ASSESSMENT OF ORGANIZATIONAL AND FINANCIAL NEEDS ASSOCIATED WITH STORMWATER MANAGEMENT FOR WATER QUALITY IN THE GREENWICH BAY WATERSHED IN WARWICK, RHODE ISLAND

Over the past several years there has been a growing awareness of water pollution problems in Greenwich Bay, a subembayment of Narragansett Bay which contains valuable shellfish beds. Studies have shown that water quality problems in the bay are due largely to nonpoint source pollution, which is conveyed by stormwater runoff. Nonpoint source pollution can be treated with a variety of source-control and structural techniques to manage stormwater, known as best management practices, or BMP's. Establishing storm water BMP' s to address water quality is often complicated by the fact that stormwater management has historically been a low priority for most communities, and by the high cost of some BMP' s. This study analyzes the existing stormwater management policies and activities in Warwick, identifies changes that may be made to address water quality issues in the Greenwich Bay watershed, and assesses potential organizational and financial needs that would result from those changes. The analysis was conducted using a rational approach to program analysis, outlined by Morgan (1984). Major stormwater quality problems are defined, along with a statement of goals and objectives for improving water quality. Current stormwater management activities are identified. Possible changes in the stormwater management program and their expected levels of effectiveness are described. An assessment is made of impacts that changes may have on the existing program, and suggestions are made for prioritizing activities. The study concludes with a review of potential funding sources for BMP' s and organizational structures that have been used for stormwater management programs.


Chapter One Introduction
Background and Problem Statement 1 Greenwich Bay is a shallow embayment of Narragansett Bay with a surface area of 4.3 square miles. It contains the most productive shellfishing beds in Rhode Island , numerous marinas that support recreational boating activities, and several bathing beaches. Shellfishing in Greenwich Bay and related industries have traditionally been an essential component to the economy of the City of Warwick, which surrounds the bay. The value of these industries has been estimated at $4 million per year (NBP, 1994 ).
Pollution associated with urbanization in Greenwich Bay's watershed, however, poses a threat to the health of this resource. In December, 1992, Greenwich Bay was closed to shellfishing due to levels of fecal coliform bacteria which exceeded shellfish growing water certification standards (RID EM, 1988b ). In 1994 a beach along the bay was also closed to swimming for a short period of time due to elevated fecal coliform counts. Since July, 1994, the bay has been open to shellfishing during dryweather conditions. State and local officials, environmental and marine-trade organizations, as well as members of the general public, however, have expressed concern over the future health of Greenwich Bay. Studies of pollutant loadings indicate that there are many diffuse (nonpoint) sources of pollution in the bay's watershed that are flushed into the bay during wet-weather conditions (RIDEM, 1992;FDA, 1994;City of Warwick, 1994b ).
Greenwich Bay has a relatively small watershed of approximately 26 square miles. Approximately 23 square miles (88%) of its watershed lie within the City of Warwick, Rhode Island; the remaining watershed area is located in the towns of East Greenwich and West Warwick, Rhode Island 1 • The watershed is depicted in Figure   1.1.

Nonpoint Source Pollution
The initial focus of water pollution control measures in the United States was on "point sources" of pollution. The United States Environmental Protection Agency (US EPA) has defined point sources of pollution as "any discernible, confined and discrete conveyance, . .. , from which pollutants are or may be discharged" (US EPA, 1993a). Typical point sources that have been regulated by the federal government have been sanitary sewer and industrial outfalls. However, as impacts from point sources have been mitigated, the environmental impacts of other, diffuse sources carried by storm runoff has become more apparent. Water pollution that is not issued from point sources is termed "nonpoint source pollution" (US EPA, 1993a).
Nonpoint source pollution is caused by rainfall or snowmelt moving over or through the ground, carrying natural and anthropogenic pollutants into lakes, rivers, streams, wetlands, estuaries, other coastal waters and groundwater (US EPA, 1993a).
The sources of the pollution found in runoff following rain events and snowmelt are 1 A portion of the town of North Kingstown would also be included if the Hunt River were considered part of the Greenwich Bay watershed. This study has not included the Hunt River, since its effect on water quality problems in Greenwich Bay has not been documented.  Quadrangles, 1975;M. Brusseau, Warwick Planning Dept., 1993. 6 cleaning up Greenwich Bay and has made progress in numerous initiatives (City of Warwick, 1994f).
In June 1994 residents of Warwick approved a bond referendum which allocated $5 million for projects designed to benefit the bay. These funds were allocated as follows: $2.5 million for sewer construction in the watershed, $1 million for a grant/loan program for homeowners to repair or replace failing septic systems, and $1.5 million for research, design and construction of stormwater structures (structural best management practices or BMP's) that would remove pollutants instead of flushing untreated drainage directly into the bay and its tributaries.
The funding for stormwater activities will enable the city to sponsor research of stormwater impacts in portions of the Greenwich Bay watershed (scheduled to begin in Summer 1995, augmenting current studies sponsored by RIDEM) and implement certain mitigation pilot projects. However, it will not enable the city to fully develop a comprehensive stormwater management program, a recommendation made in the Greenwich Bay Plan. The city's 1991 Comprehensive Plan also calls for the development of a "master plan for drainage system improvements". Although there are few published definitions of the term, a "stormwater master plan" generally identifies a system of improvements and regulations, which maximizes the effectiveness of each individual component (ASCE and WEF, 1992;.
The Greenwich Bay Plan's stormwater management recommendations include installing structural BMP's for stormwater storage and treatment, regular maintenance of existing storrnwater control devices, and increased frequency of street sweeping. The Comprehensive Plan also recommends that the city develop policies for protecting the quality of receiving water bodies and retrofit water quality improvement techniques into existing drainage systems.

Stormwater Management
While there is some debate about the parameters of the discipline, the American Society of Civil Engineers (1992) has defined stormwater management as "the conceptualization, planning, design, construction, and maintenance of stormwater control facilities". Some practitioners define the field more inclusively, as all governmental actions undertaken to control storm runoff and its causes . Stormwater management (or drainage) programs have traditionally focused on the disposal of stormwater and flood control, with an emphasis on structural solutions. Only recently has mitigation of environmental impacts emerged as an important issue in the field of stormwater management ASCE and WEF, 1992).
As nonpoint source contributions to the degradation of water resources have become more apparent, governmental agencies and researchers have attempted to characterize and address pollution conveyed by stormwater. In 1983 the US EPA sponsored the Nationwide Urban Runoff Program (NURP) which characterized pollutants occurring in urban runoff, based on data from runoff samples collected at various geographic locations around the country. Many other studies have since documented water quality problems resulting from pollutants conveyed by stormwater (ASCE and WEF, 1992;US EPA, 1993a). Best management practices (BMP's) employing both structural and non-structural approaches have been developed to manage stormwater quality. The use of BMP's to mitigate water quality problems has been required by various federal, state and local regulations. Regulations pertinent to stormwater management in Warwick will be discussed in Chapter Two.
For many stormwater management programs, the incorporation of water quality goals and requirements into existing programs has led to major institutional changes (Prince George's Lindsey, 1988b;. Stormwater management has historically taken a lower priority than more immediately apparent infrastructure needs, such as water service, sanitary sewers, and road construction and repair. In many communities stormwater management was only initiated after severe flooding problems occurred . Additionally, few local public agencies have been found to conduct an adequate operation and maintenance program for stormwater facilities . Where institutional analyses of stormwater functions have been conducted, it has often been found that the assignment of responsibility for various stormwater management activities is unclear (Lindsey, 1988b ). Introducing new, costly waterquality requirements into existing stormwater management programs has revealed many long-standing problems, which are usually related to inadequate resources .
would result from changes in the existing stormwater management program to address water quality problems in the Greenwich Bay watershed.
This needs assessment will generally follow a step-by step rational approach to program analysis described by . A rational approach is generally regarded as the standard or "textbook" approach to decision-making in public policy . Its advantages include: a step-by-step formula for problem-solving is more easily understood by observers than an incremental, unplanned approach ; the rational approach is widely accepted by policy-makers and the general public ; and a rational process has been observed to enlighten policy decisions with information . Use of a rational approach to decision-making should be accompanied by recognition of its inherent disadvantages: adequate information is often lacking; there is generally insufficient time and money to analyze all relevant information; and community or individual values are difficult to analyze rationally.

Methodology to assess organizational and financial needs was developed from
Morgan's approach to program analysis. It will be conducted using the following steps: 1) a clear definition of major stormwater quality problems will be made, along with a statement of goals and objectives for improving water quality, 2) current stormwater management activities will be identified, 3) possible changes in the stormwater management program and their expected levels of effectiveness will be described, 4) impacts potential program changes could have on the existing program will be assessed, and 5) setting priorities will be discussed, along with possible .
funding sources and organizational structures. These steps are explained below.

Defining the Problem, Goals, and Objectives
A clear definition of the local stormwater problem should be used as a basis for formulating attainable goals and objectives for a local stormwater management program . Defining the stormwater quality problem in the study area will involve reviewing all available water quality data, obtaining the current understanding of storm.water's role in Greenwich Bay's pollution problems, and itemizing regulations that affect stormwater quality.
Flooding problems in the Greenwich Bay watershed will also be noted so as to state the water quality problem in the context of other program needs. Necessary information will be obtained through reports of water quality testing, interviews with state and local officials, and regulatory documents. The results of this research will be reported in Chapter Two.

Assessing Cu"ent Activities
Identifying the extent of current stormwater management policies and activities will help determine what additional policies and activities would be beneficial to address water quality issues Lindsey, 1988b ). This assessment will also provide insight regarding how new initiatives could be integrated into Warwick's existing stormwater management program. Interviews with local officials and a review of the city's Comprehensive Plan, Capital Improvement Program, and other documents will be conducted. Findings of this assessment will be reported in Chapter Three.

Itemizing Possible Program Changes
Actions to mitigate nonpoint source pollution should be matched with a watershed's unique situation . Criteria will be developed to identify management practices bestsuited to solving identified problems in the study area. A list of potentiallyappropriate BMP's will be developed, based on authoritative sources of information regarding stormwater management practices for water quality. These sources will include publications by the American Public Works Association (1991), American Society of Civil Engineers and Water Environment Federation (1992), US EPA (1993a), US , RIDEM and RI CRMC (1993). The listing of BMP's will include a brief description and summary of advantages and disadvantages for each practice. This information will be presented in Chapter Four.

Assessing Impacts on Existing Program
Anticipated benefits of changes in stormwater management practices should be evaluated in the context of their financial and organizational impacts on the existing stormwater management program (Heaney, 1988;. A preliminary set of BMP's that appear to most fully meet selection criteria identified in Chapter Four will be selected from the comprehensive list described in Chapter Four. Information regarding organizational requirements and general costs of these activities will be obtained from secondary sources and interviews with state and local officials. Based on available data, assessments will be made of potential organizational and financial impacts that recommended changes could have on Warwick's stormwater management program. Results of these assessments will be presented in Chapter Five.

Identification of Priori.ties and Funding Sources
In an environment with limited resources and many needs, priorities must be set in keeping with the defined problem and community needs Heaney, 1988). Criteria will be recommended for setting priorities for the implementation of water-quality-related stormwater activities. These will be based on earlier identification of the stormwater problem, as well as recommendations for stormwater management priority-setting made by the APW A, ASCE and WEF, US EPA, and City of Warwick. Possible sources of funding for proposed changes in stormwater management practices will be researched and explained, as will organizational structures for stormwater management programs. These topics will be addressed in Chapter Six.

Chapter Two Defining the Stonnwater Quality Problem in the Study Area
The stormwater management program administered by Warwick's Department of Public Works (DPW) focuses primarily on the resolution of flooding problems and the removal of stormwater from streets and property (Sheahan, 1995). The purpose of this chapter is to describe known water quality problems in Greenwich Bay and to assess the extent to which these problems could be appropriately addressed by the existing stormwater management program of the City of Warwick.
A clear definition of the local stormwater quality problem is essential to setting attainable water quality goals and objectives for a stormwater management program . This problem will be defined by reviewing the primary pollutants known to affect Greenwich Bay and their probable relation to stormwater, stormwater management, regulations, and the goals and resources of the existing stormwater management program. This chapter will also examine the potential for community support of stormwater management for water quality. The resultant definition of the local stormwater quality problem will provide the basis for setting attainable stormwater quality goals and objectives.

Water Quality Problems in Greenwich Bay
Studies conducted by RIDEM and the FDA have identified bacterial contamination as the most significant water quality problem in Greenwich Bay (RIDEM, 1988a;FDA, 1994). Additionally, severely depressed levels of dissolved oxygen have also been recorded in Apponaug Cove. One of Greenwich Bay's five coves, it has a surface area of 0.2 square miles. The ratio of bottom organisms to sediment is low throughout Greenwich Bay, and particularly low ratios occur in Apponaug and Greenwich Coves (RID EM, 1988a;. Many diverse pollutants are carried into Greenwich Bay by stormwater runoff (RID EM, 1988a;City of Warwick, 1994b ). Since concern for the bay has been mobilized by limitations of use (City of Warwick, 1994b ), this study will focus on those pollutants most likely to be associated with the loss of uses.

