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Provision C.3. New and Redevelopment Performance Standards

Provision C.3. New and Redevelopment Performance Standards. Sue Ma Water Quality Control Board San Francisco Bay Region November 15, 2006. C.3. New and Redevelopment Controversial Issues. 5000 ft 2 threshold for requiring treatment Reporting – Databases Small projects Regulated projects

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Provision C.3. New and Redevelopment Performance Standards

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

  2. C.3. New and RedevelopmentControversial Issues • 5000 ft2 threshold for requiring treatment • Reporting – Databases • Small projects • Regulated projects • O&M inspections

  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 • 3rd party certifications of treatment designs • Infiltration limitations

  4. Impervious Surface DataProject Categories • Group 1 Projects > 1 acre • Group 2 Projects > 10,000 ft2 & < 1 acre • Small Projects < 10,000 ft2 • Single-Family • Non Single-Family

  5. City of FairfieldNew Impervious Surface146.3 AcresFiscal Year 2004 - 2005 0.2 acres 144 acres 2.1 acres

  6. Suisun CityNew Impervious Surface56.5 AcresFiscal Year 2004 - 2005 54.6 acres 0.5 acres 0.5 acres 1.4 acres

  7. City of DublinNew/Replaced Impervious Surface25.5 AcresJanuary – December 2005 23.9 acres 0.2 acres 1.4 acres 0.2 acres

  8. City of LivermoreNew/Replaced Impervious Surface 49.1 AcresJanuary – December 2005 0.52 acres 39 acres 1.1 acres 9 acres 0.59 acres

  9. City of Pleasanton3-Year SummaryNew/Replaced Impervious Surface88.7 AcresJanuary 2003 – November 2005 0.4 acres 69.7 acres 4.0 acres 3.6 acres 15.0 acres

  10. City of Pleasanton3-Year SummaryNew/Replaced Impervious SurfaceSmall Projects, 4.0 AcresJanuary 2003 – November 2005 78% (3.16 acres) > 5000 ft2 & <10,000 ft2 (95% single-family res.) = 2.99 acres (5% non single-family res.) = 0.17 acres 22% (0.87 acres) < 5000 ft2 (71% single-family res.) = 0.62 acres (29% non single-family res.) = 0.25 acres

  11. City of Menlo Park5-Year SummaryNew Impervious Surface14.7 AcresApril 2000 – March 2005 10.2 acres 3.1 acres 10.7 acres 0.9 acres 0.5 acres

  12. City of Menlo Park4-Year SummaryNew Impervious SurfaceSmall Projects, 10.7 AcresApril 2000 – March 2005 7% (0.8 acres) > 5000 ft2 & <10,000 ft2 (all single-family res.) 93% (9.9 acres) < 5000 ft2 (95% single-family res.) = 9.4 acres (5% non single-family res.) = 0.5 acres

  13. City of Palo Alto4-Year SummaryNew/Replaced Impervious Surface43.3 AcresOctober 2001 – December 2005 19.34 acres 13.7 acres 21.5 acres 8.1 acres 2.12 acres

  14. City of Palo Alto4-Year SummaryNew/Replaced Impervious SurfaceSmall Projects, 21.5 Acres October 2001 – December 2005 87% (18.8 acres) < 5000 ft2 (92% single-family res.) = 17.34 acres (8% non single-family res.) = 1.42 acres 13% (2.7 acres) > 5000 ft2 & <10,000 ft2 (74% single-family res.) = 2 acres (26% non single-family res.) = 0.7 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 ft2 of impervious surface • 5000 ft2 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 ft2 new/replaced impervious surface • Site Design BMPs required for single-family homes creating/replacing > 5000 ft2 new/replaced impervious surface • Implementation in 4th year of MRP adoption • Required data collection for new/replaced impervious surface for small projects

  17. MRP Provisions 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

  18. Alternative Compliance • 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.)

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

  20. Reporting 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

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