Impervious and Total Land Use Areas in D.C. by Category
D.C. Has a Unique Relationship with Federal Facilities
Federal facilities are the second largest landholder in the District
Federal facilities don’t pay taxes
Many federal facilities lie in areas technically outside of the MS4 area referred to as “other areas” where they discharge stormwater directly to the Anacostia and Potomac Rivers.
Because of the large amount of land they occupy and their physical location close to the rivers and streams, D.C. must find a way for them to contribute to the obligations of the Bay TMDL and D.C. WIP
D.C.’s Approach to Working with Federal Facilities
DDOE has had a long standing working relationship with federal facilities regardless of regulatory requirements
DDOE held a meeting in March of 2009 to discuss the implementation of section 438 of EISA
EISA states that: Federal projects shall retain the 95th Percentile Rainfall Event (1.7” in the District), or Replicate the pre-development hydrology of the site
DDOE has held follow up meetings with DoD and GSA discussing EISA requirements and even for a specific GSA project
During the development of the District’s WIP, DDOE reached out to nearly all federal facilities in the District; ensuring that all initiatives by federal facilities were accounted for in the WIP
D.C.’s relationship with the federal facilities is very straightforward where the MS4 Permit is concerned
Good intentions are often expressed, but budget constraints stand in the way of firm commitments on any projects that are not somehow regulated
D.C. has limited regulatory authority and little recourse
Logistical constraints exist due to the scattered nature and sheer number of federal facilities located in D.C.
DDOE plans to hold a meeting with federal facility partners once the District’s new MS4 permit is issued and the District’s new stormwater regulations have gone out for public comment
This meeting will focus on the expectations of federal facilities to comply with the WIP. Complying with the WIP will also bring the federal facilities into compliance with the TMDL,Executive Order #13508, EISA, DC MS4 Permit, and District stormwater regulations.
DDOE plans to help federal facilities write their own 2 year milestones that will complement and inform the District’s 2012 two year milestones
Deputy Director Office of Natural Resources
District Department of the Environment