HomeMy WebLinkAbout2015-06-09; City Council; 21983; Acceptance National Pollutant Discharge Elimination System Water Quality Improvement, Jurisdictional Runoff Management Plan8
CITY OF CARLSBAD - AGENDA BILL
AB# 21.983 ACCEPTANCE OF NATIONAL POLLUTANT DISCHARGE
ELIMINATION SYSTEM WATER QUALITY IMPROVEMENT
PLAN AND JURISDICTIONAL RUNOFF MANAGEMENT PLAN
DEPT. DIRECTOR'p'T-
DATE: 06-09-2015
ACCEPTANCE OF NATIONAL POLLUTANT DISCHARGE
ELIMINATION SYSTEM WATER QUALITY IMPROVEMENT
PLAN AND JURISDICTIONAL RUNOFF MANAGEMENT PLAN
CITY ATTY.
DEPT. PW-PEM
ACCEPTANCE OF NATIONAL POLLUTANT DISCHARGE
ELIMINATION SYSTEM WATER QUALITY IMPROVEMENT
PLAN AND JURISDICTIONAL RUNOFF MANAGEMENT PLAN
CITYMGR.
RECOMMENDED ACTION:
Adopt Resolution No. 2015-139 accepting the Carisbad Watershed Management Area Water
Quality Improvement Plan, including the City of Carisbad's Jurisdictional Runoff Management Plan.
ITEM EXPLANATION:
On June 27, 2013, the San Diego Regional Water Quality Control Board (SDRWQCB) adopted the National
Pollutant Discharge Elimination System (NPDES) Municipal Permit, Order No. R9-2013-0001 (Permit).
This updated Permit applies to all 18 San Diego cities, the County of San Diego, the San Diego Unified
Port District and the San Diego Regional Airport Authority. The areas of South Orange County and
Riverside County, also included in SDRWQCB's Region 9 jurisdiction, will be incorporated into this Permit
upon renewal of each expiring order. The Permit is a re-issuance of the previous NPDES Municipal
Permit Order No. R9-2007-0001 issued on Jan. 24, 2007.
The new Permit continues to implement many ofthe requirements ofthe previous order; however, it is
fundamentally centered on watershed-based program planning and program outcomes. The Permit
requires Responsible Agencies in each of the region's watersheds to develop a Water Quality
Improvement Plan (WQIP). The CaHsbad Watershed Management Area (CWMA) Responsible Agencies
include the following: City of Carisbad, City of Encinitas, City of Escondido, City of Oceanside, City of San
Marcos, City of Solana Beach, City of Vista and the County of San Diego. The City of Carisbad has agreed
to serve as the CWMA Principal Watershed Copermittee and fulfill the required responsibilities for the
duration ofthe Permit.
The Permit is designed to enable jurisdictions to prioritize and focus resources and efforts in various
ways to effectively prohibit non-storm water discharges to its storm water conveyance system, reduce
pollutants in storm water discharges and achieve interim and final numeric goals. The CWMA WQIP
establishes watershed goals and strategies that the City of Carisbad used to guide the development of
the Jurisdictional Runoff Management Plan (JRMP). The City of Carisbad's JRMP contains the strategies,
standards and methods to be implemented in response to the priorities and goals established in the
WQIP.
DEPARTMENT CONTACT: Elaine Lukey 760-602-7582 elaine.lukey@carlsbadca.gov
FOR CLERK USE.
COUNCIL ACTION: APPROVED CONTINUED TO DATE SPECIFIC •
DENIED • CONTINUED TO DATE UNKNOWN •
CONTINUED • RETURNED TO STAFF •
WITHDRAWN • OTHER - SEE MINUTES •
AMENDED • REPORT RECEIVED •
Accept NPDES WQIP and JRMP
June 9, 2015
Page 2 of 2
FISCAL IMPACT:
Compliance with the programs and strategies established by the WQIP and the JRMP are not expected to
result in any increases to the General Fund or any other city revenue source at this time. All program
costs associated with activities established by these documents are anticipated to be accommodated by
existing staff and/or budgeted expenses in the Fiscal 2015-16 budget. City staff will continually assess
programs related to the storm water pollution prevention program to evaluate future annual budgetary
needs relative to the Permit requirements and the associated compliance documents and request
additional resources in future years, if needed.
ENVIRONMENTAL IMPACT:
This action is exempt from the California Environmental Quality Act pursuant to CEQA Guidelines Section
15308. This section exempts activities taken by regulatory agencies, as authorized by state or local
ordinance, to assure the enhancement or protection ofthe environment.
EXHIBITS:
1. Resolution No. 2015-139 ^ accepting the Carisbad Watershed Management Area Water
Quality Improvement Plan, including the City of Carisbad's Jurisdictional Runoff Management Plan.
2. Report titled "Carisbad Watershed Management Area Water Quality Improvement Plan" dated June
2015, previously distributed, on file with the Public Works Department.
3. Report titled "City of Carisbad Jurisdictional Runoff Management Plan" dated June 2015, previously
distributed, on file with the Public Works Department.
EXHIBIT
1 RESOLUTION NO. 2015-139
2 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD,
3 CALIFORNIA, TO ACCEPT THE NATIONAL POLLUTANT DISCHARGE
ELIMINATION SYSTEM WATER QUALITY IMPROVEMENT PLAN
4 AND JURISDICTIONAL RUNOFF MANAGEMENT PLAN.
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Y 0 the San Diego Region, Order No. R9-2013-0001 (Permit); and
11 WHEREAS, the Permit requires all Watershed Management Areas within San Diego
County to develop and implement a Water Quality Improvement Plan to establish water quality
priorities, goals and strategies for the watershed; and
WHEREAS, the Carisbad Watershed Management Area Copermittees include the
following: City of Carlsbad, City of Encinitas, City of Escondido, City of Oceanside, City of San
WHEREAS, on May 27, 2013, the San Diego Regional Water Quality Control Board adopted
the National Pollutant Discharge Elimination System Permit and Waste Discharge Requirements
for Discharges from the Municipal Separate Storm Sewer Systems Draining the Watersheds within
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17 Marcos, City of Solana Beach, City of Vista and the County of San Diego; and
18 WHEREAS, the City of Carisbad has agreed to serve as the Carisbad Watershed
Management Area Principal Watershed Copermittee and fulfill the responsibilities required in
the Permit; and
WHEREAS, each jurisdiction within the Carisbad Watershed Management Area must
develop and implement a Jurisdictional Runoff Management Plan to control the contribution of
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1 NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Carisbad, California
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as follows:
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1. That the above recitations are true and correct.
