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LA County MS4 Permit: Permit Management Plan & Notifications to Develop Watershed Management Programs

LA County MS4 Permit: Permit Management Plan & Notifications to Develop Watershed Management Programs. Item 14. Outline. Background Board staff activities to date Permit management/staffing approach Key deliverables – Years 1 & 2 Summary of notifications of intent

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LA County MS4 Permit: Permit Management Plan & Notifications to Develop Watershed Management Programs

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  1. LA County MS4 Permit: Permit Management Plan & Notifications to Develop Watershed Management Programs Item 14

  2. Outline • Background • Board staff activities to date • Permit management/staffing approach • Key deliverables – Years 1 & 2 • Summary of notifications of intent • Critical upcoming tasks • WMPs/EWMPs • TSO requests • Petitions: Responses and administrative record • Communication Plan (internal & external) • Conclusion

  3. Background • New permit based largely on watershed specific requirements • Requires increased oversight/feedback from Board staff • ‘Permit management plan’ will help guide oversight by Board staff • Initial scope of PMP~ First 2 years (12/28/12-12/28/14)

  4. Board staff activities completed/underway (Nov. ‘12-present) • Hosted 3 information sessions • Participated in 2 information sessions hosted by LACFD • Presentations to various Permittee groups • CASQA, SCWC, SMBRC, SGVCOG, Gateway WMA • Outreach to City Councils • Mailing & presentations (ex. La Puente) • Outreach to other NGOs • Presentation to national EPA/states workgroup • Numerous one-on-one meetings • Designation agreement with Region 8 (Middle Santa Ana River TMDL) • Preliminary response to petitions • Admin Record compilation • Evaluation of TSO requests / draft TSOs • Input on managing potable water supply discharges to MS4 • Formation of TAC • Development of guidelines for reasonable assurance analysis • Review of notifications of intent to develop WMPs/EWMPs Outreach Technical

  5. Permit Management: Team Approach

  6. Staffing Management Plan • Core group (~10 staff) • Balance of engineers and scientists • Multiple areas of expertise • Extended in-house team • Engineering, modeling, GIS, statistics, chemistry, biology, ecology, watershed management, monitoring program design, hydrogeology/site cleanup; communication/facilitation, program administration

  7. Key Permittee Deliverables: Years 1 & 2 Year 1 • Notifications of intent related to Watershed Management Programs (WMPs)/Enhanced Watershed Management Programs (EWMPs) – Received / under review • Notifications of intent related to Integrated Monitoring Programs (IMPs)/Coordinated Integrated Monitoring Programs (CIMPs) - Received / under review • Time schedule orders (TSOs), if appropriate, for final WQBELs with past deadlines - Received / drafting • Annual Report – Due December 15, 2013 Year 2 • Draft WMPs • Detailed work plans for EWMPs • IMPs/CIMPs • Annual Report

  8. WMPs/EWMPs:Summary of Notifications of Intent Submittals received as of June 28, 2013: • 12 EWMP notifications • 6 Group WMP notifications • 11 Individual WMP notifications • 2Permittees did not submit a WMP or EWMP notification

  9. Internal Work Breakdown: EWMPs/WMPs Stages of Oversight: • Input and review of notifications of intent to develop WMPs and EWMPs • Input regarding Permittees’ options to develop WMPs/EWMPs and requirements of notifications of intent (0-6 months) • Review of notifications of intent received from Permittees (6-9 months) • Early input during WMP/EWMP development • WMPs(6-18 months) • EWMP detailed work plans (6-18 months) • EWMPs(18-30 months) • Review of drafts and final approval • 12-month WMPs(none proposed) • 18-month WMPs(18-28 months) • EWMPs(30-40 months)

  10. Internal Work Breakdown:Review of Notifications of Intent • Led by Core group • Developing a ‘review form’ for consistency • Notifications distributed among five staff • TMDL Program staff assigned as support on watershed basis • Estimated review/comment timeframe • Individual WMPs • ~2-3 weeks: 2 core staff assigned • Group WMPs/EWMPs • ~4-6 weeks: 3 core staff assigned

  11. Time Schedule Orders • Purpose: Provide additional time, where appropriate, to achieve final WQBELs to implement a TMDL, where final compliance deadlines have passed • Stages of oversight: • Review requests for TSOs (0-8 months) • Development of TSOs (6-12 months) • Oversight of TSOs (1-5 years)

  12. Time Schedule Order Requests Received as of July 1, 2013

  13. Petition Response • 37 Petitions (41 Petitioners) • Requests for Stay – Denied • Response to Petitions • State Board 30-day letter issued July 8, 2013 • Continuing to prepare administrative record (estimated time to complete: 4-6 weeks) • Developed preliminary responses to issues raised • Prepare formal response for submittal

  14. Communication - Internal

  15. Communication - External • Phase I – clarification and direction to Permittees regarding options • Participated in LACFCD/County of LA Information Sessions (Dec. 2012, Jan. 2013) • Hosted three information sessions (Feb., Apr., Jun. 2013) • Participated in other meetings hosted by groups of Permittees, including: • Gateway Water Management Authority (Apr. 2013) • San Gabriel Valley COG (Apr. 2013) • CASQA Quarterly Meeting (May 2013) • Southern California Water Committee (Jun. 2013), • Santa Monica Bay Restoration Commission Governing Board (Jun. 2013), • South Bay Cities COG (scheduled Jul. 2013) • Participate in EWMP Coordinators Meeting (Jun. 2013) • Make presentations to City Councils (see Attachment 4) • Host individual meetings, as requested, and provide written feedback where necessary • Ex. Hidden Hills, Walnut, Vernon, Commerce, among others

  16. Communication - External • Phase II – technical meetings to discuss implementation strategies & provide feedback on deliverables • Technical Advisory Committee (TAC) • Participation in monthly or bi-monthly meetings • Development of guidelines for conducting “reasonable assurance analysis” using modeling techniques • Guidance on comprehensive evaluation of opportunities to implement multi-benefit regional retention projects • Guidance on development of IMPs/CIMPs • Watershed based Permittee/stakeholder meetings

  17. Conclusion • Board staff • Developed effective permit management plan and staffing approach • Significant outreach and technical related activity by Board staff to date • Continued reporting to Board on regular basis • Permittees • Responsive to June 28, 2013 deadline for notifications of intent • 84 of 86 permittees submitted notifications • 73 permittees (85%) are participating in a group WMPor EWMP • 46 permittees participating in EWMPs (possibly up to 66) • Draft LID ordinances / green streets policies developed • Revisions to existing LID ordinances planned

  18. Coming together is a beginning; keeping together is progress; working together is a success

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