Stormwater Management Initiative Update

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

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

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 Multiple requests for more information, design changes Constant danger of schedule slipping Constant danger of schedule slipping Heavy load on ODEQ/ODOT liaison Heavy load on ODEQ/ODOT liaison

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) 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 Shift QC for SWMPs from ODEQ to ODOT ODEQ moves into more of a QA role ODEQ moves into more of a QA role

I. Streamline the ODEQ Stormwater Management Plan Approval Process Determine Objectives/ Goal(s) Water Resources Impact Assessment 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 Reviews SWMP Submittal Package DEQ Approves SWMP

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

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

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

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 Lack of congruence in water quality requirements between ODEQ and NMFS Changing thresholds for effects determinations in ESA Section 7 consultations Changing thresholds for effects determinations in ESA Section 7 consultations Difficulties in using NMFS HCD Guidance Difficulties in using NMFS HCD Guidance

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 BMPs for stormwater treatment Compile and synthesize literature on Pollutants of Concern Compile and synthesize literature on Pollutants of Concern Develop criteria for identifying the water quality design storm Develop criteria for identifying the water quality design storm Develop a BMP Selection Matrix Develop a BMP Selection Matrix Formalize a process to select BMPs Formalize a process to select BMPs Develop a performance measurement and reporting method Develop a performance measurement and reporting method

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

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

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 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 Energy is devoted to mitigation efforts that can result in little net benefit to the watershed Projects that dont meet Resource Agency goals subject to squabbling and uncertain additional requirements Projects that dont meet Resource Agency goals subject to squabbling and uncertain additional requirements

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

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

Where We are Now Stormwater Effects Active working group with NMFS, USFWS, EPA and DEQ Active working group with NMFS, USFWS, EPA and DEQ Design Storm survey complete Design Storm survey complete –Work beginning on defining criteria Literature review complete, focused review beginning Literature review complete, focused review beginning

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