Bacterial Contamination
Detection and treatment of stormwater runoff that has been contaminated by human waste prevents communication of infectious diseases, such as gastroenteritis and hepatitis-A. These diseases can be communicated through consumption of raw shellfish from polluted waters . Contamination by pathogenic organisms is often measured by counts of fecal coliform, a type of bacteria which occurs naturally in the intestinal tracts of warm-blooded animals and humans. While fecal coliforms are generally not etiological agents of disease, their presence in water samples indicates the potential for pathogenic bacteria or viruses to be detected 1 . RIDEM has classified the waters of the state, designating the use or uses which they may accommodate (RIDEM, 1988b). For each classification RIDEM has 1 A good review of the adequacy of fecal coliform counts as an indicator of viruses is found in Buzzard's Bay Project 1991. developed criteria for determining whether individual water bodies have attained water quality standards necessary to support the designated uses. Fecal coliform counts are one criterion used in making these determinations. Acceptable levels of fecal coliform in shellfishing waters are based on National Shellfish Sanitary Program (NSSP) standards. The FDA has observed that from 1984 to 1992 Greenwich Bay never stringently met NSSP standards in winter months, due to high fecal coliform counts (FDA, 1994). Current use classifications and levels of attainment for Greenwich Bay are presented in Table 2.1. Remaining Area SA Conditionally approved SA = shellfish harvesting for direct human consumption, bathing and primary contact recreation, fish and wildlife habitat. SB = shellfish harvesting for human consumption after depuration, bathing and primary contact recreation, fish and wildlife habitat. SC = boating and other secondary contact recreation, fish and wildlife habitat, industrial cooling, good aesthetic value. Source: RIDEM, 1994b.

Nutrient Problems
Low levels of dissolved oxygen in Apponaug Cove have been attributed to high levels of nutrients in runoff (RID EM, 1988a;. Apponaug Cove has failed to support SC uses, due to hypoxic (low oxygen) and anoxic (lack of oxygen) conditions, especially during the summer months when algae growth rates peak. High nutrient inputs are also a likely cause of low organism-sediment values in benthic environments throughout Greenwich Bay, and particularly in Apponaug and Greenwich Coves (RID EM, 1990; ). An additional deleterious effect of nutrients is algal growth, which is often regarded as a nuisance by the general public.
The introduction of large amounts of nutrients into a water body can lead to eutrophic conditions and decreased concentrations of dissolved oxygen. High nutrient inputs stimulate lush and rapid growth of aquatic plants, particularly algae.
An over-abundance of aquatic plants results in high respiration rates and the decay of large quantities of plant material, thus creating a high biological oxygen demand (BOD). The depletion of dissolved oxygen stresses aquatic organisms and renders the environment unsuitable for many species. Marine environments tend to be nitrogen-limited, and fresh-water environments phosphorus-limited. This means that nitrogen inputs generally stimulate lush plant growth in marine waters, and phosphorus has this effect on fresh bodies of water. Mitigating BOD and algal growth in Greenwich Bay will require reduction of nitrogen inputs. Reduced phosphorus inputs will limit plant growth in the bay's tributaries, which is expected to have a positive --though less direct --impact on the bay.

Sediment Problems
Although they are not inherently toxic, large deposits of sediments can smother bottom organisms . Sediment also transports pathogens, nutrients, and metals to receiving waters (Horsley and Witten, 1994 ). Effects of sedimentation on stormwater facilities are of particular concern to stormwater management programs. Large volumes of sediment in runoff increase the need for maintenance and contribute to structures' failure, which can result in flooding problems.

Nonpoint Source Pollution and Stormwater
As explained in Chapter One, nonpoint source pollution originates from many diffuse sources and is carried by rainfall or snowmelt. In undeveloped areas naturally-occurring pollutants are carried by runoff into stream channels and water . bodies. However, natural drainage systems are usually in equilibrium (ASCE and WEF, 1992) and allow for treatment of pollutants. As runoff moves through vegetated areas, plant cover slows the rate of flow and filters out larger solids.
Water is detained in depressions, allowing suspended solids to settle. Some runoff seeps into the soil, where processes occur which neutralize certain dissolved pollutants. Runoff is also used by plants, some of which assimilate various dissolved pollutants (Horsley and Witten, 1994).
Urbanization disrupts this natural equilibrium. Pollutant loads increase.
Impervious surfaces inhibit processes which treat pollutants, while increasing the amount and rate of runoff ASCE and WEF, 1992).

Bacterial Contamination and Stormwater
Bacterial contamination is typically found in urban runoff (US EPA, 1983;1993a;. Microorganisms are generally transported by runoff as dissolved pollutants, but they can also be carried by sediments (Horsley and Witten, 1994 ). Bacterial contaminants are known to originate from the following sources: surface ponding from septic systems that are malfunctioning or are sited in poor soils, areas with high water tables, and areas with high population density; groundwater infiltration into stormdrains from malfunctioning or improperlysited septic systems; illicit discharges of sanitary waste to natural or manmade drainage-ways; groundwater infiltration from leaking sewer pipes; and animal waste from agricultural operations, pets and wildlife.
The FDA has identified seven direct, priority sources (streams and stormdrains) of bacterial pollution to Greenwich Bay (FDA, 1994). RIDEM is sponsoring a study, which will be completed in Spring 1995, of the largest identified contributor, Hardig Brook. In the Summer of 1995, the City of Warwick will sponsor a study of pollution loadings to two other significant contributors identified by the FDA study (Baker Creek and Tuscatucket Brook). The Hardig Brook study has already identified a direct discharge of wastewater from a renovated mill building.
There is evidence that other, small point sources --such as illicit discharges or failing septic systems --can be identified and corrected .
Septic systems may contribute significantly to the bacterial problem. There are approximately 6,200 housing units in the study area, at least 5,000 of which are not sewered (City of Warwick, 1994b ). Properly-functioning septic systems generally allow for adequate treatment of pathogenic bacteria and viruses. However, where many systems are used on neighboring lots smaller than one-acre, the soil's capacity for treating pathogens may be exceeded . Other factors which may prevent adequate treatment of pathogens from septic systems include high water tables and soils which are not suitable for septic systems (SCS, 1961;. Bacterial contamination also enters receiving water bodies from direct discharge of waste from boats. This source is being addressed by RIDEM with federal funding of pump-out stations that will serve Greenwich Bay. Decreases in discharges of marine waste will benefit the bay. These discharges, however, are of greatest concern in summer months during peak recreational boating use (US EPA, 1993a). Since Greenwich Bay's most severe fecal contamination problems generally occur in winter months during wet-weather events (FDA, 1994 ), contributions from boat discharges appear to be of less significance than land-based sources.

Nutrients and Stormwater
Nutrients commonly occur in urban runoff (US EPA, 1983). They originate from natural organic material, atmospheric deposition, fertilizer application, waste from pets and wildlife, improper disposal of yard waste, and septic systems --even systems appropriately sited and properly maintained (Horsley and Witten, 1994 ).
Agricultural operations that do not implement best management practices can contribute major amounts of nutrients to runoff (US EPA, 1993a). A few farms still operate in the Greenwich Bay watershed in Warwick.
Nitrogen, the major nutrient of concern in marine waters, is generally transported by runoff in dissolved form, while phosphorus often adheres to sediments.
Dissolved nitrogen from properly-functioning conventional septic systems leaches through the soil, often partially oxidized to nitrates or nitrites. Denitrifying bacteria in waterlogged soils may convert nitrates and nitrites to gaseous form (N 2 ). This function of waterlogged soils is not a practical means of treating septic effluent, however, since systems tend to fail in poorly-drained soils (Henry and Heineke, 1989). Most often, nitrogen from septic systems is not denitrified as it enters the groundwater and eventually flows into surface waters. Phosphorus from septic systems, on the other hand, adheres to soil and usually does not present a problem for groundwater or surface water bodies that receive groundwater.

Sediment and Stormwater
Construction sites with improper soil erosion and sediment control practices contribute the most significant amounts of sediment to runoff ASCE and WEF, 1992). Also contributing to this problem are: sanding and salting of roads in winter, lawn-care and gardening practices, and agricultural practices. While the pollution problems documented in Greenwich Bay have not been directly attributed to sediment inputs, reduction in these inputs would reduce stress on stormwater management facilities, reduce maintenance costs, and may help decrease nutrient and pathogen problems.

Pollution and Stormwater Management
Stormwater structures designed for efficient removal of water from streets and property can contribute to water quality problems . This is due to accelerated rates of flow, increased volumes of water, and the bypassing of natural processes that treat pollutants in runoff.
As mentioned in Chapter One, various structural "best management practices" (BMP's) have been developed to treat stormwater quality problems. In general these BMP's take advantage of natural purifying processes, including filtration, infiltration, settling and biological assimilation. The appropriateness of structural practices depends on the pollutant(s) to be controlled and the land uses in the catchment area Horsley and Witten, 1994).
Non-structural BMP's are also used to address nonpoint source pollution.
These practices generally attempt to control pollution at its source, rather than treat pollutants after they enter the stormwater system. Where possible, source controls are preferred to structural controls  As with structural BMP's, the appropriateness of non-structural practices depends on the pollutant(s) to be controlled and the land uses in the catchment area Horsley and Witten, 1994). Site-specific information may also be required to select the most appropriate non-structural BMP's ).

Stormwater Management Regulations
The U.S. Congress and the Rhode Island Legislature have passed laws directed at mitigating impacts of nonpoint source pollution. Some of this legislation will affect Warwick's stormwater management program.

Federal Regulations
The 1987  Stormwater management will be one of the main focuses of 6217 (g) programs. The entire state of Rhode Island has been designated a coastal area, and RI CRMC is currently preparing Rhode Island's 6217 (g) program, with assistance from RIDEM.
The program will be submitted by July 1995 and is expected to focus on requiring various BMP's for new development (Boyd, 1995). State programs are scheduled to go into effect upon receipt of final federal approval. However, it is possible that the new Congress will delay implementation of these programs (Boyd, 1995 (Millar, 1994).

Implications of Regulatory Framework
There are no regulations requiring the City of Warwick to take any action to address stormwater quality for existing development. Forthcoming NPDES/RIPDES regulations for communities of less than 100,000 are expected to require municipal action, but the nature of the requirements is not known at this time. Certain projects undertaken by the city, including improvements of existing roads, are subject to RI CRMC and/ or RID EM reviews. Certain types of new, private development in certain areas of Warwick are also subject to RI CRMC and/or RIDEM reviews.
These reviews generally require proper quantitative and qualitative management of 27 stormwater quality.
The city currently requires new development to manage stormwater quantity.
There is currently no mechanism to require stormwater quality management for new development that is not subject to RI CRMC or RIDEM reviews. There is also no requirement for upgrading existing stormwater facilities --whether publicly or privately owned --to address water quality.

Stormwater Quality, Existing Resources and Goals
Clearly defining the stormwater quality problem in the Greenwich Bay watershed in Warwick should be put in context of the community's current goals and allocation of resources for stormwater management. Stormwater management in Warwick has been organized around solving water quantity problems. It appears that addressing water quality problems will require additional resources, or some reallocation of existing resources.
Recommendations for changing current practices should be tempered by evidence that the program's current funding resources may be inadequate to fully address water quantity problems. Improvements to the stormwater management system are made reactively, as flooding problems occur. At present there are a handful of unresolved flooding problems in various sections of the city, scheduled for correction this year (Villella, 1995a). While the DPW recognizes that flooding problems can often be prevented by a comprehensive system of stormwater improvements, financial resources have not been available to develop a comprehensive drainage improvement plan since the 1970s (Sheahan, 1995).
A further limitation to proactive, preventive stormwater management is a reduced capacity to maintain existing facilities, due to shortages of funding and manpower (City of Warwick, 1991;Sheahan, 1995). Chapter Three will review the allocation of resources to stormwater management.  has observed that stormwater management programs cannot successfully address a situation unless the community perceives it as a problem and supports its solution. Research has shown that the public perceives water quality problems largely in terms of use restrictions (Heaney, 1988). It is outside the scope of this study to scientifically survey community perceptions of Greenwich Bay's water quality problems, although such information would be useful in developing a comprehensive watershed protection program (Heaney, 1988;. In the absence of scientific survey information, public and political support can be estimated, by reviewing statements of public officials and public records, such as election results.

Community Perceptions of the Stormwater Problem
Prior to the closure of Greenwich Bay to shellfishing, the bay's pollution problems were not a political issue in Warwick. After the 1992 closure to shellfishing, a bond referendum designating $5 million to projects to benefit the bay was approved by 70% of the voters. Exit polls indicated that, if $3 million for asbestos removal had not been tacked onto the "bay bond", the approval margin would have been greater (Stevens, 1994). Warwick Mayor, Lincoln Chafee, has stated that the unconditional re-opening of Greenwich Bay to shellfishing is a "top priority" of his administration (City of Warwick, 1994f). Since shellfishing in Greenwich Bay has been limited by bacterial contamination, mitigation of this pollutant has strong potential for community support.
While the costly effects of sediment loading on stormwater facilities are recognized by the DPW, the public has not perceived sediment as a pollution problem (Villella, 1995a). At this time, Apponaug Cove appears to be the only portion of Greenwich Bay where there is a direct link between nutrients and failure to attain water quality standards. Unfortunately, this cove is not widely used or viewed by the public. Although it is within 500 feet of a bustling village center, the cove is not visible from the main roads, sidewalks, or other frequently-used public areas. Unaesthetic algal growth and loss of species in this cove may be noticed by the few individuals that live or work in buildings immediately adjacent to Apponaug Cove. However, these problems are unlikely to concern the general public unless there is an increased awareness of Apponaug Cove.
Although governmental action should be taken in response to public demand, defining water quality problems in terms of public perception has serious disadvantages. The public is unlikely to understand technical stormwater problems caused by sediment loadings. Ignoring sediment problems can result in excessive stormwater management costs and increased flooding problems, as well as environmental degradation. Although some residents may regard abundant algal growth as a pollution problem, the public is not likely to perceive or understand the early warning signs of hypoxia, anoxia and low organism-sediment values. Failure to address nutrient inputs at this stage may result in severe restrictions on use of the bay in the future.
Planning for the public sector often requires that a balance be struck between responsiveness to urgent problems and prevention of future problems . The implications of failure to address sediment and nutrient problems indicates that these pollutants should not be removed from stormwater quality considerations.

