparison to their current state. ​Figure 5.2.1​ displays aerial views of
the land Stockton University’s Galloway campus now resides on both in 1930 and 2017 to add
visual aid to this concept, with the 1930 image displaying a barren area and the 2017 area ample
development. For further context, the $202.5 million capital construction bond issue and $15
million earmarked approved in 1968 for a college in southern New Jersey came nearly eleven
years prior to the establishment of The Pinelands Commission, and therefore nearly eleven years
prior to a majority of current regulation (Stockton University, 2020b). Nevertheless, in 1969
when the Pinelands were chosen for what would soon become Richard Stockton State College,
the school began dipping into the concept of creating an environmental legacy (Warner, 1970).
The college was first recognized for this due to the enclosed spaces for the students to walk
throughout with the goal of not disturbing mosquitoes and therefore ecology in the area, as well
as metal panels that can be changed at any time with the intention of having buildings capable of
always meeting human needs (Warner, 1970).

Figure 5.2.1

Aerial View of Stockton University Galloway Campus in 1930 (left) and 2017 (right)

(Google, 2020)
 The 1971 Comprehensive Architectural Master Plan emphasized the natural environment
and stated, “the identification of the most desirable natural areas on the campus and
administrative action now, to assure the recognition of their unique values and to insure their
perpetual protection, will demonstrate the vision of the College’s founders (Cromartie, 2011).”
With the intent of causing the least possible damage to the environment, initial construction was
no taller than two stories to prevent it from reaching above treelines (Schwartz, 2011).
Additionally, the metal exterior panels allowed not only for buildings that could change with
human needs, but trees near buildings were able to be spared too (Schwartz, 2011).
However, were the New Jersey Wetlands Commission of this time given the job of
determining whether or not the vision of a natural environment was present, they might say it
was lost in translation. While it’s true that regulating documents like the Pinelands
Comprehensive Management Plan wouldn’t exist until 1981 and the New Jersey Stormwater
Management Rules until 2004, the New Jersey Wetlands Commission’s history also dates back
to 1969 (NJDEP, 2020b). According to Schwartz (2011), their existence was one of the largest
obstacles faced during early Stockton construction as they had ruled a number of acres to be too
close to sea level to support building development. Critical concerns were raised by the
community as well, but these instead stemmed from Stockton’s sewer plan. Consisting of two
175-foot deep wells meant for water supply, some of which included drinkable water to be
sprayed on the land, the issue found was the potential for Moss Mill Stream to be contaminated
(Schwartz, 2011). To console the public, the facility explained that the options were to continue
with the plan or instead attach the facility to Atlantic City treatment facility, which at the time
allowed raw sewerage to flow into the Atlantic Ocean (Schwartz, 2011). Through displaying it as
the lesser of two evils, no agency stopped the on campus plant’s construction.
On top of the sewer plan’s threat to the stream, the ample amount of development
Stockton went through without a regulating force was becoming threatening as well. In 1971,
runoff from the campus was channeled directly into Lake Fred and surrounding wetlands, and
one stream was converted into a drainage ditch. Plus, though the 1971 Comprehensive Master
Plan suggested the implementation of native plants even for lawn, Stockton replaced both natural
forest and field cover with turn and ornamental trees which require irrigation, fertilizing, and
mowing (Cromartie, 2011). One positive aspect of this era was the commitment faculty and
students alike truly did have to sustainability. Various research was conducted on campus,
including some that inspired protest towards proposed plans for development on the Kennedy
farm (Cromartie, 2011). This allowed for the existence of the Stockton Arboretum, which now is
used for research and maintains over 80 specimens of trees and shrubs, and eight raised beds
containing many display and medicinal plants. (Stockton University, 2020b)
Figure 5.2.2

