Paying for TMDL Compliance: The Calleguas Creek Example Don Kendall, CMWD Ashli Desai, Larry Walker Associates February 28 th, 2007

Introduction Description of Calleguas Creek Watershed Motivation for developing TMDLs What’s involved with developing a TMDL Challenges and benefits Implementation

Map

StakeholderCommittee SteeringCommittee Public Outreach / Education Subcommittees Water Resources / Water Quality Habitat / Recreation Land Use Flood Protection / Sedimentation Agriculture 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 SourcePossible Implementation Action High Annual Cost Low Annual Cost POTWs Elimination 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