Sunday, October 26, 2008

FREE PUBLIC WORKSHOP on the Storm Water Pollution Prevention Program

ABSTRACT: A Free Public Workshop on the Monterey Regional Storm Water Management Program, Storm Water Pollution Prevention Program, Draft Annual Report, is to be held on Monday, November 3, 2008 at 12:00 P.M. at the Monterey City Council Chambers. Email comments on the Draft Annual Report to Program Manager by November 9, 2008. The Executive Summary of the DRAFT ANNUAL REPORT is reproduced and a link to the document is provided. A link to Appendix C, Year Two Annual Report Materials, City of Carmel-by-the-Sea, is presented.

WHAT: Free Public Workshop on the Storm Water Pollution Prevention Program undertaken by the local cities of Carmel-by-the-Sea, Del Rey Oaks, Marina, Monterey, Pacific Grove, Sand City and Seaside, the County of Monterey, Pebble Beach Company and Unified School Districts of Carmel, Monterey and Pacific Grove

WHEN: Monday, November 3, 2008 @ 12:00 P.M.

WHERE: Monterey City Council Chambers
Corner of Madison St. & Pacific St., Monterey, CA.

Email comments on the Draft Annual Report to the Program Manager @ Please type “Annual Report Public Comments” in the subject box and email comments by Sunday, November 9, 2008.

Monterey Regional Storm Water Management Program
November 15, 2008

Executive Summary
This document comprises the annual reports required by the General Permit issued to the Monterey Regional Storm Water Permit Participants Group by the Regional Water Quality Control Board (RWQCB) on September 7, 2006. The Storm Water Management Program (SWMP) for each of these Permittees is the Monterey Regional Storm Water Management Program (MRSWMP) which was reviewed and approved by the RWQCB in conjunction with issuing permit coverage to the entities comprising this Group. The Permittees in this Group consist of the cities of Pacific Grove, Monterey, Seaside, Del Rey Oaks, Sand City, Marina, and the County of Monterey.

Subsequent to the issuance of permit coverage to these entities, the city of Carmel-by-the-Sea submitted to the RWQCB its Notice of Intent to be covered by the State Water Resources Control Board’s (SWRCB’s) General Permit. The RWQCB granted permit coverage to Carmel-by-the-Sea on May 2, 2008, and authorized it to join with these other entities by using the MRSWMP as its Storm Water Management Program. When it submitted its Notice of Intent, Carmel-by-the-Sea also submitted an addendum to the MRSWMP to incorporate specific information pertaining to its facilities and programs. Prior to being granted permit coverage Carmel-by-the-Sea had been taking the same steps and had been working to implement the same types of procedures and policies as the other Permittees, just as though it was already permitted and using the MRSWMP as its SWMP.

This Annual Report has been prepared in the format recommended by the SWRCB for NPDES Phase 2 storm water permittees to use in preparing their annual reports. It has been adapted only slightly to match the BMP and Measurable Goals matrix format used in the MRSWMP. It constitutes a single Annual Report that fulfills the annual reporting requirements for all of the Permittees.

This Executive Summary briefly covers all of the major sections of the annual report. In preparing this Executive Summary, the following series of questions, which were recommended by the SWRCB for use in preparing the Annual Report, were considered by all of the Permittees. The responses represent the collective input from all of the Permittees covered by the MRSWMP.

Question: How effective was your program at reducing pollutants in your storm water discharge?

Response: This is a difficult question to answer, as the term “effective” can have different meanings under different contexts. The question is answered in general terms below, with reference to each of the six Minimum Control Measures:

Minimum Control Measure No. 1 – Public Education and Outreach
We believe that our Program was very effective in educating the public about storm water pollution prevention issues. The educational component was presented in a variety of forms including print ads, brochures, posters, and hands-on experiences. The public was reached through a variety of venues including movie theater ads, print ads, bus ads, classroom presentations, and informational booths at public events. The Program reached many different segments of the public, from young children to older adults, as described in detail in Appendix A. There has been a noticeable increase in public awareness. Some entities reported that they observed more residential car washing being done on soil areas where the water percolates rather than running off into the storm drainage system. It was also reported that more mobile washers were observed using proper BMPs to prevent storm water pollution. This is believed to be in part a result of the public education program of the MRSWMP.