2. The City Council accepts the Carisbad Watershed Management Area Water Quality
Improvement Plan and the Jurisdictional Runoff Management Plan for the City of
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PASSED, APPROVED AND ADOPTED at a Regular Meeting ofthe City Council ofthe City
of CaHsbad on the 9^*^ day of June, 2015, by the following vote to wit:
AYES:
NOES:
Council Members Hall, Blackburn, Schumacher, Wood, Packard.
None.
ABSENT: None.
MATT HALL, Mayor
ATTEST:
BARBARA ENGLESONUZity Clerk
(SEAL) .o^S^^^.^^'e:''.
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EXHIBIT 2
Carlsbad Watershed Management Area
Water Quality Improvement Plan
San Diego Regional Water Quality Control Board
Order R9-2013-0001
June 2015
Prepared and Submitted by the
Carlsbad Watershed Management Area Responsible Agencies
City of Carlsbad City of San Marcos
City of Encinitas City of Solana Beach
City of Escondido City of Vista
City of Oceanside County of San Diego
This page intentional for printing purpose
Table of Contents
List of Tables iii
List of Figures iv
List of Appendices v
List of Acronyms and Abbreviations v
Acknowledgements vi
Executive Summary i
1 Introduction 1
1.1 Background and Watershed Description 1
1.2 Purpose 2
1.3 WQIP Development and Updates 4
1.3.1 Public Participation Process 5
1.3.2 Regional Clearinghouse 6
1.3.3 Plan Updates 7
2 Water Quality Improvement Plan Components 9
2.1 Priority Water Quality Conditions 9
2.2 Goals 16
2.3 Strategies 17
2.3.1 Geographic Characteristics 17
2.3.2 Geographic Prioritization 18
2.3.3 Optional Strategies 19
2.3.4 Watershed Management Area Analysis 19
2.4 Iterative and Adaptive Management Process 21
2.4.1 Re-evaluation of Water Quality Conditions 23
2.4.2 Adaption of Goals and Schedules 24
2.4.3 Strategies and Schedules 25
2.4.4 Adaptation of Monitoring and Assessment Programs 25
2.5 Monitoring 26
2.5.1 JRMP Program 27
2.5.2 Regulations and Policy 27
2.5.3 Water Quality Monitoring Program 27
2.6 Assessment 37
2.6.1 JRMP Program Assessments 37
2.6.2 Regulatory and Policy Assessment 38
2.6.3 Storm Drain Discharges Assessments 38
1
2.6.4 Special Studies Assessments 42
2.6.5 Receiving Waters Assessment 43
2.6.6 Integrated Assessment 45
3 Hydrologic Area Implementation 47
3.1 Loma Alta HA (904.1) 53
3.1.1 Loma Alta HA Sources 54
3.1.2 Loma HA Area Goals and Strategies 55
3.1.3 Loma Alta HA Focus Areas 58
3.1.4 Loma Alta HA Monitoring and Assessment 66
3.2 Buena Vista Creek HA (904.2) 69
3.2.1 Buena Vista Creek HA Sources 70
3.2.2 Buena Vista Creek HA Goals and Strategies 72
3.2.3 Buena Vista Creek HA Focus Areas 75
3.2.4 Buena Vista Creek HA Monitoring and Assessment 84
3.3 Agua Hedionda HA (904.3) 87
3.3.1 Agua Hedionda HA Sources 88
3.3.2 Agua Hedionda HA Goals and Strategies 89
3.3.3 Agua Hedionda HA Focus Areas 92
3.3.4 Agua Hedionda HA Monitoring and Assessment 100
3.4 Encinas HA (904.4) 103
3.4.1 Encinas HA Sources 104
3.4.2 Encinas HA Goals and Strategies 104
3.4.3 Encinas HA Monitoring and Assessment 105
3.5 San Marcos HA (904.5) 107
3.5.1 San Marcos HA Sources 108
3.5.2 San Marcos HA Goals and Strategies 110
3.5.3 San Marcos HA Focus Areas 117
3.5.4 San Marcos HA Monitoring and Assessment 129
3.6 Escondido Creek HA (904.6) 133
3.6.1 Escondido Creek HA Sources 134
3.6.2 Escondido Creek HA Goals and Strategies 135
3.6.3 Escondido Creek HA Focus Areas 140
3.6.4 Escondido Creek HA Monitoring and Assessment 158
4 References 161
List of Tables
Table 1: Jurisdictional Breakdown of Carlsbad WMA 2
Table 2: Carlsbad WMA Water Quality Improvement Consultation Panel 6
Table 3: Summary of Receiving Water Data and Information 11
Table 4: Summary of Receiving Water Data and Information (Results from Public Data Call) 12
Table 5: Priority Water Quality Conditions by Waterbody 13
Table 6: Highest Priority Water Quality Conditions by Waterbody 15
Table 7: MS4 Outfall Monitoring 28
Table 8: Number of Major MS4 Outfalls per Jurisdiction 29
Table 9: Carlsbad WMA Special Studies Monitoring 31
Table 10: Receiving Water Monitoring Program 34
Table 11: Carlsbad Watershed Long-Term Receiving Water Station 35
Table 12: Dry Weather MS4 Outfall Assessment Evaluation Process and Potential Outputs 39
Table 13: Wet Weather MS4 Outfall Assessment Evaluation Process and Potential Outputs 41
Table 14: ROWD Assessments Evaluation Process and Potential Outputs 42
Table 15: Special Studies Assessments Evaluation Process and Potential Outputs 43
Table 16: Receiving Water Assessment Evaluation Process and Potential Outputs 44
Table 17: Pollutant Generating Sources - 904.1 Loma Alta Hydrologic Area 54
Table 18: Loma Alta HA Interim and Final Numeric Goals 55
Table 19: Loma Alta HA Strategies 56
Table 20: Pollutant Generating Sources - 904.2 Buena Vista Creek Hydrologic Area 71
Table 21: Buena Vista Creek HA Strategies 73
Table 22: CB-PAl Focus Area, Interim and Final Numeric Goals 76
Table 23: CB-PA2 Focus Area, Interim and Final Numeric Goals 78
Table 24: CB-PA3 Focus Area, Interim and Final Numeric Goals 81
Table 25: BV06 Basin Focus Area, Interim and Final Numeric Goals 83
Table 26: Dry Weather Data Collection by Jurisdiction for the Buena Vista Creek HA 86
Table 27: Pollutant Generating Sources - 904.3 Agua Hedionda Hydrologic Area 88
Table 28: Agua Hedionda HA Strategies 90
Table 29: AH04 Basin Focus Area, Interim and Final Numeric Goals 93
