The current statewide stormwater Phase II NPDES permit was issued in 2003 and expired in 2008. It’s been extended administratively while State Water Resources Control Board staff drafts an update.
This permit tells smaller California cities and towns what they must do to reduce the amount of pollutants discharged from their streets, gutters, and drainage pipes.
Tomorrow I’m headed to Sacramento for an all-day meeting to discuss one permit provision—the provision governing how land development projects must be built so that runoff impacts are minimized.
This is my living, and I’m glad to donate a day, serving no client, to assist the State with this project.
But the meeting participants didn’t get the latest draft of the provision until this morning. And it is a very rough draft, with placeholders and sentences that trail off. There are proposed requirements that clearly haven’t been thought through. And this is four years after this permit should have been written, reviewed, debated, settled, and adopted.
I’m embarrassed for Water Board staff, who I know are capable and have good intent.
I can’t help but try to imagine what level of political and bureaucratic dysfunction, what kind of organizational and management clusterf*ck, could be going on behind the scenes at the Water Board.
Tomorrow I’ll put that imagining aside and, once again, focus on the issues: why the proposed criteria don’t make technical sense and can’t be implemented consistently, why the objective of the required studies is unclear and unattainable, how developers’ engineers will game the weak language, why this is an invitation to lawsuits against the Water Boards and the cities. And on. And on.
