Item C: Stormwater Permit and Program Developments

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HISTORY OF ACTIONS RELATED TO EUGENE'S STORMWATER PERMIT The Clean Water Act of 1972 established the federal NPDES pennitting program. The original purpose of the NPDES program was to control and eliminate pollutants from single identifiable sources, sometimeS called point sources. The Clean Water Act was reatlthorized by Congress in 1987. The reauthorized law was expanded to include non~point source pollution: overland runoff C()ntaining pollutants which do not originate from one specific location, The expanded law required municipalities over 100,000 in population to obtaiil NPDES permits for their srormW<lter discharges. In response to the 1987 reauthorization of the Cleali Water Act, the Eugene City CoundladoptedaComprehensive . Srormwatei Management Plan {CSWMP} in 1993. Key elements of this plan include: · Amultiple-objective approach to stonnwater management that addresses drainage, water quality. and stormwater- rdatednatural resources; · A set of policies, goals and implementation actions to guide the City's stormwater program; · Two types of implementation actions - best management practices (BMPs) to specilicaUy comply withNDPES permit requirements, and "other actions" consistent with co1l1munity expectations fot stormwater tnanagement. The set of BMPs that specilic;,tlly complies with NPDES permit tequirefilenrs defines the City's NPDES Permit Stormwater Management Plan (SWMP). Eugene's first five~ year permit was issued by DEQ in 1994. In March 2004 the DEQ issued a new NPDES permit to Eugetle. In resf>onse to the new permit. . the City is proposing to revise its SWMP. The new SWMPdiffers from the prcn:<)us SWMP in several significant ways: . -The revised SWMP recognizes that Eugene's stormwater program has been in place for ten years and that many activities have heen implemented. Therefore, the revised SWMP is designed to focus more on program implementation, water quality monitoring. assessments ofBMP effectiveness, and adaptive management. . · The revised SWMP addresses new permirconditions related to specific pollutants of concern for Eugene's waterways, especially 303(d}~l1sted water bodies (see glossa.ry). lIte new SWMP anticipates that J?ollutantdischarge limitations will be established for Eugene's waterways as Total Maximum Daily Load (TMDL) requirements. . RESULTS OF THE NPDES PERMIT--RELATED EVALUATION City of Eugene staff conducted an internal review of Eugene's existing Stormwater Management. Plan (SWMP), including23 best management practkes (BMPs) proposed for the 2005 SWMP. In . evaluating the plan, its BMPs, and existing program activities, staff considered a variety of factors, induding monitoring and reporting requirements, ways to reduce pollutants to the maximum extent practicable, ways to address 303(d).., listed pollutants, and ways to control nOn..,stormwater discharges to the municipal stormwater system. 'Ihe results of this evaluation will be the basis of a second-year report to the DEQdescribing Eugene's compliance. with the new permit. One of the first things staff did was to validate the importance of existing program activities considered essential to meeting new permit conditions. 2 These existing program activities include: · Stormwater education - Erosion prevention · Street sweeping · Industrial.stormwatetprogram · System deaning - illicit discharge and spill response programs - Continued basin planning In its evaluation of the SWMP' staffplac<;:d the highest priority on the need roaddress gaps between existing program activities and permit requirements. Specifically, two actions "Were identified. to respond to gaps: · Adopt water quality design standards for new development · Establish a consisteilt policy related to public use of pesticides, herbicides and fertilizers Additionally, staff recommended several "adaptive management" strategies to address new requirements related to problem pollutants: · Implement a new bacteria pilot study. · Expand the storrnwater monitoring program to meet new permit conditions and indude in each BMP description the menies used to measure BMP effectiveness. · Continue to collect and analyze production data from street sweepers and vactor truckS, with a goal of using this data to optimize the effectiveness of these programs for water quality. - Conduct a business awareness effort related to the proper use of pesticides, herbicides and fertilizers. · Formalize: the process to document locations and characteristics of water quality. facilities so this information can be used more readily for evaluation and rer :ng purposes.. - Formalize processes to evaluate the impact of new flood control capital . projects on water quality;