FAQ: Meeting Stormwater Management Requirements through Off-Site Retention Volumes

1. How can off-site compliance make my project cheaper, easier, and greener?

Choosing to meet part of your regulated project’s stormwater management obligation by using Stormwater Retention Credits (SRCs) may be cheaper, easier, and greener than complying fully on-site. You should consider using SRCs if you want your project to be:

Easier, cheaper, and greener: SRCs can be used to meet the District’s stormwater management regulations as an alternative to on-site green infrastructure
Easier, cheaper, and greener: If your project drains to Combined Sewer System (CSS) storage tunnels, you can comply 100% off-site with your retention requirement.
Easier and cheaper: Using SRCs may be a good option if on-site conditions limit opportunities for cost-effective stormwater management practices.
Cheaper: If on-site stormwater management practices displace amenities that would generate revenue for your property, such as rooftop patios or underground parking spaces, you can use SRCs instead.
Easier: Using SRCs may save time in permitting if you can submit a simpler design that involves less on-site stormwater management.
Easier: Using SRCs may minimize requirements for maintenance of on-site stormwater management practices
Easier: Using SRCS may increase flexibility to change compliance strategies or uses of space in the future
Greener: by using SRCs, you can support construction of green infrastructure in areas that maximize environmental improvements. New GI has the most benefits for the District’s waterbodies when it is installed in the area served by the Municipal Separate Storm Sewer System (MS4), since stormwater pollution from these areas typically flows untreated into District waterbodies.
Easier and greener: Using SRCS may qualify your project for LEED credit.
Cheaper and greener: DOEE provides a payment to certain SRC sellers who offer their SRCs to buyers at reduced rates. This payment is available to SRC Price Lock Program, who all sell High Impact SRCs. DOEE’s payment increases for large or multi-year transactions, making larger purchases even cheaper for buyers. Since the payment is only available for High Impact SRCs, this helps to make it less expensive to meet your stormwater obligation with the SRCs that are best for the District’s waterbodies.

2. How do I buy Stormwater Retention Credits (SRCs)

Buying SRCs can be a quick process if you follow these steps:

Look up recent SRC trading prices to get a sense of the going rate over the last 12 months.
Decide how many years of Offv compliance you want to achieve. For example, if you have an Offv of 5,000, you could purchase 50,000 SRCs to comply with your Offv for 10 years. Buying SRCs for multiple years at a time means you don’t need to keep purchasing SRCs in small groups on an annual basis. Buying in bulk may also help you negotiate a better price.
Look up SRCs for Sale to find contact information for sellers. Use the filters on the page to search for sellers who are able to provide the number of SRCs you need at the price you want and to identify SRCs that will maximize the environmental and community benefits of your purchase.
Contact some of the SRC sellers. You can offer to pay whatever SRC price that you think is fair, even if it’s different than the seller’s asking price.
Agree to terms. While you are not required to sign a contract, DOEE offers a template contract that you can use. Many SRC sellers already have experience filling out this template for use in trades. DOEE is not involved in these negotiations.
The SRC seller will notify DOEE that they want to sell some of their SRCs to you. DOEE will record that you are now the owner of the SRCs and send you an email confirmation within one business day of receiving this notification.
After DOEE has recorded that you are the owner of the SRCs, you must also submit a form through the DOEE Surface and Groundwater System to use your SRCs for Offv compliance. DOEE will record that you have used the SRCs and send you an email confirmation.

3. Are SRCs available for me to purchase?

Since DOEE certified the first SRCs in 2014, there have always been SRCs available to buy. Use the list of SRCs for Sale to find contact information for sellers. Review recent SRC trading prices so you know what other buyers have paid recently. SRCs can be banked indefinitely, meaning that you can purchase them now and save them for use on future projects. You can also purchase and use SRCs to achieve multiple years of Offv compliance at once.

In addition to purchasing SRCs on the market, organizations that own many properties may be able to generate their own SRCs by voluntarily installing green infrastructure (GI) on their other properties. This may be beneficial if the other properties have opportunities for low-cost GI projects.

