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Patterns in Stormwater Permitting

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  1. Trends in Stormwater Permitting Joyce Brenner, P.E. Chief of Stormwater Policy, Planning, and Permitting Division of Environmental Analysis Caltrans Headquarters Road Ecology Meeting February 26, 2009

  2. Overview • Caltrans NPDES Permitting History • Status of New Permit • Upcoming Trends in Permitting • Stormwater Quality Issues/Concerns • Our Anticipated Tasks

  3. Brief History on Caltrans NPDES Permit • Originally 9 NPDES Permits • Consolidating Caltrans permitting with the State Board to insure statewide consistency. • Statewide Permit issued in 1999

  4. Awaiting new NPDES Permit • Statewide NPDES permit term ended in 2004, administratively extended • Continue to operate under current permit • New Draft Permit expected ??? • Public Comment Period ??? • Workshops ??? • Adoption??

  5. Anticipated new NPDES Permit • Extensive Location-specific Requirements • Hydromodification (pre-post hydrologic balance) • Proposed New Construction Permit Requirements • TMDLs and 303d listings of Impaired waterbodies

  6. 303(d) Listed • 1,780 pollutant/ waterbody combinations listed • Stakeholder in more than 40 TMDLs • Potential for up to 200+ TMDLs

  7. Water Quality Issues / Activities • Floodplain encroachment – NPDES, Biology • Critical Habitat (ESA) - Biology • Water supply/Groundwater- Hydraulics • Discharges to land (WDRs) – NPDES, Construction, Maintenance • Stormwater - NPDES/Design/Construction/Maintenance • Hydromodification – NPDES, Design, Hydraulics • Dewatering (groundwater vs. stormwater) – NPDES, Hydraulics, Construction, Maintenance

  8. 401 and NPDES Permit • Section 401 water quality certification should be consistent with beneficial uses identified in the Basin Plan • Section 401 certification should contain reference to the beneficial uses to be protected, and link the conditions to restoring, or maintaining past, present, and/or probable beneficial uses. • Address early in the project to avoid delays • Part of NPDES permit water quality requirements – permit requires compliance with water quality standards 40

  9. Current Compliance Tasks • Water Quality issues have created challenges for project delivery • Analysis at late stages of project delivery creates difficulties in modification of projects • HQ has been working with the State Water Board, Districts working with 9 Regional Boards on a project by project basis. • Major changes are on the horizon. Changes driven by Regional Board initiatives

  10. Anticipated Compliance Requirements • Planning/Environmental review • Increased focus on watershed impacts and mitigation • New numeric limitations on pollutants and runoff volume • Increased right-of-way for treatment, flow controls: ponds, grass swales, and infiltration of runoff • More collaboration with locals • TMDLs for “impaired” waterways will require retrofit treatment controls • Design • Limit runoff – no increase in volume, duration • Low impact development (LID) – change from end-of-pipe treatment to “holistic” controls • Technology to meet specific numeric limits on pollutants • Controls during construction – can’t leave it to contractor

  11. Anticipated Compliance Requirements • Construction • Approval process for sediment controls in addition to established BMP’s – possible delay • Controls during construction – can’t leave it to contractor • Treatment costs to control runoff turbidity for some sites with fine soils: chemical addition and filters • More public oversight – all site documents posted • Maintenance • Increased costs to manage all treatment controls • More institutional controls

  12. Current – Anticipated Compliance Requirements • DEA (Division of Environmental Analysis) • More program effort – extensive tracking, reporting • Management • Government focus on costs – are all TMDLs doable? • Need support from other agencies – e.g., legislation to reduce copper from brake pads

  13. Recent Modifications in Analysis • Maximum Extent Practicable (MEP) – Statewide Interpretation • “NPDES permits issued for MS4 stormwater discharges require controls to reduce the discharge of pollutants to the Maximum Extent Practicable (MEP)… • Water quality requirements in our statewide permit: stormwater discharges may not cause or contribute to exceedance of water quality standards.” • Design Staff: Modifications to Project Planning Design Guide (PPDG) December 2008 • Interim Scoping Questionnaire for Water Quality Issues http://pd.dot.ca.gov/env/stormwater/tech_notes/tech_notes.htm • Projects that require a 401 certification should evaluate the feasibility of post construction BMPs, to insure that water quality standards are met.

  14. New SER Language Proposal • WQ section will include a discussion of watersheds and receiving waters that are potentially affected by the project • A checklist to assess water quality impacts will be used until final guidelines for water quality assessment are adopted

  15. Questions? Joyce Brenner, P.E. Chief of Stormwater Policy, Planning, and Permitting Division of Environmental Analysis Caltrans Headquarters (916) 653 2512 joyce_brenner@dot.ca.gov