Transcript RBF Consulting

Environmental Reform:
Stormwater Quality and Ventura County
Anna Lantin, PE, CPESC, CPSWQ
RBF Consulting
Where does rainfall and urban
stormwater go?
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4.
Drains to curb inlets
then to sewer plants
Drains to curb inlets
then to rivers/ocean
Soaks into the
ground
Don’t really know
25%
1
25%
25%
2
3
25%
4
Are there stormwater quality
requirements in Ventura County?
1.
2.
Yes
No
50%
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50%
2
Agenda
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Drivers: Clean Water Act and NPDES Permitting
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Ventura MS4 Permit - what this means to
Developers, Land Planners, and Municipalities
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Environmental Reform
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What’s the end game?
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Approaches to environmental objectives
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National Efforts on stormwater, what to expect
“Brief” Clean Water Act and NPDES History
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1969 California Porter-Cologne Act
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1972 Federal CWA (start NPDES)
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1990 EPA Publishes NPDES Regulations
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1990 RWQCBs adopt MS4 Permits
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1992 SWRCB adopts General
Construction Permit
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2009 New Construction General Permit
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2010 New Ventura MS4 Permit
MS4 : Municipal Separate Storm Sewer System
Why is Stormwater Quality a concern?
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When it rains it drains!
Storm Water Pollution
is a concern
Enforceable regulations
Who Enforces These Laws?
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EPA
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SWRCB / RWQCBs
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Other Agencies
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Private Citizens
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NRDC
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Baykeepers
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Other Watchdog Groups
Why Water Quality?
Urban runoff causes
surface water
pollution.
Best management
practices;
swales, detention
basins, low impact
development, trash
removal devices,
sweeping
Calleguas Creek Watershed, Ventura Co.
So. California
Regional Municipal Permits
 Ventura County –adopted 2010
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Los Angeles County
City of Long Beach
Orange County (2)
San Diego County
San Bernardino County
Riverside County (3)
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Lessen
water County
quality impacts
development
Ventura
MS4ofPermit
Purpose
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Promote Smart Growth, Compact Development, Infill,
Redevelopment
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Minimize impacts on biological integrity of Natural Drainage
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Mimic predevelopment water balance
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Minimize pollutant loading through source control, LID, and
treatment control BMPs
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Proper design of BMPs to address pollutants of concern
and to ensure long-term adequate function
What does the MS4 Permit apply to?
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All projects ≥ 1 acre disturbed area and >10,000 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
What does the MS4 Permit apply to
(cont’d)?
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Roadway project Implement “Green Streets”
Single family hillside home
Redevelopment projects
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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
Urban Runoff Treatment BMPs
Low Impact Development (LID)
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The permit
fundamentally changes
development through
use of “low impact
development” (LID). All
projects must capture,
treat, retain and infiltrate
runoff from storm
events.
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
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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.
Is this the end game?
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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?
Long-Term Strategy
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Stormwater dischargers must ultimately achieve
receiving water quality standards, but there are
compliance problems
The true scope of the problem is unknown:
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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)
Environmental Reform?
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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:
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Plumbing is wrong, grading is wrong
Costs are too high
Effectiveness is modest
And, pace of redevelopment is slow:
Consider…
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About 110 million acres currently ‘developed’ in
the US (5.5% of land area)
Redevelopment proceeds modestly….
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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
Meanwhile, Regulatory Pressure is Increasing….
1998 - 21,749 waterbodies impaired in US.
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2008, the number rose to 43,446 in US
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Leading Causes (US EPA):
1. Pathogens
2. Mercury
3. Metals
4. Nutrients
5. Sediment
 California
 1700 pollutant-waterbody impaired
 60% of State drains to impaired
waterbodies
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Need for Change
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The current regulatory system is reactive and based
on proxies to achieve water quality standards:
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Best management practices (BMPs)
The system is not working
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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’
True Source Control
Source Control = keeping potential pollutants out of
stormwater
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Operational
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Focused on physically keeping potential pollutants out of
contact with rainfall and stormwater runoff through covering,
berming, or cleaning
True (or Original)
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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
True Source Control
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↓ Potential Pollutants
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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
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Start at the Source / Low Impact Development (LID)
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
Effectiveness
Receiving water
Treatment
Control
Costs
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
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Chollas Creek watershed – San Diego
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Without brake pad copper reduction = $1.4 B
With = $10s M
Los Angeles River watershed – Los Angeles
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Without brake pad copper reduction = $15 B
With = $10s M
Questions?
Anna Lantin, PE
RBF Consulting
[email protected]
www.rbf.com