DOEE is actively working to ensure a stable long-term supply of SRCs through the SRC Price Lock Program, which was launched with $11.5 million to incentivize SRC generation. In the unlikely event that SRCs are unavailable, sites with Offv obligations also have the option to pay In-Lieu Fee (ILF) or install more on-site GI.

4. Should I buy SRCs or pay the In-Lieu Fee?

It is cheaper to use SRCs than it is to pay ILF. One SRC achieves one gallon of Offv compliance for one year. An ILF payment of $3.78 also achieves one gallon of Offv for one year (based on the ILF rate effective April 21, 2017), but is 79% higher than the 2017 average SRC price of $2.02.

The In-Lieu Fee (ILF) has the effect of creating a price ceiling in the SRC market. DOEE adjusts the ILF price annually for inflation.

5. How Does DOEE’s Payment Help Buyers Save Money, Especially in Large Transactions

DOEE offers a payment to assist with buying SRCs. When a buyer views the list of SRCs for Sale, the registry automatically incorporates DOEE's payment, showing the price the buyer will pay (buyers can continue to negotiate price and quantity). The payment is only available when buying SRCs from participants in the SRC Price Lock Program. These SRCs are all considered "High-Impact," meaning that they come from the green infrastructure projects that do the most to protect the District's rivers.

This payment helps buyers save money over time when purchasing in large transactions. For example, if a buyer has a 4,000-gallon Off-Site Retention Requirement, the buyer could purchase 4,000 every year. If the seller charges $1.79/SRC, the buyer would pay $7,160 each year. However, if the buyer seeks to comply for 25 years up front by purchasing 100,000 SRCs, DOEE will pay the seller to drop the buyer’s price to $1.39/SRC. The buyer would pay $139,000, which would save $40,000 as compared to paying $7,160 each year for 25 years.

6. Should I meet my Offv for multiple years at a time?

You must comply with your Offv requirement for at least 1 year at a time, but you have the option to meet your Offv for multiple years up front. For example, if you have an Offv of 5,000, you could purchase 50,000 SRCs to comply with your Offv for 10 years.

Purchasing a larger number of SRCs to comply with your Offv for multiple years may also help you negotiate a more favorable purchase price. When viewing the list of SRCs for sale, you can pick how many SRCs you want to purchase. You will note that certain SRC sellers will offer lower prices for larger transactions sizes as a result of the payment DOEE will make to support your SRC purchase. Complying with your Offv requirement for multiple years at a time may also save you time by consolidating SRC purchases and by reducing the number of times you need to submit an Application to Use SRCs.

7. Which SRCs should I buy? Are there restrictions on which SRCs I am allowed to use? Are some SRCs better than others?

Most SRC buyers are required to purchase SRCs generated from the Municipal Separate Storm Sewer System (MS4). The list of SRCs for Sale makes it easy to identify MS4 SRCs. Additionally, Anacostia Waterfront Development Zone (AWDZ) sites should use SRCs generated within the Anacostia River watershed. If these sites use SRCs generated outside of the Anacostia watershed, they must use 1.25 SRCs to satisfy each gallon of Offv. Additional details are available below.

To maximize the environmental and community benefit of your SRC purchase, you should buy SRCs generated by a voluntary GI project that drains through the MS4 to a small stream in the Anacostia River watershed. The list of SRCs for Sale allows you to filter for these SRCs.

SRCs that a site can use are summarized below. You can use DOEE’s searchable map to determine where your regulated site is located or download a PDF copy.

Regulated Site Location	Amount of SWRv Achieved On-Site	SRCs that may be Used
AWDZ sites*		SRCs from MS4**
MS4	>=50%	SRCs from MS4***
MS4	<50%*	SRCs from MS4***
CSS areas where CSOs are reduced with GI	>=50%	Any SRC
CSS areas where CSOs are reduced with GI	<50%*	SRCs from MS4 SRCs from CSS areas where CSOs are reduced with GI
CSS areas where CSOs are reduced with storage tunnels	>=50%	Any SRC
CSS areas where CSOs are reduced with storage tunnels	<50%	SRCs from MS4

^{* Relief from extraordinarily difficult site conditions is required.

