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RPVCCA_CC_SR_2014_06_17_G_Watershed_Mgmt_PgmCrrYOF RANCHO PALOS VERDES MEMORANDUM TO: FROM: HONORABLE MAYOR & CITY COUNCIL MEMBERS MICHAEL THRONE, DIRECTOR OF PUBLIC WORKS ~ DATE: JUNE 17, 2014 SUBJECT: ENHANCED WATERSHED MANAGEMENT PROGRAM WORKPLAN AND COORDINATED INTEGRATED MONITORING PLAN REVIEWED: CAROLYNN PETRU, ACTING CITY MANAGER~ Project Manager: Andy Winje, Associate Engineerj\YJ RECOMMENDATION Direct Staff to submit the Draft Enhanced Watershed Management Program Work Plan and Draft Coordinated Integrated Monitoring Plan on behalf of the Peninsula Water Management Group in accordance with the MS4 permitting schedule. EXECUTIVE SUMMARY The Municipal Separate Storm Sewer System (MS4) Permit was adopted by the Regional Water Quality Control Board on November 8, 2012. In response, the City has elected to develop an Enhanced Watershed Management Program (EWMP), including a Coordinated Integrated Monitoring Program (CIMP), with other agencies having stormwater jurisdiction on the Palos Verdes Peninsula. The agencies are known as the Peninsula Watershed Management Group (Peninsula WMG). The City of Rancho Palos Verdes serves as the administrative lead for Peninsula WMG and is required by MS4 regulations to submit an EWMP Work Plan and the completed CIMP prior to June 28, 2014 to remain in compliance with the permit. The group has met and worked collaboratively to prepare these documents with the assistance of technical experts hired through the MOU, which was entered into for this purpose. The documents are being made ready for submittal by the deadline on June 28, 2014. The documents, subject to a few minor changes, are available for review on the City's website at http://palosverdes.com/rpv/publicworks/stormwater-quality/. BACKGROUND Staff has presented information on the new stormwater quality (MS4) permit requirements G-1 EWMP Work Plan and CIMP June 17, 2014 Page 2of3 to the City Council on several occasions. These presentations have outlined the evolution of the City's response to the permit requirements as Staff has worked to determine the most advantageous path forward. At its June 18, 2013 meeting, the City Council authorized Staff to notify the Los Angeles Regional Water Quality Control Board (Regional Board) that the City would follow the EWMP approach in conjunction with the Peninsula WMG. A Notice of Intent was filed on June 27, 2013 with the Regional Board to signal this approach. The Regional Board approved the Notice of Intent. On August 6, 2013, the City Council approved a Memorandum of Understanding between the Peninsula WMG agencies in order to begin collaborative work on the EWMP and the CIMP for the new stormwater quality permit requirements. Because it is the largest agency by area within the group, the City of Rancho Palos Verdes serves as the administrative lead. On October 1, 2013, the City Council awarded a contract to John L. Hunter & Associates to begin work on the EWMP and GIMP documents. DISCUSSION The 2012 MS4 permit gave cities and agencies three pathways towards compliance, including development of an EWMP, which was selected by the Peninsula WMG. The EWMP is a comprehensive assessment of the conditions of the watersheds that the City drains to, and based on those conditions prepares a detailed analysis of steps necessary to achieve pollution reduction goals. This plan requires considerable time to prepare and so the Regional Board requires that an interim document be submitted to be sure that agencies are developing their EWMP in accordance with the Regional Board's expectations. · This interim document is called the EWMP Work Plan and it is due for submittal on June 28, 2014. As part of the EWMP process the cities and agencies will be required to prepare a Reasonable Assurance Analysis (RAA). The RAA involves a model which mathematically tests the effectiveness of the treatment system proposed by EWMP. Locating sites for installing treatment systems and securing funding to construct treatment systems will be very challenging. The final EWMP document itself, due one year from now subject to approval of the Regional Board, will describe in detail what projects and programs the City will be doing to meet water quality goals. Costs associated with the new implementation measures described in the EWMP will not be incurred until sometime in 2015 but they could be substantial. Costs will not be known until the EWMP is approved and projects designed. In the interim, the EWMP Work Plan lists both construction projects and non-structural programs that might be required. When the EWMP is approved by the Regional Board, stiff numerical limits (that is, field measurable criteria) will be phased in as the standard by which compliance is determined. (Past permits required only that agreed upon preventive actions be implemented according to an implementation schedule.) To determine what pollutants are present in the City's stormwater discharge, and as a baseline against which reduction goals are measured, the City must develop a monitoring plan that involves taking runoff water samples and performing laboratory testing. The monitoring plan will be coordinated with G-2 EWMP Work Plan and CIMP June 17, 2014 Page 3of3 the other Peninsula WMG agencies and integrated to consider multiple potential pollutants in an effort to conserve resources. This Coordinated and Integrated Monitoring Program, or GIMP, will describe what pollutants will be tested for, where and how often samples will be taken and what laboratory procedures will be used for analysis. Monitoring under the GIMP protocols will begin either in late FY 2014-15 or early FY 2015- 16 depending on the speed by which the Regional Board can respond and approve it. The City will incur some costs to perform this work but they are as yet undetermined. Although the GIMP will determine the scope of work for the contractor eventually selected to do the work, the GIMP is not really committing the City financially to anything not already mandated by the 2012 MS4 Permit. The GIMP was developed with financial consideration in mind and every effort was made to specify only that which is deemed necessary to satisfy the requirements of the permit and the Regional Board. Presumably, costs will be shared among the Peninsula WMG agencies upon approval of a CIMP Implementation MOU, which is yet to be developed. CONCLUSION The City has committed itself to the EWMP process, including a CIMP, by earlier City Council action in accordance with Staff's recommendations. An MOU to perform the required work collaboratively has been approved by the Peninsula WMG. The agencies, with the help of technical experts have prepared the required documents to be submitted per the Regional Board's schedule. The other agencies have reviewed and authorized the City to submit the documents on behalf of the Peninsula WMG. Staff is seeking City Council direction to file these documents with the Regional Board prior to the deadline on June 28, 2014. FISCAL IMPACT Costs for preparation and submittal of the documents have been allocated in earlier City Council actions. The CIMP will commit the City to certain monitoring activities and their associated costs beginning as early as late next year. However, the CIMP only describes what and how the City will perform the monitoring. The permit itself requires the monitoring to be done and so costs to perform monitoring result primarily from the adoption of the permit, rather than submittal of the GIMP. A firm estimate of annual monitoring costs will not be available until the Peninsula WMG obtains proposals from qualified firms to implement the Regional Board approved GIMP. An MOU among the involved agencies for funding and managing the GIMP implementation will be brought back to the City Council for approval prior to initiation of that monitoring. If additional funds need to be allocated in this fiscal year, Staff will bring back a recommendation for a budget adjustment. Otherwise, funds will be proposed within the FY 2015-16 budget recommendation. G-3