CDM -- Camp Dresser & McKee Inc.

Stormwater Management Element

MEMORANDUM

TO: Bill Spikowski

FROM: Mike Heyl, QEP

DATE: December 10, 1996

SUBJECT: Stormwater Management Element

BACKGROUND

One of the problems facing coastal communities is how to provide adequate drainage to minimize flooding. Coastal flooding can arise from two different sources. One source of flooding in Fort Myers Beach is unrelated to rainfall and stormwater, and occurs when the water in the Gulf of Mexico and Estero Bay rise to unusual heights due to strong on-shore winds. Often, this type of flooding occurs without rainfall.

In contrast to flooding caused by water flowing onto the island, flooding caused by stormwater (the second source) is the result of a conveyance system which is inadequate to get water off of the island and into the Gulf or Bay. Usually barrier islands have several intrinsically good drainage features because of their narrow profile and the short drainage pathways coupled with highly pervious sandy soils. However, the overall drainage process can be stymied because of low relief and slope, with the simple result that there is no place for the water to flow. It is also aggravated by increased development reducing the natural drainage functions.

Disregarding water quality concerns for the moment, typical solutions to stormwater flooding attempt to move larger volumes of stormwater runoff away from roads and building at a faster rate, or to store the runoff until a later time when the system can accept flow without flooding. For existing development, this is accomplished by increasing the size of drainage pipes, eliminating obstructions, and cleaning or enlarging ditches.

However, it should be noted that these same improved stormwater conveyances will also allow rising water in from the Gulf at a faster rate. At the community level, the only effective technical remedy to rising flood water is to dike the island and outfit the outfalls with flapper valves - an impractical solution for an island of this size. There are however, community activities which can remedy some of the damage. For example, adding dunes to the Gulf side with walk-overs will provide a form of energy dissipation for onshore waves. Rising water would still encroach from the Bay side and flooding will occur, but wave damage would be reduced.

In some respects, stormwater quality issues stand in stark contrast to the causes and solutions to stormwater flooding. Most flood control efforts are focused on the prevention of stormwater flooding up to and including flooding associated with abnormal events, such as extreme rainfall that occurs only once every 5, 10 or 25 years. Because of the infrequent nature of these events, these storms are of little consequence in stormwater quality. The water quality concern is about pollution carried in numerous small storms. Generally, the west coast of Florida experiences about 100 storm events annually. Of these, more than 90 percent produce less than one inch of rainfall. Stormwater treatment technology therefore is geared to treat the runoff from up to a one-inch rainfall, thus providing treatment for 90 percent of the events.

Whereas part of the solution to flooding is to move stormwater as quickly as possible to the Gulf or Bay, several forms of stormwater treatment rely on slowing the movement of water to allow solids and metals to settle out, or storing it in depressions and allowing it to soak into the ground. For example, grassed swales provide good treatment for the small storm events where the depth of water in the swale is small and is slowed by the vegetative cover. During bigger events, the swale fills and the effectiveness of the vegetation in slowing the water becomes progressively less.

The term Best Management Practices (BMP) is used to describe techniques for stormwater management. Structural BMPs are physical devices intended to control the quantity and/or quality of stormwater. A stormwater pond is one example of a structural control. Other BMPs are categorized as source controls, which are designed to control the problem at the source and minimize the need for structural controls. For example, reducing the amount of impervious area results in less runoff. This results in more room in the drainage system for the remaining runoff and results in less water that needs to be treated. Source controls are often the only alternative for built-out communities with little room to install structural controls.

The susceptibility of a community to flooding or water quality problems due to stormwater can be measured by assessing the level of service (LOS) available. For flooding issues, a LOS can be expressed in terms of the degree of roadway flooding and/or the extent of first floor flooding for a given hypothetical storm event. For example, for some communities, a 'C' level of roadway service is defined as no more than six inches of water on evacuation routes during the largest one-day rain event expected every 25-years. A 25-year recurring storm means a storm has 1/25 of a chance of occurring during a given year. The current Lee County Comprehensive Plan stormwater management LOS is that designated evacuation routes shall not be flooded for more than 24 hours by rainfall from a "25-year, 3 day" storm, and . . . new development (except widening of existing roads) shall hold excess stormwater to match the predevelopment discharge rates for a "25-year, 3-day storm." (Note that the definition applies only to flooding which results from rainfall and not to flooding from rising water.)

LOS definitions vary considerably by community. In 1993, a task force consisting of FDEP and representatives from each of the water management districts jointly published a recommended set of criteria (Report to Plan Oversight Committee Stormwater Level of Service Conventions Committee) for flooding LOS. These recommendations defined level 'C' as standard flood protection, which means evacuation routes and arterial roadways must be passable during a 100-year flood event, and collector roadways must be passable during a 25-year event.

The same task force also developed standards for water quality. Compared to a flooding LOS, the concept of a water quality LOS is new in the State of Florida. The water quality ranking system promotes land use controls, followed by structural treatment measures, and penalizes untreated discharge from urban areas. A water quality LOS is not required in the Comprehensive Plan, but should the Town wish to include one, this approach can be considered.

REGULATORY ISSUES

The stormwater management policies in the Fort Myers Beach comprehensive plan will be influenced by a variety of federal, state, and regional regulations. For our immediate purposes, the most direct involvement is through Chapter 163.3177(6)(c) of the Florida Statutes and Rule 9J-5.011 of the Florida Administrative Code. These require that the local comprehensive plan have an element establishing broad and long-term policy guidance for implementing stormwater management throughout the Town. Specific management techniques are not contained in these regulations; but through the formal review process, state and regional agencies will ensure that the policies are coordinated with surface water management policy contained in a variety of other plans. Attachment A contains a complete summary of other federal, state, regional and local objectives for management of stormwater and its potential impact on the Town of Fort Myers Beach, including the impending implementation of the National Pollutant Discharge Elimination System (NPDES) process.

PROBLEM STATEMENT

While there appears to be very little water quality data collected within the Town's corporate boundaries, the regional evaluations for Charlotte Harbor (including Matlacha Pass) provided by Florida Department of Environmental Protection (FDEP) are applicable. In FDEP's 1994 biennial report to EPA, FDEP stated that "The predominant pollution problems are associated with development: bacteria from accelerated urban runoff through canals[,] and sediments from construction . . . ." The water quality in urban canals tends to be poor for a variety of reasons. First, urbanization introduces higher pollutant loads from stormwater runoff. Lawn care adds nutrients, pesticides, herbicides and fungicides to the land, some of which will be broadcast directly into the canals during application, or indirectly carried as stormwater runoff. Stormwater runoff also washes off roadway pollution into the canal systems. Roads collect oil, anti-freeze, brake fluids, petroleum products, brake and tire dust, and combustion products. These residues contain high levels of toxic metals and organic compounds, many of which are attached to solids. In the absence of a stormwater treatment facility for settling and removal, these solids and attached pollutants are washed directly into the Gulf and canal systems. In other cases where the drainage is routed through unvegetated areas such as beaches, high rates of runoff will cause erosion which compounds the problem.

Other impacts from urbanization include direct and indirect discharges of wastes, both domestic and industrial. Septic tanks drainfields contribute pollutants through groundwater seepage into the canals. Local contractors have reported that many discharges still remain from Estero Island homes and businesses despite central sewer service. Because many of these canals are dead-end, circulation is poor and pollutants tend to accumulate in the water column and in the sediments, adversely affecting the flora and fauna with the canal system. Fish kills, increased tissue levels of toxic compounds in fish and shellfish, reduced productivity and diversity all result from degraded water quality. While there are regulations against causing pollution through direct, or indirect discharges, there are no federal, state, or regional requirements to sample the ambient waters for pollution except when such monitoring is included as a permit condition. Sampling and monitoring of existing conditions must generally be initiated at the local level. In the future, however some monitoring will be required of the Town by the stormwater NPDES permit.

The major impediment to better flood control on Estero Island is the lack of available land for structural improvements in the older, northern third of the island where Estero Boulevard frequently floods. Improving flood control in this portion of the island will require solutions for both coastal flooding due to rising water and for better control of stormwater runoff. For many areas, drainage simply flows overland to the beach, bay or nearest canal. The existing drainage system is largely undocumented, and some facilities are partially buried or otherwise poorly maintained. In the absence of increased maintenance, the performance of the remaining structures will diminish, or cease due to siltation. The best opportunity for drainage improvement may consist of identifying and maintaining the existing system, coupled with land-use controls for redevelopment. For improvements to the stormwater quality, source controls should be emphasized and structural controls incorporated wherever possible during retrofits.

Conditions improve to the south, where drainage facilities are more abundant and better maintained. Properly maintained, these facilities have a life expectancy of 20-50 years. The commercial and multi-family residential developments constructed after the mid 1980s were built to meet the SFWMD requirement that the rate of runoff after development be no greater than before development (for the highest 3-day rainfall total expected every 25 years). Thus, in cases where the development occurred over undisturbed lands, the rate of runoff is equal to the natural rate of runoff.

PLANNING OPTIONS

Coastal Flooding - Options to reduce the frequency and severity of road and structural flooding resulting from rising water are limited, and best addressed during redevelopment. Technical options include installation of flapper-valves on discharge pipe outfalls located above high tide, raising roadways and structures, berming, and flood proofing structures. While berming is effective at keeping the rising water out, some mechanism (usually pumps) would be required to remove water from within the bermed enclave during large rain events, and raising of roadways often trades dry evacuation routes for flooded structures. Not withstanding evacuation issues and in lieu of a prevention strategy, the most cost-effective strategy is to design/build or redevelop in a manner that will minimize the damage of coastal flooding.

Stormwater Flooding - The performance of the neglected existing drainage facilities could be improved by routine maintenance. Pipes and outfalls should be located, and cleaned. Swales on private property provide small on-site storage and reduce the amount of stormwater that must flow through the conveyance system. Swales also provide water quality treatment and recharge of the surficial aquifer as additional benefits. In the north, it is likely that many pipes are undersized due to the need to drain increased impervious area which has been added over time. The extent of improvement which that be obtained can be determined with mapping and master planning the drainage of the north end of the island, as suggested in the recommendations section of this memorandum. Minimizing impervious area remains a good strategy for both quantity and quality concerns, but some of the popular structural solutions to flooding have not withstood the test of time well. For example, after five years of use, 75% of a porous pavement tested failed to percolate properly, and 50-100 % of the infiltration facilities (without pre-treatment) failed after five years. Another strategy, raising roadways, may improve the roadway flooding LOS, but potentially at the cost of additional off-road flooding or nearby buildings. Despite these limitations, strategies which can effectively minimize impervious area and maximize infiltration will reduce the flooding potential and water quality problems.

Stormwater Quality - There are several options available to improve the quality of stormwater runoff:

• Street sweeping is an effective source control to remove sand and floatables and has the added benefit of improved aesthetics.
• Vegetated swales are also attractive and provide treatment.
• Vegetated buffer strips work in a similar fashion by slowing the rate of flow and allowing the solids to settle. However, being of fixed width, buffer strips are more sensitive to the velocity of runoff and therefore are recommended only for small structures.
• Catch basins could be replaced with water quality inlets (baffled concrete tanks for solids and oil separation), but regular vacuuming and maintenance must be provided to ensure optimal removal rates.
• Infiltration and exfiltration facilities are popular in retrofit conditions where useable space is limited. Infiltration trenches are rock filled ditches which receive stormwater at the top. Exfiltration trenches are similar in design, but stormwater is introduced into the interior of the trench via a pipe which runs through the middle of the trench. (The current improvements to Estero Boulevard include several exfiltration trenches to be installed below the road's pavement from Times Square to the Lani Kai.) Both devices have limited life expectancies (perhaps five years?) unless some form of pretreatment is provided. Application on Estero Island may be further limited by a high water table which is reported to be at 1.0 foot NGVD, with roadway elevations averaging about 3.0-5.0 ft NGVD. For proper operation of this type of facility, a minimum of 2 to 4 feet is recommended below the bottom of the trench to seasonal high water. Since the road surface, road bed, and depth of the trench all consume vertical space, exfiltration trenches may not be effective in some locations along Estero Boulevard.

  Because of existing development on the island, there are limited options for large-scale water quality treatment facilities. There are however, numerous other options available to improve water quality including both structural and source controls which can be evaluated and potentially incorporated into redevelopment plans or master planning efforts. Other examples include:

• minimize or reduce use of lawn chemicals in swales and along a buffer bordering the canals,
• establishing oil recycling facility to reduce illicit dumping of used oil,
• establish a program to locate and eliminate unwanted or illicit discharges,
• discourage, or prohibit discarding of lawn clippings in canals,
• institute a routine inspection/maintenance program for remaining septic tanks,
• institute leash laws and pet clean-up requirements,
• establish limits on impervious areas, encourage permeable alternatives to impervious surfaces (e.g., wood decks instead of concrete patios etc.) ,
• encourage the use of slow-release fertilizers,
• encourage natural lawn care instead of chemical control,
• sand filters / enhanced sand filters (similar in function to infiltration trenches, but shallower and with greater surface area).

  The advantages and disadvantages of various structural controls are summarized in Table 1.

   

  Table 1 -- Comparison of Stormwater Best Management Practices
  URBAN BMP OPTIONS	Reliability for Pollutant Removal	Longevity*	Applicability to Most Developments	Regional Concerns	Environmental Concerns	Comparative Costs	Special Considerations
  Extended Dry Detention Areas	Moderate, but not always reliable	20+ years, but frequent clogging and short detention common	Widely applicable	Very few	Possible stream warming and habitat destruction	Lowest cost alternative in size range.	Recommended with design improvements and with the use of micropools and wetlands
  Wet Detention Ponds	Moderate to High	20+ years	Widely applicable	Arid and high ET regions	Possible stream warming, trophic shifts, habitat destruction, safety hazards	Moderate to high compared to conventional stormwater detention	Recommended, with careful site evaluation
  Stormwater Wetlands	Moderate to High	20+ years	Space may be limiting	Arid and high ET regions; short growing season	Stream warming, natural wetland alteration	Marginally higher than wet ponds	Recommended
  Multiple Pond Systems	Moderate to High; Reduncancy increases reliablility	20+ years	Many pond options	Arid regions	Selection of appropriate pond option minimizes overall environmental impacts	Most expensive pond option	Recommended
  Infiltration Trenches	Presumed moderate	50% failure rate in 5 years	Highly restricted (soils, groundwater, slope, area, sediment input)	Arid and cold regions; sole-source aquifers	Slight risk of groundwater contamination	Cost-effective on smaller. Rehab costs can be considerable.	Recommended with pretreatment and geotechnical evaluation
  Infiltration Basins	Presumed moderate if working	60-100% failure in 5 years	Highly restricted (see infiltration trench)	Arid and cold regions; sole source aquifers	Slight risk of groundwater contamination	Construction cost moderate, but rehab costs high	Not widely recommended until longevity is improved
  Porous Pavement	High (if working)	75% failure in 5 years	Extremely restricted (traffic, soils, groundwater, slope, area, sediment input)	Cold climate; wind erosion; sole-source aquifers	Possible ground water impacts; uncontrolled runoff	Cost-effective compared to conventional asphalt when working properly	Recommended in highly restricted applications with careful consideration and effective maintenance
  Sand Filters	Moderate to High	20+ years	Applicable (for smaller developments)	Few restrictions	Minor.	Comparatively high construction costs and frequent maintenance	Recommended, with local demonstration
  Grassed Swales	Low to Moderate, but unreliable	20+ years	Low density development and roads	Arid and cold regions	Minor.	Low compared to curb and gut	Recommended, with checkdams, as one element of a BMP system
  Vegetated Filter Strips	Unreliable in Urban Setting	Unknown, but may be limited	Restricted to low density areas	Arid and cold regions	Minor.	Low.	Recommended as one element of a BMP system
  Water Quality Inlets	Presumed low	20+ years	small (<2 acres), highly impervious catchments	Few	Resuspension of hydrocarbon loadings. Disposal of hydrocarbon and toxic residuals	High, compared to trenches and filters	Not currently recommended as a primary BMP option
  * Based on current designs and prevailing maintenance practices. Source : A Current Assessment of Urban Best Management Practices, Techniques for Reducing Non-Point Source Pollution in the Coastal Zone. Metropolitan Washington Council of Governments.

   

  RECOMMENDATIONS

  To the extent possible, the Town of Fort Myers Beach should incorporate the following activities into the objectives and policies of the comprehensive plan.

  One task which should be completed soon is mapping of existing drainage facilities within the Town. The mapping should include a description of relic systems (e.g., filled swales etc.) which are no longer structurally intact or functioning. From the data gathered, an evaluation of system response to a design storm (either SFWMD or a locally derived standard) should be completed under (a) existing conditions and (b) conditions of a fully maintained and operational system. Depending on the results, a limited area stormwater master plan should be considered to evaluate options available to achieve the desired level of service for stormwater flooding. Through the master planning process, the feasibility of drainage options can be evaluated, and the potential for increasing groundwater recharge can be evaluated. For example, it may be that increasing pipe size will have little or no effect because there is insufficient slope in certain areas and pumps may be the only alternative for improvements. Each step could be considered as a short-term objective under a general goals statement which acknowledges the limitations of improvements in highly developed, or redeveloping urban areas. In essence, the goal(s) should establish an attitude of optimal flood protection and water quality improvements within the constraints.