**AWDZ sites must use 1.25 SRCs for every gallon of Offv if SRCs are generated outside the Anacostia River watershed.

***Any SRC may be used in the MS4 if the SRC was self-generated from a SWMP approved prior to April 30, 2020 and used to meet an Offv approved by DOEE prior to April 30. This requirement is also waived if the SRCs are purchased in accordance with a contract signed prior to April 30, 2020.

****Any SRC may be used if generated under a common plan of development (e.g. two phases of a multi-phase project).}

8. How much of my stormwater management requirement can I meet with SRCs?

For any project draining to Combined Sewer System (CSS) storage tunnels, you can achieve 100% of your retention requirement with SRCs, provided that those SRCs are generated in the MS4. All other sites must achieve 50% of the requirement on-site before using SRCs, unless they obtain DOEE approval for extraordinarily difficult site conditions, in which case they can meet more than 50% of their requirement off site.

You can use DOEE’s searchable map to determine where your regulated site is located or download a PDF copy.

9. How long do SRCs last? Do I need SRCs from a specific year?

Once used, one SRC satisfies one gallon of Offv for one year. However, SRCs can be banked indefinitely with no expiration or decrease in their ability to achieve an Offv. Therefore, the date on which an SRC is certified or purchased does not affect your Offv compliance. You can purchase SRCs now to save for use later, and you can purchase multiple years-worth of SRCs up-front.

10. If I buy SRCs and the seller fails to maintain the SRC-generating GI, will I fall out of compliance with my Offv obligation?

No. When you buy SRCs, you do not assume any liability for maintaining the SRC-generating GI. If the original SRC seller fails to maintain the SRC-generating GI, then the original SRC seller is responsible for compensating DOEE for the lost retention capacity.

11. How does DOEE track SRC trades?

DOEE tracks each SRC using its Surface and Groundwater System. DOEE publishes information about available SRCs and SRC sales through the SRC and Offv Registry. The terms of SRC sales are negotiated privately between the buyer and seller. DOEE is not involved in these negotiations.

When an SRC sale is negotiated, the seller submits the Application to Transfer SRC Ownership through the DOEE Surface and Groundwater System. Sale prices are recorded in the SRC and Offv Registry, but the identities of buyers and sellers are not.

12. Is it environmentally responsible to comply with my regulatory requirement off-site by purchasing and using SRCs?

Purchasing and using SRCs can help to get green infrastructure (GI) installed faster and more cost-effectively in the areas where it provides the greatest benefit. To ensure your SRC purchase achieves this outcome, you should purchase SRCs labeled “High-Impact[EM(1] ” in the SRC registry.

GI is especially important within the MS4, where stormwater drains directly to the District’s waterbodies, often without treatment. Purchasing and using SRCs generated by new, voluntarily-installed GI in the MS4 can encourage GI development where it will provide the greatest water quality benefits. When regulated sites located in the Combined Sewer System (CSS) purchase SRCs from the MS4, this has the effect of shifting the location where GI is installed from the CSS to the MS4. Because billions of dollars of GI is required in the MS4 and public funding is limited, this shift helps accelerate progress towards restoring fishable, swimmable waterbodies.

Purchasing and using SRCs also encourages smaller scale and more dispersed GI, which retains volume from a greater area. This results in more total runoff captured in more frequent, smaller storms, including more of the dirtiest “first flush” volume.

13. Can sites that trigger the District’s stormwater management regulations generate SRCs?

Sites that trigger the District’s stormwater management regulations can generate SRCs in two ways: by installing GI within the site’s regulated area that retains stormwater beyond the required Stormwater Retention Volume (SWRv), up to the volume of runoff in a 1.7-inch storm, or by voluntarily installing GI outside the regulated area of the site. While sites that generate SRCs by exceeding their SWRv are not eligible to participate in the SRC Price Lock Program, sites that generate SRCs by voluntarily installing GI outside of the regulated area can participate in the SRC Price Lock Program if they are located within the MS4.

Additionally, sites that trigger the Districts Soil Erosion and Sediment Control and/or Green Area Ratio regulations, but not the stormwater management regulations, can generate SRCs by installing GI according to a voluntarily-submitted Stormwater Management Plan. This can be a cost-effective option since construction resources have already been mobilized on the site. These sites are also eligible to participate in the SRC Price Lock Program if they are located within the MS4.