water quality issues for the construction and building industry in 2014 a presentation for the...
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Water Quality Issues for the Construction and Building Industry in 2014
A Presentation for the
Orange County Business CouncilJanuary 14, 2014
Mark Grey, Ph.D., Technical DirectorConstruction Industry Coalition on Water Quality
Building Industry Association of Southern California
Remarks Today On: • Municipal Separate Storm Sewer System
(MS4) permit renewal for North Orange Co.• Observations on permit implementation and
experiences over past 5 years, and• Land use and building adaptation to the latest
generation of MS4 permits in California• Collaborative efforts (public-private) for
permit compliance and infrastructure planning– MS4 LID Alternative Compliance Program
• Stormwater program compliance funding
Latest Generation of Phase 1 MS4 Permits in southern California
Location Regional Board Date Adopted or Proposed
North Orange County Santa Ana 6/3/2009San Francisco Bay Area San Francisco Bay 10/14/2009South Orange County San Diego 12/16/2009Western Riverside County Santa Ana 1/29/2010San Bernardino County Santa Ana 1/29/2010Ventura County Los Angeles 7/8/2010Southern Riverside County San Diego 10/13/2010Los Angeles County Los Angeles 11/8/2012San Diego Regional San Diego 5/9/2013
Additional Stormwater Permitting Activity by State Water Resources Control Board
Permitting ActionDate Adopted or
ProposedPhase II MS4 Permit February 5, 2013
Caltrans MS4 Permit September 19, 2012
Ocean Plan ASBS Discharge Exceptions March 20, 2012Industrial General Permit 2014?
Construction General Permit 2014?
Low Impact Development principles incorporated into MS4 permits in California
• Mimic Predevelopment Hydrology– Use natural features– Use site design– Use source controls– Use distributed controls, not
centralized• Use Integrated Water
Resources Management– Treating stormwater as a
resource at all scales– Improving water quality and
augmenting water supplies regionally, watershed-wide
Stormwater LID Best Practices Categories
Infiltration Harvest and Use Evaporative Biofilter/Biotreat$-$$ $$$ $$$$ $$
Grading Rain Barrels Green Roof Bioretention
Swale Cisterns Brown Roof Biofiltration
Trench Tanks Blue Roof Planter BoxBasin Canopy Intercept Constr. Wetland
Drywell Uses: Soil Amendment Vegetated Swale
Gallery IrrigationToilet Flushing
Vehicle WashingEvaporative CoolingIndustrial Process
Dilution WaterOther Non-Potable
Runoff Dispersion Vegetated Strip
French Drain Proprietary Device
Permeables:--Asphalt
--Concrete--Pavers
Biotreatment may use underdrains or overdrains
What is the San Diego Regional Permit Adopted in 2013 Telling Us About North
Orange County Revisions in 2014?• Watershed-based construct for water quality
compliance (planning and monitoring programs)• A nod to more robust consideration of regional
solutions through LID BMP Alternative Compliance• Push for zero discharge of stormwater (retention) as
the engineering standard; minimize use of biofiltration to meet the retention standard
• Push to remove all hydromodification control (stream protection) exemptions for development
Observations and lessons from the existing North Orange Co. MS4 permit
• OCPW reports more than 10,000 acres of property developed in the past 5 years instrumented with LID stormwater BMPs
• Use takes several forms, mostly infiltration and biofiltration BMPs installed on-site
• Generally smooth transition by development interests to adopt and use LID principles
• Water conservation efforts not overlooked in achieving clean beaches/compliance
MS4 permits allow Alternative Compliance Programs for Qualifying Projects
• Permits require that the design capture volume is managed on-site using LID BMPs
• The volume of runoff NOT managed in LID BMPs must be “mitigated” or “offset”
• Options are identified in MS4 permits:– “Mitigate” the volume difference at an
off-site location– Pay a fee equivalent to managing runoff
from the project location using LID BMPs– Credit trading systems– Watershed planning elements/instruments
LID BMP Installation Alternative Compliance Program Development
Basis: Phase I MS4 water quality permit conditions for complianceBackdrop: Increase water supply reliability in S. Calif. and emphasis on
creating multi-benefit water conservation projects• Evaluating and selecting projects and options• Identifying and creating framework elements• Identifying appropriate programs for the region• Establishing “equivalence” of alternative compliance options with on-site
compliance• Creating participation options and agreements among parties:
– Private development interests– Regional water quality and flood control agencies– Water and wastewater districts
Alternative Compliance Framework Elements
Needs and Opportunity AnalysisOff-site and Regional BMP Framework Credit Trading System FrameworkRegulatory and Legal BasisCore Economic and Development DataResource Expectations for ProgramExperiences from Other Programs
Off-site, Regional, and Credit Trading Framework: Some Options
1. Developer mitigates off-site2. Developer purchases credits through private
seller with retention capacity3. Reimbursement agreement 4. Negotiated mitigation agreement (variations)5. Community facility district
Content taken from Arne Anselm/Rebecca Winer-Skonovd, CASQA Conference 2012;Alternative Compliance in Ventura County: Viable Options and Lessons Learned
What are examples of off-site project alternatives for water quality compliance?
