HomeMy WebLinkAboutReso 2017-158RESOLUTION NO. 2017-158
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
CHULA VISTA AUTHORIZING THE CITY MANAGER OR
HIS DESIGNEE TO NOTIFY THE SAN DIEGO REGIONAL
WATER QUALITY CONTROL BOARD OF THE TRACK
SELECTED (TRACK 2) TO COMPLY WITH TRASH
AMENDMENT INVESTIGATIVE ORDER NO. R9-2017-0077
WHEREAS, on June 2, 2017, the San Diego Regional Water Quality Control Board
(RWQCB) issued Investigative Order (IO) No. R9-2017-0077, directing the Owners and
Operators of Phase I Municipal Separate Storm Sewer Systems (MS4 permittee) Draining the
j Watersheds within the San Diego Region to Submit Reports Pertaining to the Control of Trash
in Discharges from Phase I MS4s to Ocean Waters, Inland Surface Waters, Enclosed Bays, and
Estuaries in the San Diego Region; and
WHEREAS, order No. R9-2017-0077 requires MS4 permittees to submit written notice
indicating whether Track 1 or Track 2 control measures will be used to comply with the trash
discharge prohibition by September 05, 2017; and
WHEREAS, jurisdictional maps and implementation plans associated with either Track 1
or Track 2 control measures must be submitted to the RWQCB by December 03, 2018; and
WHEREAS, the City of Chula Vista (City), as well as the other 20 Copermittees must
decide between two compliance paths (Track 1 or Track 2) and implement `'full capture" of trash
in Priority Land Use Areas by 2028; and
WHEREAS, Priority Land Use areas (commercial, industrial, high density residential,
public transportation, and "mixed urban') are deemed to have elevated trash generation rates.
The City has identified approximately 1,800 storm drain inlets subject to this Order within
Priority Land Use Areas (Attachment 1); and
WHEREAS, Track 1 requires the installation and maintenance of certified structural
devices, see Attachment 2, ("full capture systems") on all storm drains that capture runoff from
Priority Land Use Areas; and
WHEREAS, compliance with Track I requirements is achieved when the City has
demonstrated annually the installation, operation, and maintenance of full capture systems and
provides mapped location and drainage area served by full capture systems; and
WHEREAS, Track 2 requires a combination of certified structural devices where feasible
and programmatic controls (e.g. catch basin cleaning, street sweeping, trash receptacle programs)
to capture all trash generated from Priority Land Use areas ("full capture equivalence"); and
Resolution No. 2017-158
Page No. 2
WHEREAS, compliance with Track 2 requirements is achieved when the City has,
"developed and implemented a set of monitoring objectives that demonstrate mandated
performance results, effectiveness of the selected combination of treatment and institutional
controls, and compliance with full capture system equivalency"; and
WHEREAS, in preparation for the expected Trash Order, on August 02, 2016, by
Resolution No. 2016-156, City Council approved a contract with D -Max Engineering, Inc. (D -
Max) to prepare Trash Amendments Baseline Assessment Report ("Baseline Report"); and
WHEREAS, D -Max completed a preliminary evaluation of different compliance
scenarios considering data from Public Works, Engineering, Geographic Information Systems,
and Economic Development Departments, and submitted a final Baseline Report dated June 19,
2017 (Attachment 3); and
WHEREAS, a 20 -year planning horizon was considered by D -Max, along with six
scenarios from Track 1 and Track 2. Overall, Track 1 scenarios had higher total costs than Track
2 scenarios; and
WHEREAS, the distribution of costs also differs between tracks, with a much larger
proportion of costs required to cover monitoring, reporting, and program management under
Track 2; and
WHEREAS, the RWQCB has indicated that it will be acceptable for a city to initially
select a Track 2 approach and then later switch to a Track 1 approach. This strategy might be
desirable if, for example, after implementing the first few years of a Track 2 program, the City
finds that its nonstructural BMP efforts turn out to be less effective or more costly than
anticipated; and
WHEREAS, the Trash Order requires the City to notify the RWQCB of the selected
compliance track by no later than September 5, 2017, and submit implementation maps, time
schedules, and (if applicable) compliance plans by December 3, 2018; and
WHEREAS, based upon an analysis of the two tracks, staff is recommending that the
RWQCB be notified that the City is selecting the Track 2 approach to comply with the Trash
Amendment Investigative Order (IO) No. R9-2017-0077; and
WHEREAS, the Director of Development Services has reviewed the proposed project for
compliance with the California Environmental Quality Act (CEQA) and has determined that the
project qualifies for a Categorical Exemption pursuant to State CEQA Guidelines Section 15301
Class 1 (Existing Facilities) and/or Section 15303 Class 3 (New Construction or Conversion of
Small Structures). Thus; no further environmental review is required.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Chula
Vista, that it authorizes the City Manager or his designee to notify the San Diego Regional Water
Quality Control Board of the Track Selected (Track 2) to comply with the Trash Amendment
Investigative Order No. R9-2017-0077.
Resolution No. 2017-158
Page No. 3
Presented by
Approved as to form by
V
William S. Valle len R. Googins
Director of Engineering & Capital Projects CNV Attorn
PASSED, APPROVED, and ADOPTED by the City Council of the City of Chula Vista,
California, this 15th day of August 2017 by the following vote:
AYES: Councilmembers: Aguilar, Diaz, McCann; and Salas
NAYS: Councilmembers: None
ABSENT: Councilmembers: Padilla
ATTEST:
Kerry igelo , MMC, Acting City Clerk
STATE OF CALIFORNIA
COUNTY OF SAN DIEGO
CITY OF CHULA VISTA
I, Kerry K. Bigelow, Acting City Clerk of Chula Vista, California, do hereby certify that the
foregoing Resolution No. 2017-158 was duly passed, approved, and adopted by the City Council
at a regular meeting of the Chula Vista City Council held on the 15th day of ?august 2017.
Executed this 15th day of August 2017.
Kerry K igelow, /MC, Actino City Clerk
Resolution No. 2017-158
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Attachment 1
City of Chula Vista Priority Land Use Areas
Resolution No. 2017-158
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Attachment 2
Full Capture Devices
0
. . . . . . . . . . .
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City of Chula Vista
Compliance Track Evaluation for the Statewide Trash Amendments
Table of Contents
1.. Background........................................................................................................................
4
2. Purpose..............................................................................................................................
4
3. Identification of Priority Land Use Areas and Affected Inlets
............................................... 5
3.1 Priority Land Use Identification....................................................................................
5
3.1.1 Identification of Affected Inlets..............................................................................
6
3.2 Pilot Investigation of Alternative Priority Land Use Area
............................................... 6
4. Full Capture System Equivalency Options..........................................................................
6
4.1 General Approach........................................................................................................
7
4.2 Full Capture System Equivalency................................................................................
7
5. Track 1 Assessment........................................................._.................................................10
5.1 Structural BMP Types ..................................................................................................
