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Storm Water Program - STORMS

STORMS - Strategy to Optimize Resource Management of Storm Water

Chapter 4. Implementation Strategy

An overall goal of the Storm Water Strategy is to leverage existing regulatory tools for management of storm water to better focus on incentive-driven multiple benefit approaches that achieve tangible results in terms of both improved water quality and supply. Concepts and efforts captured as part of the Draft Proposal (Appendix C) were used to establish a framework for the following proposed implementation strategy. The intent is to establish priorities, focus energy and resources, and ensure that staff and stakeholders are working toward common goals.

4.1 Terminology

The following terms are defined in this document as follows:
  • Goal – A broad statement describing a desired end state.
  • Objective – A specific, measurable output that supports achievement of a goal.
  • Project – A set of tasks that contribute to achievement of an objective.

4.2 Goals

The guiding principles identified in the Draft Proposal were developed by a multidisciplinary team composed of engineers, scientists, and geologists from the State and Regional Water Boards through a thoughtful internal process. The guiding principles were further refined through a stakeholder involved process that included representatives of environmental advocacy groups, non-profit organizations, storm water permittees, and the general public. In order to recognize and preserve the collaboration and thought placed into development of the guiding principles, they have been revised as the goals of this Storm Water Strategy. The goals listed below represent the fundamental values the Water Board aspires to uphold and advance, from the perspective of the regulator as well as the regulated community and other stakeholders. Furthermore, the manner in which each individual project addresses or contributes to the Storm Water Strategy’s goals is detailed in the attached Proposed Project List (Appendix A).

Goal 1 – Change the Perspective that Storm Water is a Waste or Hazard, and Treat it as a Valuable Water Resource

Storm water is a valuable resource and a critical element of local sustainability. Past land development practices increased impervious areas and compacted soils, resulting in less storm water infiltrating and more surface runoff. Traditional MS4s and infrastructure were designed to rapidly convey storm water from the landscape into receiving waters and eventually the ocean, bays, and estuaries. In many cases under predevelopment conditions, storm water would infiltrate and recharge the water table rather than discharge to surface waters. As a result of land use impacts, groundwater characteristics and flow regimes are also altered, reducing available groundwater supplies as well as base flow for perennial streams during dry periods. This paradigm needs to shift. Capturing and using storm water as a resource can provide multiple benefits such as offsetting drought related impacts through additional recharge and aquifer storage, mitigating storm water pollution, creating open space, enhancing fish and wildlife habitat, supporting watershed processes, and improving water use efficiency while mitigating the adverse effects of flood flows.

Goal 2 – Manage Storm Water to Preserve Watershed Processes and Achieve Desired Water Quality and Environmental Outcomes

In California, pollutants in storm water from urban areas are a primary cause of impairment of rivers, lakes, reservoirs, estuaries, and the ocean. Urbanization causes changes in the natural landscape and hydrology resulting in increased loads of pollutants, increased toxicity, changes in stream flow magnitude and frequency, changes in the seasonality of various discharges, physical changes to stream, lake, and wetland habitats, changes in the energy dynamics of food webs, sunlight, and temperature, and biotic interactions between native and exotics species. Management of storm water to maintain watershed processes within natural ranges can avoid these impacts. Restoring key watershed processes(7), through actions such as retrofitting of the existing urban environment, can help mitigate the damage done by past land development practices.

Goal 3 – Implement Efficient and Effective Regulatory Programs

Improving the efficiency and effectiveness of the Water Boards’ Storm Water Program increases Water Board productivity while concurrently achieving progress toward desired environmental outcomes. Because external stakeholders must focus on environmental outcomes, the Water Boards should ensure its regulatory and funding programs also focus on environmental outcomes. Implementing a more efficient and sustainable storm water program will allow staff to work on other important program issues and is a critical key to success of this effort. As California’s population increases, pressure mounts on the environment, which leads to pressure on the Water Boards to improve regulatory results (e.g. updated permits, inspections, improved data management, policy changes). Accordingly, the Water Boards seek to improve regulatory results while also achieving environmental outcomes such as improved water quality, reliable water supply, and healthy watersheds.

Goal 4 – Collaborate in order to Solve Water Quality and Pollutant Problems with an Array of Regulatory and Non-Regulatory Approaches

While standard regulatory approaches such as issuing permits can be effective, other less common regulatory and source control approaches can play an important role in reducing pollutant discharges and protecting water quality. For example, removing pollutants before they enter storm water can be more effective than traditional treatment-based management practices. Limited resources have been applied to source control related techniques, such as product replacement, product substitutions, and green chemistry. Supporting, and where possible, implementing and incentivizing these concepts through the Water Boards’ Storm Water Program can appreciably improve storm water quality at reduced cost relative to treatment-based management practices. For example, few materials commonly reported in storm water are evaluated from a lifecycle perspective: that is, what actions, processes, or handling techniques are causing high pollutant levels in storm water and what actions, behaviors, or processes could be altered to reduce the exposure. These types of actions necessitate extensive collaboration with industries and require those agencies with appropriate authorities to take action to achieve success. Additional efforts will include public and stakeholder outreach to share information and promote change.


