1. Regulatory Perspective Statewide Construction General Permit
SAN DIEGO WATER BOARD
Regulatory Perspective
Statewide Construction General Permit
LUP/CIP/PIP
October 26, 2016 Western Chapter – International Erosion Control Association
Laurie Walsh, PE
Senior Water Resource Control Engineer
Storm Water Management Unit

2. Presentation Outline San Diego Water Board Perspective on: 1. LUP
Capitol and Private Improvement Projects
Top Compliance Issues
Enforcement
2016 WC-IECA

3. San Diego Water Board

4. San Diego Regional Perspective
Statewide Construction Storm Water Permit
San Diego Water Board Region 9
> 1300 Active construction NOIs
What we notice……….
Failure to know your site discharges to a waterbody impaired for sediment
Failure to implement effective system of BMPs
Non-compliant management of the site
Paperwork
Training
Disconnect QSPs -> QSDs & contractors
2016 WC-IECA

5. Linear Underground/Overhead Projects
Notice of Termination
Termination requirements are different depending on complexity of LUP
Submittal of the NOT certifies compliance with CGP
Stabilization Requirements
70% coverage
Returned to original line and grade
Equivalent stabilization measures
Vegetation
2016 WC-IECA

6. The most cost effective BMP
Capitol Improvement & Private Development Projects
Problems we see……
Scheduling –
The most cost effective BMP
What we see in reality is: Mass Grading and Sediment Basin BMPs
2016 WC-IECA

7. 2016 WC-IECA

8. 401 Permits – Ask if there is one ! No Wipe Outs Allowed
Capitol Improvement & Private Development Projects
Problems we see…..
401 Permits –
Ask if there is one !
No Wipe Outs Allowed
Sites that flow into mitigation areas may have Low Flow requirements during construction
Municipalities have the authority to Stop Work
2016 WC-IECA

10. 2016 WC-IECA

11. Spraying is not enough….
Capitol Improvement & Private Development Projects
Problems we see….
Spraying is not enough….
2016 WC-IECA

14. Capitol Improvement & Private Development Projects
Problems we see….
Who’s in charge: Developers?, Contractors?, QSDs?, QSPs?
CGP Compliance: Begins when WDID Issued
Planned Development Phasing and Post Construction BMPs: Model Homes
Provision XV.D oversight by San Diego Water Board-
Triggered when more oversight is needed, large sites
Reduced the REAP NOAA trigger from 50% to 30%
Required weekly inspections be uploaded to SMARTS
2016 WC-IECA

15. Enforcement Administrative Complaints 2015/16
$595,367 against San Altos-Lemon Grove, LLC for violations of the CGP (ACL Order No. R )
$875,166 (pending) KB Home’s construction activity resulted in unauthorized fill to Los Coches Creek without obtaining a CWA Section 401 water quality certification
$50,000 against SANDAG for violations of the CGP (ACL Complaint No. R )
$46,718 Jacobs Center for Neighborhood Innovation, Northwest Village Creek Construction Project for violations of the CGP (Stipulated ACL Order No. R )
$430,851 City of Encinitas and USS Cal Builders, Inc. for violations of the CGP & MS4 Permit (Stipulated ACL Order No. R )
Important for you to know
We can rely on anyone else’s photos to allege noncompliance…and we will
We can infer intervening days of violation
2016 WC-IECA

16. Construction General Permit - The Future
State Water Resources Control Board is planning on
Add Total Maximum Daily Loads into CGP
Add Statewide Trash Policy 16
2016 WC-IECA

17. Thank you
Laurie Walsh, PE Storm Water Management Unit San Diego Water Board