Idaho Seeks to Cut Infrastructure-Related Plastic Usage

The Idaho Transportation Department (ITD) is engaged in a broad effort to develop environmentally-friendly solutions that reduce plastic waste from entering the natural environment; particularly where infrastructure projects are concerned.

[Above photo by the ITD]

For instance, the agency is now using biodegradable erosion control loose weave “blankets” without joints that allow snakes and other wildlife to easily move over or through them. Those “blankets” play a key role in the agency’s Erosion and Sediment Control or ESC practices that prevent soil loss and reduce sediment-laden stormwater runoff in and around transportation infrastructure.

Cathy Ford, the ITD’s roadside program administrator, noted that those ESC practices – used in transportation construction, maintenance, and operations activities – can be temporary or permanent.

She noted that biodegradable material will decompose under ambient soil conditions into carbon dioxide, water, and other naturally occurring materials within a time period relevant to the expected service life to the material.

“As more DOTs require the use of natural, biodegradable products, the upfront costs of purchasing the product are expected to decrease based on efficiency of scale,” Ford added in a statement.

The ITD said that plastics are commonly used as ESC solutions due to their availability, durability, and low cost, but they are rarely recycled, ending up in landfills or breaking down into micro-plastics, which are an emerging pollutant of concern.

Pieces of plastic netting can contaminate waterways and interfere with aquatic resources, the department noted, with plastic erosion control materials potentially ensnaring and killing fish and wildlife, interfering with highway mowing equipment, creating garbage, and resulting in added costs for removal and disposal.

The agency noted that older “photodegradable” plastics can still be intact a decade after construction projects are completed if vegetation prevents sunlight from breaking down the plastic. When these photodegradable plastics do break down, they continue to be a hazard to natural ecosystems as a micro-plastic, ITD explained. By contrast, biodegradable products typically degrade within one to two years into naturally occurring substances.

RIDOT Helps Support ‘Gotham Greens’ Path Project

The Rhode Island Department of Transportation is helping support – in concert with various federal, state, and local agencies – the new “Gotham Greens” off-road multi-use path along the Woonasquatucket River Greenway via stormwater mitigation efforts.

[Above photo by RIDOT]

This new path, located behind the Gotham Greens building in Olneyville, offers new access to the Woonasquatucket River and will serve as a connector between the Greenway and the Washington Secondary Bike Path – helping “knit together” a “patchwork of pathways” in the City of Providence to promote active transportation use while protecting the local environment from stormwater flooding.

The nonprofit Woonasquatucket River Watershed Council, the City of Providence, and Gotham Greens jointly built the new path, while RIDOT – in concert with the Environmental Protection Agency, Rhode Island Department of Environmental Management, and the Narragansett Bay Estuary Program – will work to mitigate the potential for future flooding along the pathway.

“Urban flooding and resilience are complex issues that demand collaborative, innovative, and targeted responses,” explained Governor Dan McKee (D) in a statement.

This second phase of improvements to the pathway – currently under RIDOT’s supervision and supported in part by the National Coastal Resilience Fund – focuses on streambank restoration and “green infrastructure,” which is the installation of plants, soil, and other natural materials to manage stormwater and prevent flooding and pollution.

ETAP Podcast: WSDOT Stormwater Management

The latest episode of the Environmental Technical Assistance Program or ETAP podcast digs into the innovative stormwater management practices of the Washington State Department of Transportation.

[Above photo of Tony Bush via WSDOT]

The ETAP podcast – a technical service program for state departments of transportation provided by the American Association of State Highway and Transportation Officials – explores a wide array of environmental topics that affect transportation and infrastructure programs.

In this episode, Tony Bush (above) – stormwater branch manager for WSDOT – explains how the agency historically managed stormwater runoff from a safety and road preservation perspective and how it then later built in environmental stewardship and regulatory practices to support that stewardship into its processes.

Bush also goes into a current WSDOT research effort regarding the environmental impact of a contaminant called 6PPd-quinone from old vehicle tires and how that contaminant might affect salmon populations. To listen to this episode of the ETAP podcast, click here.

Kansas DOT Wins Two Environmental Awards

The Kansas Department of Transportation recently received two awards for its stormwater management policies from the Water Environment Federation or WEF.

