Santa Ana Region Stormwater Permit TMDL Requirements and Costs Jason Uhley Chief of Watershed Protection Riverside County Flood Control and Water Conservation District

Clean Water Act Federal program to protect the Beneficial Uses of lakes, rivers and streams Recreation on Canyon Lake Fishing Water Supply Warm and Cold Water Habitat

Construction Industrial Clean Water Act implemented through National Pollutant Discharge Elimination System (NPDES) Permits Construction Industrial Municipal Separate Storm Sewer System (MS4) De-minimus (dewatering) Pesticide/Herbicide Use

Today discussing MS4 Permit Municipal Separate Storm Sewer System (MS4) Santa Ana Permit reissued in 2010 Issued jointly to cities and County (Permittees) Regulates Permittee Activities Regulates private Activities Residential Business Development Other governments Construction Industrial De-minimus (dewatering) Pesticide/Herbicide Use

MS4 Permit requires Cities and County to comply with Lake Elsinore/Canyon Lake Total Maximum Daily Load (TMDL) Riverside County* Beaumont Canyon Lake Hemet Lake Elsinore Menifee* Moreno Valley* Murrieta* Perris Riverside* San Jacinto Wildomar* * Only applies to portions of the City/County within the San Jacinto Watershed

Permittee TMDL Compliance Activity Timeline 2001 – San Jacinto Construction Permit – interim new development controls 2002 – Third-term Stormwater Permit Adopted 2004 – TMDL Adopted 2006 – TMDL Task Force Formed 2006 – Final Water Quality Management Plan for New Development 2007 – Stormwater compliance programs enhanced to better address TMDL 2010 - Fourth-term Stormwater Permit Adopted 2020 – Compliance with TMDL required

Comprehensive Nutrient Reduction Plan (CNRP) for Lake Elsinore/Canyon Lake TMDL Required by 2010 Permit, due to RWQCB December 31, 2011 Must specify compliance actions and schedule for implementation Allows for adaptive management Allows Permittees to plan and budget Requires RWQCB approval Alternative: Direct liability for TMDL targets Substantive fines and penalties for non-compliance

Typical BMP Design Event 0.5”/day rainfall VOLUME: The impediment to compliance Scenario 1: Typical Storm 83,000 acres of urbanized area (17% of total watershed area) ~90% urban area untreated May need 700 acres set aside for treatment (across urban area) $177 Million capital cost + O&M Typical BMP Design Event 0.5”/day rainfall

VOLUME: The impediment to compliance Scenario 2: The “BIG” Storm Peak rainfall 3”/day Minimum 4,000 acres set aside within urban area for treatment Equivalent to a “NEW” Lake Elsinore Billion dollar solution + O&M Needed once every 20 years January 1993 – 10”/10 days December 2010 – 7”/ 8 days

CNRP Proposal – Identify and Implement Feasible Watershed Based Controls Illegal Discharge Investigations Urban Retrofit Projects New Development Controls Street Sweeping Business Inspection Programs Education/Outreach

Alternative Option: In-Lake Treatment Chemical Addition Water Column Mixing Fishery Management Aeration/Oxygenation

In-Lake Solutions = Greater Cost/Benefit BMP Capital Costs (estimated) Annual Operation Costs (estimated) Lake Elsinore Aeration, Mixing, Fish Management N/A $500,000 Hypolimnetic Oxygenation System $2-4 million $250,000 Lake Water Addition $1,500,000 Chemical Nutrient Binders $300,000 Watershed BMPs only: $1 Billion (?) $ millions (?)

In-Lake Solutions Pros Potentially order of magnitude less expensive Multiple Cost-Share Partners Treat extreme events over time Cons Requires Regional Board approval Will still need watershed controls May require enhancements

Consider other pollutant trading options Agricultural land fallowing / MSHCP conservation Septic system to sewer conversions Other pollutant trading opportunities

Next Steps CNRP Development – Due to RWQCB December 31, 2011 District coordinating draft with City / County staff City staff providing data on existing and proposed BMPs TMDL Task Force providing data on in-lake solutions Review draft with City Managers in November