Minimum Control Measure No. 2 – Public Involvement and Participation
We believe that our Program was very effective in involving the public in activities and events that were directly related to storm water pollution prevention measures. In these activities and events, a broad cross-section of the public participated in hands-on activities which helped to carry out the types of storm water pollution prevention messages that were presented under MCM No. 1. These are described in detail in Appendix B and in the Section of this Annual Report pertaining to MCM No. 2. One of the most direct indicators of the effectiveness of the MRSWMP are the results of the outfall monitoring work that is being conducted under this MCM. The Urban Watch and First Flush Monitoring Report contained in Appendix P provides a comparison of the monitoring results from the six years preceding Year 2 (the average of results from the period 2000 to 2006) and for Year 2 (2007-2008).

Results from the Year 2 Urban Watch and First Flush expanded monitoring program showed that:

Dry Run/First Flush (wet season):
• Nitrate concentrations were lower than previous years’ averages and rarely exceed the water quality objective during wet weather.
• Orthophosphate concentrations reflected comparable values from previous years and
usually exceeded the water quality objective.
• E. coli and enterrococcus were high everywhere; however, enterrococcus was not as high as in previous years.
• Most copper concentrations were lower than in previous years.
• Urea measurements were generally less than 1000 ppb.

Urban Watch (dry season):
• The Steinbeck Plaza drainage area in Monterey remained a problem during the dry season for bacteria, orthophosphate and detergents.
• The Greenwood Park drainage area in Pacific Grove had high bacteria levels and intermittently high hits of detergent.
• Trash is a problem at all Monterey Peninsula outfalls.
• Most of the Carmel outfalls, most of the new expanded Pacific Grove outfalls, and the Pajaro outfall were dry during the summer.

A trend analysis was performed on the data using a statistical analytical methodology. Only three outfalls were found to have produced data that indicated a significant trend with a high level of statistical confidence. These were the outfalls at:
1. The Monterey Library where copper was trending to lower levels,
2. The Twin 51 outfalls in Monterey where the E. Coli levels were trending higher, and
3. The Congress site in Pacific Grove where the orthophosphate levels were trending

Data from the other sites did not indicate any significant trends. It may be that it will take additional years of monitoring data before trends will become statistically apparent.

With regard to the cost information provided under BMP 2-2.d pertaining to the Urban Watch and First Flush monitoring programs, it should be noted that the citizen volunteers are not paid. However, the professional personnel that oversee and direct them are paid. In addition to these labor costs, there are significant costs for the sampling equipment, laboratory analyses, data interpretation, and report preparation. The total cost to carry out these two monitoring programs during Year 2 was $43,210. The program was funded as a Group activity on behalf of all of the co-permittees.

Some entities felt that the storm drain inlet stenciling program was effective both in terms of educating people to not put non-storm water discharges into the inlets, and also in getting the stenciling done via volunteers, rather than having to pay city staff to do this work. Other entities elected to perform the stenciling work using their own staff, based on their determination that this was more cost-effective than overseeing the stenciling work in their jurisdictions.

Minimum Control Measure No. 3 – Illicit Discharge Detection and Elimination
Work under this MCM was in the preliminary stages during the current reporting period. It included adopting and implementing storm water ordinances containing specific requirements pertaining to illicit connections and illegal discharges, encouraging the public as well as members of the permittee’s staffs to report such activities, following up on such reports to correct these violations, and developing and implementing business inspection programs. Some entities reported that a moderate number of illicit connections and illegal discharges were reported or detected during the current reporting period, while others reported from none to very few such reports. The co-permittees will be discussing their procedures and experiences in detecting and following up on reports of these types of incidents in an effort to have a consistent approach being used throughout the MRSWMP area.