[Above photo by the Kansas DOT]

The agency received a bronze model for innovation and a silver medal for program management as part of WEF’s National Municipal Stormwater and Green Infrastructure Award contest.

“The quality of stormwater runoff is important to the health of our rivers, lakes, streams, and wetlands,” noted Dale Kirmer, a staff engineer with Kansas DOT, in a statement.

“Rainwater can pick up many different pollutants when it hits the ground and has no treatment facility,” he added. “It drains into our waterways through pipes and ditches. The pollutants can cause turbidity (i.e. cloudy water) and overgrowth of algae as well as harm aquatic organisms and the ecosystem.”

The Kansas DOT manages compliance within six areas of municipal separate storm sewer systems, also known as MS4, on state-owned right-of-ways statewide. As a result, the agency has developed an MS4 compliance strategy that promotes stormwater quality, optimizes processes, and looks for new opportunities to minimize impacts to stormwater runoff.

The agency’s stormwater management plan includes several interconnected compliance elements, such as promoting an Adopt-a-Highway litter removal program; creating comprehensive construction site runoff requirements for all Kansas DOT projects; and focusing on post-construction stormwater management, specific to the highway environment.

In the future, the agency plans to keep identifying opportunities to improve its documentation processes, among other items. The goal is not to only check a box, Kansas DOT stressed; the goal is to improve the quality of stormwater runoff from the state’s transportation systems.

Other state departments of transportation across the country are engaged in water-management efforts that mirror Kansas DOT’s stormwater control philosophies in many ways.

For example, as part of its “Let’s Change This to That” public education campaign, the California Department of Transportation began highlighting the top six sources of stormwater pollution across the state in May as well as ways to prevent them from contaminating California’s waterways.

Meanwhile, in August, the hydraulics unit of the North Carolina Department of Transportation won a 2022 Pelican Award from the North Carolina Coastal Federation for its efforts to both protect and improve coastal water quality. The Pelican Award honors volunteers, businesses, agencies, and organizations that go “above and beyond” to ensure a healthy North Carolina coast for future generations.

The Federation commended the NCDOT team – one of three winners of Pelican wards this year – for its dedicated advancement of nature-based resilience initiatives, such as its work on the living shoreline project along N.C. 24. That project is part of NCDOT’s effort to make more than 500 miles of coastal roads resilient to storms using nature-based solutions.

In May 2021, the Maryland Department of Transportation unveiled three “smart ponds” built via a public-private partnership or P3 stormwater control project that seeks to reduce pollutants and curb local flooding.

The agency said this “smart pond” project is the first of its kind involving a state transportation department and it involved the Maryland Department of Environment, Environmental Protection Agency, Walmart, and The Nature Conservancy. Overall, the Maryland DOT said it owns about 800 ponds that could benefit from this smart pond technology.

Tennessee DOT Helps Turn Old Tires into Walking Trail

An eyesore of thousands of dumped tires were recently recycled into material for a hard-surface walking and biking trail at the Tennessee state park in Memphis they once littered, thanks in part to a grant from the Tennessee Department of Transportation.

[Above photo by the Tennessee DOT]

The Tennessee DOT and Tennessee State Parks recently opened the 2.5-mile-long walking and biking trail at T.O. Fuller State Park in Memphis. Billed as one of the longest rubber-bearing trails in the country, the new trail is primarily composed of 24,000 recycled tires.

Tennessee DOT issued a $200,000 litter grant to support the trail project, which shredded those 24,000 abandoned tires into quarter-inch pieces of crumb rubber. A federal recreational trails program provided another $280,000, with the Tennessee Department of Environment and Conservation or TDEC providing an additional $250,000 grant.

“Litter and illegal dumping are costly and damaging to Tennessee,” explained Joseph Galbato, III, who until recently served as Tennessee DOT’s interim commissioner, in a statement.

[In May, Governor Bill Lee (R) appointed Deputy Governor Butch Eley to serve as the agency’s commissioner in addition to Eley’s current duties.]

“We are thankful for collaborative partnerships like the ‘Tires to Trails’ project which not only addresses the litter problem but turns it into a meaningful and positive long-lasting resource for the community,” Galbato added.

