The Stormwater Blogs

I understand the goal that EPA is trying to achieve (improved water quality) but EPA is too assumptive that MS4s have the skills and resources to hit the ground running. You mention wasteload allocations, numeric limits, and such. I don't even have TMDLs for our receiving waters. Writing our permit to meet these limitations without having all of the data is putting the cart way before the horse. I don't want to be locked into attempting to control every drop of runoff from construction sites and then not have the ability to do so due to extraneous reasons, like crazy weather patterns. What would the ramifications be from EPA should we continuously exceed estimated limits? What about heavy rain events? Are those built into a margin of safety? EPA is very mum, keeping their thoughts and regulations very close to their vests. MS4s want to know what to expect and what they're going to get really hammered with. I see costs for our programs going upward more and more each year. Unless better, low-cost training is provided, many small MS4s are going to be left to hang.

I agree with the John. As a jurisdiction with TMDLs and a turbidity standard in the state construction permits, trying to monitor and run MUSLE programs seems way beyond what MS4s and contractors can hadle. All the best BMP science -even the old stuff out of EPA - shows that even simple BMPs can have significant effects on limiting environmental impacts. When we as regulators are still struggling to get contractors to even use surface roughening and appropriately installed and maintained perimeter controls, these more numeric related evalautions seem just beyond the capability of many of the small construction firms we deal with. I would rather see regulators at all levels, including EPA, working in the field getting real results rather than spending time working with more esoteric evalaution tools that have so many assumptions and safety factors they may not really represent what is going on with the landscape anyway.

Just to clarify, I'm not against these newer, more prescriptive approaches. TMDLs and more detailed requirements are necessary (and often required) to meet our water quality goals. Its just going to take a lot of time and work to bring educate and train everyone. As an example, most municipalities do not conduct regular stormwater inspections at commercial businesses. However, California identified these as potential stormwater pollution sources in the 1990s and began requiring programs to address these (starting with education, then inspections). The cities fought this, but used the cities own datat to show that these commercial businesses were causing water quality problems. Now most of the Phase I cities in California have some type of commercial inspection program. The only way you advance the stormwater program is by figuring out what's working, what's not, and introducing revised programs and approaches to address the problems. That, after all, is the iterative approach that is the basis of EPA's stormwater management philosophy.

The Cities in Ventura County are facing a draft Storm Water NPDES permit from the L.A. RWQCB that institutes Municipal Action Levels (end of pipe numeric limits). The only reasonable way to attempt to achieve the MAL's is to retrofit the existing communities with structural BMP's at a significant cost. This may well be the trend of future storm water compliance and there are significant technical issues associated with the concept. However the City of Fillmore's primary concern is that it is financially impossible to achieve the retrofit work required because there is no financial mechanism permitted by the State of California to generate the funds necessary. With the passage of Proposition 218 and following court decisions cities would have to obtain 2/3rds voter approval of the tax or fee increase to pay for the retrofit work. Therefore the City of Fillmore is asking the L.A. RWQCB to strike the MAL's from the permit and pursue the retrofit concept simultaneously State wide in California. This is the only way a financial mechanism can obtain enough political support to be implemented. Without the a financial mechanism it can't happen. To retrofit the City of Fillmore with storm water treatment devices will cost $900 per year or $75 per home per month. The voters have said they will approve $20 per year so there is a $880 per year gap between the voters and RWQCB. Retrofitting the existing community is a huge step and it needs to be implemented with public support state wide or it won't happen.

John Many years ago when the first call for pubic comment came on NPDES program. Region IV in Atlanta held one of those meetings. I made the comment at the time that sampling and monitoring would be necessary. that was long before BMP's became a common buzz word. Griffin was one of the NSF/ETV Protocol Test Site for Proprietary BMP's. Said it then and I will say it again. This is going to be a more complicated financially than anything. With have had an on going extensive monitoring and sampling program since 1998. It has supplied us with the knowledge necessary to figure out the what but it also has shown that most local govenments even with a funding source of a stormwater utility will not begin to have the financial ware abouts. Wastewater was given a significant funding from Big Brother and the a major reduction in pollutants was achieved. It not "complicated" it's "Financial" Sometimes I wonder why we don't put it back in a CSO setting.

I completely agree with the above comments. I continue to work more and more with utilities that are struggling with financial burdens because of NPDES -- burdens that they will not be able to take care of. Working as an engineer for consulting firm R. W. Beck, www.rwbeck.com, we are continuously working in the field to provide real lasting solutions. The problem continues to be that utilities can not afford to implement these solutions. Finance is the key to so much that we have created specialized processes to help utilities get out and stay out of the hole. In the past we started with the processes, now we start with the finance.