Environmental Reform: Stormwater Quality and Ventura County

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Environmental ReformStormwater Quality and
Ventura County

• Anna Lantin, PE, CPESC, CPSWQ
• RBF Consulting

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Where does rainfall and urban stormwater go?

1. Drains to curb inlets then to sewer plants
2. Drains to curb inlets then to rivers/ocean
3. Soaks into the ground
4. Dont really know

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Are there stormwater quality requirements in
Ventura County?

1. Yes
2. No

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Agenda

• Drivers Clean Water Act and NPDES Permitting
• Ventura MS4 Permit - what this means to
  Developers, Land Planners, and Municipalities
• Environmental Reform
• Whats the end game?
• Approaches to environmental objectives
• National Efforts on stormwater, what to expect

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Brief Clean Water Act and NPDES History

• 1969 California Porter-Cologne Act
• 1972 Federal CWA (start NPDES)
• 1990 EPA Publishes NPDES Regulations
• 1990 RWQCBs adopt MS4 Permits
• 1992 SWRCB adopts General Construction Permit
• 2009 New Construction General Permit
• 2010 New Ventura MS4 Permit
• MS4 Municipal Separate Storm Sewer System

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Why is Stormwater Quality a concern?

• When it rains it drains!
• Storm Water Pollution is a concern
• Enforceable regulations

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Who Enforces These Laws?

• EPA
• SWRCB / RWQCBs
• Other Agencies
• Private Citizens
• NRDC
• Baykeepers
• Other Watchdog Groups

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Why Water Quality?
Urban runoff causes surface water
pollution. Best management practices swales,
detention basins, low impact development, trash
removal devices, sweeping
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Calleguas Creek Watershed, Ventura Co.
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So. CaliforniaRegional Municipal Permits

• Ventura County adopted 2010
• Los Angeles County
• City of Long Beach
• Orange County (2)
• San Diego County
• San Bernardino County
• Riverside County (3)

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Ventura County MS4 Permit Purpose

• Lessen water quality impacts of development
• Promote Smart Growth, Compact Development,
  Infill, Redevelopment
• Minimize impacts on biological integrity of
  Natural Drainage
• Mimic predevelopment water balance
• Minimize pollutant loading through source
  control, LID, and treatment control BMPs
• Proper design of BMPs to address pollutants of
  concern and to ensure long-term adequate function

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What does the MS4 Permit apply to?

• All projects 1 acre disturbed area and gt10,000
  sf impervious area
• Industrial park 10,000 sf
• Commercial strip mall, roadway projects 10,000
  sf impervious area
• Retail gasoline, restaurants, automotive service
  facilities 5,000 sf
• Parking lots 5,000 sf impervious area or 25
  spaces
• Projects located in or directly adjacent to, or
  discharging directly to ESA and 2,500 sf
  impervious area

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What does the MS4 Permit apply to (contd)?

• Roadway project Implement Green Streets
• Single family hillside home
• Redevelopment projects
• Create, add, or replace 5,000 sf of impervious
  area
• Existing single family homes are exempt unless
  they create, add, or replace 10,000 sf of
  impervious area

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Urban Runoff Treatment BMPs
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Low Impact Development (LID)

• The permit fundamentally changes development
  through use of low impact development (LID).
  All projects must capture, treat, retain and
  infiltrate runoff from storm events.

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What if not technically feasible?

• Developer must prove that low impact development
  is technically infeasible.
• A developer still must create an EIA that is at
  least 30, but financial contributions or
  construction to public or private offsite LID
  projects may be used as an offset.
• The Alternative Program Projects
• In the same watershed complete construction by
  May 7, 2013
• Approved by the Regional Board
• Demonstrate a reduction of volume and load for
  the subwatershed
• Alternative Program Projects is critical to
  future development in Ventura County.

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Is this the end game?

• Current permit is to lessen impacts from new
  development/redevelopment
• Current permits are based on iterative approach
• Updated every 5 years
• Will this ultimately reduce stormwater pollution?

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Long-Term Strategy

• Stormwater dischargers must ultimately achieve
  receiving water quality standards, but there are
  compliance problems
• The true scope of the problem is unknown
• Nearly 23 million organic and inorganic
  substances
• About 7 million of these substances are
  commercially available1
• Current system is not an efficient approach

1 Daughton (2004)
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Environmental Reform?

• We are investing significant resources in the
  urbanizing fringe, but this area is not the
  problem
• The emphasis on treatment control or LID is not
  the answer for the built environment
• Plumbing is wrong, grading is wrong
• Costs are too high
• Effectiveness is modest
• And, pace of redevelopment is slow

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Consider

• About 110 million acres currently developed in
  the US (5.5 of land area)
• Redevelopment proceeds modestly.
• ABAG estimates 22,274 acres redeveloped from 1985
  to 1995
• This represents 0.5 of land area in the 8
  counties sampled over the 10 year period.
• And, residential areas rarely redevelop

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Meanwhile, Regulatory Pressure is Increasing.

• 1998 - 21,749 waterbodies impaired in US.
• 2008, the number rose to 43,446 in US
• Leading Causes (US EPA)
• Pathogens
• Mercury
• Metals
• Nutrients
• Sediment
• California
• 1700 pollutant-waterbody impaired
• 60 of State drains to impaired waterbodies

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Need for Change

• The current regulatory system is reactive and
  based on proxies to achieve water quality
  standards
• Best management practices (BMPs)
• The system is not working
• Plans to fix impairments require more program
  resources
• Litigation taking more program resources
• Municipal governments being asked to pay for
  programs with no clear pathway to the goal

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True Source Control

• Source Control keeping potential pollutants out
  of stormwater
• Operational
• Focused on physically keeping potential
  pollutants out of contact with rainfall and
  stormwater runoff through covering, berming, or
  cleaning
• True (or Original)
• Focuses on the original source of a potential
  pollutant or on runoff by eliminating or
  significantly reducing the existence of the
  potential pollutant or runoff thereby negating
  the need to physically prevent contact between
  the two 

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True Source Control

• ? Potential Pollutants
• Reduce the number potential pollutants Green
  chemistry (DTSC), Design with nature
• If you make it, you take care of it
  (Cradle-to-cradle) Product stewardship (CPSC),
  Extended Producer Responsibility (EPR) (CIWMB)
• ? Runoff
• Start at the Source / Low Impact Development (LID)

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True Source Control (?Potential
Pollutants)Product-based Pollutants Conceptual
Relationships
Manufacture
True Source Control
Sale
Use
Source Control
Release to urban runoff
Urban runoff discharge
Treatment Control
Receiving water
Costs
Effectiveness
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An Example of Source Control

• Brake pads are the single largest source for
  copper in highly urbanized watersheds in
  California
• SB346 Brake pad bill to minimize copper in
  brakepads

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Costs / Benefits

• Chollas Creek watershed San Diego
• Without brake pad copper reduction 1.4 B
• With 10s M
• Los Angeles River watershed Los Angeles
• Without brake pad copper reduction 15 B
• With 10s M

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Questions?Anna Lantin, PERBF Consultingalantin_at_
rbf.comwww.rbf.com