10
5.2 Scenarios 1 A through 1 C............................................................................................11
5.3 Scenario 1D................................................................................................................12
5.4 Track 1 Implementation Schedule...............................................................................13
5.5 Track 1 Implementation, Monitoring, and Reporting....................................................14
5.6 Track 1 Costs..............................................................................................................14
6. Track 2 Assessment..........................................................................................................16
6.1 Track 2 Approach.......................................................................................................16
6.2 Track 2 Scenarios...........................:...........................................................................16
6.3 Existing Activities and Enhanced Efforts.....................................................................17
6.4 Track 2 Implementation Schedule...............................................................................21
6.5 Track 2 Implementation, Monitoring, and Reporting....................................................21
6.6 Track 2 Costs..............................................................................................................21
7. Track -Switching Assessment.............................................................................................23
7.1 Scenario Assessed.....................................................................................................23
7.2 Costs for Track -Switching Approach...........................................................................23
8. Discussion.........................................................................................................................24
8.1 Track Cost Comparison..............................................................................................24
8.2 Track -Switching Costs................................................................................................26
8.3 Other Risk Factors......................................................................................................26
8.3.1 Compliance Confidence.......................................................................................26
8.3.2 Flooding and Infrastructure Damage....................................................................27
8.4 Impact on WQIP Goals...............................................................................................27
9. Conclusions.......................................................................................................................29
10. References.....................................................................................................................31
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City of Chula Vista
Trash Amendments Baseline Assessment
List of Appendices and Attachments
Appendix A — Identifying and Classifying Priority Land Uses
Appendix B — Visual Trash Assessment for Alternate Land Uses
Appendix C — Large BMP Analysis
Appendix D — Cost Calculations
List of Tables
Table 1. Key Dates for Trash Amendment Adoption and Compliance ........................................
4
Table 2. Priority Land Use Breakdown for the City of Chula Vista ..............................................
6
Table 3. FCSE Calculation from PLU areas in tons per year ......................................................
8
Table 4. BMP types used in primary Track 1 assessment.........................................................10
Table 5. 20 -Year Costs for Track 1 Scenarios...........................................................................15
Table 6. Existing Trash Removal Efforts....................................................................................18
Table 7. Enhanced -Trash Removal Efforts................................................................................'19
Table 8. 20 -Year Costs for Track 2 Scenarios...........................................................................22
Table 9. 20 -Year Costs If Switching From Track 2 to Track 1 after 5 Years..............................23
Table 10. 20 -Year Costs for All Scenarios................................................................................25
List of Figures
Figure 1. Modeled Trash Generation Rates for Priority Land Use parcels in the City of Chula
Vista........................................................................................................................................... 9
Figure 2. Example Strategic Location for CPS Installation........................................................13
Figure 3. Cost Comparison for Track 1 Scenarios....................................................................15
Figure 4. Cost Comparison for Track 2 Scenarios....................................................................22
Figure 5. Costs Breakdown if Switching from Track 2 to Track 1 ..............................................24
Figure 6. 20 -year Costs for All Scenarios.................................................................................25
Figure 7. Comparison of Annual Costs for Track -Switching vs. Standard Scenarios ................26
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City of Chula Vista
Trash Amendments Baseline Assessment
1. Background
In April 2015, the State Water Resources Control Board (SWRCB) adopted Amendments to the
Water Quality Control Plan for Ocean Waters of California (Ocean Plan) as well as the Water
Quality Control Plan for Inland Surface Waters, Enclosed Bays, and Estuaries (ISWEBE Plan) —
collectively referred to as the "Trash Amendments."
The Trash Amendments provide two "tracks" that the City of Chula Vista (City) may select from
to pursue compliance:
• Track 1: The City must install and maintain "full capture devices" in its MS4 to capture
trash in runoff from all "priority land uses" in the City's jurisdiction.
• Track 2: The City must use a combination of full capture devices and other structural
and non-structural BMPs to achieve an overall trash load reduction equivalent to what
would be achieved in the Track 1 approach.
The Trash Amendments are statewide regulations, but the actual mandate to comply with the
Trash. Amendments was a 13383 Order (No. R9-2017-0077) issued by the San Diego Regional
Water Quality Control Board (Regional Board). This order dictates the timeline for the City to
make its decision between Track 1 and Track 2 and to submit initial trash program
documentation to the Regional Board. The compliance timeline is shown in Table 1.
2. Purpose
The purpose of this baseline assessment is to provide the City with information to make an
informed decision between a Track 1 and a Track- 2 approach. The largest component of this
effort involves identifying the BMPs; both structural and non-structural; needed to achieve
compliance under each Track and then developing planning -level estimates of the quantities
and associated costs. Additionally; this assessment includes information on differences in the
anticipated compliance confidence associated with each Track. Furthermore, the City is also
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City of Chula Vista
Trash Amendments Baseline Assessment
obligated to meet trash -related goals set forth in the San Diego Bay Watershed Management
Area Water Quality Improvement Plan (WQIP). Since there may be significant programmatic
overlap in achieving compliance with both the Trash Amendments and the WQIP, this report
also provides an assessment of how each Track option will affect the City's compliance with
trash -related WQIP goals.
3. Identification of Priority Land Use Areas and Affected Inlets
3.1 Priority Land Use Identification
The Statewide Trash Amendments require the City to address trash in Priority Land Use (PLU)
areas or equivalent alternative land use areas via full capture devices (Track 1) or to implement
BMPs throughout the City to address the amount of trash equivalent to the amount generated in
PLU areas (Track 2). As such, the first step for assessing compliance options is to determine
the extent of the PLUS within the City's jurisdiction. PLU areas include:
• High-density residential (>10 dwelling units per acre),
• Industrial,
• Commercial,
• Mixed urban (combination of high-density residential, industrial, and commercial), and
• Public transportation stations.
A land use analysis was performed using the most recent land use GIS data provided by the
City. The 391 discrete land use categories present within boundaries of the City were compared
to the definitions of the five PLUs designated in the Trash Amendments to determine which land
uses and parcels fall within the PLU definitions. The analysis resulted in the designation of 261
of the land uses within the dataset as PLUs under the Trash Amendments. The City land use
categories do not match up exactly with the definition of high-density residential land use in the
Trash Amendments (i.e. >_10 dwelling units per acre). Therefore, for several of the residential
land use categories, a GIS analysis was performed to calculate the number of dwelling units per
acre. An updated summary of the PLUs within the City's jurisdiction is provided in Table 2 and
the final estimated PLU areas within the City are illustrated in Figure A-1 of Appendix A. Note
that while the portion of the City that lies east of 1-805 contributes a larger amount of total PLU
area, that side of the City is significantly larger overall and the ratio of PLU to non-PLU areas is
actually higher on the west side of 1-805.
The City conducted a thorough review of the identified PLUs and the assumptions used during
the identification process. Detailed information about the PLUs and the assumptions utilized in
developing the City's PLUs is provided in Appendix A.
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Trash Amendments Baseline Assessment
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3.1.1 Identification of Affected Inlets
Under a Track 1 compliance approach, full capture trash control devices are required to be
installed at storm drain structures that receive runoff from PLUs. GIS analysis was used to
identify storm drain structures that receive runoff from PLUs. A total of 2,662 such inlet
structures, herein referred to as "PLU inlets," were identified. These locations are mapped in
Figure A-1 of Appendix A.
3.2 Pilot Investigation of Alternative Priority Land Use Area
The Trash Amendments also allow a municipality to select alternative land use areas that differ
from the specified PLU categories. Exact areas for potential alternative PLUs were not
identified during discussions with the City, so no alternative PLU areas were incorporated into
this baseline study. However, the City expressed interest in exploring this option further.
