ࡱ> %` XbjbjNN 8|,,L  $&$&$&8\&L&< c&&''''R(.(( $h\ /J(N(// ''4333/p ' '3/33x H'& 0JӇ$&e0pH~d30cXM0MHVpM ƒ(R*3,T-(((y3j(((c//// $     MEMORANDUM TO: California Regional Water Quality Control Board, San Diego Region  SEQ CHAPTER \h \r 1 FROM: Wes Ganter, PG Environmental, LLC Scott Coulson, PG Environmental, LLC DATE: 30 June 2008 SUBJECT: Watershed Urban Runoff Management Program (WURMP) Assessments Overview On April 15 - 18, 2008, PG Environmental, LLC, a USEPA Region 9 contractor, and the California Regional Water Quality Control Board, San Diego Region (Regional Water Board), conducted a series of interviews of copermittees regulated by Regional Water Board Order No. R9-2007-0001 (NPDES Permit No. CAS0108758). Regional Water Board Order No. R9-2007-0001 (hereafter, Order) regulates twenty-one municipal copermittees residing within eight Watershed Management Areas (WMAs). Section E. of the Order, Watershed Urban Runoff Management Program, requires that each copermittee collaborate with other copermittees within its WMA(s) to implement an updated Watershed Urban Runoff Management Program for each watershed and reduce the discharge of pollutants from the MS4 to the maximum extent practicable (MEP), and prevent urban runoff discharges from the MS4 from causing or contributing to a violation of water quality standards. Pursuant to this requirement, each copermittee has participated in the development of one or more Watershed URMP documents (hereafter, WURMPs) for their respective WMAs. As of March 24, 2008, copermittees were required to be implementing the programs and BMPs described within the individual WURMP documents. For the purposes of this activity, the San Diego Bay and Carlsbad WMAs, along with their respective WURMP documents, were selected from the eight watersheds within the San Diego County area. Likewise, ten copermittees residing within either the San Diego Bay or Carlsbad WMAs were selected for use in the assessment of individual WMAs. Resource constraints required the selection of a subset of watersheds and copermittees within the jurisdictional boundary of the Order and additional assessments may occur as resources allow. In all, interviews were held with the following ten copermittees: San Diego Bay WMACarlsbad WMAImperial Beach, City of La Mesa, City of Lemon Grove, City of National City, City of San Diego, City of San Diego, County ofCarlsbad, City of Escondido, City of Oceanside, City of San Marcos, City of San Diego, County of On-site activities consisted of a 2 4 hour interview with copermittee staff coupled with a brief discussion of observations. Purpose The purpose of the activity was to assess each copermittee's: (1) understanding and implementation of watershed-scale runoff management, (2) the iterative process (Section A.3. of the Order), and (3) the design and application of BMPs targeting existing water quality impairments.The assessments were based on informal examination, questioning, and open discussion among the interview attendees. In some instances, copermittees provided information regarding their participation in the development and implementation of the WURMPs, and its relationship with their overall program and other targeted BMP efforts. Each copermittees interpretation, participation and implementation of the WURMPs and associated BMP programs were understandably different and therefore this memorandum does not attempt to summarize or document their individual actions. Rather the open discussion between the attendees adequately fulfilled the primary purpose of the activity and this memorandum therefore only documents some key observations. An ancillary purpose was to use the interviews to assess the likely effectiveness of the WURMPs in collaboratively addressing identified high priority water quality problems and to identify impediments in meeting that goal. As such, this memorandum presents some identified impediments that may inhibit the effectiveness of the WURMP process. It should be noted that the interviews and the San Diego Bay and Carlsbad WURMP documents provide the basis for the observations made in this report. The interviews were not an attempt to evaluate or assess compliance with other requirements of the Order, nor were the evaluations intended to be a comprehensive evaluation and review of the previously submitted WURMP documents. The remainder of this memorandum is organized as follows: General observations regarding anticipated effectiveness of the WURMPs in collaboratively addressing identified high priority water quality problems and identified impediments and inefficiencies in meeting that goal (hereafter, Observations and Identified Impediments). Recommendations for improved WURMP reporting and communication. Observations and Identified Impediments Understanding of WURMP Goals and the Ramifications and Integration of TMDLs. Most copermittees generally exhibited a clear understanding of the Regional Water Boards expectations for the WURMPs and the potential ramifications of current and future TMDLs. As such, current and future TMDLs were a primary area of emphasis for many of the copermittees. Recognition of Water