Loading...
HomeMy WebLinkAboutItem C: Stormwater Permit and Program Developments EUGENE CITY COUNCIL AGENDA ITEM SUMMARY c Work Session: Stonnwater Permit and Program Developments Meeting Date: October 10, 2005 Department: Public Works www.eugene-or.gov Agenda Item Number: C Staff Contact: Therese Walch Contact Telephone Number: 682-8647 ISSUE STATEMENT In March 2004, the Department of Environmental Quality issued the City of Eugene a new National Pollution Discharge Elimination System (NPDES) permit for its municipal stormwater system discharges to waters of the state. The new permit includes additional requirements, in comparison to the City's first NPDES permit issued in 1994, including in the areas of water quality monitoring, reporting, evaluation, addressing specific problem pollutants, and public involvement. An internal review of the City's NPDES permit-related activities in light of the new permit conditions has recently been completed and public outreach is now underway. This work session is to update the City Council on the results of the review, to forecast other upcoming developments in the stormwater program, and to provide an opportunity for the council to give advanced input on including funding for NPDES permit- related items in the FY07 budget. BACKGROUND Local Stormwater Policy In 1993, the Eugene City Council adopted the Comprehensive Stormwater Management Plan (CSWMP), thus providing the policy framework for a comprehensive approach to stormwater management. The impetus for CSWMP came from the need to meet the federal Clean Water Act. 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 has 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. First NPDES Permit The City of Eugene received its first National Pollution Discharge Elimination System (NPDES) permit in 1994, a requirement of the Clean Water Act for communities greater than 100,000 in population. Eugene was one of six large communities in Oregon issued permits under "Phase I" of the NPDES program. In Oregon, the Department of Environmental Quality (DEQ) is the responsible state agency for administering the NPDES program. The NPDES permit lists best management practices (BMPs) that the City has committed to implement. Stormwater Program Review 2003 In 2003, the council held a series of four work sessions on the stormwater program due to a projected budget deficit of $2.1 million in fiscal year (FY) 2005. In August 2003, the council directed staff to L\CMOI200S Council AgendasIMOSIOIOISOSIOIOC.doc prepare the FY05 budget assuming no increase in user fees and $2.1 million in service level reductions. The council also voted not to implement a $0.50 user fee increase to fund an enhanced stream corridor acquisition program. The council was aware that the decisions would result in a program which would still meet the requirements of the 1994 NPDES permit, but that implementation other CSWMP measures would be over a much longer period of time, and some non permit-related program measures would be eliminated. Staff informed the council of the status of the City's new NPDES permit, which at that time not yet been issued, and the likelihood that the new permit would contain more rigorous conditions which would, at a minimum, require reallocation of resources within the program. The City Council subsequently approved a FY05 budget which reflected the restoration of funds for some of the services that had been identified for cuts following the 2003 program review. User fees were increased 2.5% effective July 1, 2004, to restore funding for the Willamette River bank cleanup, the NeighborWoods program, and financial support for the Long Tom and McKenzie Watershed Councils. To allow continued funding of stormwater services consistent with the proposed FY06 budget, stormwater user fees were increased by 3.5% effective July 1, 2005. Permit Renewal The City joined efforts with the five other permittees under Phase I of the NPDES program during the permit renewal process beginning in 2003 and culminating with new NPDES stormwater permits for all six permittees in March 2004. The four Portland-area permits (issued to the City of Portland, Clean Water Services, Gresham, and Clackamas County and their co-permittees) were subsequently challenged, pulled for reconsideration by DEQ, revised, and re-issued in August 2005. The four Portland-area permittees have been given additional time to compile the results of their internal permit- related evaluation, and are now required to submit an "Evaluation Report" in May 2006. Eugene and Salem remain on the original timeline for submitting evaluation reports with the second annual NPDES report, due to DEQ by December 1, 2005. New NPDES Permit & Program Evaluation The new permit includes additional requirements in the areas of water quality monitoring, reporting, evaluation, addressing specific problem pollutants, and public involvement. An evaluation of the City's program in light of new permit requirements has been completed and public outreach is now underway. The evaluation process and results are summarized in Attachment A ("National Pollution Discharge Elimination System Stormwater Management Plan"). The evaluation confirmed the importance of core stormwater program activities including