Archive for the ‘Stormwater management’ Category
Posted by George J Janczyn on August 15, 2014
Posted by George J Janczyn on October 21, 2013
A San Diego Independent Budget Analyst (IBA) report on the fiscal impact of new storm water regulations was delivered last Wednesday (October 16, 2013) to the city council’s Natural Resources and Culture (NR&C) Committee. While no action was taken at this meeting, the report left no doubt that the City is in serious need of new revenue (read: fees and taxes) to comply with the new regulations, for infrastructure, flood risk management activities, and deferred capital improvement projects for storm drain assets.
Earlier this year the San Diego Regional Water Quality Control Board approved a new five-year municipal storm water sewer system permit. The so-called Regional MS4 Permit regulates both storm water and non-storm water (dry weather) discharges into the region’s storm water conveyance facilities to prevent pollutants such as trash, metals, bacteria, chemicals, and pesticides from being washed into storm drains and into creeks, rivers and the ocean. Compliance with the permit is projected to be expensive.
The City’s Storm Water Division administers San Diego’s storm water program and is responsible for ensuring compliance with these regulations. The Division’s FY2014 budget includes $35.1 million for operations and maintenance drawn from the General Fund, and $25.9 million in Capital Improvement Project (CIP) funds.
The Storm Water Division’s operating budget is projected to rapidly escalate and could reach $107.6 million by the end of the 18-year outlook discussed in the IBA report, while the total CIP required for the outlook range could hit $2.7 billion (with an emphasis on “B”).
The City collects a storm drain fee from water and sewer customers to help offset the burden on the General Fund but it is, in the words of the IBA report, “significantly short of full cost recovery.” Storm drain fee collections for FY2014 are expected to cover only about 16.2% of the Storm Water Division budget.
The current fee for single-family residences is a flat rate $0.95 per month.
Interestingly, the storm drain fee paid by single family residences is billed at a flat rate while the fee for commercial/industrial and multi-family developments is based on the amount of water they use, under a rate structure that dates back to 1996. According to the Storm Water Division spokesman Bill Harris: “It was thought at the time that a flat rate, like the water and waste water service base fees, would be easier to accept and calculate…..given the hundreds of thousands of service connections. It seemed logical, I am sure, at the time.”
Harris said that in the future, fee structures would likely be more uniformly based on land-use impact models taking into account things like acreage, impervious surface area, and water usage.
The Storm Water Division will need additional funds (in ever-increasing amounts) beginning in FY2015 to address regulatory compliance and for additional flood management activities. For the next five years alone:
With a water rate increase already proposed to take effect in January 2014, San Diego residents will be less than happy to learn that the storm drain fee (one of several fees bundled with the water bill) is likely to dramatically rise over the coming years. For single-family residences it could jump from the current $0.95 per month to $3.49 per month in 2015, ballooning to $11.14 per month by 2019.
If that’s not sobering enough, the picture through the year 2031 should make one sit up. The IBA report says: “By the end of the 18 year outlook in FY 2031, $43.25/month would be required from single family residences.”
One consolation is that beyond the first five year estimate which is fairly certain, standards, methods, and technology may evolve in ways that could reduce anticipated costs in later years.
Any increase in the municipal storm drain fee would require an election with approval by either a majority of property owners or two-thirds of the general electorate.
The City could face monetary non-compliance penalties if action is deferred beyond FY2015. The IBA report noted that state penalties could amount to $10,000 per day per violation, along with federal penalties of $27,500 per day per violation. Each storm drain outfall may be counted as a separate violation.
Another financial consideration is that the City has deferred some $146 million in needed storm drain infrastructure replacement/rehabilitation.
“[T]he City will need to find a dedicated funding source for Storm Water activities as mandated regulations become increasingly stringent and costly. If no funding is identified the City’s General Fund will have to continue to contribute increased funding in order to remain in compliance, reducing funding for other priorities and services. If funding is not identified from either a dedicated revenue stream or the General Fund, the City may fall out of compliance which could potentially result in significant penalties assessed by the state and federal government. Additionally, deferring flood risk management exposes assets to an increased risk of failure, causing sinkholes, property damage and costly emergency replacement and repair.” — the IBA report’s conclusion
Urban storm water management is informally thought of as devising ways to channel rainwater runoff away from roads, structures, parking lots, and other impermeable surfaces as quickly as possible into storm drains leading to creeks and streams and eventually the ocean. It’s more complicated, though, and regulations are just part of the picture.
The City of San Diego lies in six separate watersheds: San Dieguito, Los Peñasquitos, Mission Bay and La Jolla, San Diego River, San Diego Bay, and Tijuana River.
Watersheds cross political boundaries. This map from Project Clean Water is a good illustration of the watersheds in San Diego County (if you use the above link to view the map on their website you can move your mouse pointer across the map to highlight and click for description of specific watersheds.).
