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Low Impact Development for Compliance with NPDES Treatment and Hydrograph Modification Management Requirements in Contra Costa County. Tom Dalziel, Assistant Manager Contra Costa Clean Water Program Dan Cloak, Principal Dan Cloak Environmental Consulting
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Low Impact Development for Compliance with NPDES Treatment and Hydrograph Modification Management Requirements in Contra Costa County Tom Dalziel, Assistant Manager Contra Costa Clean Water Program Dan Cloak, Principal Dan Cloak Environmental Consulting CASQA Pre-Conference Workshop, 10 September 2007
Topics • Brief history of LID in California • Contra Costa Approach: • What’s been working for us • Planned improvements
A Brief History of LID in CA • Contra Costa Approach • Hydrograph Modification Mgt. • SWRCB Bellflower Decision • Portland Stormwater Manual • Low Impact Development Manual • Imperviousness and flow-control • Start at the Source • Stormwater NPDES Permits • Village Homes, Davis 2003 2000 1999 1994 1978
Village Homes • Narrow streets • Surface drainage • Swales as an amenity
Stormwater NPDES—Early Years • Characterization of urban runoff • Focused on demonstrating reductions of pollutant loads • End-of-pipe treatment vs. BMPs • Design criteria for conventional treatment facilities • “Do what you can, where you can.”
Start at the Source • Preceded by San Francisco Bay RWQCB “Staff Recommendations” (1993) • Emphasis on reducing imperviousness to reduce pollutant loading • Addressed need to identify site-design alternatives • Integrates urban design and site design • No regulatory mandate
Imperviousness • Importance of Imperviousness (1994) • Empirical relationship between watershed imperviousness and stream degradation • Awareness of the effects of small storms and increased runoff frequency • Peak flow control over a range of storm sizes • Continuous simulation After Before
Low Impact Development • Developed as an alternative to treatment detention basins • Addressed preserving site hydrology and natural functions • Site design and bioretention (“rain gardens”) • Included hydrologic criteria based on matching curve numbers
Bellflower Decision and HMPs • Bellflower made the L.A. RWQCB’s treatment criteria a statewide “maximum extent practicable” standard • San Francisco Bay Board added “Hydrograph Modification Management” Before After
Contra Costa’s Approach • LID is a means to achieve compliance with NPDES treatment and flow-control requirements • Focus Program resources on helping small developments, infill, and redevelopment to comply with NPDES requirements • Be pro-active
Things that are working • Collaborative Problem Solving • Development Review Process • Regulatory Compliance Approach • Prescriptive • Flexible • Continuous Improvement
Collaborative Problem-Solving • The Bathtub Theory of Government • Organize across disciplines and levels • Engage top decision-makers • Learn from developers and development professionals
Development Review Process Pre-Application Meeting Completed Application “Deemed Complete” Section Review Planning Commission Conditions of Approval CEQA Review Detailed Design Plan Set and Permit Application Construction
Development Review Process Discuss design, O&M responsibility Pre-Application Meeting Completed Application “Deemed Complete” Respond to questions and revise plan Lay out the site and stormwater facilities Prepare and submit a Stormwater Control Plan Section Review Planning Commission Conditions of Approval CEQA Review Construct facilities. Submit Final O&M Plan prior to end of construction Stormwater requirements are attached to COAs Incorporate facilities in plans and specifications Detailed Design Plan Set and PermitApplication Construction Submit draft Stormwater Facilities O&M Plan Transfer Maintenance Responsibility
Regulatory Compliance Approach • Ordinances reference Guidebook • Countywide consistency • Empowers municipal reviewers • Ability to update requirements • Options and flexibility • Design criteria and specifications
Showing Treatment Compliance • NPDES Permit sizing criteria for treatment control: • “collect and convey” drainage design • Conventional “end of pipe” treatment • Composite “C” factors to determine design inflow or volume
Sizing criterion for treatment 0.2 inches/hour BMP Area/Impervious Area = 0.2/5 = 0.04 Planting medium i = 5 inches/hour
LID for flow control After Before • Can LID facilities mitigate increased peaks and volumes of flows from impervious areas? • How would we demonstrate that? • What are the design criteria?
Analysis for flow control • 33 years hourly rainfall • Pre-project condition • 100% impervious condition • Hydrologic soil groups A, B, C, D • Swales, Bioretention Areas,In-ground and Flow-through Planters • Underdrain with flow-restrictor in C&D soils • Dry wells, infiltration trenches and basins
LID Site Design • Divide the site into Drainage Management Areas • Use landscape to disperse and retain runoff where possible • Route drainage from remaining areas to bioretention facilities • Check facility locations for available space and hydraulic head
Drainage Management Areas • Four Types of Areas • Self-treating areas • Self-retaining areas • Areas draining to a self-retaining area • Areas draining to a treatment facility • Only one surface type within each area • Many-to-one relationship between drainage areas and facilities
Self-treating areas • Must be 100% pervious • Must drain offsite • Must not drain on to impervious areas • Must not receive drainage from impervious areas • Must not drain to treatment facilities • No treatment or flow control required • No further calculations required
Self-retaining areas • Berm or depress grade to retain 1" rain • Set area drain inlets above grade • Amend soils • Terrace mild slopes • Have limited applicability in • Dense developments • Hillsides
Areas draining to self-retaining areas • Impervious areas can drain on to self-retaining areas • Example: Roof leaders directed to lawn or landscape • Maximum ratio is 2:1 for treatment; 1:1 for flow control • No maintenance verification required
Areas draining to Bioretention Facilities • Areas used to calculate the required size of the bioretention facility • Where possible, drain only impervious roofs and pavement to bioretention facilities • Delineate any pervious areas as separate Drainage Management Areas
Calculating Facility Size A-2: Paving 10,000 SF A-1: 5,000 SF Roof Bioretention Facility A A-3: Turf 20,000 SF
Treatment Effectiveness Policy • Maximum Extent Practicable • Remove small particles • Biological action/multiple pathways • Withstand shock loadings and deferred maintenance • Visibility and ease of inspection • Future availability and cost of materials • Special Site Conditions—under one acre and: • Zero lot line development • Redevelopment subject to “50% rule” • Ranked Selection—Prescriptive and Flexible • Bioretention facilities served by gravity • Bioretention facilities served by pumps • Conventional detention basins or sand filters • High-rate biofilters • Vault-based filtration systems
Improvements for 4th Edition • Compliance for subdivision maps • Operation and maintenance responsibility in small residential subdivisions • Treatment effectiveness policy • Improved facility designs and specs • Better integrated design guidance • Emphasize landscape choices • Emphasize need to coordinate developer’s design team
tdalziel@pw.cccounty.us www.cccleanwater.org/construction/nd.php dan@dancloak.com www.dancloak.com