Environmental Site Design for Clean Water Advocates

If you’re concerned about an aquatic resource threat then contact CEDS at 410-654-3021 (call-text) or Help@ceds.org for an initial no-cost discussion of strategy options.

Housing projects, shopping centers, and other forms of growth has impaired 2,000 miles of Maryland waterways. New growth may affect another 20 miles annually.

As illustrated in the following graphs, Environmental Site Design (ESD) is so effective in reducing polluted runoff from rooftops, streets and other impervious surfaces that it offers the possibility of getting nutrient loads close to natural rates thereby halting the decline. But this will only happen if both volunteer and professional clean water advocates provide the oversight and public support critical to making ESD work. To learn how you can help read on.

ESD nitrogen graph

ESD phosphorus graph
What is Environmental Site Design
ESD is a comprehensive approach to planning development so we get more of the benefits and fewer aquatic resource impacts. Through ESD project planners:

identify those portions of a site where development can occur with the least impact to wetlands, streams, forests, and other sensitive resources;

consider alternatives for minimizing the area of rooftops, parking lot, streets and other new impervious surfaces created on the site;

locate buildings and other impervious surfaces so they drain to areas on the site suited to the use of highly-effective aquatic resources protection practices; and

ensure that all impervious surfaces drain to one of 15 ESD practices which are highly-effective in trapping pollutants, reducing downstream erosion, and getting runoff into the soil to maintain dry-weather inflow for nearby wetlands and streams.
To see these 15 ESD practices and for further detail on how ESD works check out the following Adobe version of our PowerPoint presentation: Does A Concept Plan Show ESD Has Been Used To Maximize Aquatic Resource Protection?

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Restoring Waters Harmed By Past Growth
A major difference between ESD and past approaches to stormwater management is that runoff from both existing and new impervious surfaces must be treated. For example, let’s say a 20-acre site has an existing block of stores on it which covers about five acres. A proposal is made to build more stores and expand parking areas which will add another five acres of impervious area.

In the past, treatment would only have been required for the new five acres of impervious surfaces. But with ESD runoff from all ten acres of existing and proposed rooftops, parking, and other impervious surfaces must be treated if located within the limits of disturbance.

The implications of this requirement are truly profound.

Over time most existing developed areas will be modified in ways that will result in treating runoff with ESD practices. In other words, treatment will eventually be provided for most existing impervious areas. This treatment will allow recovery of downstream waters.

How quickly could this happen?

Well, Philadelphia has requirements similar to ESD. Officials there believe as much as 59% of the existing impervious area may be retrofitted with treatment practices as soon as 2035.

It is unclear if ESD in its present form can provide this tremendous benefits. If the Limits of Disturbance are defined very narrowly then little existing impervious area runoff will be treated with ESD practices. However, defining limits more broadly may increase development costs. If this is the case then we should explore ways that we can provide incentives to maximize treatment.

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Does A Project Fully Comply With ESD?
We offer two levels of review for answering this question: Initial and Detailed. Click the following text for a PowerPoint presentation describing both levels of review:

Does A Concept Plan Show ESD Has Been Used To Maximize Aquatic Resource Protection?

The first step with both levels of review is to obtain the ESD Concept Plan and Narrative as well as the site or subdivision plan from the local planning-zoning staff or the local stormwater review officials:

Stormwater Review Officials – County

Stormwater Review Officials – Municipal

If you have difficulty obtaining the plans or narrative contact us at Help@ceds.org or 410-654-3021. We can make a call to see if we can get the documents. There’s no charge for this service.

Preliminary Review: With the project plans spread out before you, check the following items. A “yes” to each of these questions indicates ESD compliance.
If wetlands, streams or other waters are present on or next to the site, then do you see buffer areas adjoining these sensitive resources?
Do the plans show a forest conservation easement or other areas which will remain in forest or will be planted with trees?
Do the plans show that all existing and proposed impervious areas will drain to one or more of the ESD practices presented in: Overview: How ESD Works & Maximizing the Benefits?
If you answered yes to each of these questions, then chances are the project is making good use of ESD. However, take a moment to look for the following. A “yes” to any of these questions indicates that full ESD compliance has not been fully achieved.

Do you see a note on the plans indicating forest conservation has been waived or a “fee-in-lieu-of” will be paid?
Is there a note indicating the applicant has requested a waiver to wetland or stream buffer requirements?
Will any proposed streets or other development intrude upon wetland or stream buffers?
Do you see a note on the plans or any reference in the narrative that end-of-pipe structural measures will be used?
Note that the preliminary review applies to most projects with the exception of those considered Redevelopment. A redevelopment project is one where more then 40% of a site is covered by existing impervious surfaces. See Detailed Review below for advice on evaluating ESD compliance on Redevelopment projects.