Table 30: SM-AH Focus Area, Interim and Final Numeric Goals 95
Table 31: CB-PA2 Focus Area, Interim and Final Numeric Goals 98
Table 32: Dry Weather Data Collection by Jurisdiction for the Agua Hedionda HA 102
Table 33: Pollutant Generating Sources - 904.4 Encinas Hydrologic Area 104
Table 34: Encinas HA Strategies 106
Table 35: Pollutant Generating Sources - 904.5 San Marcos Hydrologic Area 109
Table 36: San Marcos HA Dry Weather Interim and Final Goals Ill
Table 37: San Marcos HA Wet Weather Interim and Final Goals 112
Table 38: San Marcos HA Strategies 115
Table 39: Basins B, C & D Focus Areas, Interim and Final Targeted Outcomes 122
Table 40: County of San Diego San Marcos HA Focus Areas, Interim and Final Targeted Outcomes 126
Table 41: Dry Weather Data Collection by Jurisdiction for the San Marcos HA 131
Table 42: Pollutant Generating Sources - 904.6 Escondido Creek Hydrologic Area 134
Table 43: Escondido Creek Strategies 137
Table 44: Solana Beach Drainage Area, Interim and Final Numeric Goals 141
Table 45: Cardiff Channel and San Elijo JPA Outfall Drainage Areas, Interim and Final Numeric Goals.. 145
Table 46: County of San Diego Escondido Creek HA Focus Areas, Interim and Final Goals 148
Table 47: ESC 113, ESC 128, ESC 143 Focus Areas, Interim and Final Numeric Goals 153
III '1
Table 48: City of San Marcos, SM-EC Focus Area, Interim and Final Numeric Goals 156
Table 49: Dry Weather Data Collection by Jurisdiction for the Escondido Creek HA 160
ist of Figures
igure 1: Carlsbad Watershed Management Area 1
igure 2: Five-Year process for Planning, Implementation and Assessment of WQIP 3
igure 3: Long-Term WQIP Process 4
igure 4: Initial WQIP Development Process - Planning Consisting of Assessment 9
igure 5: Demonstrated Improvements Using Iterative Process 21
igure 6: Balance of Water Quality Improvement Plan Components 22
igure 7: Carlsbad WMA Monitoring Locations 30
igure 8: Carlsbad Watershed Management Area - Highest Priority Water Quality Conditions 47
igure 9: Example Hydrologic Area Map 48
igure 10: Example Goals Table 49
igure 11: Example Hydrologic Area Strategy Table 50
igure 12: Example Focus Area 51
igure 13: Loma Alta Hydrologic Area Highest Priority Water Quality Conditions and Focus Areas 53
igure 14: Oceanside Jurisdiction within Loma Alta HA 58
igure 15: Collins Basin Drainage Area/Focus Area 61
igure 16: Temple Heights Drainage Area/Focus Area 62
igure 17: Oceanside/Vista Residential Focus Area '. 64
igure 18: Buena Vista Hydrologic Area Highest Priority Water Quality Conditions and Focus Areas 70
igure 19: CB-PAl Focus Area - Buena Vista Creek HA 75
igure 20: CB-PA2 Focus Area - Buena Vista Creek 78
igure 21: CB-PA3 Focus Area - Buena Vista Creek 80
igure 22: BV06 Basin Focus Area 83
igure 23: Agua Hedionda Hydrologic Area Highest Priority Water Quality Conditions and Focus Areas.87
igure 24: AH04 Basin Focus Area 92
igure 25: SM-AH Focus Area 94
igure 26: CB-PA2 Focus Area 98
igure 27: Encinas Hydrologic Area 103
igure 28: San Marcos Hydrologic Area Highest Priority Water Quality Conditions and Focus Areas 108
igure 29: Cottonwood Creek and 2nd Street Drainage Areas 117
igure 30: San Marcos Drainage Basin B 120
igure 31: San Marcos Drainage Basin C 121
Igure 32: San Marcos Drainage Basin D 121
igure 33: County of San Diego San Marcos HA Focus Areas 125
igure 34: Escondido Creek HA Highest Priority Water Quality Conditions and Focus Areas 133
igure 35: Solana Beach Drainage Area/Focus Area 140
igure 36: Cardiff Channel Drainage Area, City of Encinitas Focus Area 143
igure 37: San Elijo JPA Outfall at Cardiff Drainage Area, City of Encinitas Focus Area 144
igure 38: County of San Diego CAR 007 Focus Areas 146
igure 39: County of San Diego CAR 015 Focus Areas 147
igure 40: County of San Diego CAR 059 Focus Areas 147
igure 41: Escondido ESC 113 Focus Area 152
igure 42: Escondido ESC 128 Focus Area 152
igure 43: Escondido ESC 134 Focus Area 153
igure 44: San Marcos SM-EC Focus Area 155
V V) IV
List of Appendices
Appendix A - General Descriptions for Select Strategies
Appendix B - Provision B.2 Submittal: Water Quality Conditions, MS4 Sources and Potential Strategies
Appendix C - Provision B.3 Submittal: Numeric Goals and Schedules, Strategies and Schedules
Appendix D - Watershed Management Area Analysis
Appendix E - Offsite Alternative Compliance Candidate Projects List
List of Acronyms and Abbreviations
303(d) Clean Water Act Section 303(d) list of impaired waters
AGR Agricultural Supply
ASBS Area of Special Biological Significance
Basin Plan Water Quality Control Plan for the San Diego Basin
BIOL Biological Habitats of Special Significance
BMP Best Management Practice
Caltrans California Department of Transportation
COD Chemical Oxygen Demand
CWA Clean Water Act
HA Hydrologic Area
HPWQCs Highest Priority Water Quality Conditions
HSA Hydrologic Sub-Area
IBI Index of Biological Integrity
JRMP Jurisdictional Runoff Management Program
JURMP Jurisdictional Urban Runoff Management Program/Plan
LTEA Long-Term Effectiveness Assessment
MAR Marine Habitat
MEP Maximum Extent Practicable
MLOE Multiple Lines of Evidence
MS4 Municipal Separate Storm Sewer System
MUN Municipal and Domestic Supply
NNE Nutrient Numeric Endpoint
O/E Observed-to-Expected ratio
PWQC Priority Water Quality Condition