Land Use Within Lake Fred Watershed

​ ake Fred can be identified in the farthest right portion of the map, displayed as water and
Note. L
in between two areas of urban development which include the Galloway campus.
 Post Pinelands Commission Background. ​Through the passage of the National Parks
and Recreation Act of 1978 and the New Jersey Pinelands Protection Act in 1979, The New
Jersey Pinelands Commission was given authority to protect the Pinelands through its
implementation of the Comprehensive Management Plan (CMP) (Pinelands Commission, 1979).
The CMP contains the rules that guide land-use, development and natural resource protection
programs in the state Pinelands Area and was officially published in 1981 (Pinelands
Commission, 1981). This meant that after already being established for several years, Stockton
would now have to abide by zoning, development, and other like regulations as established by
the plan. Ironically, at the same time, Stockton College exceeded 5,000 students which called for
further development to properly accommodate the students (Stockton University, 2020b).
It didn’t take long for the two entities to clash. With the student population growing and
rent in the area rising as a result, Stockton proposed $9 million dormitories to be built; existing
housing could only accommodate 1,000 of the nearly 5,000 students (Shen, 1980). The dilemma
arose when the Pinelands Commission pointed out that the proximity to Lake Fred was within
300 feet whereas the panels standard permitting construction is no closer than 300 feet of a
wetland area (Shen, 1980.) Stockton fought the commission as to whether or not the school
should be exempt from the rule, with the time spent leading to an extra $500,000 being spent on
the project, but as observed in ​Figure 5.2.2​ it wasn’t all in vain. On the other hand, it also wasn’t
without causing further concern from the public resulting from the constant construction.
Residents who watched Galloway welcome a plethora of new students and construction thought
the pinelands were being destroyed and it was, “those fancy Stockton people that's shown 'em
where to put the bulldozers (Specter, 1981).”
Figure 5.2.2

Stockton University (Galloway Campus) Construction Not Outside of a 300 ft Wetlands Buffer

(Google, 2020)
An important consideration in regards to the citizen anger felt in the 80s is that it doesn’t
stand as an example of Stockton’s negative impact and instead more so represents the major
alterations that the college brought to the area. In fact, prior to the college even opening
President Richard Bjork accounted for the fact the welcoming of a college in South Jersey would
need what he called an “adjustment period (Posner, 2011).” Until 1978, much of Galloway had
been zoned for agriculture but in the 80s plans for new houses, schools, road, and sewers were
being made almost daily (Specter, 1981). This included what was advertised as the largest
planned-housing development in New Jersey, containing 6,800 homes with 20,000 residents, a
shopping mall, parking lots, recreation areas and a luxury hotel, that were set to be built in
Galloway (Specter, 1981). As mentioned, Stockton students were responsible for rent raising in
the area as well as bringing forward the need for more housing. Further, the college can be
credited for much of Galloway’s early growth, with cited involvement in things such as but not
limited to;
● The $9 billion air-traffic control modernization program at the Federal Aviation
Administration's Technical Center, which resulted in the construction of a $2 million
 office building and a 45,000-square-foot office building, included involvement from
Stockton College (Sardella, 1985);
● A 110-bed satellite division of the Atlantic City Medical Center, located on part of the
1,600-acre campus of Stockton State College, was to be the third component of an
educational/health complex which was hoped to lead to the establishment of a medical
school without walls (Sardella, 1975);
● There was a major increase in sewage in the area in the 80's generated mostly as a result
of, “new residential and commercial development, The Richard Stockton College of New
Jersey, and the growth spawned by the casino / hotel industry (ACUA, 2020);”
● Researchers from Stockton and Rutgers University joined forces to establish the Jacques
Cousteau National Estuarine Research Reserve on the Mullica River. NJDEP and IMCS
were set to jointly manage and operate the reserve. The agreement document reads,
​"Faculty have been active in teaching and conducting research in the Great Bay area
since the founding of the college in 1971. They have considerable data on a variety of
parameters in the area," in reference to Stockton College (McDonnel, 1998);
● Atlantic City has been long-known for its casinos. However, Stockton actually
contributed to the growth of them; The Stockton Institute for Gaming Management
(SIGMA) has now trained over 15,000 casino hotel employees (Posner, 2011); and
● Large influxes of commuters resulted from the college, to the point of which Atlantic
City transit was impacted by route changes that would be necessary to accommodate the
students. Specifically, the Master Plan made note of “Stockton College students, who
were noted to lack adequate transit services to the malls as well as other activity and
employment centers (Atlantic County Department of Regional Planning and Economic
Development, 2000).”
Much of this growth has had a positive impact on the community following what Bjork
would’ve called the “adjustment period” and formed bonds between the community and college,
just as he had hoped would one day occur (Posner, 2011). Additionally, in 1990 Stockton
released its first master plan that stated, “Wetlands buffers in the central core development area
of the 1990 Master Plan were agreed to be established at 175’. Outside the core areas, many, if
not most, areas are more environmentally sensitive and will require a larger buffer area. With
this consideration, Stockton has agreed to use a 300’ buffer in all areas outside of the core, and
so the various maps show the extent of additional land between 175’ and 300’ protected by this
decision (Stockton University, 2020c).” With the schools relationship with the community
repaired overtime, this statement exhibits how the schools relationship with the Pinelands
Commision was repaired with compromise.
Stockton University Today. ​Today, Stockton University boasts several campus
locations, including the main Galloway campus, the Atlantic City campus, the Manahawkin site,
and multiple research centers (Stockton University, 2020a). Known partly as New Jersey’s Green
University, the school’s founding commitment to the environment is still present throughout
campus. The mission statement includes, “The University seeks to promote an ethic of resource
conservation, sustainability, and social justice on our campuses and throughout the region in its
strategic planning and operations as well as its teaching, research, and service. Stockton
embraces the obligation of stewardship this environment demands (Stockton University,
2020c).”
After the creation of the 1990 Master Plan, stormwater management related plans and
documents followed. In 2004, as mandated by N.J.A.C 7:14A Stockton received authorization of
their Public Complex Stormwater General Permit and SPPP (Stockton University, 2020c). In
2005, the College developed a Facilities Master Plan where proposals included replacement of
the large existing surface parking lots with green space, buildings and parking garages. This plan
was updated in 2010, when Stockton developed and submitted for Pinelands approval a Master
Stormwater Management Plan that supported the development needs at that time (Stockton
University, 2020c). Stockton also maintains storm sewer location plans.
On September 23, 2020, Stockton University released their most updated Facilities
Master Plan. This plan still utilizes the 2010 Stormwater Management Plan that supported the
development needs at that time on the basis of design for the future needs identified in the 2020
Master Plan Update (Stockton University, 2020c). These plans act predominantly under New
Jersey’s Stormwater Management Rules and The Pinelands CMP, with a few exceptions. Firstly,
the Pinelands CMP states, “No development shall be carried out within 300 feet of any wetland,
unless the applicant has demonstrated that the proposed development will not result in a
significant adverse impact on the wetland, as set forth in N.J.A.C. 7:50-6.7 (Pinelands
Commission, 1981).” Due to early construction, Stockton University still maintains buildings
within 300 feet of a wetland without proper demonstration of impact.

