Los Angeles River and Ballona Creek Stakeholder-Led Total 2019-07-18¢  Los Angeles River and Ballona

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  • Los Angeles River and Ballona Creek Stakeholder-Led Total Maximum Daily Load (TMDL)

    A Comprehensive Collaboration for Water Quality Improvements and Beyond

    Dave Jones, P.E., CH2M HILL Heather Boyle Van Meter, P.E., CDM

    Sheila Brice, City of Los Angeles, Bureau of Sanitation Donna Chen, City of Los Angeles, Bureau of Sanitation


    555 S. Flower St., #3550 Los Angeles, CA 90017

    ABSTRACT In response to the 1999 Consent Decree resulting from Heal the Bay, et al. vs. United States Environmental Protection Agency (USEPA), Total Maximum Daily Loads (TMDLs) for water bodies in the greater Los Angeles (LA) basin were required to be developed on an aggressive schedule. The first one, the Trash TMDL, was developed in the absence of a collaborative stakeholder involvement effort and was met with stiff resistance from the regulated community. An ensuing lawsuit resulted in the TMDL being remanded back to the California Regional Water Quality Control Board (Water Board). To avoid similar litigation and conflict on future TMDLs, the USEPA and the Water Board prepared a TMDL strategy document inviting agencies and organizations to take on the role of a lead stakeholder, facilitating involvement and collaboration among community interests with the objective of developing TMDLs that would be coop- eratively implemented by the regulated community. The City of LA accepted the invitation and is now leading the stakeholder-led TMDL effort for the LA River and Ballona Creek. This effort is called “CREST,” which stands for Cleaner Rivers through Effective Stakeholder TMDLs. Since the initiation of CREST in 2004, the stakeholder group has collaborated on the develop- ment of three TMDLs: Ballona Creek Toxics, Ballona Creek Bacteria, and LA River Bacteria. For the Ballona Creek Toxics TMDL, CREST developed joint comments among the stakeholders emphasizing compliance and implementation schedule issues. As a result, the draft TMDL was significantly revised to reflect stakeholder concerns while still achieving the Water Board’s desired adoption time frame. For the Ballona Creek Bacteria TMDL, CREST prepared a TMDL Implementation Strategy document that focused on implementation options and monitoring strategies, including estimated costs and schedule. The document identified specific approaches and facilities for implementation emphasizing decentralized, watershed-based solutions versus large, end-of-pipe structural solutions. CREST is now in the midst of developing the LA River Bacteria TMDL with a time line of having the TMDL ready for adoption in 2007. KEYWORDS TMDL, Stakeholder, Los Angeles, LA River, Ballona Creek



    Copyright 2006 Water Environment Foundation. All Rights Reserved©

  • INTRODUCTION The Los Angeles (LA) River and Ballona Creek are the two primary receiving water bodies within the LA basin that drain to the Santa Monica Bay. The LA River runs 51 miles through the northern, central, and southern portions of LA and other cities. The LA River watershed is 834 square miles consisting of a broad cross section of land uses from dense urban to open- spaced forest. See Figure 1. Ballona Creek flows 10 miles, draining the western portions of the Los Angeles basin serving a watershed of 130 square miles also consisting of a broad spectrum of land uses, mostly highly urbanized but also with undeveloped, open space in the upper watershed. See Figure 2. The LA River and Ballona Creek receive the dry and wet weather runoff from an estimated 4 million people plus the discharge from three major publicly owned treatment works (POTWs). These water bodies provide multiple beneficial uses including vital flood control for protection of billions of dollars in infrastructure and vital environmental habitat for aquatic and terrestrial species. AGGRESSIVE TMDL REQUIREMENTS AND THE NEED FOR ADAPTIVE IMPLEMENTATION In addition to trash, several other pollutants of concern are required to have TMDLs developed for the LA River and Ballona Creek including: nitrogen, metals, bacteria, pesticides, polychlorinated biphenyls (PCBs), polynuclear aromatic hydrocarbons (PAHs), tributyl tin (TBT), volatile organic compounds (VOCs), and other organics. The Consent Decree requires development of all of these TMDLs between 2004 and 2012. This aggressive schedule demands that TMDLs be developed before any of the desired water quality standard studies be performed. The water quality standard studies would normally confirm attainable beneficial uses and site-specific water quality objectives suitable for the attainable uses. Therefore, it is widely accepted that TMDLs be developed as mandated by the Consent Decree with the provision for ”re-openers” in the future to incorporate the results of special water quality studies. This “adaptive implementation” strategy will allow TMDLs to be developed pursuant to the Consent Decree while allowing flexibility to adapt implementation strategies in response to new data and other information pertinent to protecting beneficial uses and attaining the necessary water quality objectives. “CREST” - A COLLABORATIVE APPROACH TO ACHIEVE MULTIPLE COMMUNITY