Therefore, a pilot -level investigation was conducted to. visually assess the amounts of trash
found in specific PLU and non-PLU areas of the City and assesses the feasibility of utilizing
alternative PLU areas in the future. The investigation is discussed in Appendix B.
4. Pull Capture System Equivalency Options
In order to develop a compliance approach estimate for the funding needed under a Track 2
approach, an estimate of a full capture system equivalency (FCSE) value is needed. FCSE is a
trash load reduction target the City would need to meet through implementation of a
combination of programmatic, operational, and structural controls. Achievement of the FCSE
target demonstrates compliance with the Trash Amendments.
The Trash Amendments provide two examples of approaches to determine FCSE: (1) a trash
capture rate approach and (2) a reference approach. Both methods rely on measuring or
otherwise quantifying the arnount of trash captured by full capture devices to establish a
baseline value.
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4.1 General Approach
The method used to quantify trash generation was based on a literature review but it also allows
for future refinement based on results from pilot studies, such as the efforts currently underway
by the County of San Diego to monitor area -specific trash generation.
A literature review was conducted, which focused on four trash generation studies completed
within the United States: two in California' land two in Maryland 3. The studies were compared
and analyzed for relevance to the City. A comparison of the studies is presented in Table A-4 of
Appendix A.
These studies were used to determine the trash generation rates (TGRs) associated with PLU
classifications as defined by the Trash Amendments. The literature review was used to
determine a series of metrics correlated with TGRs. A geospatial analysis using median
household income and population density data from the 2010 Census was conducted to
evaluate and characterizethese metrics for each of the four study cities. Then, regression was
used to determine the best fit model between the derived metrics and the literature TGRs to
.isolate. the best -predictor of TGRs for each category of PLU.
The TGRs obtained as described above were based on the best available trash generation data
from the literature. However, since none of the available studies characterized trash generation
rates within the San Diego region, the County of San Diego's Regional Trash Generation Rate
Study will provide valuable region -specific data upon its completion, which is scheduled for fall
2017. If this study finds that trash generation rates in San Diego County are significantly
different than in the areas from the literature study, this region -specific trash generation data
could be incorporated into the model in the future.
4.2 Full Capture System Equivalency
After the literature review and model development, it was determined that the metric that
provided the best fit for the published TGRs for commercial and industrial land uses was the
ratio of Median Household Income (MHI) to Population Density. For high density residential
PLUs, the best fit model was.obtained using the MHI and population density from census blocks
with greater than or equal to 10 households, as High Density Residential is defined by the Trash
Amendments. TGRs for mixed urban and public transportation station PLUs were not
represented in the available literature, and thus, were derived from the average of the
Commercial, Industrial, and High Density Residential Trash Generation Rates. In order to
calculate the FCSE for the City at this stage, the TGR model was applied to the census metrics
associated with each individual PLU parcel, generating a range of TGRs throughout the City,
see Figure 1. Following the literature, TGRs are expressed in units of gallons per acre per year.
The TGRs were multiplied by the acreage for each parcel and PLU combination. The trash
generated per year in gallons was converted into tons per year, and then the weight of trash in
tons generated per parcel was summed for each category of PLU (Table 3).
'County of Los Angeles Department of Public Works Watershed Management Division. 2004. Trash Baseline
Monitoring Results, Los Angeles River and Ballona Creek Watersheds.
2 Bay Area Stormwater Management Agencies Association (BASMAA). 2014. San Francisco Bay Area Stormwater
Trash Generation Rates. Final Technical Reoo t.
s ..
Maryland Depan tm=m of the environment. 2014. Total Maximum Daily Loads of Trash and Debris for the Middle
Branch and Northwest Branch Po lions of the Patapsco River hriesohaline Tidal Chesapeake Bay Segment. Baltimore
City and County. Maryland.
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City of Chula Vista
Trash Amendments Baseline Assessment
Table 3. FCSE Calculation from PLU areas in tons
Industrial {
26.34
{ 7.17
19.17
Commercial:;. 59,45_
29 80 ....
Mixed Use j
1.72
0.17
1.55
Public Trarisporiation Sfations ._
3 7.1 , .,_ 0;68
Total
151.53
{ 80.53 {
70.99
The total literature -based FCSE value for the City of Chula Vista is 151.53 tons, or 36,294
gallons per year of trash, based on a wet weight conversion.
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City of Chula Vista
Trash Amendments Baseline Assessment
S. Track 1 Assessment
5.1 Structural BMP Types
Under a Track 1 approach, the City would be required to install full capture devices in storm
drain structures conveying runoff from all the PLU areas in its jurisdiction. Based on full capture
devices commonly implemented in other regions of the state, the BMPs in the table below were
selected:
Table 4. BMP types used in primary Track 1 assessment
Curb inlet style drainage insert Can capture trash entering
The Round Curb Inlet through a curb inlet. Basket
Basket (R-GISB) can be positioned below
manufactured by Bio Clean manhole opening for ease of
was used in cost maintenance.
calculations.
Page 10
Installed at curb inlets.
ARS is not a full capture'
Automatic Retractable Screen
device. However, when used
in conjunction with a CPS, the
-°
�-'
(ARS)ARS
ARS keeps debris the
manufactured by
out of
United Stormwater was
drain and allows it to be
used in cost calculations
picked up by street sweeping,
thus reducing the required
maintenance frequency for
CPS.
fi
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City of Chula Vista
Trash Amendments Baseline Assessment
Other larger BMPs such as Bio Clean Nutrient Separating Baffle Boxes and Contech CDS units,
are also considered full capture devices when sized properly. While having higher capital costs
than the smaller BMPs in the table above, they can have lower long term maintenance costs
since a single large unit can be installed in place of several smaller individual -drain BMPs, thus
reducing the number of BMPs requiring maintenance. It is often assumed that the savings in
annual maintenance costs will result in these larger BMPs being more cost effective in the long
term. However, in site -speck analyses performed by the consultant team in other
municipalities, this assumption was not supported. Site specific investigations demonstrated
that 1) the high installation costs of the large BMPs combined with 2) limitations on the number
of smaller upstream BMPs that could be replaced by each large unit, resulted in higher total 20 -
year costs for the large BMPs. Additional detail on these findings is provided in Appendix C.
Based on the findings regarding large BMP costs, this baseline assessment did not include a
city-wide assessment of a Track 1 scenario . using these large BMPs. However, full
assessments of four different Track 1 scenarios using smaller individual -drain BMPs were
performed:
• Scenario 1A: CPS with ARS. In this scenario, full capture devices will be installed at
all public PLU inlets and at locations in public storm drains downstream of all private
PLU inlets. These inlets will be equipped with CPS in most instances and with grate
inlet style drainage inserts (GISB) in the small number of inlets where CPS cannot be
used. ARS will also be installed at all public curb inlets with a CPS.
• Scenario• 1B: CPS without ARS. This scenario is identical to the CPS with ARS
Scenario except that no ARS units will be used.