5.3 Stormwater Management at Stockton University

Balancing natural and urban systems is a challenging task for all, but especially for a
college in the Pinelands. Stockton University maintains three forms of documentation that
summarize how both NJDEP & Pinelands Commission standards are met. These documents are
the schools SPPP, Stormwater Management Plan, and storm sewer location plans. The steps
taken to achieve proper management are summarized simply as preventing litter, keeping
pollution out of storm drains, keeping pet waste off of campus, not feeding wildlife, and properly
disposing of and using hazardous products (Stockton University, 2018).
Stormwater Pollution Prevention Plan (SPPP). ​It’s understood that as a public
complex residing in a Tier A municipality, Stockton University is mandated to maintain a SPPP
as per their public complex stormwater general permit; requirements of the SPPP can be
reviewed in ​Table 5.1.1.​ Stockton University first published theirs in 2004 and most recently
updated it as of April 4, 2019. The first portion of the SPPP includes the team members, who
serve to be guiding forces in the goal of meeting requirements and can be seen in ​Table 5.3.1​.
Table 5.3.1

Stockton University SPPP Team Members

Team Member Position​ (and Title) Name

Stormwater Program Coordinator​ ​AND Employee Training Chris Corea

Coordinator​ ​(Manager E/H/S)

Public Notice Coordinator​ (Direction of News & Media Relations) Diane D’Amico

Post-Construction Stormwater Management Coordinator​ (Direction Charles “Skip” West

Facilities Planning and Construction)

Local Public Education Coordinator ​(Associate Professor of Tait Chirenje

Environmental Science)

Regulatory Mechanism Coordinator ​(Office of General Council) Brian Kowalski

Physical Plant Manager ​(Director Facilities Management and Plant John Fritsch
Operations)

Other ​(Director of Campus Public Safety) Adrian Wiggins

Other ​(Associate Director Facilities Management and Plant Bob Haviland

Operations)

Other ​(Supervisor of Landscape Maintenance) David Wood

Other ​(Associate Director Facilities Management and Plant Kari Hibbert

Operations)