street sweeping, system cleaning, education and volunteer programs, vegetation management, tree planting, erosion control, illicit discharge enforcement, spill response, and water quality monitoring. The evaluation identified two gaps in the City's program which need to be filled and specific program adjustments which need to be made in order to remain in compliance with the City's permit. Program Gap - Stormwater Development Standards One gap identified in the permit-related program evaluation is that Eugene lacks post-construction stormwater quality development standards ("stormwater development standards"). Stormwater development standards are regulations for locating, designing, constructing, and maintaining water quality facilities for new development and significant re-development. These standards are part of the current program workplan, and a draft ordinance involving changes to Chapter 9 and Chapter 6 of the Eugene City Code is under development. Public outreach is underway, including review of an ordinance summary by the Public Works Stormwater Department Advisory, and scheduled presentations L\CMOI200S Council AgendasIMOSIOIOISOSIOIOC.doc to special interest groups. An open house for interested persons is tentatively scheduled for November 3, 2005. The Planning Commission will review the draft ordinance in early 2006, and will hold a public hearing in March. The Eugene City Council is scheduled to take action on the proposed standards in May 2006. Program Gap City-wide Policy Regarding Pesticides and Herbicides Another gap identified in the permit-related program evaluation is that the City would benefit from a consistent policy related to public use of pesticides, herbicides and fertilizers which takes into account the stormwater permit requirements to reduce pollutants in stormwater discharges associated with these products. The Public Works Department has identified a staff team with the charge to establish a city- wide integrated pest management policy and outreach to all landscape operations and maintenance managers within the organization to ensure implementation of a city-wide policy. Permit-Related Program Adjustments Permit-related program adjustments necessary to meet the City's new NPDES permit requirements include: expansion of the stormwater monitoring program to include outfall monitoring, one-time upgrades for flow monitoring equipment; and a new three-year pilot study to determine likely sources of bacteria in Eugene's watersheds and assess the effectiveness of various bacteria reduction measures. Other program adjustments include: 1) analyzing production data from street sweepers and vactor trucks to optimize the effectiveness of these programs for water quality; 2) conducting a business awareness effort related to the proper use of pesticides, herbicides and fertilizers; and 3) formalizing City processes to evaluate the affects of flood control capital projects on water quality, and to evaluate the effectiveness of water quality capital projects. Program Developments The impacts of the City's new NPDES permit are reflected in the previous section with the description of gaps and necessary program adjustments. Other developments in the stormwater program are included in this section for information, and to provide a forecast to the council of items which will likely have a financial impact on the stormwater program in the near future. Water Quality Protected Waterways Implementation of water quality waterway protections for certain sensitive and impaired waterways is a part of the current program workplan. This is not a specific element of the City's NPDES Stormwater Management Plan, but is a best practice employed by other Oregon communities and is consistent with the goals and policies of the City's Comprehensive Stormwater Management Plan. Staff is working to identify waterways for protection and a draft ordinance is underway at this time. Public outreach for water quality protected waterways is scheduled to begin in January 2006, followed by Planning Commission meetings and a public hearing by May 2006, and City Council action in July 2006. River Road Santa Clara Basin Plan In April 2004, the City entered into a cooperative agreement with Lane County related to stormwater services. Included in the agreement is a commitment to collaborate on completing the draft River Road - Santa Clara Stormwater Basin Master Plan. Staff and consultant work on this project is currently underway. Public involvement has also begun, including meetings with the River Road - Santa Clara Task Force, the River Road Community Organization, and the Santa Clara Community Organization. The final basin plan will include a long term stormwater capital improvement plan and proposed development standards. Emerging issues related to the federal Safe Drinking Water Act and the continued operation of drywells in the River Road - Santa Clara area will be addressed in the final plan. L\CMOI200S Council AgendasIMOSIOIOISOSIOIOC.doc Capital improvements may be necessary to resolve the drywell issues, and could have significant financial implications for the City and Lane County. Stormwater Capital Improvement Program The City's updated Stormwater Basin Master Plans, completed in August 2002 for all basins