REC-1 Recreation Contact Water
RWQCB San Diego Regional Water Quality Control Board
SHELL Shellfish Harvesting
TDS Total Dissolved Solids
TMDL Total Maximum Daily Load
TSS Total Suspended Solids
WARM Warm Freshwater Habitat
WMA Watershed Management Area
WQICP Water Quality Improvement Consultation Panel
WQIP Water Quality Improvement Plan
WURMP Watershed Urban Runoff Management Program
w
Acknowledgements
Mikhail Ogawa Engineering would like to thank the following people for their participation in the Water
Quality Improvement Plan development process:
Alicia Appel City of Escondido
Tim Bailey Santa Fe Irrigation District
Eric Becker SDRWQCB, Consultation Panel Alternate Member
Christine Bevilacqua Antioch University
Simon Breen The Escondido Creek Conservancy
Kasey Cinciarelli Preserve Calavera
Helen Davies City of Escondido
Paige DeCino Preserve Calavera
Ruth DeLa Rosa County of San Diego
Olga Diaz City of Escondido, Councilwoman
Doug Dowden City of San Marcos
Diane Downey Green Gardens Group (G3)
Bryn Evans Resident
Cheryl Filar City of Vista
Justin Gamble City of Oceanside
Doug Gibson San Elijo Lagoon Conservancy
Katie Greenwood City of Oceanside
Steve Gruber Burns & McDonnell, Consultation Panel Member
Ann Hough The Escondido Creek Conservancy
Alden Hough Sky Mountain Institute
Jayne Janda-Timba Rick Engineering Company
Isabelle Kay UCSD Natural Reserve System, Carlsbad Watershed Network
Taryn Kjolsing City of Solana Beach
Liz Kruidenier Canyon Network, Carlsbad Watershed Network
Mo Lahsaie City of Oceanside
Sheryl Landrom RCD of Greater San Diego
Greg Lang Pasco Laret Suiter
Elaine Lukey City of Carlsbad
Cynthia Mallett City of Oceanside
Mayela Manasjan City of Encinitas
Greg McBain The Escondido Creek Conservancy, Consultation Panel Member
Sheri McPherson County of San Diego
Michael McSweeny BIA
Tim Murphy City of Carlsbad
Crystal Najera City of Encinitas
Scott Norris County of San Diego
Jon Nottage City of Vista
Diane Nygaard Preserve Calavera
MattO'Malley San Diego Coastkeeper
Jessica Parks Santa Fe Irrigation District
Rick Pickett Resident of Escondido
Kevin Porter County of San Diego - AWM
Travis Pritchard San Diego Coastkeeper
VI
Samantha Richter Agua Hedionda Lagoon Foundation
Brad Roth Carlsbad Watershed Network, Consultation Panel Alternate Member
Deborah Ruddock California Coastal Conservancy, Carlsbad Watershed Network
Samantha Russo 1 Love A Clean San Diego
Fred Sandquist Batiquitos Lagoon Foundation
Hal Schillinger Kristar
Cor Shaffer Santa Fe Irrigation District
Norelee Sherwood RCD of Greater San Diego
Kimberly Silva City of Escondido
Nancy Stalnaker County of San Diego
Erik Steenblock City of Encinitas
Reed Thornberry City of San Marcos
Ann Van Lee The Escondido Creek Conservancy
David Varner San Elijo Lagoon Conservancy
Tory Walker Tory R. Walker Engineering, Inc., Consultation Panel Alternate Member
Laurie Walsh SDRWQCB, Consultation Panel Member
Jo Ann Weber County of San Diego
Stan Williams Poseidon Water
James Wood City of Carlsbad
VII 11^
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VIII
Executive Summary
In May 2013, the San Diego Regional Water Quality Control Board (RWQCB) adopted Order R9-2013-
0001 - National Pollutant Discharge Elimination System Permit and Waste Discharge Requirements for
Discharges from the Municipal Separate Storm Sewer Systems (MS4) Draining the Watersheds within
the San Diego Region. The Permit requires the owners of storm drain systems, municipal agencies or
Responsible Agencies, to implement management programs to limit discharges of non-storm water
runoff and pollutants from the storm drain systems. The Permit requires Responsible Agencies in each of
the region's watersheds to develop Water Quality Improvement Plans (WQIP)s. The Carlsbad Watershed
Management Area (WMA) Water Quality Improvement Plan was developed in response to the
requirements ofthe 2013 Permit.
The 2013 Permit is fundamentally based on watershed-based program planning and program outcomes.
The Permit's intent is to enable jurisdictions to focus their resources and efforts to "effectively prohibit
non-storm water discharges to its MS4, reduce pollutants in storm water discharges from its MS4...and
achieve the interim and final numeric goals..." This approach represents a paradigm shift from previous
permits that led jurisdictions to essentially implement the same activities at the same frequencies
throughout their jurisdictions with little or no regard for prioritizing water quality conditions and sources
of pollutants that occurred within geographically-based areas.
The purpose of the Carlsbad WMA WQIP is to guide the Responsible Agencies' Jurisdictional Runoff
Management Programs (JRMP)s toward achieving improved water quality in MS4 discharges and
receiving waters. Through the WQIP, priorities and goals are established and strategies selected for
implementation through the Responsible Agencies' JRMPs to progress toward improvements in water
quality. This approach establishes the WQIP as the overarching plan that each Responsible Agency will
use to develop and implement their jurisdictional programs. Responsible Parties' JRMPs contain the
strategies, standards and protocols by which each Responsible Agency will implement their individual
program in response to the priorities and goals established in the WQIP.
