Regulating Deicing Runoff from Highway Operations

摘要

This paper describes the increasing regulatory pressure on the runoff of roadway deicing chemicals projects future trends in the permitting of those discharges. In recent years, increasing attention has been paid to the environmental consequences of pavement deicing activities. With the advent of the Clean Water Act's storm water permitting program in 1987, the U.S. Environmental Protection Agency was given an express mandate to control storm water discharges through federal wastewater discharge permits. Deicing discharges from roadways were excluded largely in the first phase of that program. Phase II of the storm water program brings a new focus on the potential water quality impact of highway deicing runoff. With this focus comes the increased likelihood that dischargers adjacent to impaired waters will be subjected to stringent permit terms. As these trends mature, states may conclude mat the issuance of permits for highway deicing runoff should be the rule rather than the exception. To meet this challenge, state departments of transportation and other entities responsible for roadway deicing activities should begin to think through the options with which they will be presented. Working with regulatory agencies early on to ensure that potential water quality impacts will be fairly and accurately characterized will be critical. Equally important will be advance work with permitting agencies to frame permitting strategies mat would not unduly burden roadway deicing operations.