• Scenario 1C: Curb Inlet Baskets. In this scenario, curb inlet baskets (R-GISB) rather
than CPS will be installed at public PLU curb inlets. No ARS will be used. Cost
calculations were based on the assumption that all inlets projected as having a CPS with
ARS in Scenario 1A would instead have a curb inlet basket with no ARS in Scenario 1C.
CPS will still be used for locations downstream of private PLU inlets, and CPS or GISB
will still be used for a small number of public inlets where curb inlet baskets cannot be
used.
• Scenario 1D: Downstream Locations. This scenario is based on the assumption that
the City would be able to identify key storm drain junction locations where a single CPS
could be used to collect trash from multiple upstream public PLU inlets. This scenario
requires fewer total BMPs, but it is assumed more frequent maintenance will be required
due to the increased average drainage area of each BMP. ARS will be installed at all
public PLU curb inlets in this scenario.
5.2 Scenarios lA through 1C
In Scenarios 1A, 1B, and 1C, one full capture device is installed in each public PLU inlet. The
type of device depends on the scenario and on the type of inlet structure, as indicated in the
attributes of the SW Junction GIS layer provided by the City. For example, some drainage
structures can accommodate either a CPS or curb inlet basket, so they would have a CPS
installed in Scenarios 1A and 1B and a curb inlet basket in Scenario 1C. Conversely, a small,
square grated inlet can only accommodate a GISB, so it would have that BMP in all three
scenarios.
Approximately half of the identified PLU inlets are privately owned, but the City does not have
legal authority to require private property owners to install BMPs in these drains. Therefore; full
capture devices would be installed in public storm drain structures downstream of these private
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PLU inlets. Since site specific feasibility analyses would be required to determine the exact
locations where these devices could be installed, for the purposes of this baseline study, a GIS
analysis was performed to determine an estimate of the number of full capture devices that
would be needed to intercept flows from all private. PLU inlets. This was done by identifying all
the locations where a privately owned storm drain pipe within a PLU connected directly to a
downstream publicly owned junction, plus all locations where a private PLU inlet connected
directly to a downstream publicly owned pipe. This resulted in an estimate of 365 full capture
devices that would be needed to intercept flows from 1195 private PLU inlets. It was also
assumed that these 365 full capture devices would all be CPS since runoff would likely be
conveyed to the public structure via a pipe, making it infeasible to use GISB and curb inlet
baskets to capture trash. Since these CPS would tend to receive flows from multiple upstream
inlets, a higher required maintenance frequency was assumed for these CPS compared to CPS
receiving runoff from a single public inlet.
5.3 Scenario 1D
This scenario assumes that key locations can be identified such that a single CPS can be
installed in a structure that receives, runoff from multiple public PLU inlets. The total number of
full capture devices used to treat public inlets was thus reduced to 60% of the number in the
Scenarios 1A through 1C. An example of a strategic location is provided in Figure 2 below.
However, it should be noted that all of the public inlets that would have an ARS installed in
Scenario 1A will still have an ARS installed in the this scenario, even if that drain will no longer
have a CPS installed. The assumption is that having ARS installed upstream of the structures
with CPS will still be beneficial for minimizing the required maintenance frequency. Despite
retaining the same number of ARS as Scenario 1A, this scenario still results in an increased
average drainage area per BMP, so CPS in public inlets are assumed to have a higher required
maintenance frequency.
Note that the reduction in number of CPS installed in this scenario applies to locations treating
flows entering public PLU inlets. For private PLU inlets, the BMP implementation would be
identical to the Scenarios 1A through 1C (i.e. an estimated 365 CPS installed to handle 1,195
private inlets).
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Figure 2. Example Strategic Location for CPS Installation.
In this example, one CPS would be installed at the downstream junction (green)
rather than installing three CPS in the upstream drains (blue).
S.-? T-ra_K _ Lmr1 em en -a di on -QcheUule
The Trash Amendments require full compliance within ten years, with permittees required to
demonstrate achievement of interim milestones. For Track 1 the anticipated requirement is
installation of approximately 10 percent of the total full capture devices each year. Therefore, in
the Track 1 scenarios the installation schedule of all BMPs has been distributed evenly over the
first 10 years of the program.
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5.5 Track 1 Implementation, Monitoring, and Reporting
Unlike a Track 2 approach, a Track 1 approach does not require the City to prepare an
"Implementation Plan" in which it outlines its entire trash control program and submits it to the
Regional Board for approval. However, significant staff time will still be needed to plan the
program prior to actual implementation. Cost estimates for Track 1 scenarios include a one-
time cost for program planning plus additional annual costs to cover program management.
According to the Trash Amendments, a Track 1 approach requires annual reporting but does
not require a monitoring program. Annual reporting will primarily entail reporting on progress
toward installation of all full capture devices and on annual maintenance activities. Therefore, a
significant proportion of the reporting program will be'the ongoing collection and management of
this BMP data. Additionally, collecting data on BMP installation will be completed in year 10, so
reporting costs are reduced in years 11 through 20.
It should be noted that the 13383 Order issued by the Regional Board indicates that there will
be "monitoring and reporting" requirements for both Track 1 and Track 2. However, Regional
Board staff added a footnote to the Order indicating that these monitoring and reporting
requirements will be based on the corresponding section of the Trash Amendments that
indicates monitoring is only required for Track 2. While the 13383 Order still leaves the door
open for the Regional Board to issue stricter monitoring requirements, based on previous
feedback from the Regional Board staff and on the addition of the previously mentioned footnote
to the 13383 Order, it is understood that the intention is to require a true monitoring program
(e.g. performing field assessments at outfalls and water bodies) only for Track 2. Therefore, no
separate costs were included for a monitoring program in the Track 1 scenarios.
5.6 Track 1 Costs
Although full compliance is to be achieved over a ten year period, annual costs were calculated
for a twenty year period. This was done to better reflect the impact of the long term program
costs that the City will continue to incur even after all of the full capture devices have been
purchased. Table 5 and Figure 3 below summarize both the total number of full capture devices
installed and the twenty-year total costs for all four Track 1 Scenarios. To reflect the relative
impact of different program components, costs have been broken down into the following
categories:
• Structural BMP Capital Costs: This covers the purchase and installation of all
structural trash control BMPs. It also includes an estimated cost to cover the staff time
.needed to coordinate with vendors to acquire the BMPs.
• BMP Maintenance: This covers regular inspection and maintenance of structural trash
control BMPs by City staff. Maintenance rates were based on data provided by City staff.
Based on conversations with Los Angeles County, the maintenance frequency used for
an inlet with a CPS and ARS was three cleanings plus one additional inspection per year.
For situations where a CPS will be used downstream of multiple PLU inlets, the number
of cleanings per year was increased to seven to cover monthly cleanings during the
rainy season.
• Repair and Replacement: This includes costs to cover repairs when installed BMPs
become damaged as well as costs to cover full replacement when BMPs are damaged
beyond repair.
Data Collection, Reporting, and Management: This covers the annual data collection
and reporting activities discussed in the previous section; as well as initial program
planning costs and an annual cost to cover ongoing management of the program.
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City of Chula Vista
Trash Amendments Baseline Assessment
• Contingency: A 15% contingency was included to account for unforeseen increases in
BMP capital costs or in City labor costs.