except River Road - Santa Clara, identify $64.6 million in user fee funded capital improvement needs for FY06 through FY35. Following the 2003 program review and the need to reduce costs, the annual user fee funded portion of the Stormwater Capital Improvement Program (CIP) budget was reduced to $640,000 effective FY05. The current CIP budget level will extend the timeline for implementing the capital projects identified in the Stormwater Basin Master Plans, including neighborhood water quality facilities, pipe and culvert retrofits, stream corridor acquisition, and stream restoration. Additional projects identified in the River Road - Santa Clara Basin Master Plan will exacerbate this issue. Future Regulations Total Maximum Daily Loads In January 2005, Eugene submitted comments to the DEQ on the proposed Total Maximum Daily Loads (TMDLs), or pollutant load allocations, for the Willamette River watershed. Eugene, along with other agencies within the Willamette River watershed, will be required to reduce certain pollutants to ultimately achieve compliance with state water quality standards. Permit conditions in the City's 2004 NPDES permit are intended to ensure that the City will undertake actions to begin addressing specific pollutants of concern in the short term, in advance of completion of the TMDL. Financial and/or Resource Considerations The evaluation of the City's NPDES permit-related activities in light of new permit conditions resulted in the identification of a program gap and needed program adjustments which will require additional resources to address. Stormwater development standards, identified as a gap in the City's program, are a part of the current program workplan and are scheduled for adoption by the City Council in May 2006. Preliminary estimates of the financial impact of proposed stormwater development standards are that an additional $230,000 per year will be needed beginning in FY07 to support the program including plan review, inspection, enforcement and maintenance. Beyond FY07, the cost to maintain an increasing number of water quality facilities is expected to grow as new facilities come on-line. Detailed information about the financial impacts of stormwater development standards will be provided to the council along with the draft ordinance in spring 2006. Permit-related program adjustments which will have a financial impact beginning in FY07, along with preliminary cost estimates, include: expansion of the stormwater monitoring program ($25,000 annually); one-time upgrades for monitoring equipment ($31,000 in FY07); and a new three-year bacteria pilot study ($21,000 in FY07, with additional funds needed in FY08 and FY09). Two stormwater program developments which will require additional resources to implement beginning approximately in FY08 are: 1) adoption of proposed water quality waterway protections for specific sensitive and impaired waterways; and 2) implementation of the River Road - Santa Clara Stormwater Basin Master Plan. Detailed information about the financial implications of water quality protected waterways will be provided during the ordinance adoption process in June 2006. Detailed information about River Road - Santa Clara capital projects will be provided both as part of the FY08 budget adoption process, and during the 2008-2013 Capital Improvement Program adoption process in the spring of 2007. L\CMOI200S Council AgendasIMOSIOIOISOSIOIOC.doc Timing The City's second annual NPDES report, including the results of the internal review of the City's NPDES permit-related activities, proposed changes to the permit-related activities, and a summary of public outreach is due to the Department of Environmental Quality (DEQ) by December 1, 2005. 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 worksession 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 management measures." City Council goals applicable to this agenda item are as follows: SUST AINABLE DEVELOPMENT - A community that meets its present environmental, economic, and social needs without compromising the ability of future generations to meet their own needs: Stormwater program refinements that ensure continued compliance with federal water quality regulations contribute to the City's environmental stewardship, for the benefit of future generations. EFFECTIVE, ACCOUNT ABLE MUNICIPAL GOVERNMENT - A government that works openly, collaboratively, andfairly with the community to achieve measurable and positive outcomes: Public involvement in the NPDES permit review, and other upcoming program developments demonstrates open communication, and a desire for community input to help shape the final outcome. FAIR, STABLE AND ADEQUATE FINANCIAL RESOURCES -A government whose ongoing financial resources are based on afair and equitable system of revenues and are adequate to maintain and deliver municipal services: Forecasting well in advance the resource implications of the City's new NPDES permit and other upcoming stormwater program developments allows sufficient time for discussion and appropriate process, and ensures fair, stable and adequate financial resources. COUNCIL OPTIONS This is a work session and, as such, the council is not required to take any action. However, it would be timely for