Statement of Stormwater Quality Problems
To define the stormwater quality problem in the Greenwich Bay watershed in Warwick, this chapter has reviewed: water quality information, the role of stormwater in transporting major pollutants, the potential for stormwater management to address these pollutants, pertinent regulations, the goals and resources of the existing stormwater management program, and the potential for community support of stormwater quality management. This review indicates that the stormwater quality problem should defined in terms of three pollutants.
Bacterial contamination of shellfish areas appears to be the primary water quality problem. However, this problem may be better addressed by source controls than stormwater management structures. Some of these practices may be appropriately implemented by the stormwater management program, and others may be more appropriately implemented by other local programs. Chapter Four will provide a thorough analysis of BMP's to mitigate bacterial contamination and the appropriate agencies to implement them.
Sediment will be considered a secondary problem, due to its impact on stormwater facilities, its capacity for transporting pathogens and nutrients, and its potential impact on the benthic environment. Nitrogen will be considered a tertiary problem. This pollutant is ranked lower than sediment primarily because the scope of dissolved oxygen and algal problems appears to be limited at present. A second reason for ranking sediment as a higher priority than nitrogen is the fact that reduction of sediment inputs reduces some maintenance requirements for stormwater management structures. Reduction of nutrients does not have a similar benefit to stormwater management programs, which indicates that there may be a greater imperative for mitigating sediment than nutrients in stormwater.
Nitrogen is not omitted from consideration, though, since it could potentially cause wider-spread restrictions on use of the bay. Although it seems likely that phosphorus loadings have negative effects on the bay, it will not be considered a priority pollutant. This choice was made partly to limit the complexity of analysis, but also because the effects of phosphorus on marine waters are less direct than those of nitrogen, and the mitigation of sediment will likely reduce phosphorus loadings. Chapter Four will provide an analysis of appropriate non-structural and structural BMP's to treat sediment and nitrogen problems, with particular emphasis on BMP's which accomplish multiple purposes.

Stormwater Quality Goals and Objectives
Once a stormwater quality problem is defined, it can provide a basis for formulating attainable water-quality goals and objectives for a local stormwater management program . Goals tend to be general statements which describe a desirable future outcome, while objectives are oriented toward translating goals into specific action .
This study will suggest goals and objectives the city may wish to adopt in order to address the above-defined stormwater-quality problem. Suggested goals to accomplish this are: Implementation of non-structural and structural best management practices designed to mitigate bacterial contamination, sediment inputs, and nitrogen inputs, for critical developed areas within the Greenwich Bay watershed.
Implementation of policies for new development which would mitigate bacterial, sediment and nitrogen inputs to stormwater, within the Greenwich Bay watershed.
Action-oriented objectives for accomplishing the identified goals are outlined below. This study will offer guidance for implementing some of these objectives, as indicated. Suggested objectives are: 1) Identification of appropriate BMP's, which offer the most effective mitigation of bacterial contamination at least costs. And, where possible, identification of BMP's which also mitigate sediment and nitrogen inputs. See Chapter Four.
2) Assessment of organizational requirements and costs associated with implementing BMP's in critical areas. See Chapter Five.
3) Identification of sources of funding needed to accomplish stormwater quality goals. See Chapter Six. 4) Identification of priority areas, with guidance from water quality studies of Hardig Brook, Baker Creek and Tuscatucket Brook. Not within scope of this study.

Conclusion
Introducing stormwater quality goals to Warwick's stormwater management program is not intended to replace the traditional focus on managing quantity, but to supplement it. Failure to manage stormwater quantity can directly threatened human life and property (City of Warwick, 1991). In the Greenwich Bay watershed, failure to manage stormwater quality can result in significant damage to the public welfare. Social impacts of poor water quality include loss of economic activity, loss of recreational uses, potential decreases in property values, and potential health hazards of swimming in a polluted bay or eating contaminated shellfish.
In summary, neither quantity nor quality goals for stormwater management in the Greenwich Bay watershed should be omitted. However, where financial resources are limited, priority should be given to problems that directly threaten human life and property.

Chapter Three Description of Current Stormwater Management Program
This chapter identifies the existing stormwater management policies and activities of the City of Warwick. The information presented here will provide the basis for developing recommendations for changes in storrnwater management to help relieve water quality problems identified in Chapter 2.
The structure of this program description is patterned after an inventory of storrnwater management activities prepared by . The following sources were also used in structuring this chapter: American Public Works Association (1991); Florida Department of Environmental Management (1993); Prince George's , Lindsey (1988b); Washington County, Oregon (no date); and .
This description will first identify the authority for stormwater management, the purpose of stormwater management, and guiding policies. Subsequently, public and private stormwater management activities will be examined according to functional category. Finally, staffing and financial resources of the public stormwater management program will be discussed.

Statement of Authority to Manage Stormwater
Like most communities in the U.S., Warwick manages stormwater both directly by installing and maintaining stormwater facilities and indirectly by setting standards for stormwater management on private property. Authority for direct and indirect stormwater management flows from different sources. Authority to construct and maintain public stormwater facilities is provided by Warwick's City Charter. It states that the Department of Public Works is responsible for "the functions and services relating to highways, engineering, street lighting, public parking lots, waste disposal, ... and such other public works activities as may be defined by ordinance"  A review of these documents --along with interviews of DPW and DOP staff --indicates that the purpose of stormwater management has been to protect public safety by controlling the quantity of runoff. The Mayor and City Council have endorsed the Greenwich Bay Plan, which calls for implementing stormwater management practices to help mitigate the effectso of nonpoint source pollution on Greenwich Bay. Officials of the DPW and DOP have also expressed interest in addressing stormwater quality issues. However, the focus of stormwater management remains on quantity. A review of city documents that describe the purposes of storm.water management in Warwick follows.

The Comprehensive Plan
The Services and Facilities component of the Comprehensive Plan provides an overview of the activities and organization of public storm.water management in Warwick. The portion of this overview that is closest to a statement of purpose for storm.water management is a listing of the DPW's criteria for setting priorities for stormwater capital improvements. These criteria are presented in Table 3.1. Except for a criterion that addresses the unaesthetic appearance of mud and debris, these criteria do not include water quality considerations. 3 a threat to property such as through flooding of yards and dwellings resulting in damage or loss of personal and real property; 4 adverse impacts on aesthetics such as severe ponding and puddling of muddy water and debris; 5 general nuisance such as slow draining systems; and/or 6 many and frequent complaints.
Source: City of Warwick, 1991. 38 The Zoning Ordinance The city's Zoning Ordinance was revised in 1994, in compliance with the 1991 Zoning Enabling Act. The purposes for which the ordinance was designed include the following statements that are relevant to the incorporation of water quality goals into the stormwater management program: to provide for the control, protection, and/or abatement of . .. water ... pollution, and soil erosion and sedimentation (Section 103.4 ).
to provide for the preservation and promotion of . .. aquaculture, ... and open space (Section 103.6).
to provide for the protection of public investment m ... stormwater management systems (Section 103.7).
Although these purposes would support inclusion of water quality standards for private stormwater management, the stormwater standards outlined by the ordinance (Section 604.5) primarily address quantity of stormwater runoff. These will be discussed later in the chapter.

Subdivision Regulations
Warwick's current Subdivision Regulations have not yet been revised to comply with the 1992Development Review Act. Among the purposes for creating the existing regulations, which were adopted in 1988, the statement "to conserve natural beauty and other natural resources" (Section 1.1) would provide a basis for establishing measures to protect stormwater quality. Like the Zoning Ordinance's storrnwater requirements, the Subdivision Regulations relating to stormwater management (Section 2.6.1) are aimed at controlling stormwater quantity problems. Specific policies will be discussed later in this chapter.
The state's 1992 Development Review Act identifies purposes for which municipalities may issue subdivision regulations. One of these purposes which would support the establishment of standards for stormwater quality is: promoting the protection of the existing natural and built environment and the mitigation of all significant negative impacts of any proposed development on the existing environment" (RIGL 45-23-30 [3]).

Sediment and Erosion Control Ordinance
One of the findings on which this ordinance is based identifies sediment as "a major water pollutant". This finding would support the establishment of stormwater quality standards for the sediment and erosion control plans that this ordinance reqwres.

Stormwater Management Policies
Components of the public stormwater system are to be designed for a minimum of a 25-year storm. DPW construction projects follow practices outlined in the Rhode Island Soil Erosion and Sedimentation Handbook (RIDEM and RI CRMC, 1993) to minimize sedimentation and erosion. Construction of roads and other public projects is to result in zero net increase of runoff. The city's Zoning Ordinance requires that new development be designed so as to result in zero net increase of runoff, based on a minimum of a 25-year storm.

Description of Stormwater Management Activities
This section is divided into two parts. First, activities associated with the public stormwater management system will be outlined. This will be followed by an overview of activities which regulate private management of stormwater. Division has observed that a geographical information system (GIS) would be of great assistance in recording locational, and other, information about the components of the stormwater system   The CIPB does not specify which stormwater projects should be undertaken, rather, each fiscal year the Director selects projects using criteria listed previously in Table 3.1. Capital improvements are generally made to correct drainage problems that have already occurred, rather than to prevent them. Where possible the DPW attempts to coordinate stormwater construction or repair projects with road construction or repair. If capital improvements to the stormwater system are combined with highway projects, priority is given to stormwater needs (Sheahan, 1995 (Sheahan, 1995;Villella, 1995a). This would better enable the department to construct capital improvement projects to prevent stormwater problems, a more cost-effective strategy than correction of existing problems (ASCE and WEF, 1992 Wetlands Act does, however, specifically allow "routine maintenance" of wetlands plants in stormwater facilities. It is important to note that when build-up of sediment and vegetative material is not removed, the hydraulic capacity of detention basins is reduced. This leads to the failure of basins to manage stormwater quantity or quality .
The routine inspection and maintenance of stormwater structures does not include natural components of the stormwater system. Until the mid-1980s the DPW had a full-time, three-man crew responsible for removal of obstructions to brooks and natural channels. Due to budget constraints and concern about RIDEM wetlands regulations, staff are no longer assigned to this task. At present this work is only performed in response to complaints.
Street Sweeping. The DPW has a policy of sweeping all city-owned streets twice a year. However, due to time and equipment constraints, sometimes they are swept only once. Sweeping usually occurs in the Spring, to remove winter sand and salt. The Highways Division operates two street sweepers, and two Highways staff members operate these vehicles.
Response to Complaints. The Engineering Division takes complaints, sends out a crew to identify the problem, and determines the best approach to solve it. Before a work order is issued, the Director must approve it. A tracking system records each complaint and the work order issued in response to the problem. These records are filed in hard-copy and on a computer database, according to city ward and address.
When a new complaint is registered, a staff member checks the database to see whether it is a recurrent problem.
Public Involvement. The DPW has occasionally conducted public surveys regarding stormwater management service (City of Warwick, 1991). The most recent survey was conducted in the 1970s. The primary way in which the public has been involved in Warwick's stormwater management program has been through registering complaints. The Engineering Division places a priority on timely and thorough responses to complaints.

Role in Private Stormwater Management
Review of New Development. A DPW review of drainage plans for new development is triggered by one of the following actions initiated by a property owner (or designee): 1. An Application for Physical Alteration (such as curb removal or installation) is filed with the DPW.

2.
An Application for Permit to Subdivide Land is filed with the Department of Building (DOB).
3. An Application for Building Permit is filed with the DOB, and the DOB requests a DPW review.

A Soil Erosion and Sediment Control
Plan is submitted to the DOB, and the DOB requests a DPW review.
Applications for physical alteration and subdivision of land automatically require a stormwater management review. Stormwater management reviews of building permit applications and soil erosion and sediment control plans are requested at the DOB's discretion. The DOB, or the Department of Planning, generally requests that the DPW conduct a stormwater management review after receiving a building permit application for a "large" project. Developments are generally considered large if they involve 20,000 to 30,000 square feet of impervious surface (DePasquale, 1995). However, no formal definition has been made for determining which building permit applications require a stormwater review. Table   3.2 provides a comparison of the administrative actions which may require stormwater management reviews.   Waivers. There is no official procedure for obtaining a waiver of SWM requirements. However, stormwater management reviews provide latitude for developers and engineers to negotiate how requirements will be met.
Plan Modifications.  have recommended that stormwater management review procedures include guidelines to be followed in the event a developer modifies plans after they have been approved. The DPW has not formally set such guidelines. However, once construction is completed, the City Engineer or Assistant City Engineer requires the developer to submit a copy of the construction plans certifying the plans are as-built in accordance with specifications approved by the Planning Board and Engineering Division.
Expiration of Permits or Approvals. Sedimentation can be reduced by setting a finite time within which construction must be completed . Permits to subdivide land expire one year after date of approval if the approved plat has not been recorded with the City Clerk, or an extension has not been granted by the Planning Board. Approval of Soil Erosion and Sedimentation Plans expires one year after approval, if approved construction has not been completed, or an extension has not been granted by the Building Official. Building permits and approval of applications for physical alteration have no provision for expiration.

Revocations and Suspensions.
The revocation or suspension of permits or approvals is a tool by which the government can stop work that is not proceeding according to approved plans   City Engineer or Assistant City Engineer is required before a bond may be released.
Design Criteria. The DPW has not specified criteria by which developer should accomplish Warwick's policy of "zero net increase in runoff' from pre-development to post-development conditions. The Engineering Division reviews each site plan and calculates whether proposed drainage provisions will accomplish zero net increase.
Where drainage plans fail to meet this standard, the Engineering Division may suggest methods for better controlling stormwater. The DPW has incorporated RIDEM stormwater management policies into the review of private stormwater management practices.
The case-by-case approach to stormwater reviews has resulted in varied levels of stringency applied to developments. The DPW and the DOP have recognized that specifying more explicit criteria for stormwater design would result in better attainment of the zero-net-increase goal. The zero-net-increase policy is partly intended to mitigate potentially harmful effects on adjoining property and to control sediment and erosion problems. The DOP is considering setting specific standards for controlling sediment and erosion in the new subdivision regulations.
The current review procedures do not specify that structures should be designed to facilitate maintenance. However, engineering staff will at times suggest design techniques that anticipate maintenance needs.
The outcome of reviews is currently a stamp of approval of construction plans.
The reviews do not require a developer to submit a plan or program for maintenance. Maintenance may be discussed during the review process, but there is no formal statement of what type of maintenance should be conducted, nor the frequency of maintenance activities.
The DPW currently requires that detention basins designed to contain two or more feet of standing water should be enclosed by a six-foot fence. If the fence is not gated, it can pose an obstacle to maintenance.