  Planning for water quality improvements is cost-effectively completed at the same time as the master planning process, although many aspects of source control can be implemented in the absence of the master plan. For example, street sweeping, minimizing herbicide/pesticide use near canals, and establishing a recycling facility on the island do not impact drainage and can be done in the absence of a drainage master plan. However, if water quality inlets are used as a means to improve stormwater quality, the flow catchment areas must be incorporated into the placement of the inlets. In most cases, this will be more easily evaluated during a master planning process. As in the case of the drainage goals, the water quality goal statements should acknowledge the existing constraints to large-scale or regional solutions.

  The Town should begin to develop a strategy for water quality monitoring in accordance with the commitments made in the NPDES Part 2 application. Testing of the metal content in canal bottom sediments is a cost-effective way to screen for pollutant sources, particularly contaminated urban runoff. The monitoring program should also incorporate visual inspections of exposed outfalls during dry weather when flow is not anticipated. Inexpensive field test kits can be used to assess whether the unexpected flow (if found) is likely to be a wastewater or commercial/ industrial source. The results, when coupled with the drainage facilities mapping, can be used to isolate potential sources. Periodic re-testing should be considered (e.g., 3-5 years). A history of sediment results could be used to assess the success of other water quality management strategies.

  Funding for master planning, capital improvement projects or maintenance of existing stormwater facilities can be from the general revenue, or through a dedicated source such as a stormwater utility such as previously presented (Bill Spikowski's memorandum to the LPA of 9/4/96).
  

  DEVELOPMENT OF GOALS / OBJECTIVES / POLICIES

  I will be present at the LPA's December 17^th meeting along with Scott McClelland of our firm's Tampa office. We will be prepared to discuss any of these issues further at that time. Then we will draft specific goals, objectives, policies, and LOS standards that could go into the Fort Myers Beach plan to become its stormwater management element. A revised draft with those additions will be circulated back to the LPA for their consideration.

  ---

  ATTACHMENT A - FEDERAL, STATE, REGIONAL & LOCAL OBJECTIVES

  Federal -The major objectives for EPA related to stormwater are included in the 1987 amendments to the Clean Water Act, and promulgated as regulations in the November 16, 1990, Federal Register. Those regulations required Lee County and the municipalities contained within, to submit a two-part National Pollutant Discharge Elimination System (NPDES) application to EPA. In several years, EPA will issue a permit to Lee County and the co-applicants with common and separate requirements for each municipality. The major objectives of the stormwater NPDES program pertinent to the Town of Fort Myers Beach are:

• eliminate non-stormwater discharges to the storm sewer system; and
• reduce pollutants discharged from municipal separate storm sewer systems (MS4s) to the maximum extent practicable (MEP).

  Non-stormwater discharges, referred to as illicit connections or illegal dumping, are expressly prohibited from discharging to the storm sewer system and a condition of the stormwater permit will address the detection and removal of illicit connections.

  Reducing pollutants to the MEP standards is not defined in the regulations. The permit application itself provides the applicant's concept of MEP to EPA and the permit conditions, which incorporate parts of the application, completely define MEP. These conditions require the implementation of many different pollution reduction programs rather than impose numeric discharge limitations. Program elements that have been identified for municipalities that are currently negotiating their permit with EPA, or who have received a permit, include some or all of the following:

  • Ordinances
  • Intergovernmental Agreements
  • Maintenance
  • Litter Control
  • Road Repair and Maintenance Yards
  • Street Sweeping
  • Toxic Materials Handling
  • Solid Waste Programs
  • Construction
  • Public Education
  • Illicit Connection Removal
  • .High Risk Industries Monitoring
  • Stenciling Inlets
  • Monitoring
  • Stormwater Master Planning.