Table 5. 20 -Year Costs for Track 1 Scenarios
Figure 3. Cost Comparison for Track 1 Scenarios
A more detailed breakdown of the calculations used to estimate costs for both Track 1 and
Track 2 is provided in Appendix D. Information in this appendix includes:
BMP capital costs
Maintenance rates
BMP repair and replacement estimates
Crosswalk between storm drain junction type and BMP type
• Year -by -year cost breakdowns
Page 15
_rift
Scenarios
n
Me
- On- ; :
- 0 f
.. . ,,.- --
#� Fdll Capture Devices Installed _� 1.796-- ,. -. • 1 796 j., 1 Z96 ,., _ _ 1_,223
# of ARS Installed I
.,•
1,226
0 I
0 I
-
1,226
Costs-
`
Structural BMP Capital Costs
$5,009,904 I
$3,144,790 I
$3,684,230 I
$4,007,914
BMP;Mamten- ance 3
X9;018 273 $10292,218 ; _12829U69
i_
$9:694 174.0
Repair& Replacement
$1,361,644 I
$892,439
$2,135,237 I
$1,068,871
Data Collection, Reporting, 8 j
$1 110 000 $1 110 000 ; -
$1 190000
$1 110 000
Management
ea
13 Structural BMP Capital Costs
Contingency (15%)
$2,474,973
$2,315,917
-$2,963,780 I
$2,382,144
TotaCost
$18,974;294 j
$17,75,364
03°1
, _1863,1l
Figure 3. Cost Comparison for Track 1 Scenarios
A more detailed breakdown of the calculations used to estimate costs for both Track 1 and
Track 2 is provided in Appendix D. Information in this appendix includes:
BMP capital costs
Maintenance rates
BMP repair and replacement estimates
Crosswalk between storm drain junction type and BMP type
• Year -by -year cost breakdowns
Page 15
20 -Year Costs for Track 1
Scenarios
$25
$20
N
t
_
® Contingency
S
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= -
® Monitoring, Reporting, & Mgmt.
v,
is Repair & Replacement
U
$10
a BMP Maintenance
ea
13 Structural BMP Capital Costs
o
$5
N
$0
Scenario 1 A Scenario 1 B Scenario 1 C Scenario 1 D
Figure 3. Cost Comparison for Track 1 Scenarios
A more detailed breakdown of the calculations used to estimate costs for both Track 1 and
Track 2 is provided in Appendix D. Information in this appendix includes:
BMP capital costs
Maintenance rates
BMP repair and replacement estimates
Crosswalk between storm drain junction type and BMP type
• Year -by -year cost breakdowns
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City of Chula Vista
Trash Amendments Baseline Assessment
6. Track 2 Assessment
6.1 Track 2 Approach
As described in Section 3, development of a Track 2 approach is centered on the FCSE value,
which is the estimated amount of trash per year generated from all the City's PLUs. Under
Track 2, the City must achieve an annual trash load reduction equal to the FCSE. This trash
load reduction can be achieved through a combination of the following:
• Installation of full capture devices
• Existing trash removal activities
• New or enhanced trash removal programs
First, data was collected on the City's existing programs that provide trash removal. For each
existing activity, a trash load reduction value (in gallons of trash removed per year) was then
calculated.. Next, :a --suite of potentialenhanced trash removal activities were identified. Based
on a combination of data provided by the City and from the literature, calculations were
performed to determine an estimated cost and -trash load reduction for each enhanced activity.°
The combined trash load reduction from existing activities and enhanced efforts was then
subtracted from the FCSE to determine the quantity of trash that would need to be removed by
full capture devices. A calculation was then performed to convert this trash load reduction value
into an estimate of the total number of structural BMPs that would need to be installed.
Additional information on these calculations is provided in Appendix D.
6.2 Track 2 Scenarios
Based on discussions with City staff, Track 2 costs were estimated for scenarios using the same
BMP types as Track 1 Scenarios 1 B (CPS without ARS) and 1 C (curb inlet baskets). To show
the similarity to Track 1 Scenarios that use the same full capture devices, for Track 2, these
have been labeled Scenarios 2B and 2C, respectively. Since the calculation used to estimate
the number of full capture devices required was based on a per -inlet trash removal rate, a Track
2 equivalent of the 1D "downstream locations" scenario was not included. Both Track 2
scenarios use the same existing and enhanced trash removal efforts and the same number of
full capture devices, but types of full capture devices used will be different, as described below:
• Scenario 2B: Drains will be equipped with CPS in most instances and with grate inlet
style drainage inserts (GISB) in the small number of inlets where CPS cannot be used.
ARS will not be used.
• Scenario 2C: Curb inlet baskets (R-GISB) will be installed instead of CPS wherever
possible, although CPS and GISB will still be needed for some drainage structures.
ARS will not be used.
A single cost value is reported for each of these two scenarios in Section 6.6. However,
technically, two cost calculations were performed for each scenario, and Section 6.6 reports
average values. A "conservative" and an "optimistic" version of each Track 2 scenario were
calculated. Both versions use all of the same existing trash removal activities and enhanced
efforts. The difference is in the estimated trash load reduction value assigned to each activity.
For each activity; two load reduction values were calculated: a low end value based on more
EOA, Inc. 2012. Trash Load Reduction Tracking Method: Assessing the Progress of the San Francisco Bay Area
MS4s Towards Stormwater Trash Load Reduction Goals. Technical Report (Version 1.0).
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Resolution No. 2017-158
Page No. 22
City of Chula Vista
Trash Amendments Baseline Assessment
conservative assumptions about the effectiveness of the strategy and a high end value based
on more optimistic assumptions. The conservative versions use all of the low end load
reduction values, and the optimistic versions use the high end values. Since the number of full
capture devices needed in a Track 2 approach goes down when other activities provide more
trash removal, the optimistic versions require significantly fewer full capture devices. For
simplicity, the body of this report focuses on the average of the conservative and optimistic
versions of each scenario, but full breakdowns of the optimistic and conservative version costs
are provided in Appendix D.
6.3 Existing Activities and Enhanced Efforts
Table 6 and Table 7 provide descriptions of all the existing activities and enhanced efforts,
respectively, that were incorporated into the Track 2 scenarios. A few additional enhanced
efforts were also quantified, but were not incorporated into the Track 2 scenarios. Additional
information on these can be found in Appendix D.
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Resolution No. 2017-158
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City of Chula Vista
Trash Amendments Baseline Assessment
6.4 Track 2 Implementation Schedule
Like Track 1, Track 2 also requires permittees to demonstrate achievement of interim
milestones on their way to full compliance within ten years. According to the Trash
Amendments, this entails demonstration of ten percent average trash load reductions each year.
In other words, the Track 2 program must provide trash load reductions of ten percent of the
FCSE in year one, twenty percent in year two, thirty percent in year three, etc. Since the City's
existing activities may provide over forty percent of the FCSE, implementation of new structural
and non-structural BMPs can be relatively limited in the early years of the program, resulting in
cost savings. However, completely deferring full capture device installation until later years
would potentially lead to scrutiny by the Regional Board or non-governmental organizations
(NGOs). Therefore, in the Track 2 scenarios, full capture devices are still installed during the
initial years of the program, but in slightly reduced numbers. This allows the City to monitor
installed BMPs on a small scale and apply lessons learned when ramping up installation over
the remaining years. Rollout of the new non-structural "enhanced activities" (Table 7) would be
spaced out across the first ten years, with more cost effective activities tending to be
implemented earlier.
