Stormwater Management Initiative Update

1. Stormwater Management Initiative Update

2. ODOT’s Goal Develop a streamlined stormwater runoff treatment program to: • meet all regulatory needs; • provide ODOT with certainty regarding scope, schedule, and budget • result in an overall environmental benefit and promote species recovery.

3. Components of the Stormwater Initiative Work Plan • Streamline the ODEQ Stormwater Management Plan Approval Process • Develop Strategy/Process for ODOT Projects with T&E Species and Stormwater Effects • Develop a Watershed Approach to Mitigate for Unavoidable Stormwater Effects

4. I. Streamline the ODEQ Stormwater Management Plan Approval Process Problem Statement All applications for SWMPs reviewed in detail by ODEQ, which results in • Multiple requests for more information, design changes • Constant danger of schedule slipping • Heavy load on ODEQ/ODOT liaison

5. I. Streamline the ODEQ Stormwater Management Plan Approval Process Proposed Strategy/Solution • ODOT to develop a more rigorous QC Process (i.e., ODOT review equivalent to existing DEQ review) • Shift QC for SWMPs from ODEQ to ODOT • ODEQ moves into more of a QA role

6. I. Streamline the ODEQ Stormwater Management Plan Approval Process Water Resources Impact Assessment Determine Objectives/Goal(s) Water Quality Management Design Internal ODOT Quality Control - QC Checklist Optimize Treatment Option Selection • ODOT Submits to DEQ • Submittal Application • Form • Project Description • Objectives and Goals • Stormwater • Treatment Measures • Project Plan Sheets DEQ Approves SWMP DEQ Reviews SWMP Submittal Package

7. I. Streamline the ODEQ Stormwater Management Plan Approval Process Anticipated Benefits ODEQ • Assurance that state water quality standards are being met through ODOT diligence • Substantial reduction in amount of time reviewing SWMPs • More time to provide early project support • More time to participate in programmatic and policy issues

8. I. Streamline the ODEQ Stormwater Management Plan Approval Process Anticipated Benefits ODOT • Shorter timeframe for approval of SWMPs • Higher degree of certainty about requirements and schedule, based upon well-defined expectations

9. Where We are Now:DEQ • Draft QC Checklist in final DEQ review • Draft Stormwater Management Plan submittal Checklist in final DEQ review • MOA in development • Water Quality Goals and Performance Standards in development

10. II. Develop Strategy/Process for ODOT Projects with Stormwater Effects Problem Statement Stormwater had become a major impediment to efficient ESA process due to: • Lack of congruence in water quality requirements between ODEQ and NMFS • Changing thresholds for effects determinations in ESA Section 7 consultations • Difficulties in using NMFS HCD Guidance

11. II. Develop Strategy/Process for ODOT Projects with Stormwater Effects Proposed Strategy/Process • Compile and synthesize literature on BMPs for stormwater treatment • Compile and synthesize literature on Pollutants of Concern • Develop criteria for identifying the water quality design storm • Develop a BMP Selection Matrix • Formalize a process to select BMPs • Develop a performance measurement and reporting method

12. II. Develop Strategy/Process for ODOT Projects with Stormwater Effects Anticipated Benefits Regulatory Agencies • Meet regulatory requirements • Well-defined terms and conditions that allow for flexibility in application • Protect ESA-listed fish • Protect Oregon’s water quality and wetland resources

13. II. Develop Strategy/Process for ODOT Projects with Stormwater Effects Anticipated Benefits ODOT • Certainty in project development and construction • Reduction in project delays • Support ODOT’s Sustainability goals

14. III. Develop a watershed approach to mitigate for unavoidable stormwater effects Problem Statement • Current approach to mitigate impacts of transportation projects on water resources is project specific, on-site treatment • Energy is devoted to mitigation efforts that can result in little net benefit to the watershed • Projects that don’t meet Resource Agency goals subject to squabbling and uncertain additional requirements

15. III. Develop Watershed Approach to Mitigate for Unavoidable Stormwater Effects Proposed Strategy/Solution (In Development) • Technical evaluation of needs and opportunities for mitigation • Political effort to achieve agreement on goals, methods, and interagency coordination

16. III. Develop Watershed Approach to Mitigate for Unavoidable Stormwater Effects • Work will commence when Task II is close to completion

17. Where We are NowStormwater Effects • Active working group with NMFS, USFWS, EPA and DEQ • Design Storm survey complete • Work beginning on defining criteria • Literature review complete, focused review beginning

18. Where We are NowStormwater Effects • Agreement that adequacy of design selection process and BMP selection matrix will be memorialized in Biological Opinions • Agreement that the selection process and BMP matrix can facilitate batched BOs • Work order for Matrix development is in the works • Work order includes formulating strategy for development of the Watershed Approach