Form 2 addresses the Open Public Meetings Act, N.J.S.A. 10:4-6 et seq., and falls under
the responsibility of the teams public notice coordinator. Stockton University provides public
notice in a manner that complies with the act, additionally soliciting input while developing it’s
Stormwater Program from municipalities, interested students, employees, and neighboring
residents (Corea, 2019). Form 3 addresses the new development and redevelopment program as
per N.J.A.C. 7:8. To comply, Stockton intends to consider the applicable design and performance
standards as early as possible in the project planning and design process by working with the
engineer/environmental vendor of record to help determine which of our development projects
are subject to the standard, and to assist in the design and execution of these projects. Further, on
May 8, 2014 On May 8, 2013, the University’s Board of Trustees promulgated Policy No. VI-81
Pollution Prevention which:
● Provides guidance on sound environmental practices to protect public health, safety and
welfare 2;
● Incorporates pollution prevention concerns in decision-making 3;
● Ensures all activities of the University meet or exceed compliance with applicable
environmental standards, regulations and guidelines 4; and
● Promotes environmental stewardship and sustainability opportunities in all areas (Corea,
2019).
Form 4 is that of the Local Public Education Program and is handled by the Local Public
Education Coordinator. Stockton University includes various examples of their educational
outreach programs within this form. Form 5, Storm Drain Inlet Labeling, was taken into account
by the school first in 2005. As part of the stormwater inlet cleaning maintenance, performed by
Plant Management in 2007 all labeling was confirmed to have been completed. Further, proper
storm drain inlet labelling is continually checked by Stockton operations personnel to ensure that
all labels are correctly applied and in good condition. All storm drains at Stockton University
maintain labels that promote sustainable activity. Form 6, MS4 Outfall Pipe mapping, was taken
into account by the school first in 2005 as well but updated later. In 2010 Stockton hired an
outside environmental and engineering company to perform a Stormwater Compliance Report as
well as a Master Plan, which included mapping, and as of 2019 updated mapping is in progress.
Figure 5.3.1

Storm Drain Inlet Label Outside of Stockton University’s Arts & Sciences Building

Form 7 refers to the illicit connection elimination program which the school tracks in two
ways. First, if there are any complaints from students, employees, or the general public of any
illicit connections, the Director of Facilities Management and Operations will be notified,
and they will make an initial investigation of the discharge. Second, Stockton University uses
NJDEP Illicit Connection Inspection Report forms and protocol for determining if a discharge is
an illicit connection. Form 8 is the records of processes completed per Form 7, and Stockton
University reported 0 illicit connection on all recordings.
Form 9 covers the vegetative waste collection and disposal program, but with no homes
where residents are responsible for their own yard waste nor generate any on campus, all
maintenance of common areas is performed by university employees. Form 10 covers regulatory
mechanisms, of which the following apply to the school: pet waste, litter, improper waste
disposal, and wildlife feeding. For these, the type of enforcement action will depend on the
nature of the violator. However any University student who violates a regulation will be subject
to sanctions in accordance with the University’s Student Conduct Code. Any University
employee who violates a regulation will be subject to employee disciplinary action in accordance
with applicable employment statutes and contracts and any visitor who violates a regulation will
be subject to ejection from University property. Additionally, to reduce pet waste, Stockton
University has put waste bag stations along some walking trails on campus.
Form 11 discusses storm drain inlets, but Stockton University's storm drain inlets do not
combine into a common outfall and instead discharge through numerous discrete discharge
points. Form 12 is about maintenance of street sweeping and road erosion control, and the
university complies with a set schedule for street sweeping. To comply with form 13,
Stormwater Facility Maintenance, Stockton University submits an annual report including a
record of inspections, maintenance, and repairs to the NJDEP. Form 14, of the subject of Outfall
Pipe Stream Scouring Remediation, means that if remediation is necessary, Stockton University
will repair in accordance with the Standards for Soil Erosion and Sediment Control in NJ. Form
15 is about de-icing material storage. Stockton University currently stores its de-icing materials
in a storage structure located in building 77 on campus. Finally, Form 16 covers standard
operating procedures and Form 17 employee training where Stockton explained their class
schedule. The last classes were in 2005, but on-going training as needed occurs.
Stormwater Management Plan. ​Stockton University’s Stormwater Compliance Report
was created for the 2010 Master Plan by both the university and Marathon Engineering &
Environmental Services (Marathon). The document was created with an intent to convince the
Pinelands Commission that future construction at the college should be approved. Previously,
each project was submitted to the Pinelands as a stand-alone development, which resulted in
increased cost for preparation of applications and design documents, as well as delay due to the
lengthy review time. As a result, Stockton would have to provide the Commision with notice
only to record impervious surface cover and area of disturbance (Stockton & Marathon, 2010).
Now approved by the Commission, this document is being used for the recent 2020 Stockton
University plan as well (Stockton University, 2020b).
To create this plan, there were several areas of research first completed. A stormwater
management investigation occured, noting that Phase 2 Development areas need individual
stormwater management systems that would discharge towards an onsite stream that feeds Lake
Fred. Engineering design plans were created to describe the BMP’s utilized on the project. A
detailed soil investigation evaluated all soil cointions to profile them for six proposed stormwater
management areas. Lastly, Stockton documented their stormwater compliance within the
document, most of which can be reviewed when reading about Stockton University’s SPPP.
Areas of improvements were evaluated for the Stormwater Compliance report as well. It
was mentioned that runoff was entering Lake Fred directly when the school first opened. This
stands true today as the runoff rates that affect Lake Fred have been grandfathered in and remain
the same as 1971 (Cromartie, 2011). In one development area that causes runoff to Lake Fred,
the proposed area would also come with additional open space, leading to less runoff. While
development is planned, the impervious surface cover created is compensated for with the open
space, creating a net impervious surface cover of 0.
Table 5.3.2