Quality Contribution. To some extent, the majority of the copermittees verbally acknowledged that urban runoff discharges from their MS4s were contributing to exceedances of water quality objectives (WQOs) specified in the Water Quality Control Plan for the San Diego Basin, dated September 8, 1994 (hereafter, Basin Plan); and were also potentially contributing to receiving water impairments. Recognition of the role of MS4 discharges in contributing to the water quality problems is an important step, and some of the copermittees specifically stated that they have aligned their individual monitoring program to begin answering the core management questions in Monitoring and Reporting Program No. R9-2007-0001, including: What is the extent and magnitude of the current or potential receiving water problems? What is the relative urban runoff contribution to the receiving water problem(s)? What are the sources of urban runoff that contribute to receiving water problems(s)? Collective Watershed Strategy Not Well-Articulated. The BMPs presented within the WURMPs (i.e., Watershed Activities and Strategic Plan) are generally specific to the individual jurisdictions and are not well linked and/or replicated as regional or watershed-level BMPs. In short, the BMPs were largely a patchwork of current activities and the copermittees generally could not articulate a clear vision for how the BMPs would collectively address identified high priority water quality problems within the respective WMA. That being said, copermittees recognized this issue and stated that they envisioned significant improvements and honing of these BMPs in coming years and as so called pilot-scale activities were completed. One copermittee explained that since 2001, the Carlsbad WURMP group had moved away from efforts to implement activities/BMPs across the extent of the watershed. Instead, the group is now using a pilot study approach to identify proven and effective BMPs targeting specific high priority water quality problems. The necessity of measuring implementation effectiveness was often seen as a driver for the shift to a pilot study approach. It is anticipated that the pilot studies will result in a toolbox of those BMPs that have demonstrated quantifiable benefit to discharge or receiving water quality and that may prove transferable to other locations with adjustment for local conditions. Lack of Cross-Jurisdictional BMPs. Copermittees expressed common impediments to operating and otherwise contributing resources outside their own jurisdictional boundary. Understandably, it is difficult to convince local government decision-making bodies to allocate resources for watershed-scale activities that do not follow jurisdictional lines. As such, cross-jurisdictional application of BMPs was very limited (and possibly non-existent). In many cases the copermittees expressed a need to be able to demonstrate, measure, or provide a tangible benefit to the community that would result if resources were to be allocated outside of their jurisdiction. In several cases the identification of the process by which cross-jurisdictional activities would be established appeared overly restrictive and the copermittees were thus unable to identify a preferred example or format for success. To address this issue, the copermittees should consider broadening their perspective and look towards existing multi-jurisdictional agreements regarding regional transportation, shared or contracted wastewater treatment and conveyance, other watershed planning efforts, and even collaborative monitoring programs as examples. Additionally, the Regional Water Board may be able to provide examples of past or current cross-jurisdictional agreements and activities ongoing within the region or the state. True implementation of cross-jurisdictional activities appears unlikely until this perceived barrier is addressed. WURMPS Viewed as Compliance Documents. All of the copermittees viewed their respective WURMPs predominantly as compliance documents and then secondarily as planning documents. Some of the direct ramifications of this interpretation include: A predetermined preference to only select and list qualifying Watershed Activities (as defined by provision E.2.f.(4) of the Order) in the WURMP document. For example, activities that may be unique or in either the conceptual, design, or assessment stage may not be listed in the document. A fear of including BMPs that may ultimately prove to be ineffective or fail when counting on these activities for WURMP credit (see also Observation 6 below). A fear of committing to implement unique or otherwise challenging BMPs that ultimately may not be implemented (or even be implementable). This could be due to a lack of funding, changing priorities within their jurisdiction or workgroup, a determination that the proposed BMP has been determined ineffective by another entity, or other resource constraints. The net result is that the WURMPs did not appear to be a true representation of all ongoing or planned activities. In some instances, if not most, copermittees were in fact doing more than they reported (or had