Municipal Regional Municipal Regional Stormwater NPDES PermitStormwater NPDES Permit

Overview of Requirements, Overview of Requirements, Recommended Changes, and Recommended Changes, and

Assistance NeededAssistance Needed

March 12, 2009March 12, 2009

Municipal Regional Municipal Regional Stormwater Permit – Revised Stormwater Permit – Revised

Draft 2/11/09 Draft 2/11/09 Important Dates:Important Dates:

Submit written comments by – Submit written comments by – April 3April 3 Attend hearing (potential adoption) – Attend hearing (potential adoption) – May 13May 13

Consolidates six Phase 1 municipal stormwater Consolidates six Phase 1 municipal stormwater permits in one regional permit (77 permittees)permits in one regional permit (77 permittees)

Seeks a consistent level of implementation and Seeks a consistent level of implementation and reportingreporting

Some improvements since 2007 draft permit, but Some improvements since 2007 draft permit, but much of permit is unchangedmuch of permit is unchanged..

Cost Implications Cost Implications

Requirements of the Municipal Regional Requirements of the Municipal Regional Stormwater Permit are, as before, Stormwater Permit are, as before, expected to about expected to about doubledouble the cost to the cost to implement the countywide stormwater implement the countywide stormwater programprogram

Municipalities are still evaluating local cost Municipalities are still evaluating local cost implications – City of Dublin has estimated implications – City of Dublin has estimated its costs would increase 125%its costs would increase 125%

Overall Concerns with Overall Concerns with Draft Stormwater PermitDraft Stormwater Permit

LacksLacks prioritizationprioritization of goals and of goals and needs phasingneeds phasing over multiple 5-year, permit cyclesover multiple 5-year, permit cycles

Contains many Contains many unfunded state mandatesunfunded state mandates Increases monitoring, Increases monitoring, special studies, and pilot special studies, and pilot

projectsprojects that that are expensiveare expensive and will trigger more and will trigger more requirementsrequirements

Still contains many Still contains many impractical requirementsimpractical requirements Shows a lack of understanding of municipalities’ Shows a lack of understanding of municipalities’

economic problems economic problems andand what is reasonable what is reasonable

Specific City of X Concerns with Specific City of X Concerns with Draft Stormwater PermitDraft Stormwater Permit

List specific permit concerns and why they List specific permit concerns and why they are an issue for your cityare an issue for your city

Examples of Key Issue AreasExamples of Key Issue Areas

Water quality Water quality monitoring, special monitoring, special studies, & pilot studies, & pilot projectsprojects

Trash and litter Trash and litter controlscontrols

Conditionally exempt Conditionally exempt discharges – minor discharges – minor discharges to storm discharges to storm drainsdrains

Recommended Changes: Water Recommended Changes: Water Quality Monitoring, Special Quality Monitoring, Special

Studies & Pilot ProjectsStudies & Pilot Projects Reduce and Phase Monitoring and Reduce and Phase Monitoring and

Studies to Reduce $900K/year Studies to Reduce $900K/year Cost Cost IncreaseIncrease1.1. Decrease frequency and locations of Decrease frequency and locations of

monitoringmonitoring2.2. Prioritize pollutants for emphasis now Prioritize pollutants for emphasis now

and handle others in subsequent permit and handle others in subsequent permit periodsperiods

3.3. Redirect monitoring we already pay for Redirect monitoring we already pay for through the Regional Monitoring through the Regional Monitoring Program to meet permit requirementsProgram to meet permit requirements

Recommended Changes: Trash Recommended Changes: Trash and Litterand Litter

Reduce number of hot spots and Reduce number of hot spots and focus on trash-impaired waterwaysfocus on trash-impaired waterways

Reduce hot spot monitoringReduce hot spot monitoring

Make clean up level a goalMake clean up level a goal

Focus trash requirements on trash Focus trash requirements on trash from storm drainsfrom storm drains

Reduce amount of area requiring Reduce amount of area requiring use of full-capture trash removal use of full-capture trash removal devicesdevices

Reduce and Phase Trash Clean Up Reduce and Phase Trash Clean Up Requirements to Reduce 350k/year Requirements to Reduce 350k/year

Cost Increase Cost Increase and Potential Liabilityand Potential Liability

Recommended Changes: Recommended Changes: Conditionally Exempt Conditionally Exempt

DischargesDischarges Retain requirements Water Board approved in 2004 Retain requirements Water Board approved in 2004

permit amendmentpermit amendment Eliminate impractical and unnecessary notification, Eliminate impractical and unnecessary notification,

monitoring and reporting requirementsmonitoring and reporting requirements Pumped groundwater, Pumped groundwater, Water from crawl space pumpsWater from crawl space pumps

Retain allowance for individual Retain allowance for individual residential carresidential car washing washing

Eliminate requirement for Eliminate requirement for municipalities to regulate municipalities to regulate potable potable water dischargeswater discharges to storm drains to storm drains

Your Assistance Is Your Assistance Is NeededNeeded

Make Sure Your Municipality Make Sure Your Municipality UnderstandsUnderstands Permit and Permit and Submits Written CommentsSubmits Written Comments by by April 3April 3 Due Date Due Date

Send Send Elected OfficialsElected Officials and Other City Management Staff to and Other City Management Staff to Permit Adoption Hearing on Permit Adoption Hearing on May 13May 13 Verify Hearing Attendance by April 30Verify Hearing Attendance by April 30 Testify About Local Economic Problems Testify About Local Economic Problems Support Recommended Changes to PermitSupport Recommended Changes to Permit

Support Bay Area Stormwater Management Agencies Support Bay Area Stormwater Management Agencies Association’s Efforts to Work with Water Board’s Executive Association’s Efforts to Work with Water Board’s Executive Officer to Incorporate Recommended Permit Changes Officer to Incorporate Recommended Permit Changes Needed in Current EconomyNeeded in Current Economy