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This document discusses controversial issues in water quality control standards for new and redevelopment projects, including thresholds for requiring treatment, reporting databases, small and regulated projects, O&M inspections, single-family home requirements, alternative compliance programs, lack of LID requirements, infiltration limitations, and more.
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Provision C.3.New and Redevelopment Performance Standards Sue Ma Water Quality Control Board San Francisco Bay Region November 15, 2006 1
C.3. New and RedevelopmentControversial Issues • 5000 ft2 threshold for requiring treatment • Reporting – Databases • Small projects • Regulated projects • O&M inspections 2
C.3. New and Redevelopment Controversial Issues • Single-family home requirements • O&M inspections - new treatment systems • Alternative compliance program • Impracticability, oversight, current programs • Lack of LID requirements • 3rd party certifications of treatment designs • Infiltration limitations 3
Impervious Surface DataProject Categories • Group 1 Projects > 1 acre • Group 2 Projects > 10,000 ft2 & < 1 acre • Small Projects < 10,000 ft2 • Single-Family • Non Single-Family 4
City of Pleasanton3-Year SummaryNew/Replaced Impervious Surface88.7 AcresJanuary 2003 – November 2005 0.4 acres 69.7 acres 4.0 acres 3.6 acres 15.0 acres 9
City of Pleasanton3-Year SummaryNew/Replaced Impervious SurfaceSmall Projects, 4.0 AcresJanuary 2003 – November 2005 78% (3.16 acres) > 5000 ft2 & <10,000 ft2 (95% single-family res.) = 2.99 acres (5% non single-family res.) = 0.17 acres 22% (0.87 acres) < 5000 ft2 (71% single-family res.) = 0.62 acres (29% non single-family res.) = 0.25 acres 10
City of Palo Alto4-Year SummaryNew/Replaced Impervious Surface43.3 AcresOctober 2001 – December 2005 19.34 acres 13.7 acres 21.5 acres 8.1 acres 2.12 acres 13
City of Palo Alto4-Year SummaryNew/Replaced Impervious SurfaceSmall Projects, 21.5 Acres October 2001 – December 2005 87% (18.8 acres) < 5000 ft2 (92% single-family res.) = 17.34 acres (8% non single-family res.) = 1.42 acres 13% (2.7 acres) > 5000 ft2 & <10,000 ft2 (74% single-family res.) = 2 acres (26% non single-family res.) = 0.7 acres 14
Conclusions • Current data represents small percentage of Bay Area cities • Data illustrates two extremes • Capturing all impervious surfaces requires threshold to be < 1000 ft2 of impervious surface • 5000 ft2 threshold for requiring stormwater treatment will have small impact • Some site design requirements appropriate for single-family homes 15
MRP Provisions • Threshold for treatment reduced to > 5000 ft2 new/replaced impervious surface • Site Design BMPs required for single-family homes creating/replacing > 5000 ft2 new/replaced impervious surface • Implementation in 4th year of MRP adoption • Required data collection for new/replaced impervious surface for small projects 16
MRP Provisions List of BMPs for Single-Family Homes • Divert roof runoff to vegetated areas before discharge to storm drain • Direct surface flow to vegetated areas before discharge to storm drain • Install driveways, patios and walkways with pervious material such as pervious concrete or pavers 17
Alternative Compliance • Preserves intent in current permits • Eliminates variability and levels playing Preserves preference for onsite treatment or compliance at Regional Project • Allows finding of impracticability based only on cost or inability to meet other federal, state or local requirements • Maintains reduction in requirements for special projects (Brownfields, low income, transit villages, etc.) 18
Operation and Maintenance Requirements: • Inspect newly installed treatment BMPs • Inspect minimum percentage • Coordinate with vector control agencies • Determine compliance rates 19
Reporting Regulated Projects: Sample reporting tables were distributed 1½ years ago; most data already being collected and reported O&M: More specific data for inspections (compliance status and enforcement actions) allows a more quantitative effectiveness evaluation by programs and Water Board Small Projects Impervious Data: Data serves to validate MRP thresholds and provide database for next permit reissuance 20