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Home My WebLink AboutItem A: Municipal Stormwater Permit Renewal ECC UGENE ITY OUNCIL AIS GENDA TEM UMMARY Work Session: Municipal Stormwater Permit Renewal Meeting Date: July 30, 2008 Agenda Item Number: A Department: Public Works Staff Contact: Therese Walch www.eugene-or.gov Contact Telephone Number: 682-8647 ISSUE STATEMENT a The City of Eugene holds a National Pollution Discharge Elimination System (NPDES) permit for discharges from the municipal stormwater system to waters of the state. By September 2, 2008, the City will submit a permit renewal application to the Department of Environmental Quality, including a revised Stormwater Management Plan and revised Monitoring Plan. In light of specific permit renewal requirements, and as part of routine adaptive management, a review of the City’s stormwater program has been conducted. This work session is to update the City Council on the results of the program review and proposed program refinements. BACKGROUND Local Stormwater Policy In 1993, the Eugene City Council adopted the Comprehensive Stormwater Management Plan (CSWMP) thereby establishing the policy framework for a comprehensive, multiple-objective approach to stormwater management. The impetus for CSWMP came from the need to meet the federal Clean Water Act mandates as well as other community values associated with stormwater such as protection of wetlands and waterways, stormwater conveyance, and flood control. CSWMP includes policies, goals, and implementation measures. The implementation measures are divided into two categories: best management practices (BMPs) submitted as part of the City’s NPDES permit and “other actions.” The BMPs are items the City committed to fulfill under the NPDES permit. The other actions are items the City desires to implement, but are not part of the NPDES requirements. NPDES Permit History to 2005 Evaluation The City of Eugene received its first municipal stormwater