6.5 Track 2 Implementation, Monitoring, and Reporting
Unlike Track 1, Track 2 requires the City to develop an implementation plan and submit it to the
Regional Board. In this implementation plan the City must define their FCSE, describe how
their program will achieve FCSE, and describe the monitoring program they will implement to
demonstrate attainment. It is expected that development of an implementation plan will be a
very involved process that will require meetings with the Regional Board staff to discuss
compliance metrics. In addition to a large upfront cost to cover the implementation plan, Track
2 is also anticipated to have higher annual program management costs since it has more
components to manage.
The other major programmatic requirement specific to Track 2 is the monitoring program. This
program will require the City to gather data annually from all of the program components and
quantify the data to demonstrate achievement of progress milestones. It is anticipated that the
monitoring program will also require field investigations, such as monitoring at MS4 outfalls or
performing visual trash assessments in PLU areas. Receiving water monitoring for trash may
also need to be added to the program in future years. .Details of the monitoring program will
need to be worked out with Regional Board staff as part of the process of developing the
implementation plan.
6.6 Track 2 Costs
Annual costs were calculated for a twenty-year period. Table 8 and Figure 4 below summarize
both the total number of full capture devices installed and the twenty-year total costs for the two
Track 2 scenarios. Costs were broken down into the same categories as those reported for
Track 1, with one additional category, "Non -Structural BMP Efforts.' Non-structural BMP efforts
refers to both the existing trash removal activities and the enhanced efforts. However, it is
assumed that the existing activities will not account for any additional costs, so only the
enhanced efforts contribute to the costs in this category. Note that a 20 percent contingency
was used for the Track 2 scenarios; as opposed to the 15 percent contingency used for Track 1.
This was to account for the higher degree of uncertainty associated with the non-structural BIAP
efforts included in Track 2.
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City of Chula Vista
Trash Amendments. Baseline Assessment
Table 8. 20 -Year Costs for Track 2 Scenarios
;rvative"
and "optimistic" assume relatively low and relatively high, respectively, levels of trash reduction from the same non-
structural BMP efforts.
Figure 4. Cost Comparison for Track 2 Scenarios
Error bars show the calculated total costs of the conservative and optimistic versions of each
scenario. Main columns depict the average between conservative and optimistic versions.
Page 22
Average 20 -Year Costs for Track 2 Scenarios
$20
$18
N
$16
c
0
c
$14
111 Contingency
$12
- 13 Monitoring, Reporting, & Mgmt.
o
® Non -Structural BMP Efforts
U
$10
u
- G Repair & Replacement
$8
N
® BMP Maintenance
$6
� � a Structural BMP Capital Costs
$4
$2
$0
Scenario 2B Scenario 2C
Figure 4. Cost Comparison for Track 2 Scenarios
Error bars show the calculated total costs of the conservative and optimistic versions of each
scenario. Main columns depict the average between conservative and optimistic versions.
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Resolution No. 2017-158
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City of Chula Vista
Trash Amendments Baseline Assessment
7. Track -Switching Assessment
The Regional Board has indicated that it will be acceptable for a city to initially select a Track 2
approach and then later switch to a Track 1 approach. This strategy might be desirable if, for
example, after implementing the first few years of a Track 2 program, the City finds that its non-
structural BMP efforts tum out to be less effective or more costly than anticipated. One example
of a track -switching was included to provide a picture of how the total and annual costs would
compare to the other scenarios.
7.1 Scenario Assessed
The situation assessed assumes that the City initially selects Track 2, Scenario 2B (CPS without
ARS) and then switches to the corresponding Track 1 Scenario, 1 B, after five years. The first
five years of program implementation and costs match the Track 2B Scenarios. The City would
install a relatively low number of structural BMPs in these years but would still need to develop
an implementation plan, perform Track 2 monitoring and reporting, and implement new non-
structural BMP efforts. Then in year six, the. City would discontinue Track 2 monitoring_ and any
non-structural BMP efforts -that it had started in years one through five and start installing a
much higher number of structural BMPs annually. For year six, it was also assumed that there
would be a relatively high amount of staff labor for program management and reporting in order
to handle the transition between tracks.
7.2 Costs for Track -Switching Approach
Annual costs were once again calculated for a twenty year period. A 20 percent contingency
was used for the entire 20 -year period. Table 9 and Figure 5 below summarize both the total
number of full capture devices installed and the twenty-year total costs for switching from
Scenario 2B to 1 B after five years.
I apse V. Zu-Tear t osis it z)wncning rrom i raCK L TO I racK i arter o Tears
- -
RII
#FullCapture.Devices Installed „. ; 3
# of ARS Installed
0
:Costs - - - . `•
Structural BMP Capital Costs
$3,144"790
BMP -Maintenance :-:
Repair & Replacement
$767,975
Non=Structural BMP Efforts _ $30 168 . ,'_
Monitoring, Reporting, & Management .
I $1,815,000 I
Contin enc 20%
l::
X2;357358 �
Total
$17,189,815
' Values reported are based on an average of the "conservative" and "optimistic" versions of scenario 2B.
"Conservative" and "optimistic" assume relatively low and relatively high, respectively, levels of trash reduction from
the same non-structural BMP efforts.
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Figure 5. Costs Breakdown if Switching from Track 2 to Track 1
Error bars show the calculated total costs based on the conservative and optimistic versions of
Scenario 2B. The main column depicts the average between calculations based on
conservative and optimistic versions of Scenario 2B.
8. Discussion
8.1 Track Cost Comparison
A breakdown of 20 -year program costs for all scenarios presented in Sections 5 through 7 is
shown in Table 10 and Figure 6. Overall, Track 1 scenarios had higher total costs than Track 2
scenarios. The distribution of costs also differs between tracks, with a much larger proportion of
costs required to cover monitoring, reporting, and program management under Track 2.
As shown by the error bars in Figure 6, optimistic and conservative versions of the Track 2
scenarios differ by several million dollars, with the Conservative versions approaching, but not
quite matching some of the Track 1 scenario total costs. However, it is important to remember
that the conservative and optimistic versions of a scenario are not two distinct approaches that
the City can choose between, but rather two projections of the same Track 2 approach. A
municipality choosing Track 2 would clearly aim to achieve the higher trash load reduction
values of the optimistic scenario, but achievement of those higher reduction credits is not a
certainty. Therefore; it may be helpful to think of the conservative and optimistic costs as
representing the range of costs for a Track 2 scenario.
Page 24
20
-Year Costs if Switching from Track 2 to Track 1
after 5 Years
$20
$18
$16
os
c
$14
B Contingency
S
$12
¢E Monitoring, Reporting, & Mgmt.
$10
a Non -Structural BMP Efforts
i0
a
$8
0- Repair & Replacement
0
N
$6
M BMP Maintenance
$4
®.Structural BMP Capital Costs
$2
$0
Scenario 26 to 1B
Figure 5. Costs Breakdown if Switching from Track 2 to Track 1
Error bars show the calculated total costs based on the conservative and optimistic versions of
Scenario 2B. The main column depicts the average between calculations based on
conservative and optimistic versions of Scenario 2B.