The Responsible Agencies within the Carlsbad Watershed Management Area include the following
agencies:
• City of Carlsbad • City of Encinitas
• City of Escondido • City of Oceanside
• City of San Marcos • City of Solana Beach
• City of Vista • County of San Diego
Figure ES-1 below shows the six major watersheds that make up the Carlsbad WMA. Each watershed or
hydrologic area (HA) has specific characteristics that distinguish it from the others including draining to
separate receiving water bodies.
The Carlsbad WQIP development was initiated during the summer of 2013. The plan will be
implemented through the effective period of the 2013 Permit - anticipated to be mid-2018. The RWQCB
has indicated that the next permit to be adopted in 2018 will be substantially the same as the current
permit. The intention of the RWQCB is to allow the long-term process of the WQIP implementation to
mature rather than redirecting the Responsible Agencies' programs after only several years of
implementation - another significant change from previous permitting processes.
ES-i
Figure ES-1: Carlsbad Watershed Management Area
The Carlsbad WMA WQIP includes several major components:
Priority Water Quality Conditions: after assessing available data sets, the water quality conditions in the
watershed were prioritized and several were identified as those that Responsible Agencies would focus
their program efforts - these are identified as highest and priority water quality conditions. This does
not mean that other water quality conditions or pollutants are to be ignored. To the contrary, many
water quality conditions are related to one another in terms of the strategies selected to address them.
Selected strategies to address priority water quality conditions are also effective at addressing many
other pollutants and water quality conditions.
Table ES-1 summarizes the Highest Priority Water Quality Conditions identified across the entire WMA.
Analyzing data and information on a geographical basis allows the Agencies to prioritize water quality
issues based on what is occurring geographically - leading to focused goals and strategies to address
issues related to the geographic areas.
Table ES-1: Carlsbad WMA Highest Priority Water Quality Conditions
Waterbody Condition Hydrologic Area
Loma Alta Slough Eutrophic Loma Alta Hydrologic Area
Buena Vista Lagoon Indicator Bacteria Buena Vista Creek Hydrologic Area
Agua Hedionda Creek Indicator Bacteria Agua Hedionda Hydrologic Area
Pacific Ocean at Moonlight
Beach Indicator Bacteria San Marcos Hydrologic Area (Cottonwood
Creek Sub-Drainage Area)
Escondido Creek Indicator Bacteria Escondido Creek Hydrologic Area
San Elijo Lagoon Indicator Bacteria Escondido Creek Hydrologic Area
ES-ii
Numeric Goals and Schedules: the WQIP establishes goals related to the highest priority water quality
conditions. Furthermore, schedules for achieving these goals are included in the WQIP. Together, the
goals and schedules establish the targets that the Responsible Agencies use for both establishing their
programs as well as measuring progress and achievement. Each highest priority water quality condition
has established interim and final goals and schedules.
Table ES-2 below is an example of a set of goals related to reduction of dry weather discharges from
specified storm drain systems. Interim goals are intended to mark temporal milestones to evaluate the
progress that Responsible Agencies are making towards final goals. If goals are not met or conversely
exceeded, that information can be used by the Agencies to adapt their programs to become as efficient
and effective as resources allow.
Table ES-2: Example Interim and Final Goals for Dry Weather Discharges from Specific Storm Drain Outfalls
Interim Goal Interim Goal Interim Goal Interim Goal Final Goal
(2013-2018) (2018-2023) (2023-2028) (2028-2033) (2033-2038)
2018 2023 2028 2033 2038
10% reduction in 20% reduction in 40% reduction in 60% reduction in 80% reduction in
anthropogenic surface anthropogenic surface anthropogenic surface anthropogenic surface anthropogenic surface
water runoff water runoff water runoff water runoff water runoff
Strategies and Schedules: the WQIP identifies the
strategies, or activities/best management practices
(BMPs), that the Responsible Agencies will
implement to address the priority water quality
conditions to progress towards achieving the
numeric goals within the schedules identified. In
addition to identifying the strategies, the WQIP
identifies schedules for development (in some cases)
and implementation of the strategies.
Strategies include a wide
including, but not limited to:
range of activities.
inspections at regulated facilities or sites;
street sweeping and cleaning of storm
drains;
constructing structural and low impact
development BMPs;
requiring regulated entities (e.g., businesses,
construction sites, residents) to implement
BMPs;
educating the general public on water quality
issues;
partnering with organizations to complete
programs/projects; and
enforcement actions against violators of
Responsible Agencies' municipal codes.
Figure ES-2: Low Impact Design BMP
Figure ES-3: Construction Site BMPs Implemented
ES-iii
Monitoring and Assessment: the WQIP includes a
monitoring and assessment program that is intended
to measure the progress towards meeting the numeric
goals established as well as improvements in
Responsible Agencies' discharges and the receiving
water bodies. Detailed Monitoring Plans for the
Carlsbad WMA are separate documents and are
available at the Project Clean Water Website -
www.projectcleanwater.org.
Iterative Approach and Adaptive Management: the
WQIP is intended to be a living planning document
that, through established long-term cycles, is assessed
and updated to reflect collected data and input. The
Responsible Agencies will use information learned from plan implementation and water quality
monitoring to improve management decisions related to water quality conditions, numeric goals,
strategies and associated schedules. The typical cycle for the implementation, assessment and the next
planning phase is illustrated in the figure below.
Figure ES-4: Dry Weather Monitoring
Five Year Cycle
Figure ES-5: Iterative Process to Inform Adaptive Management Process
WQIP Development Process
The WQIP was developed over a two-year period after the Permit was adopted in May 2013. The
development process set phased benchmarks for the development and submittal of the components of
the WQIP. Phase 1 focused on the priority water quality conditions and identification of highest and
focused priority water quality conditions. Phase 2 focused on the identification of water quality numeric
goals and schedules for achieving the goals as well as selection of water quality improvement strategies
to address the sources of pollutants contributing to the highest and focused priority water quality
conditions. Phase 3 of the process included the development of the monitoring and assessment
program that are integral to the WQIP iterative process.
