The intent of the two stormwater management credits is to limit disruption and pollution of natural water flows by managing and treating stormwater runoff. The City of Hillsboro, Oregon has created a stormwater system that effectively manages and treats all of the stormwater in the community. The city's stormwater system efficiently meets the requirements of the credits SS6.1 for rate and quantity and SS6.2 for treatment. While the USGBC's efforts in this area are laudable, in this particular case it would be redundant to provide stormwater facilities on-site at a cost of nearly $100,000 when the City annually contributes over $500,000 to a system that not only will easily handle the task and achieve the objectives of the USGBC, but goes even farther towards demonstrating our commitment to a sustainable environment. Please indulge us as we explain. Jackson Bottom has always been a special place. Native peoples used the rich bottom lands to gather food and to hunt. Waterfowl passed through in great numbers. Early settlers homesteaded the uplands. Lack of understanding led to years of abuse and degradation of the wetlands. In the last century wetlands have been considered wastelands; thought of as dangerous places with little economic value. More than half of America''s wetlands have been destroyed by filling and draining. The wetlands in Hillsboro were ditched and drained for agricultural purposes. Cattle grazed the native vegetation. The wetlands were used over time for disposal of cannery wastes and construction debris. Only recently have we come to understand that wetlands are critical ecological resources. No other part of our landscapes provide as many benefits as wetlands. In the early 1970s, the City of Hillsboro (owner of the land) made an important decision to rehabilitate the area. Developing a strategy to divert stormwater to the area and to provide tertiary treatment at its wastewater treatment plant at the edge of the wetland, Jackson Bottom Wetlands Preserve is now a 710-acre wildlife preserve located within the city limits of Hillsboro, Oregon. The quiet open waters, rolling meadows and upland ash and fir woods are homes to thousands of ducks and geese, deer, otters, beavers, herons and eagles. Song birds and small mammals, as well as salamanders and rare wetland plants, are dependent on the marshes of The Preserve. Jackson Bottom Wetlands Preserve has become the premier resource center for information and services related to wetlands and aquatic education in the metro region and Northwest Oregon. Thousands of pre-school and school-aged children, bird watchers, university staff and students, researchers and others benefit from the programs and services provided by The Preserve. Its water quality, surface water, ground water recharge and habitat enhancement projects have brought visitors from all over the US to learn from these projects and have brought academic and private sector scientists from countries such as Poland, Australia and Italy to Jackson Bottom to learn from our research. Jackson Bottom offers a wide range of workshops, in-services and customized school involvement programs for schools and educators from throughout the Northwest. Our programs range from one hour to six days in length, with graduate credit available. For school groups, all the programs are age appropriate and are aligned with the Oregon Common Curriculum Goals and State Benchmarks for education. Though Jackson Bottom is a regional and national resource, its greatest impact is felt here at home, in the Tualatin Watershed. Jackson Bottom Wetlands Preserve is a natural oasis that will become more and more precious as this area''s population density continues to intensify. The City of Hillsboro is proud to play an important part in this story. Although the Preserve now performs a variety of functions, its primary purpose is still water quality. Water is the substance that defines the Pacific Northwest and life itself. Jackson Bottom Wetlands Preserve is this region''s leader in utilizing wetlands to improve the quality of our water. Experiments at Jackson Bottom have shown that wetlands serve an important function in the reduction of numerous pollutants. In fact, the use of piped stormwater and treated waste water in constructed wetlands and marsh enhancement projects at Jackson Bottom has significantly improved both water quality and wildlife habitat. We believe our efforts and our continued support of this program satisfies the intent of these two LEED points. We respectfully request the award of these two points toward our quest for Gold Certification.
The USGBC agrees that constructed wetlands can be an excellent sustainability element unto themselves, providing so many of the positive attributes mentioned. However, the existence of a stormwater treatment/management system, such as the one into which the applicant project proposes to tap, does not necessarily address the intent of the credits. SS Credit 6.1 focuses on reducing the quantity of stormwater runoff by managing the overall imperviousness of the project site. Treatment of runoff at an off-site facility is not related to this particular credit. The credit interpretation language submitted does not indicate any efforts to reduce the overall imperviousness on the site (such as through permeable paving, garden roofs, or onsite infiltration facilities). As such, it is difficult to ascertain whether the applicant project will qualify for this point. If the applicant project does not demonstrate onsite management of infiltration, the point for SSc6.1 cannot be awarded. SS Credit 6.2 focuses on improving the quality of stormwater leaving the project site. The LEED v2 Rating System does not award points for merely tying into regional stormwater management facilities (even exemplary ones, such as Jackson Bottom). The credit interpretation language submitted does not indicate any action taken on the project site to improve the quality of water leaving the site, but rather appears to be asking for credit for tapping into an existing resource that is not part of the project to be certified. The USGBC appreciates the value of the Jackson Bottom regional stormwater facility, and encourages the applicant project to consider documenting other synergies between the project site and Jackson Bottom, such as the possible use of its water for non-potable purposes on the project site, for possible inclusion under existing or innovation credits. However, the existence of this resource does not address the requirements of this particular credit.
Related Addenda (Corrections & Interpretations)