8. Discussion
8.1 Track Cost Comparison
A breakdown of 20 -year program costs for all scenarios presented in Sections 5 through 7 is
shown in Table 10 and Figure 6. Overall, Track 1 scenarios had higher total costs than Track 2
scenarios. The distribution of costs also differs between tracks, with a much larger proportion of
costs required to cover monitoring, reporting, and program management under Track 2.
As shown by the error bars in Figure 6, optimistic and conservative versions of the Track 2
scenarios differ by several million dollars, with the Conservative versions approaching, but not
quite matching some of the Track 1 scenario total costs. However, it is important to remember
that the conservative and optimistic versions of a scenario are not two distinct approaches that
the City can choose between, but rather two projections of the same Track 2 approach. A
municipality choosing Track 2 would clearly aim to achieve the higher trash load reduction
values of the optimistic scenario, but achievement of those higher reduction credits is not a
certainty. Therefore; it may be helpful to think of the conservative and optimistic costs as
representing the range of costs for a Track 2 scenario.
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8.2 Track -Switching Costs
The scenario that switches from Track 2 to Track 1 after five years results in a total cost that is
similar to following a Track 1 approach, 1 B in this case, the whole time. One common concern
with switching tracks is that a City may end up wasting money since it would end up purchasing
the same number of full capture devices as it would have if it started off in Track 1, but it would
also have to spend money on an implementation plan and non-structural BMP efforts that it
would end up discontinuing. However, the cost calculations for the track -switching scenario
suggest that the savings in BMP repair and maintenance during the first five years of the
program can help offset the costs of these Track 2 components that are discontinued in year 6.
Although the 20 -year cost of the track -switching scenarios is similar to the 20 -year cost of
Scenario 1 B, there are important differences in the annual costs. As shown in Figure 7 below,
at the time of the switch from Track 2 to Track 1 in year six, there is a very large increase in
annual cost, because the City needs to install large numbers of structural BMPs in years six
through ten.
$1,600,000
$1,400,000
c $1,200,000
u
$1,000,000
c
Q
E $800,000
M
110L
c $600,000
LL
m
$400,000
$200,000
$0
Scenario 1B (CPS no ARS)
Scenario 2B (CPS no ARS), Average
Scenario 2B to 1B, Average
o�
Pte® Pia
0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Compliance Year
Figure 7. Comparison of Annual Costs for Track -Switching vs. Standard Scenarios
Values reported are based on an average of the "conservative" and `optimistic" versions of
Scenario 2B.
3.3 Other disk Factors
In planning any program to comply with regulations; the components of the program are
generally built around a set compliance target or standard defined in the regulation. However, it
is important to note that the compliance standard for Track 2 is not clearly defined in the Trash
Amendments. Therefore; municipalities that select Track 2 will need to engage with the
Regional Board to negotiate proposed compliance metrics and monitoring approaches prior to
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Trash Amendments Baseline Assessment
implementation plan submittal in 2018, and until those compliance standards are agreed upon
the City cannot have complete confidence that their planned program will result in compliance.
Based on previous interactions with the Regional Board on WQIP development, it is possible
that the Regional Board's interpretation of Track 2 compliance metrics may be stricter than what
was generally expected by the municipalities. It is possible that a City could plan its Track 2
program and then upon submittal of the implementation plan in 2018, the Regional Board could
decide that it will not allow a City to count certain activities toward its overall trash load reduction
value or that it will require more conservative methods for calculating trash load reduction
values associated with certain activities. Conversely, the compliance standard for Track 1 is
more clearly defined as the installation of full capture devices in storm drains receiving runoff
from all PLUs in a City's jurisdiction. Therefore, there is much more certainty that a Track 1
approach planned at this time will ultimately achieve compliance compared to a Track 2
approach planned at this time.
The lack of a clear definition of Track 2 compliance standards in the Trash Amendments could
also result in the compliance targets changing over the course- of the 1.07year compliance
window For example, even if a City is meeting its compliance milestones agreed upon with the
Regional Board, a NGO could observe trash in a water body and then challenge the validity of
the agreed upon Track 2 approach and compliance standards. This could put pressure on the
Regional Board to change the compliance standard, or it could result in the City having to
conduct costly additional studies (e.g. to demonstrate that the trash was not coming from the
City's MS4) to maintain the agreed upon compliance standard. Track 1 compliance, on the
other hand, would be much harder to challenge since it is based strictly on installing and
maintaining BMPs rather than more subjective metrics such as visual trash observations at
outfalls or in water bodies.
8.3.2 Flooding and Infrastructure Damage
While all of the structural BMPs considered in this report are designed with mechanisms to allow
water to safely bypass the BMP if it reaches capacity or clogs, there is always some risk of BMP
failure leading to flooding or infrastructure damage. If flooding occurs and leads to property
damage, there is the potential for lawsuits or other claims against the City. The risk of such a
situation is likely higher in Track 1 scenarios simply due to the larger number of structural BMPs.
However, in Track 2, especially in conservative scenarios, the City will still need to install a large
number of structural BMPs, so the difference in flood risk between Track 1 and Track 2 may not
be dramatic.
8.4 Impact on WQIP Goals
In addition to the requirements of the Trash Amendments, the City is also impacted by the trash -
related goals from the San Diego Bay WQIP. These goals only apply to the portion of the City
west of the 805 where "physical aesthetics" (i.e. trash) are identified as a "Focused Priority
Condition." To achieve compliance, by fiscal year 2028, one of the following goals must be
achieved for the Focused Priority Condition:
1. 95% of the MS4 outfalls visually assessed for trash must have an 'optimal" rating.
-- OR --
2. 100% of the high volume trash drainage area for which BMP retrofit is feasible must
have structural trash control BIvlPs installed.
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Implementing either a Track 1 or Track 2 approach will contribute to the achievement of either
one of these WQIP goals, but the degree to which: the City's Trash Amendments compliance
program overlaps with the WQIP goals may vary based on the details of the program...
One issue is that the land use -based PLU definitions do not explicitly match up with the term
"high volume trash drainage area" used in the WQIP goals. Therefore, the degree to which a
Track 1 approach contributes to meeting the BMP retrofit WQIP goal (goal #2) mainly depends
on how close the correspondence is between PLUs and high volume trash generation areas. A
Track 1 approach should also indirectly help achieve the MS4 outfall trash assesment goal (goal
#1), since installing full capture devices should reduce the trash levels observed at outfalls. A
Track 2 approach would provide the City with more flexibility on the locations of both structural
and non-structural BMPs. For example, non-structural BMPs -such as clean-up events and
increased street sweeping can target the west side of the City, which would contribute to
achieving goal #1. Additionally, Track 2 allows a City to take credit for structural BMPs installed
in non-PLU areas. If high volume trash drainage areas were defined significantly differently
than PLUs and the number of BMPs required to treat those areas was significantly less than the
number of BMPs required to treat .all. PLU inlets, it is possible that implementing a Track 2
approach could still meet goal #2. However, if PLUs and high volume trash drainage areas are
defined as being equivalent or approximately equivalent, which is likely, then implementing a
Track 2 approach would not result in enough BMP retrofits to meet goal #2. Additional'
comparison of WQIP goals and Trash Amendment requirements is provided below:
• The high volume trash drainage area BMP retrofit goal was developed to correspond
with the State Trash Amendments, as noted in footnote 5 to Table 4-23 in the accepted
2016 WQIP. In this context, "high volume trash drainage area" as used in the WQIP
would generally correspond to PLUs as defined in the Trash Amendments.
o However, the WQIP indicates that high volume trash drainage areas are portions
of the City that data indicates do in fact generate high levels of trash. On the
other hand, because the default PLUs. in the Trash Amendments are based
strictly on land use, it is possible that some areas defined as PLUs do not
generate high volumes of trash, and vice versa. There are two main approaches
to this issue:
■ Define high volume trash drainage areas as equivalent to PLUs. This is
straightforward but could result in the City being required to install
structural BMPs to treat PLUs that do not actually generate high levels of
trash to comply with the BMP retrofit goal.
