State departments of transportation (DOTs) oversee the construction and maintenance of transportation and highway systems. To construct and maintain highway infrastructure systems, DOTs and their associated contractors and consultants perform various tasks that typically involve earthwork operations at and around a project site, which can create stormwater, erosion, and sedimentation runoff issues, thereby potentially impacting receiving waters. Disturbed areas occur when vegetation, rocks, pavement, and other protective ground covers are removed during construction, thereby exposing the underlying soil, which is susceptible to erosion and sediment-laden runoff.
Examples of soil-disturbing activities include, but are not limited to, the following:
Disturbed areas requiring erosion and sediment control (E&SC) and protection are evident for projects as small as shoulder-widening and as large as mega-highway projects. Protecting surrounding areas and implementing proper stormwater management reduces the potential for polluted stormwater flowing into receiving waters (Colorado DOT, 2021).
Construction stormwater management practices protect surface and downstream water bodies from discharge and runoff. If not managed properly, stormwater can contain large amounts of sediment and suspended solids, some of which contain pollutants toxic to surrounding environments and wildlife. Stormwater management is a comprehensive program that DOTs have developed, implemented, and refined over the years to manage the water quality of disturbed area discharges, to protect water quality during land-disturbing activities, and to conform with the National Pollutant Discharge Elimination System (NPDES) and construction general permits (CGPs). The CGP authorizes the discharge of allowable stormwater and non-stormwater associated with regulated construction activities into or adjacent to receiving waters. The CGP specifies construction activities that may be authorized, are eligible for waivers, and that require an authorized individual permit (EPA, 2022). The CGP includes information about the proper discharge of stormwater associated with activities at construction sites to comply with permit requirements, which typically entails compliance with discharges of stormwater runoff from earthwork construction activities and disposal areas for excavated materials. A primary requirement of the CGP is the development and use of a site-specific stormwater pollution prevention plan (SWPPP) for construction.
Erosion and sediment control are necessary for environmental protection, water quality, and safety. Uncontrolled erosion and sediment runoff during highway construction may cause harmful impacts on receiving waters and habitats, drainage structures, and surrounding lands, and could be subject to public criticism and complaints. Best management practices (BMPs), which incorporate E&SC measures, are a set of procedures and controls installed at a construction site to help prevent soil erosion and reduce or eliminate water pollution and sedimentation problems during construction. These techniques also can minimize the need for contractors to take corrective actions during construction operations. To assist with E&SC practices, state DOTs have stormwater management programs (SWMPs), approaches, and guidelines that help address water quality degradation and minimize erosion and sediment runoff associated with highway construction activities. These SWMPs also guide the implementation of planning, construction, and proper installation and maintenance of BMPs as construction proceeds.
Although state DOTs have managed environmental and water quality issues associated with highway construction for years, information about the current state of the practice in construction stormwater management is needed to understand processes that work as well as existing challenges to managing stormwater permit and compliance requirements. In addition, gaps in knowledge and approaches can be identified for future research. Overall, a need exists to understand how state DOTs manage compliance with stormwater and environmental permit requirements for stormwater and E&SC for highway construction work.
The objectives of this synthesis are to investigate and document DOT practices, tools, and approaches for managing compliance with state and federal construction stormwater permit requirements. Specifically, this synthesis performs the following:
Based on the objectives, the following areas were considered for data collection:
The literature review provided information about the current state of the practice for construction stormwater management, as well as the Clean Water Act (CWA), permits, BMPs, control measures, and inspections. Various reports, documents, manuals, journal articles, and websites
from state DOTs, the FHWA, and the EPA were consulted that address stormwater management and control measures for highway construction projects. The findings of the literature review are in Chapter 2.
A survey questionnaire was developed using the literature review and that follows the scope of work developed for this project. The survey questionnaire captured the state of the practice in construction stormwater program management. The survey was developed using the Qualtrics online survey platform and was electronically distributed to the AASHTO Committee on Construction voting members. This distribution included representatives from all 50 state DOTs and the Washington, DC, and Puerto Rico DOTs. The survey findings are presented in Chapter 3 based on 42 state DOT respondents (81% response rate). The survey questionnaire is presented in Appendix A. Individual state DOT survey question responses are provided in Appendix B.
Following the analysis of the survey responses, case example interviews were conducted to gather detailed information from DOTs about construction stormwater program management, SWPPPs, BMPs, and training. Initially, nine state DOTs were identified as candidates for case example interviews and were contacted. In total, six state DOTs participated: Colorado (AASHTO Region 4), Florida (AASHTO Region 2), Iowa (AASHTO Region 3), New York State (AASHTO Region 1), Pennsylvania (AASHTO Region 1), and Texas (AASHTO Regions 3/4). Details of the state DOT case example interviews are outlined in Chapter 4. The interview questions used for the case examples are provided in Appendix C.
This synthesis includes five chapters.
The synthesis also includes the following sections: