Item A: Municipal Stormwater Permit Renewal

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The City was issued its second NPDES permit in 2004. The second (and current) permit includes additional requirements in the areas of water quality monitoring, reporting, evaluation, addressing specific problem pollutants, and public involvement. As a condition of the permit, and an aspect of on- going adaptive management, an evaluation of the City’s stormwater program was completed in 2005. The evaluation confirmed the importance of core program activities and identified two gaps in the City’s program: stormwater development standards and a citywide policy regarding pesticides and herbicides. Some program adjustments were also identified in the areas of water quality monitoring, a pilot study to focus on identifying potential sources of bacteria in Eugene’s stormwater; and targeted outreach to businesses and commercial landscapers related to the proper use of pesticides and fertilizers. A City Council work session was held on October 10, 2005, to update the council on the results of the review, at which time the council authorized the City Manager to include funds in the FY07 budget to address the identified gaps and program adjustments. Follow-through on 2005 Permit-Related Gaps and Program Adjustments The following actions have been taken to address the gaps and program adjustments identified in 2005: City Council adopted the Stormwater Development Standards in June 2006, and its companion ? Stormwater Management Manual was adopted in July 2006. These standards are now in effect and apply to all new development adding or replacing 1,000 square feet of impervious surface area. Parks and Open Space Division staff have developed a draft integrated pest management (IPM) ? policy and draft operations and maintenance manual for adoption by mid-2009. The POS policy and operations and maintenance manual, once finalized, may be utilized to establish a Public Works department-wide approach to IPM and beyond that, potentially, a city-wide approach. One monitoring site on the Willamette River downstream of Delta Ponds has been added. ? A bacteria pilot study was initiated including monitoring and site assessment. ? Program Assessment for Permit Renewal Application 2008 The City’s current NPDES permit is scheduled to expire in February 2009, and a renewal application will be submitted to DEQ by September 2, 2008. The permit renewal requirements include an updated evaluation of the SWMP conducted in 2005, to “determine whether implementation of the components in the SWMP is sufficient to reduce the discharge of pollutants to the maximum extent practicable.” The permit renewal application also must include proposed changes to address the urban stormwater discharges of the Willamette Total Maximum Daily Load (TMDL) approved by the EPA in September 2006. In light of these and other specific permit renewal requirements, and as part of routine adaptive management, an updated review of the City’s stormwater program was recently conducted. As in 2005, one outcome of the 2008 evaluation was the validation of existing core program activities considered essential to meeting permit conditions such as system operations and maintenance, stormwater education, erosion prevention, stormwater development standards, illicit discharge controls, capital improvement projects, and the industrial stormwater management program. Another outcome of the 2008 evaluation was to identify proposed changes to the SWMP. The nature of the changes proposed, and an updated summary of Eugene’s stormwater best management practices are described in Attachment A: NPDES Stormwater Management Plan fact sheet. Since not much time has passed since the 2005 SWMP evaluation, and because the 2005 revisions anticipated pollutant allocations for Willamette TMDL watersheds, the proposed changes to the SWMP are more refinements to the existing program than major changes. No significant gaps were identified in the 2008 evaluation. Based upon the process used to develop the initial 1994 SWMP, on-going adaptive management as reflected in the annual reports to DEQ, the 2005 SWMP evaluation and the recent 2008 SWMP evaluation, staff Z:\CMO\2008 Council Agendas\M080730\S080730A.doc