Minimum Control Measure No. 4 - Construction Site Storm Water Runoff Control
This MCM become effective beginning in Year 2, and the Ordinances adopted by the permittees establish the effective date for these ordinance provisions to be September 8, 2007. During the current reporting period we continued providing educational programs to alert and acquaint construction contractors with the Ordinance requirements pertaining to construction site storm water pollution prevention. However, it appears that the market for such presentations was nearly satisfied as a result of these presentations that were made during Year 1, and it was not possible to find enough contractor organizations to make these presentations to during Year 2 to reach the target number of attendees. Permittee staff members who are involved in site plan reviews and in construction inspection were provided the opportunity to receive refresher training on these requirements and in the use of the construction site inspection checklists and the BMP Guidance Series materials contained in the MRSWMP. Most of the entities reported that they have increased their surveillance of construction sites as a result of implementing the MRSWMP. However, it has proven to be a challenge to integrate the detailed construction site plan review and inspection procedures, which are contained in the MRSWMP, into the standard operating procedures of each of the co-permittees.

Minimum Control Measure No. 5 – Post-Construction Storm Water Management in New Development and Redevelopment
The Program calls for this MCM to become effective in Permit Year 3, and the Ordinances adopted by the permittees establish the effective date for these ordinance provisions to be September 8, 2008. Accordingly, the Ordinances adopted by the permittees establish the effective date for these ordinance provisions to be September 8, 2008. To prepare for this MCM, during the Year 3, an educational program was held during Year 2 to alert and acquaint design professionals with the Ordinance requirements pertaining to post-construction storm water management in new development and redevelopment projects. Also during Year 2, permittee staff members who will be involved in plan reviews for the types of projects to which these requirements are applicable were provided training on these requirements and in the associated BMP Guidance Series materials contained in the MRSWMP. Permit Year 3 will provide the opportunity to begin assessing the process of implementing these measures into the design of new development and redevelopment projects to help prevent storm water pollution.

Minimum Control Measure No. 6 –Pollution Prevention/Good Housekeeping for Municipal Operations
We believe that the Program was very effective in improving the knowledge and sensitivity of the permittee’s staffs in recognizing and preventing storm water pollution resulting from municipal operations. Some focused training sessions were held, and numerous inspections were conducted on a variety of types of municipal facilities to identify and correct sources of storm water pollution. It was rewarding to find from these inspections that relatively few instances of storm water pollution were occurring at municipal facilities. Those which were identified have either already been corrected, or are in the process of being corrected.

The effectiveness of these BMPs was assessed using the California Stormwater Quality Association’s (CASQA) guidelines contained in the CASQA publication titled “Municipal Stormwater Program Effectiveness Guide.” The individual BMP assessments are contained in each of the MCM sections of this Annual Report under heading “iv. Effectiveness” [OR THEY MAY ALL BE CONSOLIDATED INTO A SEPARATE APPENDIX]. The following is an overview of the CASQA effectiveness assessment process.

The CASQA Effectiveness Assessment is a process to evaluate whether BMPs are resulting in desired Outcomes (or meeting performance standards) and if these Outcomes are being achieved efficiently and cost-effectively. The assessment is performed for different Outcome Levels, which are depicted in the figure on the following page.

Outcomes refer to the results of a control measure, program element, or overall program and have been categorized into the six Outcome Levels shown in the figure. Although each Level has value in informing and/or supporting management decisions, not all Outcome Levels are used in every assessment and the Outcome Levels are not necessarily conducted in sequence. The six Levels are described below.

The purpose of this effectiveness assessment process is to confirm the desired results of the overall program, and to identify modifications that may be needed, thus ensuring the iterative process is used as an effective management tool throughout the permit implementation. The following primary questions, or Outcome Levels, help to categorize and describe the desired results of the program:

• Level 1 Outcome – Was the Program Element implemented in accordance with the Permit Provisions and SWMP?

