TO:
Honorable Mayor and Members of the City Council
THROUGH:
Mark Danaj, City Manager
FROM:
Tony Olmos, Public Works Director
Raul Saenz, Utilities Manager
SUBJECT:Title
Review Draft Enhanced Watershed Management Program (EWMP) and Authorize the City Manager to Submit the Draft EWMP to the Los Angeles Regional Water Quality Control Board (Public Works Director Olmos).
AUTHORIZE REPORT SUBMITTAL
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Recommended Action
RECOMMENDATION:
Staff recommends that the City Council review the Draft EWMP and authorize the City Manager to submit the Draft EWMP to the Los Angeles Regional Water Quality Control Board (Board).
FISCAL IMPLICATIONS:
No fiscal impact associated with this action.
BACKGROUND:
On November 8, 2012, the Board adopted the fourth Los Angeles Municipal Separate Storm Sewer System (MS4) National Pollutant Discharge Elimination System Permit (Permit) under the Federal Clean Water Act for discharges within the coastal watersheds of Los Angeles County. The Permit identifies conditions, requirements and programs that municipalities must comply with to protect regional water resources from adverse effects associated with pollutants in stormwater and urban runoff.
The Cities of Hermosa Beach, Redondo Beach, Torrance and Manhattan Beach, together with the Los Angeles County Flood Control District (Beach Cities) agreed to collaborate on the development of a EWMP for the Santa Monica Bay, Dominguez Channel, and Machado Lake watershed areas within their jurisdictions (Figure 1).
EWMPs are intended to facilitate Permit compliance to ensure that discharges from covered MS4s achieve applicable water quality targets, and that control measures are implemented to reduce the discharge of pollutants to the maximum extent practicable. The EWMP allows Permittees to collaboratively develop comprehensive watershed-specific control plans to:
· prioritize water quality issues;
· identify and implement focused strategies, control measures and Best Management Practices (BMP);
· execute an integrated monitoring and assessment program; and
· allow for modification over time.
On June 28, 2013, in compliance with the Permit, the Beach Cities submitted a Notice of Intent (NOI) to develop a EWMP to the Board. On March 27, 2014, the Beach Cities received a letter from the Board approving the NOI. On June 26, 2014, in compliance with the Permit, the Beach Cities then submitted a draft EWMP Work Plan to the Board. As the next step in the Permit compliance process, the Beach Cities developed a Draft EWMP which will be submitted to the Board no later than June 30, 2015. The Draft EWMP Executive Summary is included in this report (Attachment 1).
DISCUSSION:
As required by the Permit, the Draft EWMP comprehensively evaluates opportunities within the Beach Cities' collective watershed management area for collaboration on multi-benefit regional projects that, wherever feasible, will retain all non-storm water runoff and storm water runoff from a ¾ inch storm over a 24 hour period for the drainage areas.
Additionally, the Draft EWMP addresses required adherence to established water quality standards for each water body in its jurisdiction. Water quality standards include beneficial uses, water quality objectives and criteria that are established at levels sufficient to protect those beneficial uses, and an anti-degradation policy to prevent degrading of water resources.
Geosyntec Consultants, under the direction of Ms. Kathleen McGowen, prepared the comprehensive report in conformance with NPDES permit provisions. City staff has worked closely with the project team to assure the Draft EWMP is ready for submittal to the Board. The major components of this report have been previously presented to City Council over the course of the last year.
The following is a summary of the content of the Draft EWMP:
Section 1- Introduction - Addresses the purpose and regulatory framework of the EWMP in the context of the Permit and states that the EWMP is intended to facilitate effective, watershed-specific implementation strategies in accordance with the Permit.
The Draft EWMP summarizes the Santa Monica Bay and Dominguez Channel-specific water quality priorities identified by the Beach Cities. It outlines the program plan, including specific strategies; control measures and BMPs, necessary to achieve water quality targets and Receiving Water Limitations; and, describes the quantitative analysis completed to support target achievement and Permit compliance.