permit in 1994. The permit is a requirement of the Clean Water Act for communities of a certain size. Eugene is one of six large communities in Oregon issued permits under “Phase I” of the NPDES program. The other five communities are the City of Portland, Clean Water Services, City of Gresham, City of Salem, Clackamas County, and their co- permittees. In Oregon, the Department of Environmental Quality (DEQ) is the responsible state agency for administering the NPDES program. The City’s NPDES permit includes monitoring and reporting requirements, and a set of best management practices that comprise the permit Stormwater Management Plan (SWMP). a The full name of the permit is National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Discharge Permit. It is referred to as the municipal stormwater permit, NPDES permit, or MS4 permit. Z:\CMO\2008 Council Agendas\M080730\S080730A.doc 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 concludes that the implementation of the SWMP will reduce pollutants to the maximum extent practicable. The draft Stormwater Management Plan and Monitoring Plan are available on the City’s web site at: www.eugene-or.gov/pw (select the link to “Stormwater NPDES Permit”). A printed copy of the draft documents is also available at the City Managers Office. RELATED CITY POLICIES Goal 3 of the Comprehensive Stormwater Management Plan (CSWMP, 1993) provides the policy framework for addressing NPDES requirements. Most directly relevant to this work session are: Policy 3.1 -- “Meet or exceed federal and state stormwater quality requirements especially where they conform with existing local policy;” Policy 3.2 -- “Determine the extent, magnitude, and cause of water pollution within the City’s stormwater system;” and Policy 3.3 -- “Evaluate the effectiveness of stormwater quality measures.” COUNCIL OPTIONS This is a work session and, as such, the council is not required to take any action. CITY MANAGER’S RECOMMENDATION None. Information