I’ve been preparing comments and ideas and proposals for the up-for-reissuance San Francisco Bay Municipal Regional Stormwater NPDES Permit, and for the statewide NPDES permit covering small municipalities.
NPDES permits are issued for 5 years, and this is, by my count, my fifth go-round.
Here’s a challenge: Can anyone involved describe, in a few words, what these permits are intended to do?
Because in their written expression, and in the programs that implement them, you’ll find a bunch of intents and purposes and mandated actions–all kind of cobbled together. Trying to piece it together is like digging into a closet where stuff has been accumulating for decades. Every part has a story, but there’s no unifying theme.
I do trainings and presentations, mostly on implementing the land development requirements of the various permits. At the beginning of each presentation, I implore the trainees to bring their own purpose, and their own creative energy, to the task at hand. The permits give us a mandate and authorization, I tell them, but it takes creativity and personal engagement to achieve something useful for our local communities.
For a land development project, that creativity has expression in the grading, drainage, and landscaping, and in the placement of bioretention facilities in relationship to the buildings and pavement. At its best, the result solves many problems with simple strokes–that is, elegant design.
I want to bring that same lesson, and that same aspiration, to the jumbled, overstuffed permits I’m now commenting on. What is the unifying theme that could make sense of the mess? And how could that result in more meaningful, creative programs going forward?
Picking through the accumulation of decades… there’s the problem of dumping and illicit discharges, and enforcement against the dumpers, and inspections of commercial/industrial facilities, and public education about preventing discharges, and then public education about use of products like pesticides, and then public education about watersheds, and their function and value, and then, for while, actual attempts at watershed management, and then seeing those attempts subsumed by the demands of implementing load reductions for specific pollutants (like heavy metals, and PCBs), and then mandates to eliminate trash, and now, retrofitting streets and drainage infrastructure to mimic natural drainage.
The unifying theme, and the opportunity, I see here is: “Changing our relationship to drainage.” Each of the parts, each of the permit mandates, and each piece of the shared history of local stormwater program implementation, connects in some way to that idea.
In a future post, I’ll apply that idea to assessing some of the successes and failures of stormwater programs, and to where they might go next.