We are seeking approval for an innovation point for exemplary overall stormwater management performance which significantly exceeds the credit requirements of SSc6.1 and SSc6.2. Our project is being constructed on the site of a former landfill (a designated Brownfield) in Stafford Township, New Jersey and is surrounded by the Pinelands National Reserve. The stormwater management system for our project site is designed to meet the most stringent water quality standards ever imposed in the State of New Jersey through a combination of bioretention systems and wetlands. The Pinelands rules require 100 % infiltration of the entire volume of runoff from new impervious surfaces in the 10 year design storm which is defined as 5.4 inches of rainfall in 24 hours. In addition, this project must meet a minimum 96% TSS removal in the water quality storm, which is defined as a 1.25 inch rainfall in 2 hours. The specific stormwater management standards can be found in the New Jersey Administrative Code at N.J.A.C. 7:8 and the New Jersey Administrative Code at N.J.A.C. 7:50-6.84. According to LEED standards which define humid watersheds as those that receive at least 40 inches of rainfall per year, our site would be considered a humid watershed requiring that a 1" rainfall must be treated to meet the 90% average annual rainfall equivalent. New Jersey requires the treatment of a 1.25" minimum rainfall which is more stringent than the LEED standard. The system designed for this site treats a minimum of 2.55" of runoff which is approximately 2.7" of rainfall and infiltrates 100% of the volume of 78 of the 79 average annual storm events. Overall, the system will treat and completely infiltrate 95.5% of the 46.32 inches of average annual rainfall. The State of New Jersey Stormwater Best Management Practices Manual establishes the TSS Removal rates for various BMP\'s (page4-2). Bioretention systems and wetlands have TSS removal rates of 90%. Infiltration structures have removal rates of 80%. Multiple BMP\'s can be used in series to treat stormwater. The proposed bioretention basins remove 90% TSS. Below the bioretention media is a natural sand infiltration strata. The TSS removal for two feet of sand is 80%. The net effect of stormwater moving through the biomedia and then sand is removal of 98% of TSS according to State standards. This entire stormwater management system has been reviewed and approved by the New Jersey Pinelands Commission. They have concluded that the system meets the 96% removal requirement for TSS in a 1.25" rain event. They have also concluded that the basins have sufficient capacity to store and infiltrate 100% of the 1.25" water quality storm. The system not only treats and infiltrates 100% of the runoff from a 1" rainfall event, it completely stores, treats, and infiltrates 78 of the 79 annual storm events and 95.5% of the total annual rainfall. In conclusion, our project\'s stormwater management system significantly improves upon the predevelopment conditions (a leaching landfill) and helps to restore the natural hydrology of the area. The stormwater design substantially exceeds the LEED SS credit 6.1 & 6.2 requirements for stormwater quantity & quality control, and fulfills the credit intents to "limit disruption and pollution of natural water flows by managing stormwater runoff" & "limit disruption of natural hydrology by reducing impervious cover, increasing on-site infiltration, and managing stormwater runoff". We will provide the submittals necessary to establish sufficient evidentiary information for USGBC review of this ID credit, including a copy of the stormwater management system approval from the Pinelands Commission, schematic exhibits detailing our project\'s stormwater design, and any further information requested.
Though the stormwater management system described is laudable, there is currently no exemplary performance credit available for SSc6.1 or SSc6.2. Typically the requirement for an exemplary performance ID credit is doubling the credit threshold. Obviously it is impossible to double 80% TSS removal, and the CIR is not clear as to if the existing site is more or less than 50% impervious , and whether it is possible to double the stormwater rate and quantity reduction threshold. Although the project appears to be setting a higher performance standard than that required by the LEED NC Stormwater credits require, we do not believe that simply following a higher standard warrants Innovation In Design consideration. Applicable Internationally.