Inspections.
The City Engineer or Assistant City Engineer inspects construction sites periodically. Such inspections do not have a standardized protocol, and are generally made without prior notice. At completion of construction a final inspection is made. This provides the basis for the City Engineer or Assistant City Engineer's notice of approval to the Department of Planning. If construction does not meet with DPW approval, the developer will be requested to correct problems.
Private Maintenance. Responsibility for stormwater maintenance can be conceptualized as consisting of two components: financial and administrative . The party with financial responsibility pays for actual maintenance procedures. The party with administrative responsibility ensures that maintenance is done satisfactorily. In Warwick, the DPW has financial and 49 administrative responsibility for the publicly-owned system. It also takes over financial and administrative responsibility for detention basins in residential developments. Prior to accepting these responsibilities, the DPW ensures the facilities have been built according to approved plans.
After construction of commercial developments, both financial and administrative responsibility for stormwater management facilities are placed on the owner. There is no provision for enforcement if a developer does not uphold these responsibilities.

Allocation of Resources for Stormwater Management
Stormwater management activities that pertain to public stormwater management facilities are conducted by the Engineering and Highways Divisions within the DPW, and overseen by the DPW Director. Stormwater management activities pertaining to private development are conducted primarily by the DPW Engineering Division, with some involvement of the DOP and the DOB. A review of staffing and financial resources allocated to stormwater management will help determine where changes might be made to address water quality issues.

Staff Assignments
Brief summaries are given below of the staffing assignments for stormwater management by the DPW, DOP, and the DOB.
The Director of the DPW The Director's role in stormwater management consists primarily of: 1) approval of work orders to repair drainage problems, 2) determining which stormwater capital improvement projects should be undertaken.
Stormwater management is a small element of the Director's responsibilities.
The  To make a conservatively high estimate of the resources allocated to stormwater management, it will be assumed that stormwater management-related activities require 25% of the division's staff time. It will also be assumed that 25% of the commodities budget (after street lighting expenditures) are directed toward stormwater management. Calculations are presented on Table 3. 3.
In Fiscal Year 1994-95 the Highways Division's total operational budget was $2,899,926 2 • PersonneJ expenditures accounted for over 70% of the budget, commodities over 20%, and services about 6%.
To make a conservatively high estimate of resources allocated to stormwater management, it will be assumed that personnel resources dedicated to stormwater management account for 5% of the personnel budget. This amount translates to approximately 4.95 full-time staff members. That would be sufficient to include two full-time drainage maintenance staff, as well as approximately twelve staff members dedicating 25% of their time to such stormwater management activities as street sweeping and construction of capital improvements. To make a rough estimate of resources allocated to stormwater management, it will also be assumed that 5% of commodities and services are directed toward stormwater management activities.
The results of these calculations based on these assumptions are presented in Table   3.3.
Capital Budget. Capital improvements budget for stormwater management provides funds specifically directed for stormwater projects. The capital improvement budget for FY 1994-95 was $400,000. This has been allocated to a handful of CIPB funds are allocated to stormwater management projects according to bonds that have been approved by public referendum. A bond referendum was passed in June 1994 that allocated $500,000 to stormwater management studies for the Greenwich Bay watershed and $1,000,000 to the implementation of structural best management practices to correct water quality problems in the Greenwich Bay watershed. Allocations of CIPB funds for stormwater management projects for the next six years are listed in Table 3. 4. The availability of capital improvement funds beyond this horizon will depend upon the passage of future bond referenda. Sources: City of Warwick, 1994a; 1994c.

Necessary Equipment
Equipment required for stormwater management includes: pick-up trucks, backhoes, front-end loaders, clamshell excavators for cleaning catch basins, stormdrain rooters, and street sweepers. The DPW has sufficient equipment to support current stormwater management activities described in this chapter, including two streetsweepers. Increased frequency of street cleaning may require purchase of an additional sweeper. Increases in frequency or scope of maintenance activities may also require purchasing additional equipment.

Conclusion
This chapter has identified Warwick's stormwater management policies, activities, and the resources that support them. The following chapter will identify stormwater management practices that would help solve water quality problems known to occur in the study area. Chapter Five will then synthesize information about Warwick's stormwater management program (Chapter Three) and information about stormwater practices for water quality (Chapter Four).
The information presented in Chapter Three will provide insight into how changes to address stormwater quality could be integrated into the existing stormwater management program. It will also facilitate analysis of the relative ease with which various recommended changes could be made and demonstrate the extent to which resources are available to address water quality issues.

Chapter Four Stormwater Management Practices for Water Quality Improvement
As stated in Chapter One, the purpose of this study is to assess the organizational and financial needs that would result from the inclusion of water quality goals for the Greenwich Bay watershed in Warwick's existing stormwater management program. Assessing these needs requires an approximation of the most appropriate BMP's for the study area. The term "best management practice" (BMP) is used to describe one of any number of activities that may be used to mitigate nonpoint source pollution, as recommended by such sources as US EPA, RID EM, and RI CRMC.
The purpose of this chapter is to identify a preliminary list of BMP's that are most appropriate to address stormwater quality problems in the study area, as defined in Chapter Two. Chapter Two established that bacterial contamination is the primary stormwater quality problem in this area, and sediment and nitrogen were identified as secondary and tertiary problems. BMP's will be identified that mitigate bacterial pollution and, where possible, also address sediment and nitrogen. It is important to note that more specific study should be conducted before implementing BMP's identified in this chapter, if the City of Warwick chooses to incorporate water quality goals into the local stormwater management program.
The chapter will begin with a review of procedures for selecting BMP's, followed by an explanation of the approach that will be used to identify appropriate BMP's for the study area. The balance of the chapter will consist of an inventory of specific BMP's that address problems identified in the study area. A brief explanation of each BMP will be provided, followed by a discussion of its advantages and disadvantages.
Procedures for Selecting BMP's Stormwater management to address water quality problems is an emerging discipline. Innovations are continually being made in structural and non-structural BMP's, and strategies by which they are implemented (Schueler, 1994a). Many of these innovations result from recognition of weaknesses or gaps in program effectiveness.
Various methods for selecting BMP's have been used by different communities, with varied levels of success. Some communities have used a "piecemeal" approach, implementing individual non-structural or structural BMP's as opportunities arose. However, program evaluations suggest that designing a comprehensive system of BMP's can lead to more effective stormwater quality controls (Schueler, 1991;Schueler et al. , 1991;Florida DEP, 1993).

The Piecemeal Approach
As local water quality problems are recognized, state legislation passed, or funding becomes available, communities often implement individual non-structural or structural BMP's. A major advantage to this approach is that some progress in stormwater management is made without waiting for comprehensive watershed studies. This approach is especially useful for communities that do not have financial resources available for comprehensive studies.
A key disadvantage to the piecemeal approach is that implementing individual structural or non-structural BMP's often has little effect on stormwater management problems Schueler, 1991;US EPA, 1993c). Even if a community cannot sponsor a fully comprehensive watershed study, some effort should be made to coordinate implementation of BMP's (Buzzard's Bay Project, 1991).

Comprehensive Watershed Strategi,es
Research in stormwater management has consistently recommended a comprehensive approach to addressing water quality problems. Schueler (1991) has suggested that communities develop specific watershed-protection strategies to address problems associated with each phase of the land development process. He identifies specific practices and policies that protect water resources prior to development, during development, and after development has occurred.
Two major disadvantages associated with the comprehensive approach are the large amounts of time and money required to study the complexities of stormwater problems. Additionally, technical solutions do not always survive the political processes associated with implementation. Stormwater management plans may be shelved after they have been produced, due to lack of funds or political will to implement recommended BMP's. This was essentially the fate of Warwick's last comprehensive stormwater management plan. The majority of improvements studies. This approach is especially useful for communities that do not have financial resources available for comprehensive studies.
A key disadvantage to the piecemeal approach is that implementing individual structural or non-structural BMP's often has little effect on stormwater management problems Schueler, 1991;US EPA, 1993c). Even if a community cannot sponsor a fully comprehensive watershed study, some effort should be made to coordinate implementation of BMP's (Buzzard's Bay Project, 1991). Strategi.es Research in stormwater management has consistently recommended a comprehensive approach to addressing water quality problems. Schueler (1991) has suggested that communities develop specific watershed-protection strategies to address problems associated with each phase of land development process. He identifies specific practices and policies that protect water resources prior to development, during development, and after development has occurred.

Comprehensive Watershed
Two major disadvantages associated with the comprehensive approach are the large amounts of time and money required to study the complexities of stormwater problems. Additionally, technical solutions do not always survive the political processes associated with implementation. Stormwater management plans may be shelved after they have been produced, due to lack of funds or political will to implement recommended BMP's. This was essentially the fate of Warwick's last comprehensive stormwater management plan. The majority of improvements recommended were never implemented. However, when a comprehensive strategy for stormwater management is carefully constructed, and there is political will and funding to support its implementation, the comprehensive approach has proven superior to piecemeal BMP implementation .

Screening and Selection of Individual Practices
Whether BMP's are implemented in a piecemeal fashion or as part of a comprehensive watershed approach, it is beneficial to identify a number of BMP's which are most appropriate to a community's unique circumstances (US EPA, 1993c).
The US EPA (1993c) has recommended a two-step process for selecting BMP's appropriate to individual watersheds.
The first step is screening of BMP's. This step is intended to limit the sheer number of BMP's to be evaluated. It requires a literature search and/or consultation with experts to identify all possible BMP's. One or two preliminary criteria are developed and applied to screen out BMP's least likely to accomplish program goals.
Such a screening process is usually conducted qualitatively, based on professional judgement.
The second step is selection of BMP's. Selection criteria, more stringent than the simple screening criteria, are developed. The list of BMP's that resulted from the screening process are used to develop alternatives, which can include combinations of source-control and structural BMP's. The US EPA then recommends a variety of methods for evaluating alternatives according to selection criteria. Criteria. The US EPA recommends that communities use the following criteria to evaluate BMP's: 1) meets program goals, 2) cost, 3) operability, 4) buildability, 5) environmental effects, 6) public acceptance, and 7) institutional factors. Communities tailor these general criteria to their specific needs, and additional criteria are sometimes developed.
Evaluation Methods. A variety of quantitative and qualitative methods can be used to evaluate alternatives with multiple criteria (US EPA, 1993c;. Qualitative assessments may be based upon professional knowledge of technical or political issues relevant to the local water quality problems.
Quantitative methods often involve assignments of weight to various criteria and systems for scoring alternatives' levels of attainment for each criterion.

Approach for Identifying Appropriate BMP's
The approach for identifying BMP's appropriate for the study area will generally follow the steps recommended by the US EPA (1993c). This chapter will present the results of a BMP screening. Chapter Five will present results of the selection process.
BMP's have been screened based on the results of a literature search. Those listed in this chapter were determined to be 1) effective in mitigating the primary pollutant of concern, bacterial contamination, and 2) appropriate for the Department of Public Works to implement.
Many activities that are sometimes identified as stormwater management practices have not previously been conducted by Warwick's stormwater management program. Some of these practices are the responsibility of the Department of Planning, including subdivision review and site plan review. Other activities are primarily the responsibility of Department of Building, such as construction inspection and enforcement activities. Still others have not been the responsibility of any city agency. These include stormwater quality monitoring and public outreach.
The activities likely to be incorporated into the existing stormwater management program have been culled out from the others. It was assumed that activities appropriate to the DPW's stormwater management program include: 1) planning, design, construction, and maintenance of publicly-owned structural best management practices; 2) reviewing stormwater management plans for private development; and 3) some public outreach activities.

Organization of BMP Listing
BMP's will be listed m four categories, loosely based on phases of the development process identified by Schueler. This organization will facilitate the selection of BMP's that address the problems associated with various phases of development. The categories are described below.

Stormwater Planning Activities.
Planning activities for the study area will also be identified. This includes developed and undeveloped land. Reviews. Opportunities to guide the design of private developments to prevent stormwater problems will be identified. The items listed will be limited to those appropriate for the DPW to implement.

Resource
Maintenance and/or Restoration. BMP's appropriate for developed watersheds will be identified. This includes both source controls and structural BMP's.

Structural BMP's for New Development.
Structural BMP's appropriate for private and public stormwater management systems will be identified. These BMP's may be used in new development, or introduced into areas already developed.

Explaining Advantages and Disadvantages
To facilitate the selection of BMP's in Chapter Five, advantages and disadvantages of each BMP will be presented in terms of selection criteria. Although communities sometimes use additional criteria, the seven criteria recommended by the US EPA, and noted above, should prove sufficient for the limited purposes of this review. An explanation of how these criteria will be used follows.

1) Meets program goals.
For the purposes of this study, BMP's will be evaluated according to whether they meet goals of mitigating pollutants of concern (bacterial contamination, sediment, and nutrients).

2)
Cost. Low-cost alternatives are preferred to high-cost. Approximations of cost will be made. Assumptions and qualifications will be explained.

3)
Operability. Primarily concerning structural BMP's, this criterion is satisfied by low levels of difficulty in implementation and operation, including maintenance.

4) Buildability.
This criterion concerns structural BMP's. It is satisfied by low levels of construction constraints, such as site requirements and degree of difficulty.