ES-iv
During the two-year development process, public participation was a critical element. The WQIP process
relied heavily on an active public that led to a greater amount of public participation than in previous
MS4 Permit related water quality planning processes. The public participation process included four
primary components:
1) Public Input in Response to Calls for Data
2) Public Workshops
3) Water Quality Improvement Consultation Panel
4) RWQCB Public Comment Periods
During the plan development process,
the Responsible Agencies held two
public workshops to inform the public of
the WQIP process and solicit input for
water quality conditions; sources
contributing to water quality conditions;
strategies to address the sources;
numeric goals and associated schedules.
As a result ofthe solicitations, the public
provided a variety of data and
information for consideration in the
planning process.
The Responsible Agencies selected a
Consultation Panel from interested
candidates. The goal of the Consultation
Panel was to provide recommendations
to the Responsible Parties during the
development ofthe Water Quality Improvement Plan. The Consultation Panel members are:
Table ES-3: Carlsbad WMA Water Quality Improvement Consultation Panel
Figure ES-6: Water Quality Improvement Consultation
Panel Briefing - January 22, 2014
Name Representing Status
Ms. Laurie Walsh RWQCB Primary
Mr. Eric Becker RWQCB Alternate
Mr. Gregory McBain Environmental Community Primary
Mr. Brad Roth (replaced Mr. Doug Gibson) Environmental Community Alternate
Mr. Steve Gruber Development Community Primary
Mr. Tory Walker Development Community Alternate
As Responsible Agencies delivered the two phased submittals to the RWQCB, 30-day public comment
periods were initiated and facilitated by RWQCB staff. Each of the public comment periods yielded
comments for consideration in the WQIP.
WQIP Implementation
The Responsible Agencies will implement the strategies, monitoring and assessment programs as
described in the Carlsbad WQIP. Strategy implementation details are described in the eight Responsible
Agencies' jurisdictional programs. The monitoring program details are described in the program specific
monitoring plans. All of the related documents are available on the Project Clean Water website -
www.projectcleanwater.org.
ES-v
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0^ ES-vi
1 Introduction
1.1 Background and Watershed Description
The San Diego Regional Water Quality Control Board (RWQCB) adopted Order R9-2013-0001, a National
Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer Systems Permit (MS4
Permit or Permit) on May 8, 2013^ (RWQCB, 2013). Provision B of the Permit requires Responsible
Agencies, in each of the region's Watershed Management Areas (WMA)s to develop Water Quality
Improvement Plans (WQIP)s. Through the WQIP approach, highest priority water quality conditions
within the WMA are identified and strategies are implemented through the Responsible Agencies'
Jurisdictional Runoff Management Programs (JRMP)s to progress toward improvements in water quality.
The plans contain an adaptive planning and management process and a public participation component.
The Responsible Agencies within the Carlsbad WMA include the following municipalities:
• City of Carlsbad
• City of Encinitas
• City of Escondido
• City of Oceanside
• City of San Marcos
• City of Solana Beach
• City of Vista
• County of San Diego
7^
MilOT Roadways | | Carlsbad WMA
Rivers and Creeks Hydrologic Areas
IB Waterbodies Upper San Marcos Creek
I Municipal Boundaries | Watershed Management Areas
Figure 1: Carlsbad Watershed Management Area
The Carlsbad WMA is approximately 211 square miles and is formed by a group of six individual
watersheds in northern San Diego County - see Figure 1 above. The WMA is bordered by the San Luis
Rey River WMA to the north and by the San Dieguito River WMA to the south. It reaches inland nearly
^ See httD://www.swrcb.ca.gov/rwacb9/water issues/programs/stormwater/
Introduction
1
24 miles to just northeast of Lake Wohlford. The maximum elevation of the WMA is approximately 2,400
feet and it extends to sea level at the Pacific Ocean.
The Carlsbad WMA is made up of six distinct Hydrologic Areas (HA)s: Loma Alta, Buena Vista Creek, Agua
Hedionda, Encinas, San Marcos Creek, and Escondido Creek. Due to the impoundment of waters at Lake
San Marcos, the San Marcos HA is split into two separate drainage areas: the drainage area above Lake
San Marcos (aka Upper San Marcos Creek); and the drainage area below Lake San Marcos (aka Lower
San Marcos Creek).
The WMA includes the entire Cities of Carlsbad, San Marcos and Encinitas and portions of the cities of
Oceanside, Vista, Escondido, Solana Beach, and San Diego County unincorporated areas. The
jurisdictional breakdown (by land area) for each of the six Hydrologic Areas (watersheds) is shown in
Table 1.
Table 1: Jurisdictional Breakdown of Carlsbad WMA
Jurisdictional Breakdown
Watershed (HA No.) Receiving Waterbody(ies) Size
(sq.mi.) Percentage of WMA (%] Carlsbad (%) Encinitas (%) Escondido {%) Oceanside (%) San Diego County (%) San Marcos (%) Solana Beach (%) Vista (%) Carlsbad WMA (904) 211.5 100 18 9 13 8 32 11 1 8
Loma Alta (904.10) Loma Alta Slough and
Pacific Ocean 9.8 4.5 97 3
Buena Vista Creek (904.20) Buena Vista Lagoon and
Pacific Ocean 22.6 11 19 25 11 45
Aqua Hedionda (904.30) Aqua Hedionda and
Pacific Ocean Lagoon 29.4 14 41 6 24 5 24
Encinas (904.40) Pacific Ocean 5.4 2.5 100
San Marcos (904.50) Batiquitos Lagoon and
Pacific Ocean 59.7 28 29 15 5 18 33
Escondido Creek (904.60) San Elijo Lagoon and
Pacific Ocean 84.6 40 11 29 55 4 1
1.2 Purpose
The purpose of the Carlsbad WQIP is to guide the Responsible Agencies' JRMPs toward achieving
improved water quality in Municipal Separate Storm Sewer System (MS4) discharges (or storm water
discharges) and receiving water bodies. Responsible Agencies' JRMPs contain the strategies, standards
and protocols by which each Responsible Agency will implement their individual program in response to
the priorities and goals established in the WQIP.
An important note for consideration regarding the Carlsbad WQIP is the context within which the MS4
permit and the WQIP operate. The permit regulates discharges from the Copermittees' MS4 systems
prior to discharge into receiving water bodies, therefore, some conditions may be outside of the
Copermittees' purview.