the council to use this opportunity to provide advance direction to the City Manager to include funding for the following stormwater permit-related items in the FY07 budget: stormwater development standards; expansion of the stormwater monitoring program; one-time upgrades for monitoring equipment; and a new bacteria pilot study. Options available to the council in providing the City Manager direction for building the FY07 budget are: Option 1 - The council could direct the City Manager to include budget for specific identified permit-related items in the FY07 budget ($300,000). This option would ensure that the City remains in compliance with its NPDES stormwater permit. To the extent that the budget L\CMOI200S Council AgendasIMOSIOIOISOSIOIOC.doc submitted exceeds revenues, rates would be adjusted through the appropriate administrative process. Option 2 - The council could direct the City Manager to develop the FY07 budget based upon existing revenue. Option 2 would not be consistent with policy to "meet or exceed federal and state stormwater quality requirements" and would put the City at risk of being in violation of its NPDES permit. CITY MANAGER'S RECOMMENDATION The City Manager recommends the development of a FY07 budget which includes funds for the following stormwater permit-related items: stormwater development standards; expansion of the stormwater monitoring program; upgrades for monitoring equipment; and a new three-year bacteria pilot study. SUGGESTED MOTION Move to direct the City Manager to develop a FY07 budget which includes funds for additional stormwater permit-related items: stormwater development standards; expansion of the stormwater monitoring program; upgrades for monitoring equipment; and a new three-year bacteria pilot study. ATTACHMENTS A. National Pollution Discharge Elimination System Stormwater Management Plan (Fact Sheet) FOR MORE INFORMATION Staff Contact: Therese Walch Telephone: 682-8647 Staff E-Mail: therese.walch@ci.eugene.or.us L\CMOI200S Council AgendasIMOSIOIOISOSIOIOC.doc SUBMIT PUBLIC COMMENT ON EUGENE'S NPDES PERMIT SEND WRI'ITEN COMMENTS TO: NPDES Permit . Eugene Public Works 858 Pearl Street Eugene. OR 97401 SEND E~MAIL TO: Therese Walch Water Resources Manager therese. walch@d.eugene~or.us All comments must be received by the City of Eugene by 5 p.m. Friday, October 14. All persons who submit written . comments. wilt be identified as interested parties and will be notified of the Citys . response to their comments iftlJey provide a current mailing address or a valid email address. ;;:::::;: ........ ~f~:r BACKGROUND The City of Eugene holds a federal National Pollutant Discharge Elimination . System (NPDES) permit for the municipal iitormWater it discharges directly into the Wilbmette Riverand indirectly ineo the WiIlamette River through other loca.l waterways, including Amazon Creek. The permit includes . stormwater monitoring and reporting requirements, as well as a set of best management practices that define the City's Stormwater Management Plan (SWMP). The Oregon Department of Environmental Quality {DEQ} administers federal NPDES permits for municipalities and other local agencies in Oregon. The City of Eugene has remained in fun complian<.:e with its NPDES permit since it was issued in November 1994. In March 2004, the DEQ reissued Eugene's NPDES permit for a period of five years: The reissued permit includes new requirements to ensure that Eugene'sSWMP meets. the objectives of the Clean Water Act, new requirements rdated to specific problem pollutants. and more dgorous monitoring and reporting requirements. lbe City of Eugene has evaluated its SWMP and monitoring plan, and is proposing several modifications to comply with these new permit requirements. The public is encouraged to learn more about Eugene's NPDES permit and . to provide comments. Directions for obtainillg additional information and providing comments are provided in this fact sheet.. GET MORE INFORMATION ABOUT EUGENE1S STORMWATER PERMIT /PROG RAM · General and specific information about Eugene's NPDES permit and the Ciry's stormwater program are available ort the internet at www.eugene-o.t.gov (dick on thelinkto"Sronnwater NPDES Permit") . · For specific information about Eugene's NPDES permit, call Therese Walch, Water Resources Manager, at 541-682-8647. · For general information about Eugene's$tormwater program, call Kathy Eva, Srormwater Information Specialist, at 541-682-2739. 1 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; TIMELlNE March 2004 '- AHgust 30 2()()5 Staff reviews requirements in new permit, ImalyZe5 txisting SWMF ilnd Mrmitoring FIlm, eva/uales potential changes, and prepares draft materials for public review. October 10 7he Eugme City Council t(.1illlJo!da work session on the new NPDES permit. . March 2. 