Previous Lake Fred Runoff Rates VS Runoff Rates Following Improvement Project

Drain Shed Discharge North Peak Runoff Flow Rate Total Runoff Volume (cf)
to Lake Fred (cfs)

Q2 Q10 Q100 V2 V10 V100

Pre-project 53.70 85.93 161.40 216,843 363,436 677,364

Post-project 51.46 82.86 158.98 208,383 352,583 664,710

(Data from Stockton and Marathon, 2010)
As the development around Lake Fred does, all other development in the plan aims to
maintain existing pervious surface cover as well as create additional pervious surface where
possible. As a result, in accordance with N.J.A.C. 7:50-6.84(a)6ii(1), the post construction runoff
hydrographs for the two, 10, and 100-year storm events don’t exceed the pre-construction runoff
hydrographs for the same storm events. Additionally, infiltration basins were designed to
accommodate the full volume of runoff (Stockton and Marathon, 2010).
In compliance with standards from N.J.A.C. 7:50-6.84(a)6iv, the area of the basins first
underwent a groundwater mounding analysis to assess the hydraulic impacts of mounding of the
water table resulting from infiltration of stormwater runoff from the basins (Stockton &
Marathon, 2010). This factor leads to Stockton University’s compliance with N.J.A.C.
7:50-6.84(a)6v, where required permeability rates were achieved; recall that groundwater
recharge is a major factor of management in the Pinelands. Overall, Stockton University’s 2010
compliance report details not only how the school meets regulatory requirements but how they
will continue to overtime.

5.4 Best Management Practices at Stockton University

Stockton University is located within the Mullica Watershed which is the primary
drainage system for the Pinelands. In a rain event at the University, stormwater drains into Lake
Fred where it leaves through Morses Mill Stream. Morses Mill Stream has “medium” concern
regarding water quality for the stream’s pH. High pH can be caused by natural circumstances or
through human activity. In order to ensure the University is not contributing significantly to
stormwater pollution, they have implemented BMPs as well as simple measures all members of
the community can take (NJDEP, 2014). It’s important to follow BMPs because water from
campus can make its way into the Mullica River or Great Bay. Stockton’s campus is also
buffered by wetlands, which are essential to keep protected due to their natural flood reducing
capacity.

Figure 5.3.1

Morses Mill Stream Quality

(NJDEP, 2014)

Rain Gardens. ​Stockton University maintains several small-scale rain gardens that exist
to minimize impervious surfaces by reducing cartway widths and parking stall dimensions and
by breaking up or disconnecting the flow of runoff from parking areas, drives and roadways.
Designed as per the NJDEP BMP to accept the first flush of runoff and provide pretreatment of
runoff from the parking areas, the rain gardens on Stockton University can be referred to as;
● USC Quad Rain Garden,
● HSC Rain Garden,
● USC2 Rain Garden,
● USC Circle Rain Garden,
● HSC Circle Rain Garden,
● CC Front Rain Garden,
● K Wing Rain Gardens,
● H Wing Rain Gardens,
● J Wing Rain Gardens, and
● A&S Rain Garden.
Figure 5.4.1