5) Environmental Effects.
This criterion is primarily a concern for structural BMP's. It is satisfied where positive effects BMP's may have on the surrounding environment outweigh the negative.
6) Public Acceptance. This criterion is satisfied by apparent public support of a proposed BMP.

7) Institutional Factors.
This criterion is met where authority to conduct activities is clear, and/or institutional commitment to a BMP is apparent.
Where operability, buildability and/ or environmental effects are not applicable to non-structural BMP's they will be omitted. For each criterion of each BMP discussed, a brief qualitative assessment will be provided, based upon known problems in the study area and findings of stormwater management research. Each assessment will conclude with an estimation of whether the BMP satisfies the criterion, levels of satisfaction will include: full, adequate, marginal, or does not satisfy. These assessments will be used to make qualitative evaluations and a hypothetical selection of BMP's in Chapter Five.

Stormwater Planning Activities
It is generally cheaper and easier to prevent problems prior to development rather than correct them post-development. Stormwater management programs generally emphasize the need to implement non-structural BMP's that will guide the development of undisturbed areas, and serve to prevent water quality problems.
However, since 69% of land in the study area is already developed (see Appendix 2), this category includes activities which involve planning for both developed and undeveloped areas. Activities will be listed in the order in which they are normally conducted.
The term "stormwater management master plan" has been used in various ways to describe various activities to prepare for future stormwater management infrastructure needs (ASCE and WEF, 1992). For the purposes of this study, a stormwater master plan will be assumed to include: inventories of the natural and man-made drainage systems, site-specific plans for improvements to the public stormwater management system, and a schedule and budget for improvements.
Meets Program Goals. The development of a stormwater management master plan has been recommended as effective in enhancing water quality, reducing flooding problems, and making use of financial resources more effectively than a piecemeal approach to stormwater management improvements ASCE and WEF, 1992;FL DEP, 1993 However, funding sources for the cost of the plan, and ensuing improvements, must be identified. Level of satisfaction: adequate.

Capital Improvement Program and Budget (CIPB)
The DPW may consider including water quality enhancement of Greenwich Bay (or other valuable water resource) among the criteria for selecting stormwater capital improvement projects.

Meets Program Goals. This action would meet program goals insofar as
projects include structural BMP's which effectively mitigate pollutants of concern in the study area. Level of satisfaction: full.

Cost.
A very low-cost activity, since the CIPB project-selection process is already established. Level of satisfaction: full. level of satisfaction appears to be marginal.

Geographical Information System (GIS)
The DPW Engineering Division has identified potential uses for a GIS, in recording site-specific information about stormwater management infrastructure. The Department of Planning has received a grant of $8,000 to prepare specifications for a Greenwich Bay GIS. Experiences of other communities that use GIS's for stormwater management applications would be helpful in identifying specific stormwater applications for a GIS. References regarding stormwater applications listed in the bibliography include: .
Meets Program Goals. GIS applications have been recognized as highly effective in analyzing stormwater runoff problems  and managing infrastructure . Level of satisfaction: full.

Cost.
Purchasing and operating a GIS requires a sizeable investment of money and staff time. Costs associated with GIS applications far exceed the purchase price of hardware and software. Additional expenses include: feasibility studies prior to purchase, hiring of staff, training of existing staff, data collection, data structuring, attributing of information and input, and many other activities . Costs of maintaining the system once it is established should not be overlooked in assessing the feasibility of implementing a GIS . Level of criterion satisfaction: marginal.
Operability. Staff thoroughly trained in use of GIS technology is essential, and start-up time may be lengthy. Level of satisfaction: marginal.
Public Acceptance. The Cooperative Extension of URI has found GIS to be a valuable tool in preparing public-outreach materials (Joubert, 1995  . The criterion's satisfaction level for implementation by the DPW: not satisfied.

Pre-development and Construction Activities
This category of BMP's is directed largely at preventing urban runoff problems before land is developed. Although most of this watershed is already developed, land development restrictions can still prevent significant problems on the remaining developable land --and on any land that may be redeveloped. The items in t. his category will be listed in the order in which they normally occur during the development process. Where activities may occur simultaneously, they will be listed in alphabetical order.

Design Criteria
A comprehensive and unambiguous set of design criteria are essential to meeting water quality goals of stormwater management reviews  Meets Program Goals. Setting design criteria that address the pnmary pollutants of concern in the study area is the best way to prevent runoff pollution from new development Schueler, 1991). Level of satisfaction: full.
Cost. This is a relatively low-cost activity. The Subdivision Regulations must be re-written to comply with the 1992 state Land Development Act, and the writing of specifications for the new overlay zone has already been planned. Incorporating more specific stormwater design standards into these documents will not require a significant amount of extra staff time. Stormwater reviews are already included in the subdivision permitting process. More specific design standards should not greatly affect the amount of staff time required per subdivision. Level of satisfaction: full.
Operability. Some training may be required to better acquaint engineering staff with water quality considerations for stormwater reviews. Criterion is fully satisfied.
Public Acceptance. Developers may be opposed to increased regulations.
However, they may also welcome more specific design criteria that make the review process predictable. Level of satisfaction: marginal. additions or changes to buildings or structures, or change of use which require the addition or deletion of twenty-five or more parking spaces, or 2) parking areas for twenty-five or more motor vehicles (City of East Providence, 1993). RI CRMC has a policy or reviewing developments that include one acre of parking (RI CRMC, 1990). Goals. Working with developers in the site-planning process is an important opportunity to mitigate harmful effects of numerous nonpoint source pollutants, including the pollutants of concern (RIDEM and RI CRMC, 1993;Schueler, 1991

Construction Inspections
Inspections have been recommended to occur at critical stages in the construction of structural BMP's, such as setting spillway crest elevations in construction of detention basins, and any construction that will be covered when construction is complete . Some jurisdictions require developers to notify the local inspector 24 hours in advance of such construction phases.
Meets Program Goals. This activity would advance program goals by ensuring proper construction of structural BMP's. Improperly construction can lead to failure of BMP's to mitigate pollutants of concern. Level of criterion satisfaction: full.
Cost. Costs would entail the time required by the city engineer, assistant city engineer, building official, or other staff member to inspect construction sites.
Although inspections are already made, their frequency may be increased.

Experience of the Stormwater Management Administration of the Maryland
Department of Environment has demonstrated that inspectors, on average, inspect three construction projects per day for stormwater management and sediment control  of other communities has demonstrated that technical expertise in the functions of stormwater facilities is essential to effective inspection programs . As the number of structural BMP's increases, staff requirements increase . Level of satisfaction: adequate.

Resource Maintenance and/ or Restoration
This section will inventory BMP's appropriate for areas that have already been developed. This will include activities suggested for maintenance of stormwater facilities and practices intended to remedy water quality problems. It has generally been acknowledged that preventing nonpoint source pollution is easier and less costly than correcting existing problems (US EPA, 1993a; RIDEM and RI CRMC, 1993;FL DEP, 1993). However, since a large proportion of the study area is already developed, it is essential to identify opportunities to correct problems in developed areas. Use of both structural and non-structural BMP's will be considered.
Maintenance activities will be listed first, followed by restoration BMP's. Within each category items are in alphabetical order.

Maintenance Inspections
As discussed in explanations of structural BMP's, proper maintenance is necessary to ensure that stormwater facilities achieve pollutant removal targets. Lack of maintenance is also the most common cause of their flooding .
It has been observed that maintenance is frequently inadequate where private parties have both administrative and financial responsibility for maintenance of stormwater facilities (FL DEP, 1993; . Thus, regular inspections should be conducted to ensure maintenance of private facility is properly performed.

Meets Program Goals.
Maintenance inspections of private stormwater management facilities is an essential component of stormwater management for water quality. This practice helps ensure that non-public structural BMP's meet their pollutant-removal targets. Level of criterion satisfaction: full.

Cost.
It has been the experience of the Maryland Department of Environment's Stormwater Administration that one inspector can inspect approximately three sites in one day   , and Prince George's County .
Training of staff would also be necessary. Level of satisfaction: adequate.

Public BMP Maintenance
As noted in Chapter Three, the DPW has both administrative and financial responsibility for maintaining public stormwater management facilities. Chapter Three outlined the existing maintenance program, which does not include certain activities that help mitigate water quality problems. Increased frequency of certain maintenance activities could also enhance water quality. As structural BMP's are incorporated into the public stormwater management system, these will also require maintenance, as described in previous descriptions of structural BMP's. Goals. It has been demonstrated that pollution mitigation capabilities are reduced substantially where proper maintenance does not occur Schueler, Kumble, and Heraty, 1992

Stormwater Quality Monitoring
Evaluating the effectiveness of structural BMP's by monitoring water quality has been identified as a "critical component of a nonpoint source control program"

Cross-connection Identification and Removal
It has been recognized for many years that dry-weather flows in stormdrains 83 may result from illicit discharges of residential, commercial, or industrial wastewater into the stormwater system (US EPA, 1983). Recent surveys have found such discharges to contribute significantly to stormwater pollution problems ; US EPA, 1993b). The US EPA has published a user's guide which outlines procedures for identifying and correcting these problems (US EPA, 1993b ).
These procedures generally require extensive mapping, field surveys, and water quality sampling.
Current research, sponsored by RIDEM, has identified at least one direct discharge of wastewater into a tributary of Greenwich Bay . In the Summer of 1995, the City of Warwick will sponsor a study of pollution loadings to two other tributaries. Although this study is not a comprehensive search for cross connections, it will provide an opportunity to detect them in priority areas.
Meets Program Goals. The US EPA (1993b) has identified sanitary wastewater sources as among the most common sources of illicit discharges. Sanitary wastewater contributes large amounts of fecal coliform and nitrogen. A study in Washtenaw County, Michigan revealed, however, that chemical flows were much more significant than sanitary waste in that jurisdiction  Cost. These surveys generally require a major commitment of staff time . Laboratory analysis of water samples is also required.

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Criterion is not satisfied.

Structural BMP's: New Construction
Non-structural BMP's are generally preferred to structural BMP's due to cost.
In developed areas implementation of structural BMP's is rendered especially difficult and costly by the lack of available space. Because of these considerations, many stormwater management programs focus on constructing structural BMP's in developing areas. However, the amount of urbanized land in the area indicates a need for mitigation measures in existing development.

Meets Program Goals.
Installing BMP's that have proven effective in reducing pollutants of concern would help advance program goals. This would be especially worthwhile in locations where nonpoint source problems have been pronounced.
Level of criterion satisfaction: full.  (Schueler, 1994b, NVSWCD, 1994. Level of satisfaction: marginal. Public Acceptance. The positive public response to the 1994 "Bay Bond" referendum indicates level of criterion satisfaction is adequate. (City of Warwick, 1991) and Greenwich Bay Plan (City of Warwick, 1994b) have recommended retrofitting BMP's into the existing stormwater system. $1 million is available for new construction or retrofits from 1995 to 1998 (City of Warwick, 1994a). Level of satisfaction: full.

BMP's Eliminated by Screening
A number of BMP's recommended for maintenance or restoration of water quality in developed areas have proven effective for addressing pollutants of concern, but seem inappropriate for the DPW's stormwater management program to conduct.
These include: enforcing repair of failing on-site disposal systems; promoting reduced use of fertilizer, pesticides, and herbicides; animal waste reduction; and wetland restoration projects. These activities may be more properly conducted by the Departments of Building, Planning, or Parks and Recreation. Information about these BMP's is available in US EPA, 1993a.

Structural Best Management Practices
The structural BMP's listed in this section have proven effective in mitigating the pollutants of concern. Reviewing the advantages and disadvantages of these BMP's will assist the DPW in 1) recommending which BMP's should be used for private development in the study area, and 2) selecting which BMP's should be used for public projects in the study area. The descriptions provided below are brief and generally non-technical. A number of good BMP reference materials are listed in the bibliography. These include: RIDEM and RI CRMC, 1993;Schueler, Kumble, and Heraty, 1992;; and US EPA, 1993a.
Structural BMP's will be listed according to effectiveness in mitigating bacterial contamination: from most effective to least effective. Where relative effectiveness is equal or unknown, BMP's will be ordered according to effectiveness in sediment and nitrogen mitigation. Where these are equal or unknown, items will be listed alphabetically.

Wet Ponds
Wet ponds are basins designed to maintain a permanent pool of water and 88 temporarily store urban runoff until it is released at a controlled rate . This basic structure may be enhanced by a fore bay to trap incoming sediment where it may be easily removed, or by a fringe wetland. An enhanced wet pond differs from a constructed wetland in that an enhanced wet pond has less emergent vegetation and more standing water .

Meets Program Goals.
Studies have shown that wet ponds consistently achieve moderate to high levels of removal for both particulate soluble pollutants, including the three principal pollutants of concern for the study area ; US EPA, 1993a). Level of criterion satisfaction: full.
Cost. These structures have a relatively high cost of construction. They are more costly than dry basins, although dry basins are generally less effective in pollutant removal. Per-unit construction costs decline as size increases  has estimated that a wet pond with a volume of 100,000 cubic feet is capable of treating a drainage area of 50 acres. In this same study, construction of a 100,000 cubic-foot wet pond was estimated to cost $50,000. Recent experience in constructing wet ponds in Rhode Island has indicated that construction of a wet pond capable of treating a 50-acre drainage area is more likely to cost $80,000 (Spinnard, 1995).
Maintenance costs of wet ponds range from $0.008 to $0.07 per cubic foot per year (US EPA, 1993a). The mean of these two amounts is $0.039. Assuming a per-cubicfoot annual maintenance cost of $0.039, the annual cost to maintain a wet pond of 100,000 cubic feet would be $3,900. Level of satisfaction: marginal.
Operability. Moderate operability, if drainage area is greater than ten acres.
Where drainage area is less than ten acres, standing water is depleted in dry months.
Routine maintenance includes: annual inspections, mowing at least twice a year to remove woody growth. Trash and debris should also be removed regularly from the forebay

Constructed Stormwater Wetlands
Constructed stormwater wetlands are intended to simulate some functions of natural wetlands, particularly the water purification function . They do not replicate all ecological functions of natural wetlands. They are similar to wet ponds, but there is more emphasis on vegetation, and a lower depth-to-area ratio.