committed to do in the WURMPs). Basically, copermittees were only committing to the simplest or easy to implement BMPs (and likely the least effective BMPs) in fear of future enforcement. Mandatory Inclusion of Two Activities. Similar to observation 5 above, the Watershed Activities provision appears to have inadvertently resulted in copermittees limiting their stated activities thereby reducing the overall effectiveness of the WURMP document. This provision does not provide a platform and foundation for overall watershed planning (i.e., no WURMP credit for the individual conceptual, design, implementation, and assessment phases). For example, the San Diego Bay WURMP routinely mentions the need for additional monitoring and/or source identification for select pollutants. Yet nowhere in the document are these additional steps and a timeline for their implementation mentioned. Therefore, a reader is left to wonder how and when these additional steps will occur and whether a strategic plan exists elsewhere. Upon questioning, copermittees stated that those additional and important steps were not included within the WURMP document as they would not receive credit for their inclusion. The perceived compliance nature of the document and specific requirements for what is to be included, appears to limit the full and anticipated range and usefulness of the document. A compounding factor is that copermittees only receive credit during the implementation stage of the activity. In many cases, a minimum of two years may be needed to assess the long-term effectiveness of a particular BMP and ultimately this provision encourages a never ending cycle of developing new BMPs, rather than refining and expanding the use of those BMPs that have proved to be effective. JURMP and WURMP Obligations Are Causing Resource Trade-offs. Commonly, copermittees stated that their primary efforts were focused on the JURMP implementation with only the remaining resources left to WURMP development and implementation. A San Diego County representative explained, for example, that the specificity and lengthy nature of the JURMP portion of the permit leads to a more compliance driven emphasis on the JURMP when compared to the WURMP. As such, the WURMP process largely took a second position and was being implemented as resources allow. This will eventually, and may currently, have an even more significant impact on the ability of copermittees to fund and participate in cross-jurisdictional activities. In other words, it appeared that resources will likely be allocated in the following order: JURMP activities, WURMP activities within a jurisdiction, and finally the cross-jurisdictional WURMP activities. Limited Utility of the Five-year Strategic Plan. It appeared the intent of the requirement to develop a five-year strategic plan was either misunderstood by the copermittees or became compromised by the process of including the simplest or easy to implement BMPs mentioned above in Observation 5. Also, the request for the five-year plan may cause confusion with the intent for a more rapid and dynamic iterative approach. However, a limited review of the San Diego River WURMP document indicates that its five year plan is significantly more thoughtful and likely closer to the expectations of the Regional Water Board. Therefore, it is unclear if this observation applies to the WURMP process as a whole or just the two primary WURMPs reviewed. Downsizing to Hydrologic Areas (HAs). For the San Diego Bay WMA, it appeared that efforts, work groups, strategies and plans could be best segregated by sub-watersheds or Hydrologic Area (HA). For example, the high priority water quality problems and demographics within the three HAs were significantly different and the copermittees generally expressed that the work group had to make compromises regarding the designation and ultimate prioritization of the high priority water quality problems to meet the needs of the overall group. Experts in the field of watershed management have suggested that the sub-watershed hydrologic unit is an appropriate scale for achieving tangible watershed improvements. In the San Diego Bay WMA, effectiveness could have been improved if decisions and programs were better crafted at the HA level. In contrast, the Carlsbad WURMP copermittees were largely operating at the sub-watershed or HA scale by design. WURMPs not Qualifying as a WMP. Copermittees stated that the WURMPs do not fulfill the requirements of a Watershed Management Plan and are therefore not eligible for Proposition 40 Integrated Watershed Management Program grants. Additionally, the structure of the WURMPs has not readily encouraged the participation of additional stakeholder groups beyond the copermittees themselves. PG was told of broader participation within the San Diego River WURMP but that level of stakeholder participation was not present in either the San Diego Bay or Carlsbad WMAs. In contrast, a number of the Carlsbad WURMP copermittees are involved in the development of the Agua Hedionda Watershed Management Plan (AH WMP). These copermittees viewed the AH WMP as an exceptional platform