only. SUGGESTED MOTION None. Information only. ATTACHMENTS A.NPDES Stormwater Management Plan Fact Sheet FOR MORE INFORMATION Staff Contact: Therese Walch Telephone: 682-8647 Staff E-Mail: therese.walch@ci.eugene.or.us Z:\CMO\2008 Council Agendas\M080730\S080730A.doc ùÐ×ÛÎåÛÈ×ÊûÙÈ ìÊ×ÌÛÊÓÎÕÖÍÊì×ÊÏÓÈê×Î×ÅÛÐ ùéåïìÛÎØ÷ÇÕ×Î×ªÉöÓÊÉÈ ì×ÊÏÓÈè×ÊÏ ÷ÇÕ×Î×ªÉé×ÙÍÎØì×ÊÏÓÈè×ÊÏÙÇÊÊ×ÎÈ ÛÙÈÓÆÓÈ åï ûéè÷ûîûõ÷ï÷îè ú¦ôÍÇÉ×ÔÍÐØôÛÂÛÊØÍÇÉåÛÉÈ×ìÊÍÕÊÛÏ ú ¦éÍÐÓØåÛÉÈ×ïÛÎÛÕ×Ï×ÎÈ ùî íîéèêçùèóíîûîø÷å ø ÷æ÷ðíìï÷îè ÷¦éÈÍÊÏÅÛÈ×Êø×Æ×ÐÍÌÏ×ÎÈéÈÛÎØÛÊØÉ ÷ ¦éÈÍÊÏéÃÉÈ×ÏïÛÌÌÓÎÕÛÎØøÛÈÛ ï¦ê×ÕÇÐÛÈÓÍÎÍÖóÎÉÌ×ÙÈÓÍÎïÛÓÎÈ×ÎÛÎÙ× ïÛÎÛÕ×Ï×ÎÈ ÛÎØê×ÌÍÊÈÓÎÕÍÖìÊÓÆÛÈ×çÎØ×ÊÕÊÍÇÎØ ì ¦úÛÙÈ×ÊÓÛìÓÐÍÈéÈÇØÃ éÈÍÊÏÅÛÈ×ÊéÈÊÇÙÈÇÊ×É óù îøçéèêóûðíîèêíðé ì¦ùÍÏÌÐÓÛÎÙ×ìÊÍÕÊÛÏÖÍÊïÛÓÎÈ×ÎÛÎÙ× ÍÖìÊÓÆÛÈ×ÐÃíÅÎ×Øæ×Õ×ÈÛÈ×ØéÈÍÊÏÅÛÈ×Ê öÛÙÓÐÓÈÓ×É ÷ ¦÷ÊÍÉÓÍÎìÊ×Æ×ÎÈÓÍÎÛÎØùÍÎÉÈÊÇÙÈÓÍÎéÓÈ× ïÛÎÛÕ×Ï×ÎÈìÊÍÕÊÛÏ å ¦óÎØÇÉÈÊÓÛÐéÈÍÊÏÅÛÈ×ÊïÛÎÛÕ×Ï×ÎÈ ìÊÍÕÊÛÏ ìï ÷êïóèûîûõ÷ï÷îè å¦ì×ÊÏÓÈïÛÎÛÕ×Ï×ÎÈÛÎØê×ÌÍÊÈÓÎÕ ÷¦éÈÍÊÏÅÛÈ×ÊùÛÌÓÈÛÐóÏÌÊÍÆ×Ï×ÎÈìÊÍÒ×ÙÈÉ î×ÅúïìÉÌÊÍÌÍÉ×ØÖÍÊ éåïì É×ÊÆÓÙ×ÉÅÛÈ×ÊËÇÛÐÓÈÃÌÊÍÈ×ÙÈÓÍÎÛÎØÈÔ×ìÔÛÉ×óÌ×ÊÏÓÈÈ××¦ ØÐÓÉÈ×ØÅÛÈ×ÊÚÍØÃ¦ûÅÛÈ×ÊÚÍØÃÈÔÛÈ ø÷ë¦íÊ×ÕÍÎø×ÌÛÊÈÏ×ÎÈÍÖ÷ÎÆÓÊÍÎÏ×ÎÈÛÐ ø÷ëÔÛÉØ×È×ÊÏÓÎ×ØØÍ×ÉÎÍÈÏ××ÈÉÈÛÈ×ÅÛÈ×Ê ëÇÛÐÓÈÃÅÔÓÙÔÓÉÊ×ÉÌÍÎÉÓÚÐ×ÖÍÊÛØÏÓÎÓÉÈ×ÊÓÎÕìÔÛÉ×óóÌ×ÊÏÓÈÈ××¦éÏÛÐÐ×ÊÒÇÊÓÉØÓÙÈÓÍÎÉÎÍÅ ÈÔ×îìø÷éÌÊÍÕÊÛÏÖÍÊÙÓÈÓ×ÉÙÍÇÎÈÓ×ÉÛÎØÊ×ËÇÓÊ×ØÈÍÍÚÈÛÓÎîìø÷éÌ×ÊÏÓÈÉóÎÈÔÓÉ ÍÈÔ×ÊÕÍÆ×ÊÎÏ×ÎÈÛÐ×ÎÈÓÈÓ×ÉÓÎíÊ×ÕÍÎÛÊ×ÛÌÔÛÉ×óóÌ×ÊÏÓÈÈ××ÉÓÎÙÐÇØ×ÈÔ×ùÓÈÃÍÖ úïì¦ú×ÉÈÏÛÎÛÕ×Ï×ÎÈÌÊÛÙÈÓÙ×ÛÌÊÛÙÈÓÙ× ÍÊÙÍÏÚÓÎÛÈÓÍÎÍÖÌÊÛÙÈÓÙ×ÉÈÔÛÈÌÊ×Æ×ÎÈÉÍÊ ÷ìû¦çé÷ÎÆÓÊÍÎÏ×ÎÈÛÐìÊÍÈ×ÙÈÓÍÎûÕ×ÎÙÃ ÅÔÓÙÔÓÉÊ×ÉÌÍÎÉÓÚÐ×ÖÍÊÛØÏÓÎÓÉÈ×ÊÓÎÕÈÔ×éåïì¦éÈÍÊÏÅÛÈ×ÊïÛÎÛÕ×Ï×ÎÈìÐÛÎÛÉ×ÈÍÖ ÌÍÐÐÇÈÛÎÈÉ îìø÷éÌÊÍÕÊÛÏÖÍÊÈÔ×Ö×Ø×ÊÛÐÕÍÆ×ÊÎÏ×ÎÈ ÙÍÏÏÓÈÏ×ÎÈÇÎØ×ÊÓÈÉîìø÷éÌ×ÊÏÓÈÈÍÊ×ØÇÙ× ùéåïì¦ùÍÏÌÊ×Ô×ÎÉÓÆ×éÈÍÊÏÅÛÈ×Ê ïé¦ïÇÎÓÙÓÌÛÐÉ×ÌÛÊÛÈ×ÉÈÍÊÏÉ×Å×ÊÉÃÉÈ×Ï ÌÍÐÐÇÈÛÎÈÉÈÍÈÔ×ÏÛÄÓÏÇÏ×ÄÈ×ÎÈÌÊÛÙÈÓÙÛÚÐ× ïÛÎÛÕ×Ï×ÎÈìÐÛÎ÷ÇÕ×Î×ªÉÛØÍÌÈ×ØÌÍÐÓÙÃ ÛÉÃÉÈ×ÏÍÖÙÍÎÆ×ÃÛÎÙ×ÉÓÎÙÐÇØÓÎÕÊÍÛØÉÅÓÈÔ ØÍÙÇÏ×ÎÈÅÔÓÙÔÌÊÍÆÓØ×ÉÈÔ×ÖÊÛÏ×ÅÍÊÑÖÍÊ ØÊÛÓÎÛÕ×ÉÃÉÈ×ÏÉÙÛÈÙÔÚÛÉÓÎÉÕÇÈÈ×ÊÉØÓÈÙÔ×Éèïøð ÏÛÎÏÛØ×ÙÔÛÎÎ×ÐÉÉÈÍÊÏØÊÛÓÎÉÍÊÍÈÔ×Ê ÖÛÙÓÐÓÈÓ×ÉÇÉ×ØÈÍÙÍÐÐ×ÙÈÛÎØÙÍÎÆ×ÃÉÈÍÊÏÅÛÈ×Ê×ÄÌÊ×ÉÉ×ØÛÉÌÛÊÈÉÌ×ÊÆÍÐÇÏ×