If you have any questions on the preliminary review then contact us at Help@ceds.org or 410-654-3021. Also, could you e-mail us the findings from each preliminary review you conduct? We hope to compile a statewide database consisting of reviews conducted by clean water advocates.

Detailed Review: As the phrase implies, in this review the items noted above are examined in much greater detail. The Detailed Review addresses the following questions:
Have the soils most likely to cause pollution been protected from the erosive effects of rainfall and runoff?
Have all opportunities been fully explored to maximize protection of wetlands, streams, forests, and other sensitive resources?
Have all options for minimizing the extent of impervious areas and the limits-of-disturbance been exhausted?
Have impervious areas been located to drain to areas on the site suited to ESD practices?
Has ESD been utilized to the Maximum Extent Practicable?
The specifics of the detailed review are too complex to present in this webpage. Instead, the specifics are presented in the following Adobe version of our PowerPoint presentation on: How to Use ESD to Protect Aquatic Resources. We also created the following checklist to walk clean water advocates through the detailed review process: CEDS Environmental Site Design Checklist.

If you have any questions on the detailed review then contact us at Help@ceds.org or 410-654-3021. Also, could you forward us a copy of your completed checklists? We hope to use these checklists to compile a statewide database of reviews conducted by clean water advocates.

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Equitable Solutions: A Better Way To Resolve ESD Disputes
If you feel project plans show full use has not been made of Environmental Site Design, then we urge you to think in terms of Equitable Solutions rather then litigation. An Equitable Solution is one which resolves citizen concerns – in this case a perceived ESD deficiency – while allowing the applicant to achieve their goals. CEDS has found that the Equitable Solutions approach triples the likelihood of resolving citizens concerns at a fraction of the cost of hiring a lawyer to stop a project.

Here are the steps we suggest for winning greater use of ESD through Equitable Solutions:

Contact the applicant and ask that they consider making greater use of ESD.
If the applicant claims that ESD has been used to the maximum extent practicable, then speak with the local review officials to verify that this is correct. If you would like another opinion then please forward the plans and narrative to CEDS.
If you are still dissatisfied with the extent to which ESD will be used, then contact your Council representative or Commissioner. Ask what incentives might be offered to the applicant to increase the use of ESD.
If you remain dissatisfied then consider moving on to the more aggressive aspects of the Equitable Solutions approach.
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ESD Resources
Following are links to the resources cited in these presentations:

Chesapeake Bay watershed ESD-LID resources:


District of Columbia


New York



West Virginia

ESD Legal & Technical Issues Workshop Presentation

ESD Survey Results:

County Officials


Does A Concept Plan Show ESD Has Been Used To Maximize Aquatic Resource Protection?

CEDS Environmental Site Design Checklist

CEDS Equitable Solutions webpage

CEDS Exposed Soil = Pollution webpage

CEDS Smart Legal Strategies webpage

Center for Watershed Protection

Chesapeake Stormwater Network

Chesapeake Bay Stormwater Training Partnership

MDE 2000 Stormwater Design Manual

MDE 2007 Stormwater Act webpage

Maryland Stormwater Contacts – County

Maryland Stormwater Contacts – Municipal

USDA-NRCS Web Soil Survey

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Free Review of Plans for ESD Compliance
If you are seeking to protect a waterway or neighborhood from the impact of a proposed development project, then CEDS would be delighted to take a quick, no-cost look at project plans for compliance with ESD requirements. We can also check for a number of other potential impacts, such as traffic, school overcrowding, viewsheds, and other issues listed in the CEDS Quality of Life Impact Review Checklist or our 300-page book How To Win Land Development Issues.

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ESD Engineers
CEDS often receives requests from nonprofit groups, development companies, attorneys, and others for referrals to engineers who can prepare Maryland Environmental Site Design plans. To satisfy these requests we are compiling a directory of ESD Engineers. If you would like to be listed in the directory then click the following text: ESD Engineers Survey.

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ESD Workshop For Your Area
Contact CEDS at 410-654-3021 or Help@ceds.org to discuss the possibility of conducting an Environmental Site Design workshop in your area. The workshop can be a two-hour evening introduction or an all-day intensive training.

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Report Card on ESD Compliance in Your Area
We can also carry out a review of how ESD is being implemented in a watershed, town, county or other area. This would include an assessment of whether approved plans fully comply with ESD requirements, how well ESD practices are being installed and maintained, and strategy recommendations for improving both. For an example see: Opportunities to Improve Environmental Protection in the Critical Area of Saint Mary’s County.

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Upcoming ESD Workshops
Presently, no workshops are scheduled. If you’d like to discuss scheduling a workshop for your area then please contact CEDS at 410-654-3021 or Help@ceds.org.

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