  Although the general nature of the permit conditions can be anticipated from the existing draft and final permits issued in Florida, the exact permit requirements for Town of Fort Myers Beach are unknown and will not be finalized until the permit conditions have been negotiated. This will probably occur some time in 1998 or later. However, one of the program elements which is required and will become a permit condition is some form of water quality monitoring. The purposes of the monitoring are varied: to provide more detailed seasonal information for the estimation of pollutant loading from stormwater outfalls; to provide ambient sampling to show water quality improvements resulting from the implementation of the permit programs; and to provide information on the performance of best management practices. In the Part 2 application, the Town of Fort Myers Beach committed that The Town will develop a [monitoring] plan within the first year of the permit.

   

  State - Although there are many state regulatory agencies, the objectives of the State Water Policy (Rule 62-40, Florida Administrative Codes) are the most pertinent because of the linkage to the development of local comprehensive plans. The State Water Policy is provided for the stated purpose of the management of the waters of the state to conserve and protect the natural resources and scenic beauty and to realize the full beneficial use of these resources. The intent of the Rule is to clarify the policies of Chapters 187, 373 and 403, FS, and to provide guidance to the Department [of Environmental Protection] and Districts in the development of programs, rules and plans.

  First, 62-40.110, Declaration and Intent, requires that local governments consider the State Water Policy in the development of comprehensive plans. This means that in the preparation of goals, objectives, and plans for the protection or enhancement of surface water quality, the provisions of the State Water Policy must be considered. 62-40.432 provides specific surface water protection and management goals and guidelines. The first subsection defines five goals for surface water management:

• protect, preserve and restore the quality, quantity and environmental values of water resources;
• maintain the pre-development characteristics of a site; reduce channel erosion, pollution, siltation, sedimentation and flooding; reduce stormwater pollutant loadings to preserve/ restore beneficial uses; to reduce freshwater losses by encouraging reuse; to improve stormwater recharge; to maintain estuarine salinity and to address stormwater management on a watershed basis;
• eliminate the discharge of stormwater that has not be adequately treated and to minimize adverse impacts of such stormwater;
• reduce unacceptable pollutant loadings from older stormwater management systems (constructed before 1982); and,
• develop comprehensive watershed management plans to prevent flooding and water quality problems as well as to improve existing problems.

  62-40-432(3) describes the roles of the state, water management district and local government in relationship to the State Comprehensive Plan, Local Government Comprehensive Planning and Land Development Act, and the SWIM program. Issues which are to be considered for the issuance of surface water permits are identified in 62-40.432(4) and minimum stormwater treatment performance standards are identified in 62-40.432(5). Of particular interest regarding performance standards, the rule states that stormwater management systems must be designed to achieve at least 95 percent reduction of the average annual load of pollutants in Outstanding Florida Waters such as Estero Bay. These minimum standards may be modified based upon a basin specific plan to achieve pollution loading reduction goals set by the water management districts.

   

  Regional - On a regional basis, the South Florida Water Management District (SFWMD) is responsible for the protection and preservation of the areas water resources. Chapter 373, Florida

  Statutes (FS), provides the enabling legislation under which the Water Management Districts operate. Mandates from 373 FS related to water quality include:

• cooperate with FDEP in the collection and quality control of data;
• establish minimum flows and levels for ground and surface waters; and,
• establish surface water improvement and management plans and programs to protect and restore water quality, habitat, recreation and commercial uses of priority water bodies; and provide assistance to local governments to establish programs to address water quality and habitat issues.

  All changes to surface water drainage within the Town of Fort Myers Beach will be regulated on the regional level by SFWMD regulations found in 40E-40 and 40E-41 FAC.

   

  Local - In accordance with Chapter 163, Florida Statutes, Lee County adopted a comprehensive plan in 1989 which has been amended several times.

  The current plan contains the following goals which may be pertinent to surface water management in the Town of Fort Myers Beach:

  GOAL 37 : PROTECTION OF LIFE AND PROPERTY. To reduce the hazards to life, health, and property created by flooding due to rainfall in a manner consistent with the community's criteria for the preservation of environmental values and the conservation of natural resources.

  GOAL 38 : COORDINATED SURFACE WATER MANAGEMENT AND LAND USE PLANNING ON A WATERSHED BASIS. To protect or improve the quality of receiving waters and surrounding natural areas and the functions of natural groundwater aquifer recharge areas while also providing flood protection for existing and future development.

  GOAL 39 : PROTECTION OF WATER RESOURCES. To protect the county's water resources through application of innovative and sound methods of surface water management and by ensuring that the public and private construction, operation and maintenance of surface water management systems are consistent with the need to protect receiving waters.