Meets Program Goals. Studies have shown that constructed stormwater
wetlands consistently achieve moderate to high levels of removal for both particulate soluble pollutants, including the three principal pollutants of concern for the study area US EPA, 1993a  . Level of criterion satisfaction: full.

Cost.
Little information is available regarding costs associated with constructed stormwater wetlands (US EPA, 1993a; . However, it may be assumed that they are more costly to construct and maintain than wet ponds, since vegetation and area requirements exceed those of wet ponds.  bas reported an estimated construction cost range of $5,712 to $80,769 per acre. Maintenance costs have been estimated at $300 to 500 per acre in the drainage area  Heraty and Kumble (1992) have reported they require from a total surface area ranging from 1.5% to 5% of the drainage area . Maryland has required that constructed stormwater wetlands comprise a minimum of 3% of the contributing drainage area

Extended Detention (ED) Dry Ponds
ED ponds are designed to temporarily detain a portion of urban runoff.
Detention time is generally 6 to 24 hours after a storm. This allows solids and associated pollutants to settle out  pollutants of concern for the study area ; US EPA, 1993a).  has observed that design problems have caused ED ponds to be less effective in pollutant removal than wet ponds or constructed wetlands. Level of satisfaction: full. Cost. Costs are lower than those of wet ponds. The US EPA (1993a) has provided the same range of construction costs for both ED and wet ponds. Randall and Krome (1987, cited by  have estimated that construction cost for ED ponds are from 7 to 11 % higher than for dry ponds and from 16 to 57% lower than for wet ponds. Estimates of construction costs are provided in Table 4. 1. Griffin (1993) has estimated that the average annual maintenance costs for a 100,000 cubic-foot ED dry pond would be $2,000. Level of criterion satisfaction: adequate.  Operability. ED dry basins should be mown, and litter and debris removed, at least twice a year. Schueler, Heraty, and Kumble report that annual inspections should occur to unclog the control device . Regrading and revegetation may be necessary. Sediment should be removed every five to ten years.
Level of satisfaction: adequate.
Buildability. Space requirements are high. Schueler reports that ED dry ponds normally require 5% of total site area . The Washington Department of Ecology reports that steep slopes and proximity to buildings generally do not restrict site selection

Infiltration Basins and Trenches
These devices allow water to percolate through soils, where filtration and biological reactions remove pollutants. An infiltration basin is an impoundment where incoming stormwater runoff is stored until it gradually exfiltrates through the soil of the basin floor. An infiltration trench is a shallow, excavated trench that is backfilled with stone to create an underground reservoir.

Meets Program Goals. When working properly, infiltration basins have
achieved removal rates of 60% for bacteria, 45 to 100% for sediment, and 45 to 100% for nitrogen USA EPA, 1993a). However, these BMP's have a high rate of failure  Operability. Infiltration BMP's in general have been recognized as "extremely fragile systems" with high rates of failure . Failures are often partially due to improper site selection, installation, or maintenance US EPA, 1993a). Prince George's County, Maryland no longer permits the use of the present generation of infiltration basin systems . Problems with infiltration trench failures can be overcome with pre-treatment systems, such as sand filters or sump pits (Schueler, Kumble, and Heraty, 1992

Sand and Peat Filters
There are numerous variations of sand and peat filters. They generally consist of a sediment chamber, into which the first flush is diverted. This allows coarse sediments to settle and velocity to be reduced before runoff spreads over a bed of sand or peat. The runoff filters through the medium, which traps or filters out pollutants. It is then collected by an underground pipe network, and released to a receiving water body. Underground-vault sand filter systems have been used in the Washington, DC area. This allows the sand filter to be placed under streets or parking areas.

Meets Program Goals. Pollutant removal rates of sand filters have been
documented at 20 to 70% for fecal coliform, 75 to 85% for sediments, and 30 to 70% for nitrogen (Schueler, 1994b;. Pollutant removal rates have been improved by combining a filter with an extended detention pond (Schueler,97 1994b ). Level of criterion satisfaction: adequate.
Operability. Regular maintenance is essential to prevent clogging. Routine maintenance requirements include: surface sediment removal, raking, and removal of trash, debris, and leaf litter. The surface sand layer should also be replaced with relative frequency   (Schueler, 1994b ). Level of satisfaction: full.

Environmental Effects.
Little is known about the environmental effects of these BMP's (Schueler, 1994b   Operability. Water-quality inlets and oil-grit separators have high failure rates . Grassed swales should be mown two to three times per year . Sediment should be removed periodically from each of these BMP's. Overall, the operability criterion for BMP systems is adequately satisfied.
Buildability. Water-quality inlets and oil-grit separators do not require surface land area, but they do require relatively permeable soils and low water tables.
Grassed swales require small amounts of space, and space requirements of vegetated buffer strips vary. Soil capabilities and depths to ground water generally do not limit use of swales and vegetated filter strips. Overall, satisfaction level for this criterion is adequate.
Other Factors. Since these practices will most likely be used to support BMP's discussed earlier, environmental effects, public acceptance, and institutional factors will not be addressed separately. These factors are not rated.

Conclusion
Following a discussion of BMP-selection strategies, this chapter identified BMP's that met two screening criteria: 1) effectiveness in mitigating pollutants of concern, and 2) appropriateness of implementation by the Warwick DPW. The BMP's that met the screening criteria have been organized according to the stage of the development process in which they are normally implemented. Advantages and disadvantages of each BMP were identified within the context of seven selection criteria: 1) meets program goals, 2) cost, 3) operability, 4) buildability, 5) environmental effects, 6) public acceptance, and 7) institutional factors. The following chapter will use this information to assess potential organizational and financial needs that would result from the implementation of proposed BMP's.

Chapter Five Assessment of Potential Organizational and Financial Needs
As stated in Chapter Four, it is not within the scope of this study to conclusively identify the most appropriate BMP's for the study area. Rather, this chapter will outline a preliminary set of BMP's for the study area, which was developed using the selection criteria described in Chapter Four . . This will provide the basis for assessing the organizational and financial needs likely to arise if the City of Warwick incorporates water quality goals into the stormwater management program.
This chapter is organized into three parts. First, the approach used in ranking and selecting BMP's will be explained. In the second part, the selected BMP's will be listed and evaluated. The list is divided into four categories: watershed planning, pre-development design and construction, post-developmentmaintenance / restoration, and structural BMP's. The first three categories are based on phases of the development process. The use of structural BMP's is considered in each of the three phases of the development process. The fourth category compares structural BMP's. This comparison will be used to set parameters for activities selected for the three phases.
Within each of the four categories, an explanation of the selection process will be given. For each selected BMP, assumed parameters will be explained.
Assessments of organizational and/ or financial needs will be based on the assumed parameters. In general, cost estimates for each item will be based on the assumption 102 that the item is implemented in 1995. To the greatest extent possible, estimates will be made of approximate cost for the first full calendar year of implementation (1996) and for the fifth full calendar year of implementation (2000). Estimates of future costs will not be adjusted for inflation.
The third and final part of this chapter will assess the organizational and financial impacts of the selected alternatives. An inventory of organizational needs will be made. This will be followed by a rough estimate of the total cost of implementing all selected BMP's.

Selection of Alternatives
It is assumed that at least one alternative should be selected for each of the three phases of development identified above, in order to avoid leaving gaps in the overall effectiveness of pollution mitigation. For each of the four categories of BMP's, a matrix was created to compare the ratings assigned in Chapter Four. Each BMP received a rating for its level of satisfaction of selection criteria. Levels of satisfaction were rated as: full, adequate, marginal, or does not satisfy.
Although the satisfaction ratings serve as guide, selection of BMP's was based on qualitative evaluation of these attributes, as they were described in Chapter Four.
In general, alternatives that predominantly provide full satisfaction of criteria were selected, and those with more than one "does not satisfy" rating were not selected.
Greatest weight was placed on the criterion of meeting program goals. Cost and institutional considerations were, respectively, the second and third most important criteria. Knowledgeable professionals in stormwater management, planning, and watershed protection were consulted to confirm the appropriateness of these selections.
The option of using a quantitative analysis to evaluate BMP's was considered.
However, numerical ratings of satisfaction levels did not seem to increase the accuracy of the analysis. Rather, it seemed to mask the uncertainty and subjectivity of this analysis with false appearance of accuracy. Since this is a preliminary list of BMP's for planning purposes, a qualitative evaluation provides sufficient analytical rigor.

Stormwater Planning Activities
Using information presented in Chapter Four, attributes of four stormwater planning activities were compared, as presented in Table 5.1. Based on a review of these BMP's, two were selected for implementation: the stormwater master plan and the capital improvement program and budget.

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Alternatives Not Selected Regional / inter-jurisdictional stormwater management and the implementation of a geographical information system were not selected. Nonselection of inter-jurisdictional cooperation was based primarily on uncertainty of neighboring communities' commitment to addressing nonpoint source pollution problems in Greenwich Bay. Inter-jurisdictional cooperation does, however, show promise for cost-saving and improving effectiveness of watershed protection activities.
It is suggested that Warwick attempt to involve the other watershed communities in specific activities the city wishes to undertake.
Despite its strength in advancing program goals, the GIS alternative was not selected because it appears that the Department of Planning is leading that initiative.
As the DOP's research of GIS options progresses, the DPW would be well advised to identify ways in which city departments may share this technology.

Pre-development and Construction Activities
Information presented in Chapter Four was used to compare attributes of four pre-development and construction activities. This comparison is presented in Table   5.2. Three alternatives were selected for implementation: design criteria, building permit reviews, and construction inspections.

Design Criteria
Reasons for Selection. This alternative was selected because of its strength in  Organizational Needs. The Department of Planning will need to write Section 312 for amendment of the Zoning Ordinance, and the amendment must be ratified by the City Council. If the ordinance is not amended, legal advice should be obtained as to whether the DPW Director should require or recommend BMP's in environmentally-sensitive areas. Training may be required to better acquaint engineering staff with water quality considerations for stormwater reviews.
Financial Needs. The DPW already reviews all subdivision plans, and some site plans for building permit applications. Incorporating new stormwater design standards into these reviews should not require a significant amount of extra staff time. It may be possible to arrange for training in the use of the state stormwater design standards at low cost or no cost, from NRCS, RIDEM, or RI CRMC.

Building Permit Review
Reasons for Selection. This alternative was selected because of its clear advancement of program goals, its low cost, and its relative ease of implementation.
Assumed Parameters. It is assumed that the building official, in consultation with the DPW and DOP, would identify specific attributes of developments for which stormwater plans should be reviewed. For the purposes of this study, it is assumed the following attributes will trigger a stormwater review: commercial or multi-unit residential developments with one acre or more of parking facilities, roadways, or impervious surfaces.
Based on personnel cost and time estimates made in Chapter Four, it will be assumed that each review requires one hour, at a cost of $18. Cost estimates will be made for 1996, hypothetically the first full calendar year the new policy would be in effect. It is assumed that the approximate number of building permit applications in 1996 will be similar to the last few years.
The number of stormwater reviews expected to result from this formalized standard can be determined by obtaining estimates of: 1) the annual number of building permit applications that currently receive stormwater reviews, and 2) the annual number of building permit applications that meet proposed, formalized criteria. According to DPW staff, the number of building applications that have received stormwater reviews over the past several years has ranged from 5 to 12 per year. According to DOP staff, about 5% of building permit applications have met the proposed criteria over the past several years. Numbers of building permits issued for new construction per year were reviewed for 1991 through 1994. Calculating 5% of the totals for these years resulted in a range of 5 to 9. It seems most likely that the formalization of review criteria would result in an increase of no less than 0 and no more than 4 reviews annually.
Organizational Needs. The Building Official may wish to consult with the Directors of the DOP and DPW (or designees) to identify review thresholds.
Financial Needs. There would be no additional cost if the formalization of criteria results in zero additional reviews. If it results in four, this would be at a cost of $72 per year. If it is assumed that this alternative results in an average of two additional reviews per year, the cost each year is $36.

Construction Inspections
Reasons for Selection. This activity was selected because of its strength in advancing program goals, and the relative ease with which it could be implemented. Cost estimates will be made for 1996, hypothetically the first full year the new policy is in effect. It is assumed that the approximate number of subdivision applications approved in 1996 will be similar to the last few years.
Organizational Needs. Protocols for inspections at critical stages would need to be developed. Arrangements with developers would need to be made so that the DPW would be notified in advance of construction activities that require inspections. Cost estimates will be made for 1996, hypothetically the first full year the new policy is in effect. It is assumed that the approximate number of subdivision applications approved in 1996 will be similar to the last few years.
Organizational Needs. Protocols for inspections at critical stages would need to be developed. Arrangements with developers would need to be made so that the DPW would be notified in advance of construction activities that require inspections.

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Training of staff may be necessary to ensure inspections are conducted appropriately.

Alternative Not Selected
The development plan review alternative was not selected. This is due primarily to the fact that this alternative would have the greatest impact on the Department of Planning. Thus, it is outside the scope of this study which is examining potential impacts on the existing stormwater management program, which is a responsibility of the DPW.

Resource Maintenance and/ or Restoration
Information presented in Chapter Four was used to compare attributes of seven maintenance and/or restoration activities for developed areas. This comparison is presented in Table 5.3. Four alternatives were selected for implementation: maintenance inspections, increased maintenance activities for the public stormwater system, construction of new structural BMP's, and retrofitting of existing stormwater management facilities with BMP structure. Maintenance

Maintenance Inspections
Reasons for Selection. This BMP was selected primarily because strong emphasis bas been placed on the need to ensure maintenance of private facilities by numerous practitioners and researchers in stormwater management. Inspecting private facilities is significantly less costly than assuming financial responsibility for them .