• Level 2 Outcome – Did the Program Element raise the target audience’s awareness of an issue?

• Level 3 Outcome – Did the Program Element change a target audience’s behavior, resulting in the implementation of recommended BMPs?

• Level 4 Outcome – Did the Program Element reduce the load of pollutants from the sources to the storm drain system?

Although each level has value in informing and/or supporting management decisions, not all Outcome Levels are used and the Outcome Levels are not necessarily conducted in sequence. In some cases, assessments at different levels may occur at once.

Level 6 - Protecting Receiving Water Quality
Level 5 - Improving Runoff Quality
Level 4 - Reducing Loads from Sources
Level 3 - Changing Behavior
Level 2 - Raising Awareness
Level 1 - Documenting Acitivities
Source: CASQA “Municipal Stormwater Program Effectiveness Guide,” May 2007.

The following steps will be taken to revise the MRSWMP and to optimize BMP effectiveness, when the effectiveness assessment process identifies BMPs or programs that are ineffective or need improvement:

1. A review of each such BMP or program will be made by the Program Manager to try to ascertain what is making it ineffective, or how it can be improved.
2. The results of this review will be formally presented to the Management Committee which oversees the implementation of the MRSWMP, for discussion and action by that body.
3. The changes recommended by the Management Committee will be described in each Year’s Annual Report as proposed as modifications to the MRSWMP to be carried out in future years under heading “v. Proposed Modifications.”

Question: Were you in compliance with the General Permit?

Response: With the following exceptions, yes. The two principle areas of noncompliance were in the adoption of stormwater ordinances by two of the permittees (the County of Monterey and the City of Marina) and in getting all of the appropriate personnel to attend training sessions under MCMs 5 and 6. While these two entities have not yet adopted stormwater ordinances, for reasons which are detailed in the respective Appendices for these entities, these entities have existing ordinances and laws in place for grading activities and discharges to waterways that are protective of water quality. These entities anticipate that they will have their Stormwater ordinances adopted in Permit Year 3. Having all personnel available to attend Group training sessions has sometimes been difficult, due to factors such as unpredictable changes in workload, e.g. emergency repair or maintenance assignments, sickness, vacations, and internal dissemination of the information regarding the training session schedules and who should attend them. Some of the training programs will be repeated in the future to give those personnel who could not attend the earlier sessions another opportunity to attend.

Question: What was the most successful part of the program?

Response: The permittees felt that the public education and public involvement components of the Program under MCMs No. 1 and 2 were the most successful. It was gratifying to find significant improvement in public awareness and understanding of storm water pollution prevention issues that were the direct result of these efforts. The permittees also felt that the business inspections performed under MCM 3 were raising awareness regarding storm water pollution prevention within the business community, and they were pleased to find that most of the inspections were finding that the businesses were using the proper BMPs to prevent such pollution.

The permittees also felt that the training and inspections performed under MCM No. 6 were successful in building an increased level of storm water pollution awareness and understanding among their own staffs, and that this had been effective in eliminating nearly all sources of storm water pollution from public facilities.

Question: What was the most challenging?

Response: The most challenging part of the Program for all of the permittees was in coordinating and tracking the efforts of multiple departments within each entity’s organizational structure. These departments typically included Public Works, Building, Construction Management, Parks, Fire, and Police. Building an internal awareness of storm water pollution prevention issues, ordinance requirements, tracking and reporting requirements, and coordinating the work of these various departments continued to be a significant challenge for most of the permittees, particularly as additional BMPs were implemented. There is also a substantial amount of additional paperwork that must be prepared in order to carry out the BMPs and to document them. This adds to the workload, and there is a natural resistance to this in many members of the staff, in part due to the fact that budget impacts have caused many of the permittees to operate with fewer staff members than they had in the past.

Appendix C
Year Two Annual Report Materials
City of Carmel-by-the-Sea

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