1 Provision C.3. New and Redevelopment Performance Standards Sue Ma Water Quality Control Board San Francisco Bay Region November 15, 2006

2 2 C.3. New and Redevelopment Controversial Issues 5000 ft 2 threshold for requiring treatment Reporting – Databases –Small projects –Regulated projects –O&M inspections

3 3 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 3 rd party certifications of treatment designs Infiltration limitations

4 4 Impervious Surface Data Project Categories ●Group 1 Projects > 1 acre ●Group 2 Projects > 10,000 ft 2 & < 1 acre ●Small Projects < 10,000 ft 2 ●Single-Family ●Non Single-Family

5 5 City of Fairfield New Impervious Surface Acres Fiscal Year acres 0.2 acres 2.1 acres

6 6 Suisun City New Impervious Surface 56.5 Acres Fiscal Year acres 1.4 acres 0.5 acres

7 7 City of Dublin New/Replaced Impervious Surface 25.5 Acres January – December acres 1.4 acres 0.2 acres

8 8 City of Livermore New/Replaced Impervious Surface 49.1 Acres January – December acres 1.1 acres 9 acres 0.52 acres 0.59 acres

9 9 City of Pleasanton 3-Year Summary New/Replaced Impervious Surface 88.7 Acres January 2003 – November acres 15.0 acres 4.0 acres 0.4 acres 3.6 acres

10 City of Pleasanton 3-Year Summary New/Replaced Impervious Surface Small Projects, 4.0 Acres January 2003 – November % (0.87 acres) < 5000 ft 2 (71% single-family res.) = 0.62 acres (29% non single-family res.) = 0.25 acres 78% (3.16 acres) > 5000 ft 2 & <10,000 ft 2 ( 95% single-family res.) = 2.99 acres (5% non single-family res.) = 0.17 acres

11 City of Menlo Park 5-Year Summary New Impervious Surface 14.7 Acres April 2000 – March acres 0.9 acres 10.7 acres 10.2 acres 0.5 acres

12 City of Menlo Park 4-Year Summary New Impervious Surface Small Projects, 10.7 Acres April 2000 – March % (0.8 acres) > 5000 ft 2 & <10,000 ft 2 (all single-family res.) 93% (9.9 acres) < 5000 ft 2 (95% single-family res.) = 9.4 acres (5% non single-family res.) = 0.5 acres

13 City of Palo Alto 4-Year Summary New/Replaced Impervious Surface 43.3 Acres October 2001 – December acres 8.1 acres 21.5 acres acres 2.12 acres

14 City of Palo Alto 4-Year Summary New/Replaced Impervious Surface Small Projects, 21.5 Acres October 2001 – December % (2.7 acres) > 5000 ft 2 & <10,000 ft 2 (74% single-family res.) = 2 acres (26% non single-family res.) = 0.7 acres 87% (18.8 acres) < 5000 ft 2 (92% single-family res.) = acres (8% non single-family res.) = 1.42 acres

15 Conclusions Current data represents small percentage of Bay Area cities Data illustrates two extremes Capturing all impervious surfaces requires threshold to be < 1000 ft 2 of impervious surface 5000 ft 2 threshold for requiring stormwater treatment will have small impact Some site design requirements appropriate for single-family homes

16 MRP Provisions Threshold for treatment reduced to > 5000 ft 2 new/replaced impervious surface Site Design BMPs required for single-family homes creating/replacing > 5000 ft 2 new/replaced impervious surface Implementation in 4 th year of MRP adoption Required data collection for new/replaced impervious surface for small projects

17 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 MRP Provisions

18 Preserves intent in current permits Eliminates variability and levels playing field 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.) Alternative Compliance

19 Requirements: Inspect newly installed treatment BMPs Inspect minimum percentage Coordinate with vector control agencies Determine compliance rates Operation and Maintenance

20 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 Reporting