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Paying for TMDL Compliance: The Calleguas Creek Example
Don Kendall, CMWDDon Kendall, CMWDAshli Desai, Larry Walker AssociatesAshli Desai, Larry Walker Associates
February 28February 28thth, 2007, 2007
Introduction
• Description of Calleguas Creek Watershed
• Motivation for developing TMDLs
• What’s involved with developing a TMDL
• Challenges and benefits
• Implementation
Map
StakeholderStakeholderCommitteeCommittee
Steering Steering CommitteeCommittee
Public Outreach /Public Outreach /EducationEducation
SubcommitteesSubcommittees
Water Resources /Water Resources /Water QualityWater Quality
Habitat / Habitat / RecreationRecreation
Land UseLand Use Flood Protection /Flood Protection /SedimentationSedimentation
AgricultureAgriculture
Calleguas Creek Watershed Management Plan
TMDLs in Los Angeles Region
• Consent Decree– EPA with Heal the Bay, NRDC, Santa Monica BayKeeper– 92 TMDLs for over 650 listings– Need to be developed by 2012
• Calleguas Creek has 7 TMDLs for 28 constituents– Salts -Nutrients– Toxicity -Metals– Bacteria -Sedimentation/Siltation– Organochlorine Pesticides and PCBs
Motivation for Developing Stakeholder-Led TMDLs
• Chloride TMDL– Lack of watershed understanding– Scientific deficiencies– Significant costs for implementation
• Calleguas Creek Watershed Management
Plan decided to become more active in
process
What’s Involved in Developing a Stakeholder-Led TMDL?
• Coordination with regulatory agencies– Communicate with staff at all levels– Find your ally– Build trust
• Coordination between stakeholders– Needs strong leadership– Decision maker’s involvement– Diverse stakeholder group
• Financial and time resources• Flexibility and patience for an evolving process
CCW Total Maximum Daily Load Process
Monitoring and Historic Data Compilation
Numeric Targets
Stakeholder Interaction
Develop Work Plans
RB/EPA Interaction
Source Assessment and Linkage Analysis
TMDL and Allocations
Implementation Plan
Nutrients
• Meetings with RWQCB not productive
• EPA not involved• Agriculture not very
involved• Lack of trust• TMDL rewritten by
RWQCB staff
OC Pesticide and Toxicity
• Strong watershed
participation-including
agriculture
• Regular productive
meetings with RWQCB
and EPA
• Evolving trust
Metals
• Most challenging TMDL to date
• Established process
• Established trust
• Successful in working through many difficult issues
Challenges
• Input from management at regulatory agencies– Hard to get decisions made and resolutions to
conflicts on timely basis
• Precedent– Targets, margin of safety, and POTW allocations
• Different approach– Requires adaptation of traditional process
Benefits
• Local knowledge incorporated into TMDL
• Alternative approaches can be explored
• Opportunities to gather and incorporate more
data and scientific knowledge
• Offensive instead of defensive approach
• TMDL is understandable and less contentious
• Builds relationships
• Implementation actions coordinated
Implementation Plan Development
• Goal of integrating all TMDL implementation actions– All TMDL implementation plans developed by
stakeholder group– Actions linked between TMDLs
• Combination of infrastructure changes, BMPs, SSOs, special studies, and TMDL reevaluation
• Implementation actions include consideration of other benefits and impacts
Urban Implementation Actions
• Receiving water allocations measured at downstream locations
• Implemented through NPDES Permits
• Driven by metals TMDL currently, but bacteria may result in more actions
• Water Quality Management Plan
• Outreach and Education Program
• Structural and non-structural BMPs
Possible BMPs – Urban
• Implement source control – Increase street sweeping to reduce vehicle sources – Implement outreach and collection program for pesticides and
mercury containing products– Institute and enforce architectural copper ban and water
conservation ordinance– Work with programs to reduce copper brake pad content – Implement controls on industrial and commercial sources– Review and potentially revise soil removal and fill activities
• Implement dry and wet weather structural controls– Evaluate new development program – Retrofit existing development to control wet and dry weather
runoff for metals
POTW Implementation
• Implemented in NPDES Permits as end-of-pipe
limits
• Actions driven by salts and nutrients TMDLs
• POTW allocations for Hill Canyon and Camarillo
WRP met through effluent reuse and reclamation
• Simi Valley developing site-specific objectives and
investigating groundwater treatment
• All POTWs nitrifying and denitrifying their effluent
Agricultural Implementation Actions
• Receiving water allocations measured at downstream locations
• Implemented through Conditional Waiver
• Driven by pesticide and sediment TMDLs
• Water Quality Management Plan
• Identification and implementation of BMPs– Structural and non-structural
• Outreach and education
Special Studies
• Natural source exclusions
• SSOs
• Sediment transport and impacts
• Identify high concentration areas of selenium, OC pesticides, and mercury
• Investigate alternatives for diazinon and chlorpyrifos
Implementation Cost Estimate-Metals
Source Possible Implementation ActionHigh Annual
CostLow Annual
Cost
POTWsElimination of Discharge $980,000
Total estimated costs $980,000
Urban
Urban Water Quality Manag. Plan $500,000 $200,000
Structural & Non-Structural BMPs $37,520,000 $1,270,000
Total estimated costs $38,020,000 $1,470,000
Agriculture
Ag Water Quality Manag. Plan $700,000
Structural & Non-Structural BMPs $8,500,000 $581,000
Total estimated costs $9,200,000 $1,281,000
Calleguas Creek Watershed TMDLs Monitoring
Goals• Determine Compliance• Identify Causes of Toxicity• Generate Land Use Runoff Data• Evaluate Effectiveness of Implementation Actions
Approach• All Listed Constituents and Toxicity• Water Column, Sediment, and Fish Tissue Monitoring• Receiving Water Stations in Key Locations
– Additional Stations may be needed• Land Use Monitoring Stations• Annual Report w/ Revisions to Approach
Implementation Actions Underway
• Coordinated TMDL monitoring program development and implementation
• Agricultural BMP effectiveness studies and outreach
• EIR and planning for POTW diversion project
• Construction of salinity management pipeline
Keys to Success of Stakeholder-Led TMDL Development and Implementation
• Strong leadership and commitment in a diverse stakeholder group– Initiative and funding
• Strong, committed and consistent regulatory staff
• Develop trust• Identify coordinated implementation
actions with multiple benefits• Recognize it as a process
Who Pays
•POTW’s
•Agriculture
•Water District
How
• Sewer Rates
• Water Rates
• $ per acre of irrigated land
• PAYGO and Debt Service