2004 . DEQ issues fiVe-year NPDES permit to the , City of Eugme September 19- October 15 Public comment is gathered tm tbe proposed ilrqft chtinges to tbe CityofEugene's St0l7f1Water Managtment Plan and BMPs. October 15- November 30 . Staff will evalUttte aond respond to public comments, "pne the drtift SWMP itlId pre-pare a second-;'Year report to DEQ December J, 2005 Eugene submits its second-year report to the DEQ Beyond December 1, 2005 The City wit! continue t(; -refine its S'WMP, implement BMFs, and initiateadapfive management strategies to reduu the discharge of pollutants to the maJ<:imu/11 extent practicable. SUMMARY OF EUGENE'S STORMWATER BEST MANAGEMENT PRACTICES Eugene's SWMP includes 23 best management practices (BMPs) designed to reduce the discharge of stormwater pollutants to the maximum extent practicable. Each. . BMP is given a code (for example, Al) for tracking and reporting purposes; the coding is based 9n the City work section with Ie-ad responsibility; as follows: . . o. ~ Administration Division of t>ublic Works B ::::Building Division of Planning and Development E :::: Engineering Division of Public Works M :::: Maintenance Division of Public Works P '" Parks and Open Space Division of Public Works W :::: Wasr.ewater Division of Public Works TIle 23 BMPs faU into six general Categories, listed below. For each category; the general purpose of that category is provided, followed by a brief description of each BMP within that <.'ategory. Detailed information on each BMP can be found on the on the internet at www.eugene-or.gov (dick on the link to ~Stormwater 1>...lpDES Permit") .- OBLIC EDUCATION The purpose of public education BMPs is to inform the public, the. commerciaUindustrial sector, and in-house personnel about tbe sources and causes of stormwater pollution, its effect on the local receiving. waters, and to encourage active involvement (e.g. behavioral changes, volunteerism, etc.) in the effort to reduce pollution. . Al - Best Management Practices for Business Al- Stonnwater Education PI - Ed:ucational Volunteer Activities And Natural Resources Protection WASTE MANAGEMENT The purpose of the waste management BMPs is to educate the public, regulate waste management services, and to ensure proper facilities are availahle in order to minimize the potential of negative stormwater impacts from . solid waste collection, improper . disposal of toxic materials, and illegal dumping of garbage and debris. Bl - Household Hazardous Waste Program B2 - Solid "\X'aste Management OPERATIONS AND MAINTENANCE The purpose of operations and maintenance BMPs is to maintain the publicly managed stormwater system (e.g. pipes, culverts, open waterways, water quality facilities), balancing flood control, drainage services, water quality, and natural resource protection needs, and to adaptively manage for continuous improvement of current operations and maintenan<...'e practices. Operations and maintenance BMPs ate also focused on planning and performing other City services, such as . landscape maintenance or road repair projects for example, in a mannenhat minimizes the potential for stormwate.r pollution from these activities. 3 M4 ~ Prevent Leaks and Spills from Municip'al Vehicles and Equipmem M5 - Public Stormwater System Cleaning Programs M6 - Street Sweeping Program M8 - Winter Road Sanding and De- Icing Program P2 - Revise Comprehensive O&M Plans P3 -: Tree Planting Programs P4 - Vegetation Management Program INDUSTRIAL CoNTROLS The purpose of the industrial control BMP is to provide oversight of storm water discharges from industrial facilities, induding screening. inspections, technical assistance; and response to spills at permitted facilities. W2 - Industrial Stormwater Management Program IwCIT DISCHARGES CoNTROlS The purpose of illicit discharge BMPs is to became aware of, investigate, detect, mitigate, and enforce the elimination of illicit (nonstormwater) discharges and illegal. dumping to the stormwater system. M1 - Enforcement for Improper Discharges M2 - Environmental Spill Response Team M3- Litter and Illegal Dumping Programs M7 - Systematic Field Investigation for Improper Discharges P.t.ANNmG) CAPITAL IMPROVEMENTS, & DATA MANAGEMENT The purpose of planning, <:apical improvements, and ... data management is to develop ind implement Comprehensive sto.i:mwater basin plans, evaluate potential sources of); ..... .... specific pollutants.,.;... .,....... and related BMPs .:.~~r.. &'*---." to address them, evaluate the impact of city activities on water quality, maintain up to dat~ data on the stormwater system, and coordinate system information between departments and agencies for multiple applications. El - Develop Comprehensive Basin Plans E3 - Storm System Mapping and Data Management . !i~;I::!}::i . ~.. S<..ty M~IwJo~ oM SX""'""Y _1.fl'l1 . WI - Assessment of the Impact of City Activities on Water Quality W3 - Bacteria Pilot Study'" CoNSTRUCi10N SITE MANAGE:.. HAl' . & DESIGN STANDARDS FOR NEw DEVELOPMENT The purpose of the construction site management and design standards for new development BMPs is to ensure that appropriate control measures are considered, implemented, and maintained during and after the planning, design .and construction phases for new public and private development ;lnd significant redevelopment projects. ~$ E2 - Erosion Prevention <t:.~~ and Construction Site Management Program E4 - Water Quality Drainage . and Design Standards for New Development '* New EMP proposed for 2005 SWivfP . and the protection of storiilwaret-rdated. . drains or othet facilities used iop)llect and .. wastehid aUocation for a specific pollutant, natural resources. conveystOrmwolter. typically expressed as parts pet volume, 4