The National Stormwater Testing and Evaluation for Products and Practices (STEPP) Initiative seeks to improve water quality by accelerating the implementation and adoption of innovative stormwater management technologies by removing current barriers to innovation, creating regulatory confidence, minimizing duplicative performance evaluation efforts, and establishing a common framework for testing and evaluating both public domain and proprietary stormwater control measures.
As stormwater-related pollution has grown, regulatory programs have been established at the state and federal level to address the effects of stormwater runoff. Various stormwater control measures (SCMs) — proprietary products and public domain practices— have been developed and have evolved to address stormwater runoff. As the diversity and complexity of SCMs has grown, the need to develop a process to test, categorize, review, certify, evaluate, verify, and/or approve stormwater runoff controls became evident. This process ensures that the efficacy of products and practices meets expectations, which often are tied to permit requirements. Some programs to test and evaluate SCMs arose at the state, regional, and national levels, but these have had mixed results.
The STEPP Initiative was triggered, in part, by the end of the only national evaluation program for stormwater technologies, the U.S. Environmental Protection Agency (EPA) Environmental Technology Verification (ETV) program. STEPP developed from a 2012 meeting of interested parties from product manufacturing, consulting, and regulatory sectors. WEF volunteered to investigate the need for a national testing and evaluation program for stormwater products and practices, and formed the STEPP Workgroup. A white paper (2014, WEF) was released that summarized the findings of that effort. The report noted that a national SCM testing and evaluation program would be beneficial to multiple stakeholders (regulators, municipalities, technology providers, consumers, and so on). The result of this 2014 investigation was that agreement exists on the feasibility and the need for a national testing and evaluation program.
With support from EPA to move beyond the investigatory phase, a STEPP Advisory Committee was assembled in 2015. This second phase sought to develop a report to recommend the scale, scope, architecture, funding, and leadership for a national program. The Advisory Committee used five stormwater and non-stormwater technology evaluation programs as models for the potential design components to be considered for the National STEPP Program. Additionally, two informal surveys of states and MS4 permitees assessed their needs and how they might use a national program.
2016 Report Findings
The STEPP program framework document focuses on both the general programmatic and individual program elements. These include the following:
- Enhance and further implement recruitment strategies through partnerships with stakeholder groups. These include individual states, MS4 permittees, EPA, academic researchers, the development community, non-governmental organizations, and others.
- Promote the adoption of a flexible “cafeteria plan” approach for a national program that is envisioned to evolve continually over time. A cafeteria plan option allows both technology proponents and regulatory entities to have flexibility in designing a SCM study and determining how to meet specific state and local regulatory requirements.
Individual program features explored include the mission and objectives, program services, organizational relationships, operational structure, governance, funding, stakeholder engagement and transparency, testing purpose and scope, testing setting, and reciprocity. A few of these program aspects are briefly explained below.
- Program Services – The National STEPP Program should provide for both laboratory and field testing, evaluation, and verification of public domain and proprietary SCMs as its core service areas.
- Organizational Relationships – The STEPP Advisory Committee believes a “hybrid” National STEPP Program model that draws, at least initially, on the proven experiences of two existing state-level programs – the Washington Technology Assessment Protocol – Ecology (TAPE) and New Jersey Corporation for Advanced Technology (NJCAT) program – will accelerate the national advancement of the program, while quickly establishing organizational relationships that can both operate and guide the program development.
- Reciprocity – The National STEPP Program should allow for voluntary participation by individual states and municipalities. While a common SCM testing and evaluation process is promoted by STEPP, each regulatory entity will need to consider how to allow for “certification” of SCMs while meeting their unique regulatory requirements.
Beyond the 2016 Report
WEF has continued to promote the STEPP Initiative by disseminating the 2016 report findings and actively engaging such partners as the Water Environment & Reuse Foundation (WE&RF), Interstate Technology and Regulatory Council (ITRC), American Society for Testing Materials (ASTM International), EPA, individual states, the development community, academic researchers, and technology providers.
WEF hosted a partner meeting in June 2017 to further explore opportunities to advance STEPP implementation. At that meeting, several partners expressed interest in developing a consortium to further STEPP. The effort continues with these partners to further the discussion of creating a consortium that would implement a national SCM testing, evaluation, and verification program.
For further information regarding the STEPP Initiative, contact Seth Brown, Stormwater Programs Director, SBrown@wef.org.
Letters of Support
STEPP has received unsolicited letters of support from several jurisdictions, states, and organizations. See below for details:
Our associations (Associated General Contractors of America, International Council of Shopping Centers, Leading Builders of America, National Apartment Association, National Association of Home Builders, National Multifamily Housing Council, National Association of Realtors, and Retail Industry Leaders Association) are pleased to support the development of a National STEPP program, as outlined in the recent report: Framework for a National Testing and Evaluation Program Based upon the STEPP Initiative. Read more.
The Michigan Department of Environmental Quality (MDEQ), Water Resources Division, is pleased to support the recommendations of the National STEPP Workgroup Steering Committee. Read more.
It is the New Jersey Department of Environmental Protection’s understanding that WEF is determining the feasibility of creating a national protocol for the testing and evaluation of Manufactured Treatment Devices. The Department fully supports the development of such a protocol and applauds WEF’s leadership and efforts in this matter. Read more.
The Washington State Chapter of the American Public Works Association’s Stormwater Managers Committee expresses its support for developing a national testing and evaluation program for stormwater products and practices. Read more.
The State of Washington Department of Ecology supports the idea of a national program that provides a level of detail comparable to our program and addresses our concerns. We look forward to working with WEF as you move forward on this project. Read more.