• Green street adjacent or surrounding project
• Green streets near project within catchment
• Facility retrofits adjacent/near project– Parking Areas– Parks
• Streets/Retrofits outside catchment of project
• Regional infiltration within/outside project watershed
CASQA 2012 BMP of the YearSlide Source: City of Los Angeles
Agencies Performing Some Degree of Stormwater Capture in S. California
AgenciesOrange County Water District Orange County Public Works
LA County Flood Control/Public Works San Bernardino Flood Control District
LA Dept of Water and Power Chino Basin Water Conservation District
City of Los Angeles San Bernardino Valley Municipal Water District
Central Basin Municipal Water District Western Municipal Water District
Inland Empire Utilities Agency Eastern Municipal Water District
San Gabriel Valley Municipal Water District
Riverside County Flood Control and Water Conservation District
Water Replenishment District of Southern California
City of Riverside
Irvine Ranch Water District United Water Conservation District
Establishing Equivalency for Alternative Compliance Programs
Core Economic Data• Cost of installation• Cost of long term O&M• Benefits derived from
installation of LID BMPs– Water Quality– Water Supply– Environmental– Property – Health
Resource Expectations• Appears highly variable
depending upon location and development types
• Ultra urban, urban, and suburban development patterns and different needs & opportunities create variation
• Orange County development records offer some guidance on need
• Pilot projects needed in opportune locations
Case Study Analysis of On-site Retention LID BMPs Installation and 20-year O&M Per Gallon Managed
Installation and 20-year O&M Cost hierarchy normalized per gallon:
Infiltration < Infiltration Pavers ≤ Biofiltration < Harvest and Use Cisterns < Green Roof
LID BMPs Evaluated Office
ComplexResidential
Single Family
SmallUrban Infill
Retail Big Box
Large Urban
Mixed UseCost Per Gallon
Infiltration Basin $4 $2 --- $1 ---Infiltration Paver $6 $3 $18 $3 $9Cistern: outdoor $12 $7 --- $5 ---Cistern: outdoor & indoor $15 --- $49 --- $11
Green Roof $103 $38 $126 $61 $84Biofiltration $6 $4 $21 $2 $9
Equivalent Volume Retention Costs
Approximate Area (RUNOFF: GALLONS)
<0.5 Ac5,000
1-2 Ac25,000
3-4 Ac50,000
6-8 Ac100,000
> 10 Ac250,000
BMP TYPE $/GAL Design Capture Volume (GAL) Retention Range Equivalent Cost
Infl. Basin 2 $10,000 $50,000 $100,000 $200,000 $500,000
Infl. Paver 5 $25,000 $125,000 $250,000 $500,000 $1,250,000
Biofiltration 6 $30,000 $150,000 $300,000 $600,000 $1,500,000
Cistern 13 $65,000 $325,000 $650,000 $1,300,000 $3,250,000
Green Roof 38 $190,000 $950,000 $1,900,000 $3,800,000 $9,500,000
Cost Data from LID BMP Economic Analysis for Orange County, CA, 2012
Simple example of revenue potential using 2011-2012 WQMP data
Assumptions (Very Rough)• 10% of total acres covered by
WQMPs in 2011-12 can’t comply on-site (total acres =9,114)
• 10% = 911 acres• Assuming 19,000 gallons of
design capture volume per acre using rational method (90% imperviousness)
• Results in 17.3 M Gallons of runoff
Potential Revenue• (17.3 M Gal.) x ($2/ Gal.)
using infiltration basin = $34.6 Million
• Appears unrealistically high• What about 1% of sites not
able to comply on-site?• (91 Acres) x (19,000 gallons
per acre) x ($2/Gal.) using infiltration basin = $3.46 Million
Alternative Compliance Framework;Perspective and Distinctions Among Parties
Perspective• Obtaining water quality
approvals is paramount to private development
• Meeting MS4 permit requirements is paramount for principal and co-permittees
• Water districts and related agencies hold water supply reliability interests paramount
Distinctions and Variations• MS4 permit requirements drive compliance
options• On-site preferred, then off-site allowed• Where infiltration is feasible, then regional
projects may represent best opportunity to achieve compliance and augment ground water supply
• Projects could be multi-agency, multi-benefit or between private interests (credit trading, for example)
• Where infiltration is infeasible or won’t augment ground water supply, then other types of off-site projects apply
• Projects are likely to be local, where needs exist, such as green streets or park and playground improvements or retrofits of existing development
Economic Analysis Relating to Integrated Water Resource Planning
Questions:• Where will suitability of capturing
stormwater align with expected property development and with existing infrastructure plans by cities and the counties?
• Where and what benefits will be derived by implementing LID BMPs, and at what scale?
• What is the universe of benefits to consider? How will benefits be calculated? What are the acceptable methods? Who will make the calculations?
Goals:
• Make the methods and calculation procedures clear and transparent
• Use case studies to test the framework, and produce the results; augment with work of the past two years in SC
• Produce a clear understanding of benefits and costs of installing LID BMPs at relevant scales of development
Using Case Study Analysis Methods to Establish Alternative Compliance Program Framework
Orange Co. Case Study Analysis
• Apply optimization analysis and tools
• Determine and apply benefit-cost analysis framework
• Develop alternative compliance framework, including credit trading and in-lieu options using development scenarios
Orange County-Santa Ana RegionAlternative Compliance Framework
• Perform similar analysis done in Orange County specific to Santa Ana region
• Assist in developing pilot projects to test Alternative Compliance Framework
• Create a clear, simple, pathway for water quality compliance given local needs within a single Regional Board territory
Stormwater Program Financing
Funding Needs:
• Water Quality Permit Compliance
• Total Maximum Daily Load Requirements– Nutrients and Metals– Bacteria
• Retrofitting Existing Infrastructure with “Green” Infrastructure
• Water Supply Augmentation
Challenges:
• Mechanisms to raise revenue for meeting compliance obligations– Fees (voter approval)– Taxes (voter approval)– Product charges
• Public Understanding of Need
• Competing Priorities
THANK YOU Orange County Business Council!
Water Quality Issues for the Construction and Building Industry in 2014
Contact:Mark Grey, Ph.D.
909-525-0623