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Cost of Compliance with NPDES Permits. Division of Water Quality State Water Resources Control Board September 9 , 2014 Board Meeting, Item #. July 23, 2014. State Water Board Resolution 2013-0029.

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Presentation Transcript

Cost of Compliancewith

NPDES Permits

Division of Water Quality

State Water Resources Control Board

September 9, 2014

Board Meeting, Item #

July 23, 2014


State Water Board

Resolution 2013-0029

Based on principles of 2011 Resource Realignment Resolution and corresponding 2012 Report.

Commits continued stakeholder engagement.

Directs staff and stakeholder collaboration to reduce cost of compliance while maintaining water quality protection.

July 23, 2014


State Water Board

Resolution 2013-0029

Action Item 4

Directs Water Board staff to work with NPDES Wastewater Roundtable and Stakeholders

Document existing practices.

Identify steps to ensure a transparent, consistent, and efficient process to issue NPDES permits.

Report to State Water Board by Sept. 10, 2014.

July 23, 2014


State Water Board

Resolution 2013-0029

Action Item 4

Report shall include practices that:

Identify duplicative/unnecessary monitoring and reporting requirements in existing permits;

Encourage use of surrogate/representative sampling where appropriate; and

Document need, purpose, value, and use of any special studies in the permit Fact Sheet.

July 23, 2014


State Water Board

Staff Actions

Formed subcommittee from NPDES Wastewater Roundtable.

Members consist of staff from Central Coast, Los Angeles, Central Valley, Colorado River, and San Diego Water Boards, and State Water Board.

Staff and stakeholders jointly drafted report recommendations.

July 23, 2014



Develop guidelines and procedures to allow the following:

Use of collaborative monitoring requirements and studies;

Reduced compliance monitoring frequency and constituent monitoring based upon the discharger’s compliance record; and

Use of surrogate monitoring where a constituent that can be easily and inexpensively analyzed is substituted for a constituent that is more costly and more difficult to analyze.

July 23, 2014



Recommend necessary policy development efforts to further address cost of compliance with NPDES permits.

Work with the TMDL Roundtable and stakeholders to implement a phased approach to TMDLs.

Continue developing general permits for similar types of dischargers.

July 23, 2014



July 23, 2014