Work Status

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.

Next Wednesday (January 20th) I’ll be presenting a half-day workshop in Sausalito on Low Impact Development and stormwater NPDES compliance for land development projects. The following day (Thursday the 21st), I’ll be repeating most of the same content in a workshop in Napa.

Info and registration for the Marin workshop are here.

Info and registration for the Napa workshop are here.

Both workshops will focus on using the Bay Area Stormwater Management Agencies Association (BASMAA) Post-Construction Manual to implement compliance with Provision E.12 in the statewide Phase II Municipal Stormwater Permit.

The BASMAA Manual, which I authored in 2014–and additional information and resources, some of which are more recent–are available on the Marin Countywide Stormwater Pollution Prevention Program (MCSTOPPP) website.

The California Stormwater Quality Association’s annual conference is October 19-21 in Monterey. I’m delivering two presentations there.

The first is at a special workshop on the Central Coast Post-Construction Requirements. For those interested, my Powerpoint is here.

The second presentation, in a Wednesday session on green infrastructure, summarizes my work creating eight conceptual designs for drainage retrofits. The Powerpoint file can be downloaded here. The eight conceptual designs, accompanying project information sheets, a project report, and a cost estimating workbook can all be accessed here.

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I’m glad to see “Green Infrastructure” become au courant, although, as with “Low Impact Development,” it’s one of the those squishy terms that invites expansion, and drift.

“Low Impact Development” is used to refer to everything from sensible urban planning to water conservation, and now “Green Infrastructure” shows up in conversations about everything from building with recycled materials to planting trees. It’s all good, I guess.

For a while there, I was using “Low Impact Development Drainage Design” to keep things focused on what LID means to me, which is designing land development projects to treat runoff pollutants and mimic predevelopment hydrology. Maybe I’ll need to start saying “Green Infrastructure Public Drainage Systems” to keep the focus on designing—and retrofitting—streets and storm drains.

As Green Infrastructure becomes a thing, I’m trying to contribute by developing methods to rapidly identify retrofit opportunities and carry them forward to conceptual designs. Wonderfully enough, I’ve got an assignment to do just that. On Wednesday, I gave this 15-minute presentation at City of San Jose offices.

I delivered this presentation today on “20 LID Lessons Learned” at the California Stormwater Quality Association’s (CASQA’s) quarterly meeting in Sacramento.

The trip was just about perfect: I left the house at 6:28, BART at 6:30, Amtrak from Richmond at 6:47, beautiful views of the Carquinez Strait at dawn, a brilliant red sunrise over Suisun Bay, and into Sacramento on time at 8:37. Then a lovely morning stroll through Old Town Sacramento to the Holiday Inn. A day sharing information and stories with colleagues, and then the reverse trip: 3:30 Amtrak departure, a bit of a nap, and BART delivering me home by 5:30.

I just received the final version of the Bay Area Stormwater Management Agencies Association (BASMAA) MRP 2.0 Provision C.3 White Paper, including some final edits from my coauthor Jill Bicknell.

The “White Paper” provides technical data, analysis, and rationales to support some key changes to the California Regional Water Quality Control Board’s (RWQCB’s) stormwater requirements for land development projects in the Bay Area.

At BASMAA’s monthly Board meeting yesterday, as Chair Matt Fabry accepted a motion to forward the White Paper to RWQCB staff, he thanked us for our work, and he noted how difficult the process of preparation and review had been.

I seconded that thought silently. With 76 BASMAA member agencies in the review loop, it wasn’t possible to get consensus to propose a top-to-bottom overhaul of the requirements.

Many of the current requirements (in MRP 1.0) are vague, outdated, or wrong technically. Municipal staff lament this, and they lament the time they waste figuring out how to apply this regulatory mess to real-world development project proposals.

However, by now each of the 76 agencies has developed their own interpretations and ways of doing things, and the staff of each doesn’t want to change that for regional consistency.

There’s a more broadly applicable lesson there, I’m sure.

Anyway, I’m proud of the stuff that stayed in.

Last year I completed the BASMAA Post-Construction Manual, which applicants for development project approvals will use to design site drainage and incorporate rain gardens (bioretention facilities) into their projects. The manual implements requirements in Provision E.12 of the California State Water Resources Control Board’s Phase II Small MS4 General Permit.

The manual will be used by Marin, Sonoma, Napa, and Solano Counties, and by the small cities within those counties, so it has a fairly wide reach. It can (and I think will) be adapted for use by smaller cities, towns, and counties throughout California.

During January I completed an Excel-based calculator that should facilitate the iterative design process needed to prepare an elegant and optimal LID drainage design. It felt great to create what I think will be a quite useful tool in only a day (project budget was 8 hours, prepared for the City of Napa).

Additional resources: The instructions are in a tab within the calculator, but it might be helpful to also have them as a separate Word file. Also, the manual includes Technical Criteria for Non-LID facilities, but for bewildering and complex reasons these had to be published separately.