Comments on: What Is the Future of Flow-Based Regulations? https://stormwater.wef.org/2013/02/what-is-the-future-of-flow-based-regulations/?utm_source=rss&utm_medium=rss&utm_campaign=what-is-the-future-of-flow-based-regulations Stormwater News from the Water Environment Federation Thu, 07 Mar 2013 14:04:09 +0000 hourly 1 https://wordpress.org/?v=6.2.2 By: Seth Brown https://stormwater.wef.org/2013/02/what-is-the-future-of-flow-based-regulations/#comment-70 Wed, 13 Feb 2013 18:37:23 +0000 http://stormwater.wef.org/?p=1341#comment-70 In reply to John Smith.

John,

Good point regarding the margin of safety in the TMDL development. One thing to consider is just how uncertain the flow-sediment relationship is actually. Sediment transport theory is very complex, and it is not uncommon for results to be off by an order of magnitude – this is a significant difference. But focusing specifically on the Accotink case, the two unimpaired reference watersheds used have much better draining soils (70% B soils) when compared to Accotink (70% D soils), so the inherent difference between Accotink and the unimpaired watersheds goes beyond just uncertainty, in my opinion.

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By: Seth Brown https://stormwater.wef.org/2013/02/what-is-the-future-of-flow-based-regulations/#comment-69 Wed, 13 Feb 2013 18:33:36 +0000 http://stormwater.wef.org/?p=1341#comment-69 In reply to Sabu Paul.

Sabu,
Based upon fluvial geomorphic theory, the “channel-forming” discharge (often referred to as the bankfull or “effective” discharge) is that flow which – which looking over a long temporal horizine – carries enough erosive power yet occurs frequently enough to move the most sediment in the stream. Intuition may tell you that it is large, flooding (100-year) events that move the most sediment in a stream, but in most cases, it is a much higher-frequency event, such as the 1.5-year storm, that actually reflects the synergy between stream power and flow frequency. It should be noted that in an urban context, the channel forming flow frequency has been known to be as high as 1-year or even a 6-month event. Added to this flow dimension is the duration of flow – when flow in a channel exceeds the scouring velocity for a long period of time, the marginal amount of erosion which occurs in the channel increases over a situation where the duration of scouring is very short.

With all of this in mind, a reduction of the unit volume of discharge within a watershed for the 1-year event would indeed reduce the amount of erosion within the stream.

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By: Sabu Paul https://stormwater.wef.org/2013/02/what-is-the-future-of-flow-based-regulations/#comment-68 Wed, 13 Feb 2013 10:57:48 +0000 http://stormwater.wef.org/?p=1341#comment-68 Seth, Based on your article it seems like the problem in Accotink is the erosion in the streams. The erosion is more like be the result of high flows (or even extremely high). Most of the flow control (also WQ ) structures tend to control the initial flush and not very high peaks. TMDL implementation that reduces 50% total runoff will probably have no effect on the real problem, unless it is the reduction of peak flow. If it is the peak flow, how are they expecting to reduce the peak flow from a 100 year or higher rainfall event?

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By: John Smith https://stormwater.wef.org/2013/02/what-is-the-future-of-flow-based-regulations/#comment-67 Thu, 07 Feb 2013 21:26:50 +0000 http://stormwater.wef.org/?p=1341#comment-67 The analysis in the Accotink ruling identifies what I consider to be the key path to a solution by stating (see page 8, under Chevron Step Two): “If sediment level is truly ‘a function of’ the amount of stormwater runoff, as EPA claims, then the TMDL could just as easily be expressed in terms of sediment load.” Pretty simple, in my opinion. If, however, the so-called “function” that relates sediment level to stormwater quantity is not well known, the TMDL approach allows such uncertainty to be included in the margin of safety.

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