Section 2 - Santa Monica Bay Watershed, and Section 3 - Dominguez Channel Watershed summarize the technical aspects of the EWMP, including:
· Water Quality Prioritization, which characterizes the stormwater and non-stormwater discharges from the MS4 as well as receiving water bodies; prioritizes water body-pollutant combinations; and assess sources for high priority water bodies.
· BMP Selection objectives include preventing and/or eliminating non-stormwater discharges to the MS4 that are a source of pollutants from the MS4 to receiving waters; achieving all applicable interim and final water quality targets pursuant to corresponding compliance schedules; and ensuring that discharges from the MS4 do not cause or contribute to exceedances of Receiving Water Limitations.
· Reasonable Assurance Analysis (RAA) Approach requires that the Beach Cities' conduct a RAA for each water body-pollutant combination addressed by the EWMP. The objective of the RAA is to demonstrate the ability of EWMP to ensure that Permittees' MS4 discharges achieve applicable water quality based effluent limitations and do not cause or contribute to exceedances of Receiving Water Limitations
Section 4 - EMWP Implementation Schedules - Table 1 presents the compliance schedules necessary to meet the interim and final compliance deadlines for the Beach Cities EWMP water body pollutants.
Section 5 - Assessment and Adaptive Management Framework - EWMP updates are required at two-year cycles by the Permit. The Coordinated Integrated Management Program will gather additional data on receiving water conditions and stormwater/non-stormwater quality. This data will support adaptive management at multiple levels, including: tracking improvements in water quality over the course of EWMP implementation; and, generating data not previously available to support model updates. Over time, the experience gained through BMP implementation will provide lessons learned to support modifications to the control measures identified in the EWMP.
Section 6 - Financial Analysis - Provides an order-of-magnitude estimate of the financial resources that may be required to attain compliance with the water quality targets as well as a recommended project scheduling in order to meet Total Maximum Daily Load (TMDL) compliance deadlines and interim deadlines.
Section 7 - Potential Funding Sources and Financial Strategy - Overview of potentially available funding sources to pay for programs proposed in the EWMP. The funding sources included in this section for consideration are grants, interagency partnerships, bonds, State Revolving Funds, local funding opportunities, and public private partnerships.
Sections 8 - Legal Authority - The Beach Cities have the necessary legal authority to implement the BMPs identified in the EWMP.
POLICY ALTERNATIVES:
Development of a EWMP is regulatory driven and prescriptive, which does not allow for policy alternatives.
PUBLIC OUTREACH/INTEREST:
Public outreach meetings were held on May 21, 2014 and May 17, 2015 to inform and solicit input from the community regarding development of the EWMP. The presentations included an overview of regulatory requirements, general approach to meeting regulatory requirements, local context and concepts being utilized in developing the EWMP
CONCLUSION:
Staff recommends that the City Council approve the Draft EWMP and authorize the City Manager to submit the Draft EWMP to the Board.
ATTACHMENTS:
1. Figure 1 - Beach Cities Jurisdictional Areas
2. Attachment 1 - Draft EWMP Executive Summary
3. Table 1 - Implementation Time-Line
4. Attachment 2 - Draft EWMP Appenix:
A. Notice of Intent
B. Reasonable Assurance Analysis for Dominguez Channel Watershed Within the City of Torrance
C. Machado Lake Work Plan
D. Machado Lake Implementation Plan
E. Walteria Basin Supplementary Write-Up
F. City of Torrance 's Stormwater Quality Master Plan
G. Background Information on the LACFCD
H. Approach to Addressing Receiving Water Exceedances
I. Land Use-Based Wet Weather Pollutant EMC s
J. BMP Effluent Concentrations
K. Sample TLR Calculation
L. MCM Customization Summary
M. LID Ordinances
N. Green Streets Policies
O. Structural BMP Unit Cost Tables
5. Full Draft Report (via compact disc)