Because watersheds cross political boundaries we have collaborative regional management of storm water issues. For example, there is San Diego Integrated Regional Water Management Planning. SDIRWMP is an interdisciplinary effort by water retailers, wastewater agencies, storm water and flood managers, watershed groups, the business community, tribes, agriculture, and non-profit stakeholders. Its 2013 Integrated Regional Water Management Plan in turn follows California Department of Water Resources guidelines.
Background and sources
City of San Diego Independent Budget Analyst (IBA)
- Fiscal Impact of New Storm Water Regulations (the report presented to NR&C):
- PowerPoint presentation to NR&C:
City of San Diego: Storm Water Division
- Watershed Asset Management Plan (formed the basis for the IBA report):
- Related plans and reports:
- Master storm water system maintenance program:
- Jurisdictional Urban Runoff Management:
Integrated Regional Water Management
- 2013 Integrated Regional Water Management Plan:
- — Appendix 7B: Integrated Flood Management Planning Study:
- Urban stormwater management in the United States / National Research Council:
Regional Water Quality Control Boards
- San Diego Regional Water Quality Control Board – Storm Water:
- News release – San Diego Water Board approves updated storm water runoff regulations:
News media reports
- Feb 25, 2009: Dire budget could make stormwater hike attractive / Voice of San Diego:
- Jan 25, 2010: Time already running short for 2010 budget / Voice of San Diego:
- Jul 13, 2011: S.D. stormwater program under review / U-T San Diego:
- October 18, 2013: Storm drains: the city’s next big financial drain / Voice of San Diego:
Posts from this blog
- Mar 23, 2010: Increase in stormwater fees, a utilities (including water) tax, and a trash/recycling fee listed as options for San Diego:
- Jul 22, 2011: San Diego stormwater management: public comment period is almost over:
Posted by George J Janczyn on April 9, 2013
U-T San Diego, the local newspaper-in-decline, on Sunday published an editorial that would embarrass any self-respecting water journalist (“Go back to drawing board, water agency“).
The editorial claims that “A remarkable coalition of business, government and environmental groups is trying to prevent a disastrous leap into faith-based policymaking by a headstrong state agency” and “In a stunning collaboration, the environmental group Coastkeeper joined with the San Diego Building Industry Association in January to ask the state agency to slow down, develop alternatives and lean heavily on expert advisory panels. The message is loud and clear. The water quality board must delay this proceeding and start over.”
In fact, they are trying to do no such thing (and actually, the Water Reliability Coalition is San Diego’s true “remarkable coalition.”)
The truth of the matter is laid out by San Diego Coastkeeper’s Jill Witkowski in her reply to the U-T (reprinted here with her permission):
“With due respect to the U-T Editorial Board, you are wrong.
The hearings are set for Wednesday and Thursday, not Monday and Tuesday.
The standards that you suggest are “effectively impossible to meet” are not. In fact, the County and local cities have employed engineers to create a Comprehensive Load Reduction Plan, which includes a suite of options for the cities and county to implement that “are predicted to be effective” to reach the target pollution levels. These standards were developed during a multi-year process that began in 2003 and ended in 2010. The process involved scientists from the County and the City of San Diego, was peer reviewed by scientists from UC Santa Barbara and UC Berkeley, and the standards were approved by the Regional Water Quality Control Board, the State Water Resources Control Board, and the U.S. EPA.
These standards use a “reference” location in the central coast to determine, under natural conditions, how many days would have unreasonably high bacteria levels. The result? About 1 out of 5 days. This means that, during wet weather, it’s acceptable for the bacteria levels to be too high for San Diegans to swim or surf 22% of the time. Any bacteria above that can be credited to human-caused sources, not the natural environment. We can and should control the bacteria we add to our oceans and beaches to protect human health.
Many studies have shown the correlation between urban runoff and human illness. A 2012 study showed an increased risk of swimming-associated gastrointestinal illness at urban runoff contaminated beaches. (source: http://www.ncbi.nlm.nih.gov/pubmed/22356828). Another study has shown there were higher risks for gastrointestinal and respiratory symptoms when swimmers were closer to the storm drains, the source of urban runoff pollution into the ocean (source: http://www.tos.org/oceanography/archive/19-2_dufour.html).
Your editorial complains that people might actually be held accountable for their personal behaviors that add to our local pollution problems. While the cities and the County have the discretion on how they choose to get San Diegans to reduce the pollution they cause, ultimately the cities and the County are responsible for reducing our urban runoff pollution.