    A stakeholder-led TMDL Steering Committee has been formed consisting of the City of LA, LA County, other cities and agencies, environmental organizations and private-sector/business interests. This stakeholder group is name CREST, which stands for Cleaner Rivers through Effective Stakeholder-led TMDLs. To embrace the stakeholder involvement approach, a broad- based public stakeholder community has been solicited to engage all interested parties that form



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  • Figure 1



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  • Figure 2


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  • the CREST Steering Committee. In addition, the CREST Technical Committee and specific technical working groups are providing scientifically rigorous and objective work plans, study objectives and methodologies, and work products. The result of the CREST effort, facilitated by the City of LA, is achieving TMDL development and implementation strategies that will address multiple pollutants through a combination of integrated projects. These integrated projects will provide water quality improvements to comply with TMDLs and greater community benefits including green-belt restoration, community park and wetland enhancements, and institutional facility improvements. CREST PROGRESS TO DATE Ballona Creek Toxics TMDL. One of the first success stories of CREST pertained to the development of the Ballona Creek Toxics TMDL. This TMDL, which is due to be adopted in June 2006, was in the public review stage as CREST was first being formalized. Immediately, the CREST process was used as a forum to openly discuss stakeholder issues in meetings and workshops involving the regulated community, environmental groups, and regulatory agencies (including the Water Board responsible for developing and adopting the TMDL). As a result of the CREST input into the TMDL development process, the draft TMDL was significantly revised to reflect stakeholder concerns while still achieving the Water Board’s desired adoption time frame. Ballona Creek Bacteria TMDL. During the summer and fall of 2005, CREST focused on supporting the Water Board in its development of the Ballona Creek Bacteria TMDL, due to be adopted in the summer of 2006. This TMDL was already well into the development phase, so the Water Board expressed the need for CREST to assist on the implementation planning and monitoring portions of the TMDL. The CREST Technical Committee developed implemen- tation options for both dry weather and wet weather conditions that included a broad range of potential solutions including the following: • Small-scale, decentralized structural options that offer multiple community benefits

    including cisterns, bioswales, porous pavement, and creek restoration • Non-structural, institutional options to decrease both bacterial concentrations in urban

    runoff and decrease the total amount of runoff, including remote-controlled landscape irrigation

    • Large, end-of-pipe, structural storage and treatment options The CREST Technical Committee produced a technical memorandum summarizing the evaluation of the implementation options including economic (estimated capital and operation & maintenance costs) and non-economic criteria. The technical memorandum describes alternative TMDL implementation strategies and recommends a preferred strategy for compliance that emphasizes decentralized, watershed-based solutions to maximize community benefits, minimize compliance costs while achieving water quality attainment goals. The estimated costs for implementation ranged from $375 million to over $900 million in capital costs to comply over a



    Copyright 2006 Water Environment Foundation. All Rights Reserved©

  • time frame of approximately 20 years. The resulting draft TMDL document being published by the Water Board incorporates key findings of the CREST technical memorandum, including the draft implementation schedule, and will include this technical memorandum as an appendix to the TMDL document to demonstrate the value of stakeholder input into the TMD