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SENT BY:DPRA St -Paul, MN '4-12-99 ; 3:36AM <br />612 22f 9522 612 407 4191414 <br />...v n[Iq gURFACE COVERAGE <br />4u surfaces" (Town of Brunswick 1991). In this case, <br />the very low impervious limit was feasible because the <br />total area affected was fairly small, the use was largely <br />residential, and the specific pollutant of concern was <br />nitrogen emanating from septic systems, resulting in <br />zoning that called for a minimum lot size of one unit <br />per five acres. This "down -zoning" approach, which <br />has also been used � the Buttermilk Bay area in Mas- <br />sachusetts (Horsley and Witten 1991), is practicable <br />for small areas with septic -related concerns, but if ap- <br />plied over large areas, can lead in the long run to pro- <br />motion of sprawl. <br />Strict limits may be appropriate, yet in practice <br />they can result in the peed for cam plicared exemption <br />provisions, or even raise the specter of private prop- <br />ercy rights takings (Land Use Law and Zoning Digest <br />1995; Ross 1995; settle Washburn, and Wolfe 1995). <br />One method for "softening" the concept of limits is to <br />allow for flexibility on the site level. In this scenario, <br />an ordinance setting a limit (or goal) for a site's imper- <br />vious coverage would require more stringent on -sire <br />stormwarer treatment when the limit is exceeded. This <br />type of approach will undoubtedly become more com- <br />mon as the information base on removal efficiencies <br />of various treatment measures expands. Another type <br />of flexibility, comes from applying performance Stan- <br />dards to specific elements of imperviousness within <br />the landscape. In their discussion of next steps, the <br />Olympia study (City Of Olympia 1995) cites the devel- <br />opment of performance -based standards for side- <br />walks, parking, and landscaping "to encourage <br />innovation and provide flexibility in meeting impervi- <br />ous surface reduction goals." <br />One practical regulatory application of impervi- <br />ous coverage is for smrmwater utility assessment, an <br />"impact fee" that is growing in use in, urban areas of <br />the country as a way of paying for the treatment and <br />control of polluted runoff. Impervious surface has <br />long been a key determinant iri mathematical models <br />that.predict the volume of runoff from a given piece <br />of land. Scormwater ucilicy assessments have taken the <br />lead from these models in using imperviousness as a <br />basis for a utility race structure chat fairly distributes <br />the cost of treatment according to a property s contri- <br />bution to runoff. <br />Such systems are now in place in many areas, in- <br />cluding Kansas City, Missouri; Kicsip County, Wash- <br />ington; and throughout the state of Florida. This type <br />of application requires a community -wide assessment <br />of impervious coverage, and a wide range of tech- <br />niques is being used. In Kansas City, race structures <br />are based on digitized high -resolution orthorecrified <br />aerial photos (Murphy 1995), while in Florida they are <br />based on statistical surveys of area lots (Livingston <br />1995). The Kitsap County, Washington, Comprehen- <br />sive surface and Stormwater• Management Program, <br />esublished in 1994, creates a rare structure based on <br />an "equivalent service unit" equal to the average esti- <br />maced amount of impervious surface area on a single- <br />family residential parcel (Kicsap County 1994). <br />Such programs not only raise Funds far mitigation <br />of adverse impacts, but also, by attaching a cost to im- <br />perviousness, provide an economic incentive to reduce <br />it. Apparently, this effect is beginning to be seen in <br />Florida, where the cost savings associated with lower <br />stcrmwater utility fees have provided the impetus for <br />reduction of impervious cover during site redevelop- <br />ment (Livingston 1995). <br />Integrating Storm.Water Control <br />into Community Planting <br />The strategies described above demonstrate chat <br />for the planner, imperviousness can provide a useful <br />framework for addressing the impacts of urbanization <br />on water resources. But the advantage of this approach <br />goes beyond any specific application. We have found <br />that working with a town on water resource protection <br />often leads to related natural resource issues like open <br />space preservation and forest management. Our re- <br />cent experience with NEMO has taught us that fram- <br />ing water issues largely in terms of imperviousness <br />serves to expand the range of these connections. <br />Once water pollution is linked to impervious cov- <br />erage and its various components, is has a way of in- <br />sinuacing itself into issues currently "on the table" in <br />town. Road widths and curbing may be subjects of <br />town debate about cost or neighborhood character. <br />Parking and landscaping requirements for commercial <br />zones may be undergoing reexamination for aesthetic <br />reasons. The appropriateness of "big box" retailers <br />may be a hot topic, with arguments centered around <br />traffic congestion and the impact on local merchants. <br />An open space plan may be in the formative stages, or <br />the use of stream buffers being questioned. Citizens <br />may be interested in naturalistic landscaping, water <br />conservation, or volunteer monitoring of local water- <br />ways. These typical local debates, drawn from towns <br />working with the NEMO Project, now have elements <br />of water quality and impervious surface reduction as <br />part of the mix. And through these debates, the sub- <br />jecc of water quality in the community is extended be- <br />yond land -use -related staff and boards co include <br />engineering and public works departments, land <br />trusts and other nonprofits, and citizens. <br />Cross connections of this type are an important <br />key co ensuring the implementation of any planning <br />initiative. For the professional planner, they create <br />APA JOURNAL -SPRING 1996 255 <br />