The Permit's intent is to enable jurisdictions to focus their resources and efforts to "effectively prohibit
non-storm water discharges to its MS4, reduce pollutants in storm water discharges from its MS4 to the
Introduction
2
Maximum Extent Practicable (MEP), and achieve the interim and final numeric goals..." (RWQCB, 2013).
Furthermore, the Permit also states that "Where appropriate. Watershed Management Areas may be
separated into subwatersheds to focus water quality prioritization and juriscJictional runoff management
program implementation efforts by receiving water" (RWQCB, 2013). This approach represents a
paradigm shift from previous permits that led jurisdictions to essentially implement the same activities
throughout their jurisdictions with little or no regard for prioritizing water quality conditions, sources
and pollutant generating activities that occurred within geographically-based areas.
Although topographic features define watershed areas, characteristics of the watershed areas have
direct influence on non-storm water discharges and pollutants in storm water discharges, and ultimately
the water quality conditions in receiving waters. When selecting strategies to positively effect changes in
water quality, the following geographic characteristics should be considered:
• Population Demographics • Pollutant Generating Activities
• Infrastructure • Soil Conditions
• Land Uses • Receiving Water Types and Features
• Source Types
Included in the Permit is a greater emphasis on adaptive management, whereby information from
program implementation and monitoring is to be used to adapt the WQIP to become more effective in
achieving water quality improvements. This employs a five-year cycle of adaptive management which
includes planning, implementation and assessment phases that rely upon one another for information
to improve the plan's efficiency and overall effectiveness. This cycle is illustrated in Figure 2 below.
Planning
Water Quality Conditions
Sources
Strategies
Special Studies
Five Year Cycle
Figure 2: FIve-Year process for Planning, Implementation and Assessment of WQIP
Introduction
3
During each planning process iteration, information from assessments and special studies will be used to
inform the program planning process. As Responsible Agencies learn more about sources and strategies,
and utilize water quality monitoring data and analyses, informed plan modifications may be made to the
WQIP to:
1) Reprioritize water quality conditions;
2) Modify numeric goals and/or schedules;
3) Improve and/or expand the selection of water quality improvement strategies; and
4) Make general improvements to the plan.
The WQIP is intended to be a living planning document that, through established long-term cycles, is
updated and revised^ to reflect collected data and input. As each assessment process in a cycle
concludes, the WQIPs will be re-evaluated and will influence the next planning process - see Figure 3.
The potential WQIP modifications identified above will be evaluated on at least a five-year cycle. These
cycles will allow for the critical step of monitoring potential sources, pollutant generating activities and
the effectiveness of implemented strategies. The cycle is consistent with the MS4 Permit reissuance
process and provides the appropriate duration for improvements to be observed, measured and
assessed.
Figure 3: Long-Term WQIP Process
1.3 WQIP Development and Updates
The WQIP was developed over a two-year period after the Permit was adopted in May 2013. The
development process set phased benchmarks for the development and submittal of the components of
the WQIP. Phase 1 focused on the Priority Water Quality Conditions (PWQC)s and identification of
Highest Priority Water Quality Conditions (HPWQC)s. Phase 2 focused on the identification of water
quality numeric goals and schedules for achieving the goals as well as selection of water quality
Per Provision F.2.c.(l)(c) - Responsible Agencies must submit updates to the WQIP either in the WQIP Annual
Reports, or as part of the Report of Waste Discharge.
Introduction
4
improvement strategies to address the sources of pollutants contributing to the HPQWCs and in some
cases the PWQCs. The results of Phase 1 and Phase 2 are summarized in Sections 2.1, 2.2, and 2.3. The
associated submittals are included as Appendices B and C.
Phase 3 of the process included the development of the Monitoring and Assessment programs that are
integral to the WQIP iterative process. The iterative process, including the monitoring and assessment
programs, is included in Sections, 2.4, 2.5 and 2.6.
The steps taken in developing the Carlsbad WMA Water Quality Improvement Plan included identifying:
1) Prioritized water quality
conditions where
sufficient data is available
for each Hydrologic Area
within the Carlsbad
WMA. From this list of
prioritized water quality
conditions, highest
priority water quality
condition(s) for each
Hydrologic Area were
identified.
Sources that are most
likely to contribute
(having the greatest
threat to water quality) to
the highest priority water
quality condition(s) for
each identified condition.
A list of potential water quality improvement strategies that Responsible Agencies can select for
implementation, either jurisdictionally or in cooperation with other responsible agencies or
entities, with the goal of improving water quality.
Areas of focus where numeric goals will be established and strategies implemented to improve
water quality.
Numeric goals and schedules for improvements to water quality and water quality conditions.
Water quality improvement strategies and schedules for implementation. The identified
strategies represent the activities the Responsible Agencies will implement in order to make
water quality improvements that will have positive impacts on the identified highest and priority
water quality conditions.
2)
Water Quality Improvement Consultation Panel Briefing - January 22, 2014
3)
4)
5)
6)
1.3.1 Public Participation Process
During the two-year development process, public participation was a critical element. The WQIP process
relied heavily on an active public that led to a greater amount of public participation than in previous
MS4 Permit-related water quality planning processes. The public participation process included four
primary components:
1) Public input in response to calls for data
2) Public workshops
3) Water Quality Improvement Consultation Panel
4) RWQCB public comment period
Introduction
5
During the plan development process, the Responsible Agencies held two public workshops (November
2013 and July 2014) to inform the public of the WQIP process and solicit input for water quality
conditions; sources contributing to water quality conditions; strategies to address the sources; numeric
goals and associated schedules. As a result of the solicitations, the public provided a variety of data and
information for consideration in the planning process.
The Responsible Agencies
selected a Water Quality
Improvement Consultation Panel
(WQICP) from interested
candidates. The WQICP consists
of a primary and alternate from
the: RWQCB staff; development
interests; and environmental
community - see Table 2 below.
The intent of the WQICP is to
provide a "sounding board" for
the developed plan elements.
Serving on the WQICP is a
demanding undertaking, requiring
familiarity with the MS4 permit,
water quality issues and a
familiarity with the vast and
diverse Carlsbad WMA. The
Carlsbad WQICP has been Water Quality Improvement Consultation Panel Briefing - October 28, 2014
dedicated throughout the process and has provided excellent input during meetings as well as in written
comment form.