■ Collect and present data to the Regional Board to argue for adjustment to
PLUs such that areas shown by data or institutional knowledge to
generate high trash volumes are the only areas considered PLUs for
purposes of Trash Amendments compliance. This approach would be
contingent on Regional Board approval. If approved, it would likely be a
more effective use of City' resources since BMP installation would be
targeted only at areas known to generate high volumes of trash.
• The high volume trash drainage area BMP retrofit goal only applies to areas that are
feasible for retrofit. Track 1, as described in the Trash Amendments, requires
installation of full capture devices in all PLU inlets and does not mention an exemption
for infeasibility. In the Los Angeles region though, that Regional Board has developed a
framework through which jursidictions can document that BMP installation is infeasible in
certain locations and still comply via only structural BICAP installation. It is anticipated
that a similar pathway will be able to be worked out with the San Diego Regional Board,
although this will remain an uncertainty until the details of Trash Amendments
application to the Permit and the WQIP are worked out.
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• The optimal outfall rating goal is similar to a Track 2 type of approach in that it is based
on performance measured by monitoring rather than BMP implementation. The
underlying assumption is that 95% optimal scores at outfalls demonstrates full capture
equivalency. The WQIP goals were developed with Regional Board staff in view of
Trash Amendments requirements, so this view of full capture equivalency may continue
to hold in the future. On the other hand, it is also possible that once the Trash
Amendments are incorporated into the Permit, the Regional Board revises this opinion
and applies a more onerous definition of full capture equivalency. In that case, meeting
the WQIP goal for MS4 outfall trash scores may not be sufficient to demonstrate
compliance with the Trash Amendments. —
• Also note that standard and enhanced non-structural BMPs directly contribute to
achieving the MS4 outfall trash assessment goal but not the BMP retrofit goal.
It is also important to remember that the WQIP is a "living" document, and the Regional Board
expects municipalities to make regular updates to the document. Therefore, it is probable that
there -may be an opportunity to revise or clarify the WQIP physical aesthetics goals to more
closely coincide with the City's chosen Trash Amendments -compliance approach.
9. Conclusions
The following is a list of general conclusions about Track 1 and Track 2 approaches drawn from
the materials presented in this report:
1. Track 2 may be less expensive than Track 1, but that is based on the assumptions that
the City's trash removal efforts yield trash load reduction values consistent with initial
estimates and that the final compliance metrics determined by the Regional Board are
consistent with what is currently anticipated. If these assumptions are not met, the City
may need to switch to a Track 1 approach. This would result in the City accruing all the
capital costs of a Track 1 approach plus the costs of preparing an implementation plan
and doing additional monitoring during the period in which it is following a Track 2
approach.
2. Structural full capture devices would be required in both tracks. Connector pipe screens
are expected to be more cost effective than other full capture devices.
3. Because Track 2 allows the City to take credit for existing non-structural BMPs that
remove trash, such as street sweeping and cleanups, installation of full capture devices
can be ramped up more slowly over the first few years of program implementation.
Track 1 would require installing fairly large numbers of full capture devices even in the
first years of program implementation.
4. Track 2 has a higher risk of Regional Board enforcement actions or third party lawsuits
(see Section 8.1.1).
5. Track 1 has a higher risk of flooding damage and associated costs, although since a
relatively large number of structural BMPs are also anticipated under Track 2, this
difference may not be large (see Section 8.1.2).
6. Track 1 would be expected to result in achieving at least one (% of area retrofitted with
BMPs); and possibly both (full capture BMPs may also result in meeting the MS4 outfall
trash level goal), of the City's two k/VQIP goals.
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7. Track 2 may result in achieving one of the City's WQIP goals (MS4 outfall trash levels)
but most likely is not capable of achieving the other WQIP goal (% of area retrofitted with
BMPs).
Feasibility of a Track 2 approach is largely dependent on how the Regional Board will define full
capture equivalency. If a relatively reasonable and achievable definition, like the MS4 outfall
trash level goal the City has in the WQIP, is used, then Track 2 is more attractive. Under that
type of approach, Track 2 would allow for the City to focus program expenditures on controlling
trash where data shows it is a significant problem. However, if Track 2 is interpreted as
requiring the City to demonstrate that receiving waters have essentially no trash, or other
standards that effectively make the City's compliance depend on controlling sources beyond
MS4 discharges (e.g., direct illegal dumping into creeks and rivers or transient encampments),
then Track 2 becomes virtually unachievable and cost prohibitive.
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10. References
Bay Area Stormwater Management Agencies Association (BASMAA). 2014. San Francisco Bay
Area Stormwater Trash Generation Rates, Final Technical Report.
California Regional Water Quality Control Board, San Diego Region (Regional Board). 2017.
Order Number R9-2017-0077, An order directing the owners and operators of Phase t
municipal separate storm sewer systems (MS4s) draining the watersheds within the San Diego
Region to submit reports pertaining to the control of trash in discharges from Phase I MS4s to
ocean waters, inland surface waters, enclosed bays, and estuaries in the San Diego Region.
County of Los Angeles Department of Public Works Watershed Management Division. 2004.
Trash Baseline Monitoring Results, Los Angeles River and Ballona Creek Watersheds.
EOA, Inc. 2007. Pollutant Load Removal From Street Sweeping Best Management Practices.-
Development
ractices:Development of Typical Concentration Values for Pollutants of Concern. in Contra Costa County,
CA.
EOA, Inc. 2012. Trash Load Reduction Tracking Method: Assessing the Progress of the San
Francisco Bay Area MS4s Towards Stormwater Trash Load Reduction Goals. Technical Report
(Version 1.0).
EOA, Inc. 2011 Visual On -land Trash Assessment Protocol for Stormwater.
Maryland Department of the Environment. 2014. Total Maximum Daily Loads of Trash and
Debris for the Middle Branch and Northwest Branch Portions of the Patapsco River Mesohaline
Tidal Chesapeake Bay Segment, Baltimore City and County, Maryland.
San Diego Bay Responsible Parties. 2016. San Diego Bay Watershed Management Area
Water Quality Improvement Plan. February. City of Coronado, City of Chula Vista, City of
Imperial Beach, City of La Mesa, City of Lemon Grove, City of National City, City of San Diego,
County of San Diego, San Diego Unified Port District, San Diego Regional Airport Authority, and
Caltrans.
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