J Wing Rain Gardens

(Google Maps, 2020)

Vegetative Retention Swales. ​In most areas with rain gardens, there’s also vegetative
retention swales. The rain gardens and swales on campus serve only as pretreatment for runoff
on the campus; as in, their only purpose is to remove continents from runoff and not so much to
slow rates. As a result, it is not required to meet the groundwater recharge standard within rain
gardens. The excess parking area stormwater is conveyed, along with runoff from the buildings
and recreation field, and discharged into an open stormwater management basin that is
designed to retain and infiltrate the total runoff volume generated from the net increase
in impervious surfaces by the ten-year storm. The excess parking area stormwater is conveyed,
along with runoff from the buildings and recreation field, and discharged into an open
stormwater management basin that is designed to retain and infiltrate the total runoff volume
generated from the net increase in impervious surfaces by the ten-year storm. (Stockton &
Marathon, 2010).
Infiltration Basins. ​Stockton University maintains ten basin structures. These vary in
structure with the intent to maintain the lowest possible impact to the environment. For example,
some basin areas were not created by clearing and excavating and instead by minimal brush
clearing and berming on the downstream side of the area to allow the natural wooded area to
remain and act as a bioretention facility that will store runoff at shallow depths and allow it to
infiltrate in those natural wooded areas. Other basin areas required clearing due to large
variations in topography, but those basin areas are designed to be partially vegetated with low
maintenance plantings that will be left to revegetate naturally (Stockton & Marathon, 2010).
These are inspected for erosion, trash, and buildup regularly. Overall, the basin required to meet
the engineering standards is large in area, but due to the similarity in topography in most of the
downstream area where the basin is situated, much of the basin area is made up of wooded area
to remain (Stockton & Marathon, 2010).
 Of basins on campus, most are designed so that the post-construction peak runoff
discharge rates for the 10 and 100-year storm events do not exceed 75 and 80 percent,
respectively, of the pre-construction peak runoff rates. Review found that the basins absorb the
entire runoff volume from the two-year storm event (Stockton & Marathon, 2010). Many are
placed near or adjacent to parking lots, as runoff is most abundant in those areas.

Figure 5.4.2

Infiltration Basin near Lot 8A

(Google, 2020)

Rainwater Collection. ​Stockton University maintains many outdoor lab areas, but a
notable one is The Stockton Farm. Used as a laboratory in the Sustainability program, it remains
committed to sustainable practices and the advancement of sustainable agriculture in New Jersey
(Stockton University, 2020b). Sustainable agriculture lowers the amount of harmful
contaminants, such as pesticides, in stormwater runoff. However, BMP’s are also present in the
form of rain barrels. The farm uses the rainwater collected from roofs to water the agriculture,
changing it from excess runoff to a valuable asset.
Figure 5.4.3

Rain Barrels Connected to Gutter on the Stockton Farm

Permeable Parking Lot. ​In 2010, Stockton University began work to convert an athletic
field into a parking lot. Located in front of big blue, the lot is paved with a porous surface of
plastic grids. These grids, which are durable and resilient, are made from recycled polyethylene
(Kelly, 2010). A mixture of topsoil and EcoSoil from the ACUA fills the open spaces in the
grids, which are about two inches thick; EcoSoil is a 100% natural composted blend of yard
waste collected from around Atlantic County that recycles yard waste and keeps it from using up
valuable landfill space. Grass will grow in the soil provided and rainfall will soak through the
parking lot into the ground without the need for storm drains. At 1.86 acres and with room for
205 cars, in 2010 the project was the largest of its type in New Jersey (Kelly, 2010).
Figure 5.4.4

Stockton University’s Permeable Parking Lot

(Google, 2020)

On the more remote parts of campus, gravel roadways are present as well. This includes
the road leading to the Stockton Farm. Also, while a permeable parking lot wasn’t created, in
2017 re-construction of the University Walk and Parking lot 6 was completed. This is notable as
it reduced approximately 10,000sf of impervious surface, which enhances the environment and
provides additional green space.
Figure 5.4.5

