I do not support the EPA allowing DC Water to use Green Infrastructure (GI) to help meet its responsibilities for water quality improvements. Although implementing GI has tremendous environmental, social and economic benefits, DC Water’s proposal to use GI doesn’t adequately render GI as a viable option for the following reasons.
The first reason the implementation of GI is unacceptable is because DC Water has failed to show that GI works. The Long Term Control Plan (LTCP) consent decree was signed in 2005. In
2014, DC Water proposed to amend LTCP to include green infrastructure. In this nine year period,
DC water failed to demonstrate and provide site specific performance information on the
Potomac and Rock Creek illustrating that GI can achieve equal or greater reductions of combined sewer overflows (“CSOs”) compared to building tunnels. Therefore utilizing $30 million dollars of the rate‐payers money to reduce the size of the Potomac’s tunnel and replace it with GI is a poor choice since DC Water has not proved its proposed GI would fulfil the same requirement as a large tunnel would. DC Water’s General Manager, George Hawkins’ power point presentation indicates DC Water has invested 10 million in GI projects such as tree plantings, rain gardens, green roofs, bioretention, etc., but the presentation lacks providing any significant data or measuring tool on how successful the projects have been while implementing GI.
The second reason DC water should not use GI, is the concern whether DC Water intends on using public or private land to implement GI along Rock Creek and the Potomac. DC water has not addressed issues such as easements associated with GI on property as well as maintaining the green infrastructure it will install on the land. DC Water has not discussed who will bear the burden of maintaining the GI and whether GI occurs on private