Michael McClanahan, an outreach specialist with Tennessee DOT, getting his hands dirty to help pull tires out of the park.

The crumb rubber from the old tires – mixed with a rock aggregate and a polyurethane binder – does not include the metal from those tires, noted Brent Miller, manager of Patriot Tire Recycling in Bristol, TN.

Typically, recycled tires are shredded and used as fuel stock for power plants and paper mills, or made into doormats, he explained.

“This was the first time we’ve done a trail,” said Miller, whose company handles about a million tires a year.

Recycled tires can live a useful second life in some transportation applications. The crumb rubber creates a flexible roadway that resists cracking, requires less maintenance, and is easier on the feet of walkers and joggers, said Alle Crampton, environmental scientist, and manager of the Tire Environmental Act Program for the state.

The walkways also are porous, virtually reducing the stormwater runoff problems associated with concrete and asphalt. The water can soak through the trail and reach the root systems of trees, making it less likely that the root systems will expand and crack the walkway, Crampton said.

More than 400 volunteers collected the passenger, commercial truck, and heavy equipment tires from the park, with many of the volunteers coming from Tennessee DOT, TDEC, the City of Memphis, Shelby County, and Memphis City Beautiful.

T.O. Fuller State Park was the first state park open for African Americans east of the Mississippi River. Originally built in 1938, the state later renamed the park in honor of Dr. Thomas O. Fuller, a prominent African-American educator, pastor, politician, civic leader, and author.

Caltrans Highlights Key Stormwater Pollutants

As part of its “Let’s Change This to That” public education campaign, the California Department of Transportation is highlighting the top six sources of stormwater pollution across the state as well as ways to prevent them from contaminating California’s waterways.

[Above photo by Caltrans]

The agency manages stormwater runoff and mitigates potential pollution within its 350,000 acres of right of way, which includes more than 15,000 centerline miles of highways. This effort involves picking up roadside litter and clearing out storm drains to preserve roadway safety and drivability during all types of weather conditions.

Unlike water that goes down the sink or toilet in a home, Caltrans said stormwater is untreated and flows directly into lakes, rivers, and other waterways.

The agency noted that as stormwater travels into storm drains, it captures pollutants from highways, streets, sidewalks, and yards that flow into waterways. The top six pollutants have an outsized impact on the water quality of lakes, rivers, streams, and the ocean, and many are preventable through small actions Californians can take:

  • Trash and litter: Properly secure items in truck beds and put trash and recycling in the correct bin.
  • Sediments: Prevent soil erosion by using mulch in the garden, planting trees and shrubs, and sweeping driveways instead of hosing them off.
  • Nutrients: Avoid over-fertilizing lawns and plants and limit vegetation waste by keeping fallen leaves out of storm drains.
  • Bacteria: Limit pet and Recreational Vehicle or RV waste by picking up after your pet and using appropriate RV dumping stations.
  • Metals: Regularly check tire pressure, change oil and fluids, and use commercial car washes to prevent metals generated from vehicle, tire, and brake wear from ending up on highways.
  • Pesticides: Use organic pesticides and properly dispose of unused portions.

“Preventing stormwater pollution requires the help and support of every Californian, and it starts with keeping highways and roadways clean,” noted Steven Keck, acting director at Caltrans, in a statement.

“Californians must work together to take necessary steps to prevent pollution at the source and keep our waterways clean,” he said.

With the intensify drought conditions predicted to increase statewide this year, Caltrans noted it is amplifying water quality as a top priority.

During a drought, the state’s lakes, rivers, and streams have lower water levels, which leads to a higher concentration of pollutants. By preventing a buildup of metals, trash, and other pollutants on highways and roadways in dry conditions, Californians can help keep pollutants from traveling into local waterways during rainstorms.

AASHTO Comments on Latest Proposed WOTUS Revisions

The American Association of State Highway and Transportation Officials submitted a seven-page letter on February 2 to the Department of the U.S. Army and the Office of Water Oceans, Wetlands, and Communities Division within the Environmental Protection Agency to comment on the latest proposed revisions to Waters of the United States or WOTUS regulations.