for utilizing broad stakeholder support in scientifically-based actions to restore the watershed. Both the Order and future TMDL issuance appear to have an integral role in the AH WMP watershed planning effort. Limited Implementation of Watershed-based Land Use Planning. Copermittees commonly understood the connection between land use decisions and water quality. The Carlsbad WURMP document (March 2008), for instance, goes as far as re-stating the age old barrier to cross jurisdictional cooperation: Cities and counties have traditionally exercised their land use authority independently, with limited consideration of the chemical, biological, and physical processes that govern the generation, transport, and fate of contaminants and stressors at the watershed scale.Land use policies of individual municipalities have the potential to affect water quality in water bodies well beyond their jurisdictional boundaries. In recognition of this statement, one of the Carlsbad WURMP copermittees stated that the WURMP work groups act as a forum for encouraging collaborative and watershed-based land use planning. However, it was not clear that watershed-based land use planning principles had truly permeated into the copermittees jurisdictional planning departments in an operative fashion. Aside from encouraging integrated planning (e.g., providing water quality education for planners), most copermittees did not demonstrate active implementation of watershed-based land use planning (e.g., intergovernmental agreements for carrying out Watershed Activities). The copermittees commonly attributed the lack of implementation to the fact that their land use authority is limited by jurisdictional bounds. Recommendations for Improved WURMP Reporting and Communication Below are observations regarding the effectiveness of the current reporting program followed by a recommendation for improvement. Dual or Interchangeable JURMP and WURMP Reporting. Copermittees generally intended to have a significant amount of redundancy between their JURMP and WURMP annual reports. Potentially, this redundancy can be attributed to the following: (1) uncertainty as to where to report an activity, (2) overly conservative decisions being made in light of demonstrating compliance, and (3) the redundancy of reporting requirements included within the Order. The net result is likely marginalized benefit of the WURMP annual report as it is mired with activities that are truly jurisdictional in nature. Additionally, the current reporting program requires a significant investment of resources by both the copermittees and the Regional Water Board and all parties were in agreement that these resources could be better allocated. Last, it is unclear if the Annual Report documents are an effective way of transmitting information and describing planned and completed activities. For these reasons, the Regional Water Board should consider discontinuing a portion of, or all, the current WURMP annual reporting requirement. In its place, the Regional Water Board and the copermittees could establish planned semi-annual WURMP work group assessment meetings. The meetings could be used to: Set goals and expectations Provide information regarding current and future TMDLs and routes for implementation Explore/Promote ideas for cross jurisdictional implementation Provide an opportunity for copermittees to share examples of successful program implementation and pollutant load reduction measurement strategies and results Report on BMP pilot studies Establish a process for updating the WURMPs Allow for an opportunity to demonstrate compliance with WURMP provisions Obtain rapid feedback regarding proposed or ongoing activities Importantly, the meetings could provide a more open exchange of information and solicit and foster a more effective working relationship regarding the overall WURMP program. If required, a demonstration of compliance with WURMP provisions could be included within each copermittees individual JURMP Annual Report. Efforts could be taken to guard against the inherent redundancy of classifying and reporting an activity as applicable to both the JURMP and WURMP requirements.  Order Provision E.2.f(4) states: Each Watershed Copermittee shall implement identified Watershed Activities pursuant to established schedules. For each Permit year, no less than two Watershed Water Quality Activities and two Watershed Education Activities shall be in an active implementation phase. A Watershed Water Quality Activity is in an active implementation phase when significant pollutant load reductions, source abatement, or other quantifiable benefits to discharge or receiving water quality can reasonably be established in relation to the watersheds high priority water quality problem(s). Watershed Water Quality Activities that are capital projects are in active implementation for the first year of implementation only. A Watershed Education Activity is in an active implementation phase when changes in attitudes, knowledge, awareness, or behavior can reasonably be established in target audiences.      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