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

2. 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

3. 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

4. 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

5. 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

6. 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
Fourth-term Stormwater Permit Adopted
2020 – Compliance with TMDL required

7. 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

8. 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

9. 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 – 10”/10 days
December 2010 – 7”/ 8 days

10. 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

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

12. 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 (?)

13. 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

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

15. 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