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Over the last five years, Contra Costa County, along with 75 other cities, counties, and flood protection districts, has implemented the first Municipal Regional Permit (MRP) for the Bay Area by the Regional Water Quality Control Board. This permit required substantial investment in treating the quality (and sometimes the quantity) of stormwater from new and redevelopment projects, the initiation of the litter/trash abatement program, and several demonstration projects to examine the feasibility of treating stormwater to remove pollutants of concern, such as Poly-Chlorinated-Biphenyls (PCBs) and Mercury. This was in addition to the ongoing NPDES programs of Municipal Operations, Commercial, Industrial, and Construction site controls, Public Outreach and Education, and Integrated Pest Management.
Over the last year, municipal staff and consultants have met numerous times with Regional Water Board staff to discuss development of the next Municipal Regional Permit (MRP 2.0). On February 11, 2015, the Regional Board shared an “Administrative Draft” of the new NPDES Permit. Negotiations became more frequent, focused, in depth, and detailed. On May 11, 2015, the Regional Board released the Tentative Order for MRP 2.0.
The proposed MRP 2.0 will require Contra Costa County to continue to implement most of the existing NPDES Permit requirements at current levels. In addition, the County will need to reduce trash rates in unincorporated communities by an additional 30% (to a total reduction of 70%) by 2017. This will require the County to treat all parcels with “very high” or “high” trash rates to a “medium” trash rate, as well as reduce the trash rates from a substantial percent of the parcels with a “medium” trash rate to a “low” trash rate.
The County will be required to develop a plan within one year to treat stormwater from roads. This plan, called the Green Infrastructure (GI) Plan, will expand stormwater treatment from private development to require treatment of stormwater from existing roads. The GI planning area will focus on areas with historic and current industrial uses, as well as residential and commercial areas built between 1945 and 1980. This includes significant portions of west and central County communities.
The GI Plan will need to begin implementation quickly in order to achieve mandated numeric reductions in PCBs and Mercury in stormwater. Costs to build and maintain facilities identified in the GI Plan have not been identified or provided. We assume these monies will either come from the Stormwater Utility Assessments, the General Fund, or the Road Fund. If road funds are used, this will create a conflict with other road fund uses, such as pavement management, repair of transportation facilities, and road improvements. At least one GI project will need to be completed during MRP 2.0. However, in reality, several will need to be constructed in areas with high PCB/Mercury concentrations in order to help meet the PCB and Mercury load reduction requirements.
The County will also need to vigilantly enforce illicit discharge of PCB and Mercury tainted sediment coming from private properties and conduct enhanced municipal operations, including street sweeping (where feasible), storm drain inlet and pipe cleaning (where existing), and/or ditch cleaning. The County may want to consider amending the County’s stormwater ordinance to increase financial penalties and/or develop an ability to place penalties on properties that refuse to abate sediment discharges. The County can also refer these sites to the Regional Water Board. However, they have a poor record for acting quickly and decisively.
The County, along with the other 70 cities and counties, will need to develop and implement a program to prevent caulk (used in the building industry) from entering into stormwater during the renovation or demolition of buildings. This program would ideally be handled at the state level, similar to programs to abate lead paint and asbestos. Collectively, all of the cities and counties will need to develop a study to explore the potential of PCB containing caulk, used to seal storm drains, entering into stormwater. The results of this study will influence the requirements in the next MRP.
On June 10 and July 8, 2015, the Regional Water Board held hearings and took testimony on the proposed MRP 2.0. Testimony was given by many municipal staff, a few elected officials, including Supervisor Gioia, as well as staff and volunteers from several nonprofit organizations. Written comments were received through July 10, 2015. |
The County Watershed Program estimates $500,000/year to $750,000/year (or more) to implement the Trash Management Plan to achieve 70% trash reduction levels by 2017 and up to $1,000,000 over a five-year period to develop the GI Plan. These costs are in addition to costs to administer the ongoing NPDES programs. All costs will be funded through Stormwater Utility Assessments.
Costs to implement the GI Plan will be borne by transportation funds (gas tax, VLF fees, etc.) and grants (if available). The remainder of the NPDES permit is expected to cost roughly the same to implement as MRP 1.0 ($1.5 million/year). The County Watershed Program was able to transfer the costs associated with General Drainage Maintenance from Stormwater Utility Funds to the General Fund. This should free up most of the funds needed to increase trash reduction efforts and develop the GI Plan.
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