Finally, the UT needs to read the joint letter San Diego Coastkeeper and BIA submitted in January. It does not ask the Regional Board to “slow down,” nor does it ask the board itself to develop alternatives or rely on an expert panel. Instead, it asks the Regional Board to require the cities to identify alternatives that developers can use to benefit the watershed when on-site improvements become infeasible. It asks the Regional Board to require cities to involve environmental and engineering stakeholders when developing watershed-specific plans. And it asked the Regional Board to stagger watershed plan development, primarily so that one watershed could learn from another.
San Diego Coastkeeper will ask the Regional Board to approve the stormwater permit after removing a new provision just added on March 27 that violates the Clean Water Act.”
The U-T editorial writers should do a little background reading on the subject. They could begin with this brief from the National Research Council:
Posted by George J Janczyn on April 9, 2012
The San Diego Water Board is considering the development and adoption of a Regional Municipal Separate Storm Sewer System Storm Water NPDES Permit (Regional MS4 Permit) that will be issued to municipal Copermittees in San Diego County, Southern Orange County and Riverside County. Currently, each of these counties within the San Diego Region has its own municipal storm water permit. In order to better achieve regulatory consistency as well as maximum efficiency and economy of resources, the San Diego Water Board developed a single Regional MS4 Permit based on the boundaries of the San Diego Region instead of county political boundaries. Under this approach, the permit will uniformly regulate all three counties within the San Diego Region.
Posted by George J Janczyn on July 22, 2011
In late July with everything warming up, stormwater management may not be a high priority in the minds of many San Diegans but it’s probably not a bad time to be thinking about it since there aren’t flood emergencies to deal with.
Stormwater generated from our urban and suburban environment is a great challenge in many respects, but as observed in a report by the National Research Council, nearly all stormwater problems result from the loss of water-retaining and evapotranspirating functions of the soil and vegetation in the urban landscape:
“In an undeveloped area, rainfall typically infiltrates into the ground surface or is evapotranspirated by vegetation. In the urban landscape, these processes of evapotranspiration and water retention in the soil are diminished, such that stormwater flows rapidly across the land surface and arrives at the stream channel in short, concentrated bursts of high discharge. This transformation of the hydrologic regime is a wholesale reorganization of the processes of runoff generation, and it occurs throughout the developed landscape. When combined with the introduction of pollutant sources that accompany urbanization (such as lawns, motor vehicles, domesticated animals, and industries), these changes in hydrology have led to water quality and habitat degradation in virtually all urban streams.” (page 5 from the book)
Historically our urban stormwater management has been mostly about getting rainwater away from roads, buildings, parking lots, and other impermeable surfaces into creeks, pipes, and channels as quickly as possible.
Broader environmental impacts have not been not ignored but as a pragmatic budget-minded operation the City’s ability to address every issue has been tested as it develops its stormwater management plan. Whether the City can find more ways to control flooding but also to slow things down and allow more water to be naturally and usefully retained rather than discard it as quickly as possible remains to be seen.
The final meeting in the series of public forums on the City’s Master Storm Water System Maintenance Program was held yesterday evening at the Mission Trails Regional Park Visitors Center. The forum consisted of a joint presentation by Jill Witkowski, Staff Attorney for San Diego Coastkeeper, and Bill Harris, Supervising Public Information Officer for the Transportation & Storm Water Department, each offering a slightly different perspective on the program.
The underlying goal, which everyone seemed to agree on, is for the City to get away from a short-term reactionary mode where flooding problems arise, ad-hoc projects are quickly drawn up, emergency permits arranged, and different things happen depending on who is in charge that particular year. Instead, the desired strategy is a twenty-year program that locks in an orderly process that generates perhaps 3-5 projects per year, is not disrupted by management and staff turnover, and incorporates the needs and interests of the community.
The challenge is to find a balance between long-term strategic objectives and site-specific project details.
Originally, a Program Environmental Impact Report (PEIR) was prepared last year but a Recirculated PEIR had to be written because of a Coastkeeper legal appeal and additional information that developed after public review of the original PEIR.
After the presenters gave their overview and discussion with the audience ensued, one topic dominated: adequate, meaningful public participation in the future when specific project details would be developed.
In particular, Coastkeeper’s Witkowski pointed out that significant and meaningful public participation requirements have not been written into the document plan even though verbal pledges have been made to that effect. It’s not enough just to guarantee public access to information about upcoming projects, she said, but a process for responding to public feedback on those projects must also be documented.
Bill Harris acknowledged the plan needs to incorporate such language and asked for patience saying that the issue definitely needs attention and language will be written in. As the meeting continued, some individuals expressed lingering uncertainty about that documentation happening, while Harris expressed equal certainty that those desired changes will be made.
Seeing these people interact in the same room my sense was that the members of San Diego Coastkeeper and staff in the Stormwater Department are smart people who have engaged in sincere and constructive dialog with a great deal of mutual respect. I was a little startled to see a Coastkeeper publicity blurb suggesting the plan was designed “to avoid public input and prohibit neighbors from challenging projects” but I heard nothing quite that strong at the meeting. Indeed, Witkowski praised the overall plan and said it represented “a great step forward.”