Gravel Roadway Leading to Stockton Farm

5.5 Public Education and Outreach at Stockton University

Within the Pine Barrens, Stockton University is able to create a unique environment for
education and conservation. The land surrounding the school is often utilized as an outdoor
classroom, research space, and overall opportunity for learning; NAMS students at Stockton are
privileged to have 400 acres of the 2,000 acres campus set aside for field experience (Stockton
University, 2020b). Learning doesn’t stop with the students though, as Stockton University often
extends resources throughout local highschools, the community, and others interested. The
university’s Local Public Education is in partnership with the Stockton University
Environmental Studies Program, the Stockton Action Volunteers for Environment (SAVE) and
Waterwatch. Annually, SAVE holds an “Earth Day Fair” where the office of E/H/S sets up a
booth to answer questions regarding stormwater as well as to hand out educational pamphlets.
The pamphlets are sent to all employees and students at the university as well. Waterwatch is
involved in many additional activities, which include a campus cleanup (Corea, 2010). In
addition to these things though, Stockton University brings education and awareness about
stormwater to the public often.
The Annual Pinelands Short Course, a collaborative event between Stockton University
Continuing Studies and the New Jersey Pinelands Commission, is a day-long annual event
featuring educational presentations that explore the unique history, ecology, and culture of the
Pinelands. Past presentations have included “Climate Change and the Pinelands Water Cycle,”
which covered the topic of climate change bringing more precipitation and stormwater as well
as possible solutions that people can do on a daily basis. In 2019, the short course included a rain
barrel workshop in which participants had the opportunity to build their own rain barrel
(Pinelands Commission, 2019). A presentation called “Combating Climate Change with a
Jersey-Friendly Yard” offered ways to migrate downpours by teaching participants how to select
appropriate plants for sandy soil, turn their yard into a sponge, and provide habitat to support
native wildlife (Pinelands Commission, 2020). As a result of these examples and others not
mentioned, more than 10,000 people in the area have benefited and gained more knowledge
(Courier-post, 2015).

Figure 5.5.1

A presentation on native plants during the 2018 short course.

Note.​ Marilyn Sobel, a research scientist with the Pinelands Commission, was the presenter and
promoted native plant use. Native plants can filter stormwater and prevent erosion (Pinelands
Commission, 2018)
The Atlantic Estuarine Research Society (AERS) brings together students, scientists,
managers, and educators discuss estuarine and coastal environmental issues and policies, with
the intent to foster broader interest in the environment by increasing public awareness of current
issues (AERS, 2018). Stockton University has hosted AERS several times, including Fall 2014's
meeting, “Sandy and Superlative Storms; Resilience, Recovery, Restoration." The meeting ran
from October 3 to November 1 and included precentors, posters, vendors, field trips, and more
(Fertig, 2014). ​Presentations at the 2014 meeting included,
● "Effects of Superstorm Sandy on Coastal New Jersey" by keynote speaker Mike Kennish;
● "Impacts of Hurricane Sandy on Submerged Aquatic Vegetation in Barnegat Bay, New
Jersey" by Paul Bologna;
● "Naturalization of salt marsh restoration sites in the Elizabeth River, Virginia, assessed
by feeding activity and trophic level of mummichogs" by Moriah Good; and
● "Storms and landscape change: assessing impacts to human infrastructure and natural
habitat using numerical models" by keynote speaker Neju Ganju (Fertig, 2014).
Stockton University also hosted AERS in 2018, in which student made posters were also
involved. One was titled, “Nutrient bioassay experiments in Deal Lake find nitrogen limiting to
harmful algal bloom growth in the summer season” and was created by Monmouth University
and Rutgers University undergraduate students. This poster discussed how five nutrient bioassay
experiments were conducted in this fresh-to-brackish water coastal lake to determine nutrient
limitation on algal growth (AERS, 2018).
In July 2016, Stockton University gave students the opportunity to get hands on
experience in stormwater management. The U.S. Army Corps of Engineers Institute for Water
Resources was awarded a Federal Highway Administration grant to analyze how green
infrastructure, or nature-based infrastructure, can help protect Great Bay Boulevard in Ocean
County, New Jersey from flooding due to severe storms and sea-level rise.​ This project was led
by a multidisciplinary team from the USACE Institute for Water Resources, USACE
Philadelphia District, Stockton University Coastal Research Center (CRC), and Barnegat Bay
Partnership (BBP), with the support of several other partners. Results from the study include an
empirical understanding of what causes Great Bay Boulevard to flood, a survey of the
surrounding salt marsh ecosystem, and two conceptual designs that intend to simultaneously
reduce flood risks and improve ecosystem functions (US Army Corps of Engineers, 2018).
Figure 5.5.2