[Above photo by the Ohio DOT]

The foremost concern expressed by AASHTO in its letter focused on the “need to clarify the standards used for determining the jurisdictional status of roadside ditches” so that the latest proposed WOTUS rule changes “clearly exclude” the overwhelming majority of roadside ditches.

“Unlike previous iterations of regulations defining WOTUS for which the agencies extended the public comment period, this proposed rule makes numerous changes to the pre-2015 definition of WOTUS, and relies on supporting documents including a 250-page Technical Support Document and 177-page Economic Analysis,” AASHTO emphasized. “But [it] does not give the public sufficient time to fully digest and understand the agencies’ proposal and submit comments.”

The debate over changes to WOTUS regulations spans several years. In September 2019, EPA and the Department of the Army – representing the U.S. Army Corps of Engineers – repealed and ended what they described as a “regulatory patchwork” that required implementing two competing sets of Clean Water Act rules, which created a regulatory burden across the United States, especially for transportation projects.

The EPA and Department of the Army published a proposed rule in February 2019 as part of the second step in this process – developing a new WOTUS definition that would “clearly define” where federal jurisdiction begins and ends in accordance with the Clean Water Act and Supreme Court precedent.

In that proposal, the agencies said at the time they would provide a “clear definition” of the difference between federally regulated waterways and those waters that rightfully remain solely under state authority.

EPA and the Department of the Army then published a final rule in April 2020 defining the scope of waters federally regulated under the Clean Water Act, while adhering to Congress’ policy directive to preserve states’ primary authority over land and water resources.

When that new final rule went into effect, it replaced the rule published in 2019 that formally repealed a regulatory effort initiated in 2015 to expand the WOTUS definition under the Clean Water Act.

However, the EPA and U.S. Army Corps of Engineers – via a broad environmental directive issued by President Biden in January 2021 – began an entirely new WOTUS revision process in November 2021, first to repeal the 2020-era rule and then to design a brand new WOTUS regulatory framework.

The constant back-and-forth changes to WOTUS regulations are the main concern of AASHTO and state DOTs, as it impedes the ability to effectively plan transportation projects. 

“We caution that any final rule should truly be final, to the extent possible,” AASHTO said in its February 2 letter. “Frequent rule changes – especially of the magnitude characterizing the WOTUS definition – can be damaging to our members, because uncertainty has a substantial impact on transportation projects that often have a long lead time.”

AASHTO also expressed “concern” with the suggestion by the EPA and Department of the Army that an “anticipated second rule” would seek to “further refine” the test for WOTUS and “build upon the regulatory foundation” of the initial rule now being proposed.

“A second rule that does not focus solely on clearly defining WOTUS but instead introduces new concepts, standards, or requirements that go beyond the case law will increase the probability of confusion, additional lawsuits, and the need for additional changes in the future, further harming our members’ ability to plan for projects,” the organization said.

AASHTO Sends Floodplain Management Comments to FEMA

The American Association of State Highway and Transportation Officials sent a five-page letter to the Federal Emergency Management Agency on January 27 to provide feedback on floodplain management standards for land management and use; a key part of FEMA’s National Flood Insurance Program or NFIP.

[Above image via FEMA]

Developed with the assistance of the AASHTO Technical Committee on Hydrology and Hydraulics, the letter cautions against creating more requirements for specific threatened and endangered “T&E” species as that could create a “patchwork of complex regulations” among multiple federal agencies that would further complicate floodplain permitting.

”Additional impact restrictions imposed by a change to the NFIP minimum floodplain management standards could potentially delay or prevent fish passage projects at some [state] DOTs that have their own environmental regulations and requirements regarding T&E,” AASHTO said.

The organization also recommends that the NFIP focus on floodplain management while other agencies such as the U.S. Fish and Wildlife Service and National Marine Fisheries Service focus on T&E.

On another front, AASHTO pointed out that improving the distinction between river and coastal standards is critical as environmental and climate concerns are much different between them.

“State DOTs across the country are struggling with the best method to address climate change,” the letter explained. “[Yet] climate science regarding future flooding events is in a very immature state and is not well developed. Incorporation into the NFIP should not be considered until the science has stabilized and an acceptable design method is available to [state] DOTs.”