After the comment period closes, it will take 4-6 weeks to read, digest, and write responses to the comments. The hope is then to place it on the City Council docket, perhaps at their October 25 meeting.
There’s not much time left for public comment. July 29 is the deadline for comments to be accepted for review and response. Comments must focus on the new issues in the Recirculated PEIR; no reponses will be made to issues from the original PEIR.
Even if you’re strongly interested in stormwater issues, it might be daunting to read the entire Recirculated PEIR and figure out where you might contribute worthwhile comments. You may not find time for all the apendixes, but perhaps scan the report and read through the responses to the original PEIR comments. Also, if you’re up for some nitty gritty, read on for extra perspective from both sides.
A San Diego Coastkeeper handout at the meeting outlined its view of the situation:
July 29, 2011: Last day to comment on “Program Environmental Impact Report” 1300 pages, 45 day comment period.
Fall 2011: City Council hearing to approve environmental documents and “Master” site development permit for 115 creeks and channels.
If approved, annual process:
- City Stormwater staff develops “list” of channels for upcoming year. Presents list and previous year’s report to community planning groups and to City Council’s Natural Resources & Culture Committee
- City Stormwater staff prepares individual maintenance plans. Hydrology, water quality, noise, historical, mitigation
- City Stormwater staff sends detailed plans to City Development Services Department for approval
- Development Services uses Substantial Conformance Review checklist to determine if new, greater impacts in environmental review for program
If no and NOT in Coastal Zone, then Process One = DSD approval. “Courtesy” public notice to community planning group in area; no public comment period, no hearing, no appeal process.
If no, but in Coastal Zone, then Process Two = DSD approval. Notice of future decision to community planning group and residents within 300 feet; DSD decision made within 11 days of mailing notice (can extend to 30 days if CPC requests extension before decision is made); Notice of decision to people who request it no later than 2 days after decision date; residents/CPC can appeal to Planning Commission if appeal within 12 days after decision.
If greater/new environmental impacts, then Process Four = Planning Commission Hearing. Notice of application to CPC and residents within 300 feet plus those who request notice; Planning Commission hearing where public can weigh in on the projects; Appeal to City Council within 10 days of Planning Commission decision.
The City’s draft PEIR has this take on the situation:
“Although the Master Program has been amended to require hydrology and hydraulic studies be completed for each of the individual storm water facilities at the time maintenance is proposed, some of the members of the public are expected to insist that hydrology and hydraulic studies be completed for all of the storm water facilities before adoption of the Master Program. In addition, members of the public are expected to insist that detailed maintenance plans be identified prior to approval of the Master Program and PEIR to assure that the impacts are adequately anticipated.”
In response to concerns expressed regarding maintenance in open space, the City’s Storm Water Division (SWD) removed many of the storm water facilities within open space where maintenance was not likely to be required. As a result, the number of miles of storm water facilities included in the Master Program was reduced from 50 to 32 miles. In addition, SWD has determined that the estimates of disturbance width in the original PEIR was over conservative. With the reduction in the number of storm water facilities combined with the reduced disturbance width assumptions, the impact to wetlands within the City’s jurisdiction would be reduced by approximately 43 percent (30 acres) when compared to the original Master Program. Nevertheless, some members of the public are expected to request further reductions in the number of facilities to be maintained under the Master Program.
Concerns are likely to continue to be expressed regarding alternatives to the proposed maintenance. Although the City’s DSD staff believe that a reasonable range of alternatives is presented in this PEIR, members of the public are expected to contend that other alternatives exist to the proposed project.
Water quality is also expected to continue to be a concern of the public. Although the water quality discussion has been expanded in the PEIR, members of the public are expected to take the position that the water quality impacts are understated and that additional mitigation should be proposed.
In addition, the public has expressed a desire to have more involvement in reviewing annual maintenance proposals which are required as part of the Master Program. In meeting with these individuals and groups, the City has cited specific CEQA statues and guidelines and San Diego Municipal Code regulations to support their determination that annual maintenance activities that are explicitly identified in the Master Program and adequately addressed in the Final PEIR can be approved in reliance upon the certified Final PEIR. As described in Subchapter 1.6 of this PEIR, pursuant to Section 15168(c) of the CEQA Guidelines, the certified Final PEIR would satisfy CEQA requirements for subsequent maintenance activities if no new effects could occur, no new mitigation measures would be required, and all feasible mitigation measures or alternatives identified in the PEIR will be implemented. Despite the legal grounds for maintaining that no new environmental document is required for annual maintenance plans covered within the scope of the Master Program and adequately described by the PEIR, members of the public are expected to push for such review regardless of the provisions of CEQA.”