CRC researchers extracting a marsh core, and a water level logger installation

Note.​ Marsh edge site was accessible only by the R/V Osprey, Stockton University’s research
boat. This image shows the vessel moored to the marsh edge (US Army Corps of Engineers,
2018)

5.6 Future Plans at Stockton University & Recommendations

As of September 23, Stockton University released their 2020 Master Plan. This Master
Plan includes a myriad of new developments the university has planned, including but not
limited to;
● Sports Center Expansion (Phase 1),
● Sports Center Expansion (Phase 2),
● 1,200 vehicle parking structure,
● 4th Academic Quad Building,
● Campus Center Expansion,
● Welcome Center,
● Field House & Pavilion, and
 ● Stockton Residential Phase 1 – Improvements.
To elaborate, Phase 1 of the Sports Center Expansion involves constructing an 18,000 SF
addition to the Sports Center on the USC side to build a new common fitness/wellness facility.
The second phase of this would be constructing a 48,000 SF addition to the Sports Center that
connects to the upgraded outdoor track to accommodate additional classrooms and program
space (Stockton University, 2020b). Continuing, a parking garage structure that can
accommodate up to 1,200 vehicles is planned as well and the unpaved portion of surface Lot 5
has emerged as the preferred location. Housing 1, which represents the oldest residential
apartments on the Galloway Campus, is on track to soon lose that title. A proposed project in the
masterplan is demolishing the sixteen two-story structures to make way for the construction of
eight new individual five-story structures (Stockton, 2020b). However, much of this proposed
development lacks explanation as to how environmental impact will be minimized.
The 2020 Master Plan states that the 2010 Stormwater Management Plan released by the
school will still be applicable. However, a general assessment brings forward doubt regarding the
University’s ability to properly manage stormwater. Construction of the parking garage on lot
five means that the current porous paving will instead be replaced with impervious cover if the
garage location is finalized as that area. The expansion of the sports center as well as other
expansion is going to create less greenspace on campus at large rates. Changing the sixteen two
story structures that make up housing 1 into five story structures will create buildings that exceed
the tree canopy, something the founders of Stockton University tried to prevent.
In ​Section 5.2​, it was established that the 1971 Comprehensive Architectural Master Plan
emphasized the natural environment and stated, “the identification of the most desirable natural
areas on the campus and administrative action now, to assure the recognition of their unique
values and to insure their perpetual protection, will demonstrate the vision of the College’s
founders (Cromartie, 2011).” It was also said that were the New Jersey Wetlands Commission of
this time given the job of determining whether or not the vision of a natural environment was
present, they might say it was lost in translation. However, as time went on Stockton University
did repair this rocky relationship and became New Jersey’s Green University.
Nevertheless, with the amount of negative impact to the environment Stockton University
brings as well as the implications of the planned development, this vision may be fading away
permanently. While the schools environmental/sustainable education can’t be discredited,
outside of this there’s little to truly earn the school the title of a “Green University” when it
comes to stormwater. Throughout this document, examples of the school's impact have been put
throughout. This includes runoff entering Lake Fred directly; an especially harmful practice to
Atlantic White Cedars which are present on campus with a declining population as a result of
runoff related pollution; and lack of natural biodiversity; which was instead replaced with
ornamental trees and grass cover in spite of 1971 recommendations. According to the Federal
Interagency Stream Restoration Working Group (2001), biodiversity is also negatively affected
by stream channelization, which results in ecological decline. This too is present on Stockton’s
Campus.
Figure 5.6.1

An Example of Excessive Grass Cover at Stockton’s Galloway Campus

Figure 5.6.2

Stream Channelization Outside of Arts & Sciences at Stockton University

​ or stream corridors that have naturally evolved in an environment of spring floods and
Note. F
low winter and summer flows, the diminution of such patterns can result in the creation of a new
succession of plants and animals and the decline of native species.
 Prior to new construction, it would be in Stockton University’s best interest to first
account for the areas that could use improvement rather than to expand. According to the CMP
7:50-5.13 g, “Regional Growth Areas are areas of existing growth or lands immediately adjacent
thereto which are capable of accommodating regional growth influences while protecting the
essential character and environment of the Pinelands.” In many ways, Stockton University has
protected the essential characteristics of the Pinelands; the forest management plan includes
controlled burns that allow for regeneration, many areas of the campus are set aside for
preservation, and a variety of other examples exist. The same cannot be said for Stockton
University’s stormwater management and some essential characteristics of the Pinelands are
being lost as a result of it.

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