4.3 Objectives and Projects

The projects identified in the Draft Proposal have been reevaluated and further developed into projects that support this Storm Water Strategy. The projects have been unified under six overarching objectives to identify cohesion among them. The projects listed under a particular objective may require the same partnerships for implementation, use similar resources, or be led by the same Staff member. The six objectives are as follows:

Objective 1 – Increase Storm Water Capture and Use through Regulatory and Non-Regulatory Approaches

The projects captured in this objective are intended to increase sustainable management of storm water by establishing a technical guidance on capture and use, identifying key market drivers for estimating a monetary value for storm water and providing permit-driven incentives for storm water capture. Furthermore, the projects will examine the technical, legal, and financial barriers to storm water capture, in order to address and resolve them

Objective 2 – Increase Stakeholder Collaboration on a Watershed Scale

Watershed and waterbody scaled partnerships increase the efficacy of water quality improvement actions and ensure that regional projects receive adequate support and funding. The project captured in this objective promotes collaboration between flood control agencies, water conservation agencies, groundwater sustainability agencies, municipalities, and other key partners, to work toward sustainable management and use of storm water.

Objective 3 – Establish Permit Pathways to Assess Storm Water Programs and Meet Water Quality Requirements

The projects captured in this objective aim to evaluate current storm water programs, with particular emphasis on the municipal program, and identify alternative compliance pathways, as well as the appropriate tools and methods applied to asses compliance with these compliance pathways.

Objective 4 – Establish Financially Sustainable Storm Water Programs

The cost of compliance is a major issue for many storm water permittees and a significant source of contention among the regulated community, environmental advocacy groups and Water Boards. The projects captured in this objective aim to identify the costs of compliance with the municipal, industrial, and construction permitting programs. Additionally, projects within this objective will focus on making funding accessible to storm water projects.

Objective 5 – Improve and Align State Board Oversight of Water Board Programs and Water Quality Planning Efforts

Storm water is unique in comparison to other types of discharges and these differences are rarely accounted for in program planning, data collection or integration with other monitoring efforts. The projects captured in this objective aim to improve program oversight through a data-driven approach, and align storm water data collection with other water quality planning efforts at the Water Board.

Objective 6 – Increase Source Control and Pollution Prevention

The projects captured in this objective aim to develop strategies to reduce storm water pollutant discharges to waterbodies through the promotion of source control and other non-regulatory strategies that would reduce the exposure of pollutants to runoff.

Each project listed below (Table 2) is described in detail in Appendix A. A description of the associated timelines and products for each project is also included in Appendix A.


Table 2: Objectives, Projects, and Goals

Objective Projects Goal
Objective 1
Increase Storm Water Capture and Use through Regulatory and Non-Regulatory Approaches
Project 1a - Promote Storm Water Capture and Use 1
Project 1b - Identify and Eliminate Barriers to Storm Water Capture and Use 1
Project 1c - Increase Storm Water Capture and Use through Regulatory Approaches 1
Project 1d - Develop and Establish a Monetary Value of Storm Water 1
Objective 2
Increase Stakeholder Collaboration on a Watershed Scale
Project 2a - Encourage Stakeholder Collaboration to Promote Storm Water as a Resource 1
4
Objective 3
Establish Permit Pathways to Assess Storm Water Programs and Meet Water Quality Requirements
Project 3a - Develop Guidance for Alternative Compliance Approaches for Municipal Storm Water Permit Receiving Water Limitations 2
Project 3b - Develop Watershed-Based Compliance and Management Guidelines and Tools 2
Project 3c - Assess Municipal Storm Water Program Monitoring and Effectiveness 3
Project 3d - Establish Statewide Regulatory Framework for Municipal Storm Water Programs 3
Project 3e - Standardize Minimum Control Measures for Specific Municipal Program Elements 3
Project 3f - Develop Guidance for Implementation of Post-Construction Requirements to Improve Watershed Health 2
Project 3g - Establish Guidance for Storm Water Program Asset Management Planning and Cost Estimation 3
Objective 4
Establish Financially Sustainable Storm Water Programs
Project 4a - Implement Senate Bill 985 - Incorporate Principless of Storm Water Resource Plan Guidelines into Storm Water Programs 1
2
Project 4b - Eliminate Barriers to Funding Storm Water Programs and Identify Funding for Storm Water Capture and Use Projects
1
2
3
Project 4c - Identify Municipal Storm Water Permit Compliance Cost 3
Project 4d - Identify Industrial and Construction Storm Water Permit Compliance Cost 3
Objective 5
Improve and Align State Board Oversight of Water Board Programs and Water Quality Planning Efforts
Project 5a - Create Storm Water Program Data and Information “Open Data” 3
4
Project 5b - Evaluate and Increase Storm Water Permit Compliance
3
4
Project 5c - Establish Sector-specific Technology-based Numeric Effluent Limitations for Industrial and Construction Storm Water Permits 3
4
Project 5d - Align Water Quality Statewide Planning Efforts with Storm Water Program Implementation - Pilot Project Using the Biological Integrity Plan 3
Objective 6
Increase Source Control and Pollution Prevention
Project 6a - Establish Statewide Framework for Urban Pesticide Reduction 4
Project 6b - Identify Opportunities for Source Control and Pollution Prevention 4
Project 6c - Evaluate and Implement Trash Control 3
4

Goal 1 - Change the Perspective that Storm Water is a Waste or Hazard, and Treat it as a Valuable Water Resource
Goal 2 - Manage Storm Water to Preserve Watershed Processes and Achieve Desired Water Quality and Environmental Outcomes.
Goal 3 - Implement Efficient and Effective Regulatory Programs.
Goal 4 - Collaborate in order to Solve Water Quality and Pollutant Problems with an Array of Regulatory and Non-Regulatory Approaches.


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