Additional Public SJVM" Maintenance
Reasons for Selection. This action was selected due to the clear connection between proper maintenance and meeting pollution-reduction goals.
Assumed Parameters. Chapter Three established that the existing maintenance program does not include certain activities that help mitigate water quality problems.
It is assumed that the DPW would add the following items: vegetation control in and around detention basins, and removal of sedimentation from detention basins. It is also assumed that frequency of three activities will be increased: underground cleaning of detention basins, clearing of vegetation from natural channels, and cleaning and removal of sedimentation from natural channels. At present these three activities are not performed routinely.
As structural BMP's are incorporated into the public stormwater management system, and BMP's in residential developments are dedicated to the city, the need for maintenance will increase. Additional costs that result from public construction of new BMP's and BMP retrofits of existing stormwater facilities will be estimated m the "Constructing New BMP's" and "Retrofitting Stormwater Management Facilities" sub-sections.
Organizational Needs. Routines and schedules would have to be developed.
Staffing requirements will increase as the number of structures to maintain increases.
Raising public awareness of maintenance needs of stormwater management facilities may prevent objections to the cost of maintenance.
Financial Needs. Per-unit person hours and costs of equipment/ materials are based on estimates made by  and Washington County, Oregon (no date). Where sources disagree regarding hours or cost, the lower number was used.
Based on knowledge of the study area, it was estimated that the city is currently responsible for 10 detention basins and 10,000 linear feet of open channels. It is assumed that the amount of open channels will remain constant, and that the city will accept two additional residential detention basins for maintenance each year. This would result in a total of 12 detention basins requiring public maintenance in 1996 and a total of 20 in the year 2000.
Estimates of potential costs of additional maintenance activities in 1996 are presented in Table 5.4. Using the same assumptions for person-hours and costs of equipment/ materials assumptions, it is estimated that the cost of these public maintenance activities will be $22,484 in 2000. This does not include the increased costs of activities the city already performs. Sources: ; Washington County, Oregon, no date.

Constructing New Structural BMP's
Reasons for Selection. This action was selected due to the amount of urbanized land in the area. Requiring structural BMP's in new development will not substantially reduce existing pollution problems.
Assumed Parameters. Without extensive studies of site-specific problems, it is difficult to make any meaningful estimates of how many new structural BMP's might be warranted in the study area. For the sake of establishing a gross estimate of potential needs, it will be assumed that structural BMP's effective in treating the pollutants of concern will be the highly developed portion of the study area. For the purposes of this study, "highly developed areas" will include the land uses listed in Table 5.5. It was not technically feasible to fully separate community land use data.
The total amount of highly-developed land in the study area is approximately 5,330 acres. It should be recognized that this is not an accurate inventory of highlydeveloped land in the study area. There are two major sources of inaccuracy. First, some East Greenwich data is included, which tends to cause reported amount of area to be greater than actual amount. Secondly, development has occurred in this area since the land use data was collected seven years ago. This tends to cause the reported amount of area to be less than the actual amount. However, this is the best data set available for the study area. Therefore it will be used, but only for general estimation purposes.
The number of BMP's potentially required will be based upon an estimate of the amount of impervious acreage in the highly-developed portion of the study area.
Using estimated percentages listed in Table 5.6, the total amount of impervious surfaces in the highly-developed areas is estimated as 2,992 acres. It was not technically feasible to fully separate community land use data.

2
Percentages are based on U.S. Soil Conservation Service estimates reported by  It will be assumed that one-half of the highly developed area (1,496 acres) will contain newly-constructed BMP's and the other half retrofits. This will enable cost estimates to take into consideration the differences in cost between these two categories. It will be further assumed that the structural BMP's will be implemented in the highly-developed area as follows: wet ponds will be used for 35% of this area (524 acres), extended detention dry ponds for 55% (823 acres), and stormwater wetlands for 10% (150 acres). The reasons for selecting these percentages of these BMP's are explained in the "Structural Best Management Practices" section of this chapter. The cost of constructing these BMP's to serve the respective areas will be based on average costs of BMP's reported in Chapter Four.
Organizational Needs. The construction of new BMP's would need to be scheduled over a period of years. A stormwater management master plan would provide guidance for this task. Public awareness initiatives should be considered to help increase public acceptance of this costly alternative.

Financial Needs.
The assumptions made above would result in the construction of: ten 100,000-cubic-foot wet ponds at an average cost of $80,000 each, sixteen 100,000-cubic-foot ED dry ponds at an average cost of $50,000 each, and three 1.5-acre constructed stormwater wetlands at an average price of $97,500 each.
The total estimated cost of this installation of new BMP's in one-half of the study area is $1,892,500.

Retrofitting Stormwater Management Facilities
Reasons for Selection. This alternative was selected essentially for the same reason the "new construction" alternative was selected. However, retrofitting is preferred, where feasible, since it tends to be considerably less costly than new construction.
Assumed Parameters. In the absence of on-site surveys it is impossible to know how many existing stormwater facilities in the study area could be effectively retrofitted. For the sake of making a general estimate, it will be assumed that onehalf of the developed portion of the study area will be treated by retrofitted BMP's.
Costs will be estimated, using the same mix of BMP's used to estimate costs of new construction. Based on consultation with professional planners, it is assumed that retrofit costs will be one-half of the cost of new construction.

BMP's Not Selected
The following practices for maintaining or restoring water quality in developed areas were not selected: cross-connection identification and removal, stormwater quality monitoring, and street sweeping. The cross-connection option was not selected primarily because results from the on-going water quality studies sponsored by RIDEM and the city should provide better information about the relative need for further investigations. The street sweeping option was not selected, due to its relative ineffectiveness in reducing pollutants of concern, and its relatively steep funding and staffing requirements.
The stormwater quality monitoring option was not selected because, at this time, the stormwater program has neither the necessary equipment nor technicallytrained staff to conduct this activity. However, when the US EPA issues forthcoming NPDES stormwater regulations for communities with population under 50,000, the stormwater management program may be required to monitor stormwater (US EPA, 1993c).

Structural Best Management Practices
Information presented in Chapter Four was used to compare attributes of seven structural BMP's. This comparison is presented in Table 5.7. Three alternatives were selected for use in the new construction and retrofitting scenarios explained above: wet ponds, constructed stormwater wetlands, and extended detention dry ponds.

Wet Ponds
Qualitative analysis of the information on structural BMP's presented in Chapter Four resulted in ranking wet ponds as the second-most preferred structural BMP for the study area. It out-performed most other BMP's in this category in  meeting program goals, operability, cost, and public acceptance. However, it was surpassed by extended detention dry ponds in cost, environmental effects, and institutional factors. The percentage of wet ponds used for treatment of runoff of impervious areas in highly developed portions of the study area will be 35 %.

Constructed Stormwater Wetlands
This BMP ranked third in the qualitative analysis of structural BMP's.
Although constructed stormwater wetlands performed well in meeting program goals, they were surpassed by both wet ponds and ED dry ponds in categories of cost, operability, and institutional factors. In spite of this BMP's failure to meet either the cost or institutional criteria, it is suggested that some wetlands be constructed on a trial basis for treatment of runoff in the study area. They will be used to treat 10% of the impervious area in highly-developed portions of the study area.

Extended Detention Dry Ponds
Of the structural BMP's qualitatively analyzed for this study, ED dry ponds were considered the overall best choice for the study area. This is due to their good performance in meeting program goals, cost, operability, environmental effects, and institutional factors. It will be assumed that this BMP is used for treatment of runoff in 55 % of the impervious portion of highly-developed land in the study area.

Structural BMP's Not Selected
Although infiltration basins and trenches are relatively inexpensive and potentially effective in removing pollutants of concern, these BMP's were not selected due to their high rates of failure. If innovations in infiltration structures improve their operability, these BMP's would be appropriate for use in the study area. Sand and peat filters were not selected primarily due to costs of both construction and maintenance. They are, however, highly buildable in developed areas, such as the Greenwich Bay watershed and may be an option to consider in the future. BMP systems were not selected for use in the study area because they generally do not directly increase removal rates of bacterial contamination. Thus, the expense of constructing a BMP system, rather than a basic BMP may not be fully justified.

Potential Organizational Needs
The implementation scenario described above will provide the basis for assessing the organizational needs likely to arise if water quality goals are incorporated in the stormwater management program. Table 5.8 inventories these potential needs. Since the Department of Public Works has responsibility for most activities related to stormwater management, the organizational needs in Table 5 Estimates of Potential Financial Needs The implementation scenario described in this chapter provides the basis for assessing the financial needs likely to arise if water quality goals are incorporated in Warwick's stormwater management program. Table 5.9 presents a rough estimate of the total cost of implementing all selected BMP's. Earlier sections of this chapter explain the assumed parameters of each item, on which each cost estimate has been made.

Chapter Six Summary of Constraints and Opportunities
Previous chapters have identified water quality problems in the study area, their relation to stormwater, and recommendations for addressing stormwater quality.
For each recommended action, an attempt has been made to identify its potential institutional impact and financial cost. This final chapter will offer suggestions regarding possible priorities for action, in view of fiscal limitations. However, if water quality problems are to be addressed by stormwater management, some additional expense is unavoidable. Thus, suggestions for priority-setting will be followed by an overview of potential funding sources for stormwater management, and a review of organizational structures other communities have used to administer stormwater management.

Suggestions for Prioritizing Alternatives
It is suggested that priorities for implementation be developed in order to maximize benefits and minimize cost. This translates into placing greatest priority on activities that are low cost and excel in meeting water quality goals. High-cost alternatives that excel in meeting water quality goals will also be considered.
Potential obstacles to implementation, other than cost or goal-attainment, will also be discussed.

Low-Cost Alternatives
Activities with potential to substantially advance water quality goals with minimal outlay of funds include: incorporating a water quality criterion in selecting storm.water capital improvement projects, establishing stormwater design criteria to address water quality, routinizing the review of building permit applications for developments over a certain size, inspecting BMP construction at critical times, and inspecting private development to ensure proper maintenance.
Capital Improvement Projects. This activity has essentially no cost. Its capacity to meet water quality goals is limited, due to the fact that priority should be given to public safety over water quality. The only obstacle to implementation identified by this study is the possibility that restrictions on capital improvement funds may preclude incorporation of a water quality criterion.
Design Criteria. This alternative has virtually no cost, but has been described as "essential" to attaining stormwater quality goals .
Potential obstacles to implementation include: review staff may need training; developers may oppose this option; and inter-departmental communication is required (between Departments of Planning and Public Works).
Building Permit Reviews. This alternative has minimal costs, due to the low number of additional reviews it is expected to produce. The low number expected reviews also indicates that it may have relatively little impact on water quality.
Potential obstacles to implementation include developer opposition and interdepartmental communication.

Construction Inspections.
Costs associated with this alternative are high than most other "low-cost" alternatives. This cost may be justified, however, by evidence that strategically-timed inspections can prevent failure of BMP's caused by improper construction. To the extent that new development is occurring in the study area, inspections may have high impact on water quality. The fact that the study area is largely developed indicates that this option is both low cost and of limited effectiveness. Potential obstacles include: developers may oppose this option; protocols would need to be developed; and responsibilities would need to be assigned.
Maintenance Inspections. This is the most costly of the "low cost" alternatives, although it is substantially less expensive than accepting financial responsibility for maintenance of private stormwater management facilities. It is well-established that improperly-maintained BMP's fail to attain water quality goals and that ensuring regular maintenance is an integral part of any program that requires structural BMP's.
Inspecting structural BMP's on private property to ensure proper maintenance occurs can potentially yield great benefits in attaining water quality goals. However, this option would only apply to properties developed after maintenance regulation was established. It would not apply to properties already developed. Other potential obstacles include: developers may oppose this option; legal authority to inspect and enforce would have to be established; protocols would need to be developed; and staff may require training.
Suggested Priorities. Of the low-cost alternatives, those which seem to have greatest potential for maximizing water-quality benefits are developing design criteria, inspecting BMP construction, and inspecting BMP maintenance. Since these alternatives are inter-related, it would be advisable to develop regulations that implement all three simultaneously. It is suggested that the lower-ranking alternatives also be implemented, since they are simple and low-cost.

High-Cost Alternatives
More costly activities which score high in meeting program goals include:  (Offenberg, 1995). This may include cost estimates and projected impact on water quality and flooding problems. Additional Maintenance of Public Facilities. This alternative has been described as an essential component to stormwater management for water quality.
Without appropriate maintenance of stormwater facilities, they will fail. The costs are recurrent and increase as the number of stormwater structures increases. The major obstacle to this alternative is financial constraints. In the past ten years, the stormwater maintenance budget has been gradually reduced to the current level, which is not adequate to meet water quality goals. Unfortunately, this alternative will not be feasible until an institutional commitment is made to finance stormwater maintenance.  It may be more effective to partially implement all four options described above than to select from among them. A strategic way to implement these interrelated practices would be on a subwatershed-by-subwatershed basis. Focusing restoration efforts on a few high-priority streams is likely to yield greater waterquality benefit than siting individual BMP's in numerous subwatersheds (Schueler, 1991).

Overview of Potential Funding Sources
There are a many different funding mechanisms available to local governments for capital and operating expenses. This diversity in funding mechanisms has developed, at least in part, because different funding structures are appropriate for the satisfaction of different community needs. For each option, the following information will be provided: a brief description of how it works, an explanation of chief advantages and disadvantages relative to stormwater management funding, and any references that may be pertinent to the specific funding option. Good general references regarding municipal finance include:  and . Options are organized according to five categories: private sector contributions, intergovernmental transfers, bonds, local taxes, fees.

