NY/NJ Baykeeper – Statement on Stormwater Management Rules By Michele Langa February 13, 2019 Joint Statement from NY/NJ Baykeeper and Hackensack Riverkeeper on Stormwater Management Rules Recently Proposed by NJDEP The Stormwater Management Rules proposal by NJDEP is a positive step forward, yet still severely lacking in several areas. If NJDEP is willing to go though the titanic task of overhauling the rule, they should do so completely and with the future of stormwater management and climate-related changes in mind. The incorporation of green infrastructure requirements is a good example of where the rules are improved, but not wholeheartedly. Green infrastructure should be incorporated as a proximity-based measure to naturally treat runoff close to its source, not with broadly defined parameters that diminish its impact and success. Changes that define impervious surfaces as motor vehicle traveled surfaces (MVTS) limit the impact of quality-based treatment to those surfaces, leaving out all other non-MVTS. It seems like a small change, but non-MVTS includes areas like sidewalks, paved pedestrian areas, and every paved or otherwise impervious surface not traveled by motor vehicles. Removing that many impervious surfaces from quality-based treatment requirements poses a serious threat to our already suffering water quality standards. Ultimately, we appreciate the willingness of the NJDEP to improve on the Stormwater Management Rules at all and for their commitment to an open stakeholder process. We also appreciate all of our colleagues in the environmental community, who have worked tirelessly on this issue, for showing a strong, united front on behalf of stormwater-based improvements in NJ. However, it would be most beneficial to the environment to push harder for improvement that is more comprehensive, rather than incremental improvement coupled with setbacks.