LA County MS4 Permit: Permit Management Plan &

Notifications to Develop Watershed Management Programs

Item 14

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

Outline

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)

Background

Board staff activities completed/underway (Nov. ‘12-present)

Outreach Technical

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

Stormwater Permitting Unit

TMDL Program

Enforcement Program

Legal CounselWatershed

Management Coordinator

Outreach/ Facilitation

Permit Management: Team Approach

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

Staffing Management Plan

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

Key Permittee Deliverables: Years 1 & 2

Submittals received as of June 28, 2013: 12 EWMP notifications 6 Group WMP notifications 11 Individual WMP notifications 2 Permittees did not submit a WMP or EWMP

notification

WMPs/EWMPs:Summary of Notifications of Intent

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)

Internal Work Breakdown: EWMPs/WMPs

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

Internal Work Breakdown:Review of Notifications of Intent

Purpose: Provide additional time, where appropriate, to achieve final WQBELs to implement a TMDL, where final compliance deadlines have passed

Stages of oversight:1. Review requests for TSOs (0-8 months)

2. Development of TSOs (6-12 months)

3. Oversight of TSOs (1-5 years)

Time Schedule Orders

TMDL Permittees Date of Request

Los Angeles Harbor / Inner Cabrillo Beach Bacteria TMDL City of Los Angeles Dec. 24, 2012

Marina del Rey Harbor Mothers’ Beach and Back Basins Bacteria TMDL

City of Los Angeles; County of Los Angeles; LA County Flood Control District

Dec. 24, 2012

Ballona Creek, Ballona Estuary and Sepulveda Channel Bacteria TMDL

City of Los Angeles; Beverly Hills; Inglewood; West Hollywood; County of Los Angeles; LA County Flood Control District

varies

Malibu Creek and Lagoon Bacteria TMDL Agoura Hills; County of Los Angeles; LA County Flood Control District

varies

Time Schedule Order Requests Received as of July 1, 2013

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

Petition Response

Type Description Frequency Format Participants/ Distribution

Deliverable Lead

Weekly Status Report

Email summary of project status (with active work

breakdown)

Weekly EmailUnit Chief, staff, and

management

Project Action List

Unit Chief

Weekly Unit Meeting

Meeting to review project action list

and statusWeekly

In Person

UnitUpdated Project

Action ListUnit Chief

Monthly EO Report

Present status and activities during past

month to Board

Monthly

(Completed in Apr.,

May & Jun. 2013)

In Person

(and written

EO Report)

Board members and Permittees/

Stakeholders

Status and Activities

Unit Chief

Board Information

Items

Present status at key deliverable deadlines and

kickoff next phase

Jul. 2013

Feb. 2014

Sept. 2014

In Person

 Board members and Permittees/

Stakeholders

 Item Summary for Board

Unit Chief/

Section Chief

Board Action Items

Present deliverable(s) for

Board consideration and

approval

As neededIn

Person

Board members and Permittees/

Stakeholders

Draft documents for Public review; Board

Package

Unit Chief/ Section Chief

Communication - Internal

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

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

Communication - External

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 WMP or EWMP

46 permittees participating in EWMPs (possibly up to 66)

◦ Draft LID ordinances / green streets policies developed

◦ Revisions to existing LID ordinances planned

Conclusion

Coming together is a beginning;

keeping together is progress;

working together is a success