Private Sector Contributions
Negotiating Capital Improvements. Negotiating with developers to provide onsite and off-site improvements has become increasingly common since the 1970s . Such negotiations may take place during the subdivision review or development plan review process. Some states -including Maryland, Florida, and California --have enacted legislation specifically enabling municipalities to make this bargaining process a routine part of development review. As a result of negotiated agreements during the site plan review process, some developers in Austin, Texas have constructed BMP's that treat runoff from both their own properties and adjoining land. Developers may agree to make such improvements out of a desire to do community service, or as an opportunity to promote their businesses as "environmentally-friendly" (Scharlach, 1995).
A key advantage of negotiated agreements is their flexibility. As voluntary contracts, they have greater capacity to meet unique needs of specific sites than fixed exactions.
Maintenance Cost-Sharing. At times it may be possible to enter into an agreement with private businesses to share the cost of maintaining public facilities.
For example, a number of private businesses in Cincinnati, Ohio contributed to the cost of maintaining a public skywalk between skyscrapers. Private developers have also agreed to contribute to maintenance costs of new residential developments for a certain length of time after its construction

Issuing Bonds
Infrastructure improvements are commonly made with funding obtained through long-term debt. The use of long-term debt provides interternporal equity, since present and future beneficiaries pay for a project over its useful life. Municipal bonds are generally divided into two categories, general obligation bonds and revenue bonds. Good references regarding both types of bonds are Arndursky and  and .
General Obligation Bonds. A general obligation bond is supported by the full revenue-raising power of the issuer. If issued by a city, it is supported by the full resources of the city; if issued by a special-purpose governmental organization, it is support by that entity's full resources. Debt service payments on both interest and principal is generally paid out of the issuer's general revenue stream. In Rhode Island, as in all other states, a limit is imposed on the general obligation debt that a municipality may incur.
Revenue Bonds. There are many different types of revenue bonds, including "special assessment bonds", "pollution control bonds", and housing revenue bonds", to name a few. Their names generally reflect the types of projects they finance, however, they have in common the fact that they are supported by the revenues generated by the facility or program being financed, rather than the full revenuegenerating power of the issuer. Payment of a revenue bond is often accomplished by establishing a special fund (also known as a sinking fund), into which the revenue from the financed facility is deposited. In Rhode Island, debts that are paid from a sinking fund are deducted in computing aggregate municipal indebtedness (RIGL 45-12-2).
Many communities have financed stormwater management facilities using revenue bonds. Debt service payments on these bonds have been paid using revenue from special assessments, impact fees, or user fees   Lindsey, 1988;ASCE and WEF, 1992).

Special Assessments.
A special assessment is essentially an exaction based on benefits received by the payer . Courts have determined that special assessments should be considered a type of tax rather than a fee .
Properties determined to benefit from a project are assessed accordingly. The municipal government links this revenue to payment for the project, rather than crediting it to the general fund. Special assessments are frequently used to pay debt service on revenue bonds.
Special assessments are best suited to situations in which a capital improvement confers a distinct benefit on properties in a geographic subsection of a municipality. Those benefitted pay for the improvement; the rest of the community theoretically is not benefitted and does not pay. Although special assessments are typically used to finance capital improvements, they have also been used to pay for operational expenses .
Where special assessments have been challenged by lawsuits, courts have generally examined the nature of the benefit received by assessed properties. The legitimacy of special assessments for stormwater management improvements and operations have been upheld in several cases . A court ruling in Florida held that stormwater special assessments are a tax and therefore cannot be made on property owned by the state government or other tax-exempt entities .
Tax Refands. A community may offer tax refunds to property owners who retrofit stormwater management facilities to enhance water quality or repair failing septic systems (Eastern Research Group, 1991). The principal advantage of this option is that it does not impose new or increased taxes or fees on property owners.
Although private installations of structural BMP's may save the city some BMPconstruction expenses, the loss of revenue to the general fund may be unacceptable.

Fee Options
In general, fees are charged by municipal governments to the recipients of goods or services provided by the municipality. From a legal perspective, fees differ from taxes in that taxes are designed to generate revenue, whereas, fees reflect the cost to the municipality of providing specific goods or services   (Nicholas, 1988). The objective of an impact fee is not to raise money but to ensure the provision of adequate capital facilities. In order to formulate a sound impact fee, clear documentation should be made of capital costs to be offset by the fee, and of the proportionate share required to accommodate specific developments or classes of development.
Impact fees have enabled many communities to provide necessary infrastructure without disproportionate increases in property taxes. These fees are best-suited to offset capital expenditures. In reviewing impact-fee literature, there is no evidence that such fees have been used to defray operational costs . Nicholas (1988) provides an excellent overview of this subject. Important legal considerations are also discussed by .
In-Lieu-of-Fees. This option allows private developers to pay a fee to the local government in lieu of constructing infrastructure that would normally be required on-site. In-lieu-of payments are generally placed in funds designated for specific capital projects.
A key advantage to this option is that developers often prefer paying in-lieu-of fees to constructing BMP's. On the other hand, it is not always feasible to construct a public stormwater management structure to capture runoff from developments that choose to pay this fee. This option may result in numerous developments with unmitigated stormwater runoff impacts (Scharlach, 1995).
Experiences of communities that have adopted this practice, such as Austin, Texas could be valuable in determining whether and/ or how to adopt it.
User Fees. A user fee may be defined as "a price charged by a governmental agency for a service or product whose distribution it controls" . User fees are based on the linkage between use of a specific service and the rate each user is charged.  has observed that user fees may be more appropriate than special assessments in funding stormwater management. While the use of special assessments must be based on benefits accrued by the payer, user fees may be based on the need created by the impervious surface on the payer's land. In 1981 national survey found that 55% of Americans would prefer to have local services financed by user fees rather than property tax increases. Holland attributes this preference primarily to the linkage between use and payment.
Communities that charge user fees for stormwater management typically charge higher rates for properties with greater percentages of impervious surface. This is generally estimated according to land use classifications, although impervious acreage may be calculated by using geographical information systems and data from aerial photographs .
Two additional advantages of this mechanism should also be noted. Fees do not change if property values increase, and developers have an added incentive to mitigate amounts of impervious surfaces when developing or re-developing a site.
Disadvantages include: the public may resist the establishment of a new fee; unlike payment of property taxes, the payment of fees can not be deducted from federal income taxes; and 3) local governments may find the cost of administering and collecting a new fee undesirable. Authors that provide useful information regarding user fees include , , , and .

Review of Organizational Structures
Some communities have found that stormwater problems can be better managed by creating separate stormwater organizations, or divisions within existing organizations. This section will review the advantages and disadvantages of three organizational options: the stormwater utility concept, special districts, and specialpurpose governments. It will conclude with a discussion of advantages and disadvantages associated with maintaining the DPW's existing organizational structure.
The "Stormwater Utility" Concept. In the search for a reliable source of stormwater management funding, many communities have employed a "stormwater utility" concept. Some communities have actually created a new organization, while others have made some modifications to existing stormwater management programs.
While there is considerable diversity among them , "stormwater utilities" generally share these attributes: 1) they have a specific, articulated mission of managing stormwater, 2) their operations are funded by a dedicated source of revenue, usually from user fees or special assessments, and 3) they are responsible for capital improvements and operations and maintenance of the public stormwater system .
Some examples of variations in stormwater utilities have been documented by , in the results of a survey of nineteen stormwater utilities throughout the country. The majority of utilities surveyed were located in a department of utilities, along with water and sewer service. Several were located in a department of public works, or reported to the director of public works. A majority of stormwater utilities surveyed had responsibility for regulation and enforcement of stormwater management, as well as operations and maintenance. Some utilities surveyed were quasi-governmental agencies with authority to issue bonds for capital improvements, and some financed capital improvements through bonds issued by the city government. A number of utilities reported interest income on investments as a source of revenue, in addition to user fees or special assessments. Most of the utilities surveyed conduct public relations programs.
Two principal advantages of the stormwater utility approach have been identified. Stormwater management is less likely to be neglected since it is the primary concern of a governmental unit, and a dedicated source of funding ensures that all necessary stormwater management activities may be conducted. There are also noteworthy disadvantages. The public may respond negatively to a stormwater fee, and organizing a utility program and administering fees may be undesirable for local officials. There are many good references regarding the stormwater utility concept. Lindsey (1988b), , and  provide particularly helpful explanations.
Special Improvement Districts. Special improvement districts are often created in order to finance improvements specific to one section of a city. Special assessments may be made on the properties within such a district. Another way to finance improvements is to dedicate an increment of the property tax revenue from the district to a specific improvement. Revenue bonds are often issued for such projects, supported by these sources of revenue. A key advantage of this administrative option is that a project is paid for by those who enjoy its benefit. This option is not appropriate where benefits are not clearly enjoyed by a distinct geographical section of the community.

Special-Purpose Governmental
Agencies. An independent authority, with the power to raise capital and the responsibility of establishing prices, generally offers bond buyers more security than a service system that is operated as part of the general city budget. Thus, such agencies can generally issue bonds with interest rates lower than those of municipal revenue bonds . Authorities may be established with service areas that cross municipal boundaries. This type of agency may be desirable in order to address water pollution problems of an entire watershed.
In order to fund stormwater projects at lower interest rates, some municipalities have created separate stormwater agencies with the power to issue debt. Others have transferred the stormwater function to agencies that already have this power. There are, however, disadvantages to this option. Special-purpose governmental agencies are not directly accountable to the public. Also, an agency's mandate to manage a single aspect of local government may, at times, conflict with the local government's efforts to meet the overall needs of a community .

Existing Structure of the DPW
The organizational structure of the DPW was examined in Chapter Three, with an emphasis on functions relating to stormwater management. It was found that there is no mission statement regarding stormwater management and that stormwater management functions are divided primarily among two divisions, Engineering and Highways. The DPW Director is ultimately responsible for approving work orders for drainage repairs and determining which stormwater capital improvement projects should be undertaken.
There are several advantages of maintaining the organizational status quo.
Personnel are familiar with their assignments, and drastic changes would disrupt the Department's normal flow of activities.
Combining road-construction and stormwater-construction duties within the Highways Division allows for some combinations of projects, which saves time and expense. Combining road-design and stormwater-design projects within the Engineering Division has similar beneficial results.
Two aspects of the existing organizational structure may constitute disadvantages for managing stormwater quality problems. Since stormwater problems are not the primary concern of any office or individual within the Department, addressing these problems may be delayed in favor of higher-priority items.
Secondly, since stormwater management evolved as an aspect of highway construction and maintenance, it was not included in the City Charter's mission statement for the DPW, and its relation to water quality has historically received little attention.

Conclusion
This study has considered the potential benefits that changes in stormwater management practices may have on Greenwich Bay's water quality, as well as the impacts they may have on the existing stormwater management program. Chapter One laid the foundation for the study, noting signs of increased public awareness of pollution in Greenwich Bay and institutional commitment to addressing pollution problems. Chapter Two identified the major stormwater problems in Greenwich Bay.
It was also observed that anticipated federal regulations --regarding stormwater discharges (RIPDES) and the coastal zone (6217 (g)) --may require Warwick to take some of the actions recommended by this study. Chapter Three described the existing stormwater management program. Chapters Four and Five identified stormwater best management practices (BMP's) for water quality that would be appropriate to incorporate into the existing program.
This final chapter has attempted to bridge the gap between recommendations and action. First, a framework was provided for prioritizing recommended stormwater management practices for water quality. It was observed that several actions to help improve water quality can be taken at no cost or low cost, and that substantial funds have already been allocated for construction of structural BMP's.
However, it was also observed that proper maintenance of existing and future stormwater structures will require a commitment of funds.
The second section of this chapter provided an overview of revenue-generating options for implementing stormwater management practices. Some options are more appropriate for capital expenses and some for operational expenses, including maintenance. Options that may be appropriate to cover maintenance costs include private-sector cost sharing, property taxes, special assessments, and user fees.
Finally, a review was made of various organizational structures that have been used to administer stormwater management programs. It was observed that where stormwater management is the primary concern of an organization, division, or individual, stormwater management problems are more likely to receive adequate attention. It was also observed that structural changes within an organization may be time-consuming and difficult, and may create new problems.
to have a positive impact on water quality, the value of implementing BMP's that were outside the scope of this project should not be overlooked. Among these are enforcement of septic system maintenance and repair, promotion of water conservation and bay-friendly lawn-care practices, and reduction of animal waste.
These BMP's were not considered for implementation because they appeared to fall under the purview of municipal programs other than stormwater management.
Not only was the focus of this study limited by functional area, but it was also limited in geographic scope. Recommendations have been made primarily for the Greenwich Bay watershed within the City of Warwick. It is important to note that any recommended action Warwick chooses to implement could be more effective if it were also implemented by other municipalities within the watershed. The file [basindat.wk4], which is stored in Lotus [ver. 4] on the Gateway P.C., is a master compilation of all the available data on stormwater holding basin structures, both public and private, existing and proposed, that are situated in the City of Warwick, State of Rhode Island. This file lists each area by a map reference number, with a location name, type of structure, plat and lot, and the receiving watershed. There are 87 site locations to date.

APPENDIX 1 Land Uses in the Study Area
The total number of actual structures is 133, of which 16 are considered preliminary, to date. Of these, 82 are privately owned, 46 are City owned, 3 are State owned, and 1 is Federally owned. There are 66 detention basins-these hold stormwater temporarily in a manma.de basin, releasing this water by controlled discharge. There are 27 retention basins-these hold water indefinitely, usually until evaporation occurs. Underground structures-leaching chambers [galleys] or leaching drains, and multiple drywell systems-total 19 in the City. Infiltration basins [leaching fields] and sediment trapping basins, total 8. There are 7 flow spreading structures; and 5 natural hol"ding ponds [wetlands or drainage swales] in the City.