AASHTO added that a memorandum of understanding between FEMA and the Federal Highway Administration regarding hydraulic modeling within the special hazard flood area or SFHA within the NFIP would be beneficial to state DOTs.

That would be especially true when it comes to handling minor culvert and bridge maintenance, as well as ways to improve hydraulic models to limit any potential damage to streams, creeks, or other bodies of water in and around transportation projects, the organization noted.

Maryland Works to Reduce Road Salt’s Environmental Impact

In conjunction with several state agencies, including the Maryland Department of Transportation, the Maryland Department of the Environment (MDE) is spearheading an effort to reduce the amount of salts entering rivers, streams, and groundwater while also ensuring roads remain safe for winter travel.

[Above photo by the Maryland DOT]

MDE has been working for several years with state agencies and local jurisdictions on new salt application strategies, including use of improved weather forecasting, using the right amount of salt, targeting roads in most need of treatment, using brine to reduce overall salt usage, and increasing training for employees and contracted equipment operators.

The agency noted that Maryland DOT’s State Highway Administration (MDOT SHA) has used those and other strategies over the past five years to reduce its overall salt usage up to 50 percent.

MDOT SHA has moved to use salt brine – a liquid solution that is 22 percent salt and 78 percent water – before, during, and after winter weather events. Pre-treating roads with salt brine prevents the initial bonding of snow or ice, thus giving road crews time to mobilize. The agency now has two “tow plows” – separate plows towed behind a salt/plow truck to clear an additional travel lane – which enhance snow-clearing operations and reduce the need for road salting.

MDOT SHA has also designated salt brine-only routes for the duration of winter storms, resulting in less overall salt use when compared to routes where only rock salt is used. The agency pre-wets rock salt with salt brine to reduce the “bounce and scatter” effect of salt solids ricocheting off the highway.

MDOT SHA also works with weather forecasters to develop a treatment plan and employs more than 100 mobile infrared sensors at key locations, along with mobile sensors, to determine conditions and target its storm deployment – greatly contributing to salt reduction efforts.
“[We] congratulate and thank the Maryland Department of Transportation for leading by example when it comes to reducing the use of road salts that can threaten public health and our environment,” said Ben Grumbles, Maryland’s secretary of the environment, in a statement.

While sodium chloride or salt is effective, relatively inexpensive, readily available, and easily stored, it can destroy a soil’s structure and cause erosion, damage, and kill vegetation, while contributing to the corrosion of metal bridges and motor vehicles, MDE said. It can also seep into groundwater and runoff into surface waters, contaminating wildlife habitats and potentially affecting drinking water.

The agency noted it has increased monitoring for sodium chloride in the environment to gain information to help develop restoration plans. However, MDE noted that once salt has entered the environment there is no effective way to remove it. Thus, the best solution is a widespread, decreased use of road salt, it noted.

Nevada DOT Supports Stormwater Pollution Awareness Month

The Nevada Department of Transportation and Keep Truckee Meadows Beautiful are teaming up to observe Stormwater Pollution Awareness Month this October to educate the public about the importance of preserving stormwater quality. 

[Above photo by the Nevada DOT]

Stormwater Pollution Awareness Month encourages communities to make smart choices when it comes to preserving the quality of stormwater in the desert, the two organizations explained in a statement – noting that simple actions can make a huge difference in terms of preventing stormwater contamination.

The public outreach campaign includes a poster contest for kids, as well as an educational webinar about how residents can prevent stormwater pollution through the “Love NV Waters” Facebook page. 

The contest is for elementary children in grades kindergarten through sixth, with the winners featured in a 2022 calendar with the first-place poster appearing as the cover art in the calendar. The Nevada DOT will then distribute those calendars to participating schools statewide.

The poster contest wraps up on October 15 with first-, second-, and third-place winners announced on October 22, the agency added.

Editor’s note: The Center for Environmental Excellence developed a practitioner’s handbook to assist transportation agencies in developing and/or implementing a stormwater management program that satisfies the requirements of the Clean Water Act. For those agencies already with a program already in place, the handbook offers useful tips and transportation-specific references to assist program implementation.