Table 2: Carlsbad WMA Water Quality Improvement Consultation Panel
Name Representing Status
Ms. Laurie Walsh RWQCB Primary
Mr. Eric Becker RWQCB Alternate
Mr. Gregory McBain Environmental Community Primary
Mr. Brad Roth (replaced Mr. Doug Gibson) Environmental Community Alternate
Mr. Steve Gruber Development Community Primary
Mr. Tory Walker Development Community Alternate
As Responsible Agencies delivered the two phased submittals to the RWQCB, 30-day public comment
periods were initiated and facilitated by RWQCB staff. Each of the public comment periods yielded
comments for consideration in final WQIP.
1.3.2 Regional Clearinghouse
Responsible Agencies will use existing data-sharing templates to facilitate compilation of watershed-
wide datasets for assessment and reporting purposes. Regional data-sharing templates exist for
receiving water monitoring, MS4 outfall monitoring, field screening, and IDDE reporting. Responsible
Agencies will make the following data and documentation available to the public on the Project Clean
Water website:
• Carlsbad Watershed Water Quality Improvement Plan and all updated versions with date of
update
• Annual Reports for the watershed
Introduction
6
• Jurisdictional Runoff Management Programs document for each Responsible Agency within the
watershed and all updated versions with date of update
• BMP Design Manual for each Responsible Agency within the watershed and all updated versions
with date of update
• Reports from special studies conducted in the watershed
• Monitoring data uploaded to the California Environmental Data Exchange Network (CEDEN) with
links to the uploaded data
• Geographic information system (GIS) data, layers, and/or shape files that are available for
distribution and used to develop the maps to support the Water Quality Improvement Plan,
Annual Reports, and Jurisdictional Runoff Management Programs
1.3.3 Plan Updates
The Responsible Agencies will prepare annual reports and as necessary, updates to the WQIP. Updates
to the WQIP will follow a similar public participation process as the WQIP development and include a
solicitation for data and information, and consultation with the WQICP. Updates can be provided in the
WQIP annual reports or the Report of Waste Discharge (ROWD) which is required no later than
December 2017.
Plan updates would include significant changes based upon the iterative process to:
• Priority Water Quality Conditions
• Highest Priority Water Quality Conditions
• Numeric Goals and Schedules
• Strategies and Schedules
• Monitoring Program
• Assessment Program
Minor modifications to the WQIP or implementing JRMPs will be presented in JRMP and WQIP annual
reports. These types of changes may include modifications to activity frequencies, inspected inventories,
and areas of focus. Minor modifications may arise after short time periods based on the implementation
feedback process and require quick management decisions that will support the goals and schedules
selected.
Introduction
7
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Introduction
8
2 Water Quality Improvement Plan Components
2.1 Priority Water Quality Conditions
PWQCs are conditions within the WMA's receiving waters that, based on the best available data and
information, warrant focused attention through the selection and implementation of water quality
improvement strategies. Furthermore, "Where appropriate. Watershed Management Areas may be
separated into sub-watersheds to focus water quality prioritization and Jurisdictional runoff
management program implementation efforts by receiving water" (RWQCB, 2013).
For the development of the initial WQIP, the planning process included both assessment and planning
elements. Although previous watershed-based plans were developed and implemented, i.e.. Watershed
Urban Runoff Management Plans (WURMP)s and some limited number of Watershed Management
Plans (WMPs), this foundational WQIP required an assessment of a more comprehensive set of data and
information, i.e., public input and data. This planning/assessment element is illustrated in Figure 4
below.
Initial WQIP Development:
^ Assessment and Planning ^
Assess Receiving Waters Assess MS4 Outfalls
2011 Long-Term Effectiveness Assessment Dry Weather Monitoring
Annual Regional Monitoring Report Wet Weather Monitoring
(Copermittee, 3rd Party, SWAMP) Public Input
Public Input
Identify Numeric Goals and Schedules I Select Strategies and Schedules
Identify Special Studies
Figure 4: Initial WQIP Development Process - Planning Consisting of Assessment
The Responsible Agencies undertook a process to collect and evaluate best available data in identifying
Priority Water Quality Conditions (PWQC)s and Highest Priority Water Quality Conditions (HPWQC)s. The
collected data and information is summarized in Table 3 and Table 4 below. Developing and applying a
Priority Water Quality Conditions
9
prioritization process led to identifying the PWQCs and the HPWQCs for each HA in the Carlsbad WMA.
The resulting PWQCs and HPWQCs are presented in Table 5 and Table 6 below. The PWQC and HPWQC
process is documented as the Provision B.2. Submittal to the San Diego RWQCB on June 11, 2014 - see
Appendix B.
O Priority Water Quality Conditions
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2.2 Goals
identifying goals and the means to achieve them is fundamental to improving water quality in the
Carlsbad WMA. Goals define realistic water quality improvement outcomes and provide direction and
purpose to program planning. Numeric goals are quantifiable and assist in measuring progress towards
the identified goals. WQIPs include two types of goals, interim and final numeric goals.
Interim goals are intended to establish check points along the path towards achieving final numeric
goals. Based on the program efforts of the Responsible Agencies and the water quality conditions
prioritized for improvement, expected goals can be selected as benchmarks for program performance.
Interim goals for each five-year period from WQIP approval to the anticipated final goal achievement
date (including an interim goal for the current permit term) have been developed. The forthcoming
Monitoring and Assessment Program will describe the mechanisms for utilizing the interim goals to
measure progress and adapt program strategies, goals and schedules.
Final numeric goals selected by the Responsible Agencies provide an end-point that marks achievement
of desired water quality improvements. As final goals are achieved. Responsible Agencies are
anticipated to adapt their programs to maintain the status of the conditions they have achieved through
reaching the final numeric goals.
In developing initial goal schedules, the Responsible Agencies considered the following:
• Priority conditions within their jurisdictional portions of the WMA
• Potential sources of pollutants and/or stressors contributing to priority conditions
• Known effectiveness and efficiencies of strategies
• Resources required to implement strategies
• Balancing resources for competing priority areas throughout each Responsible Agencies
jurisdictional boundary - within a HA,across multiple HAs or WMAs
Responsible Agencies developed goals both collaboratively
and individually to best address the sources and stressors
within the watershed and individual jurisdictions. An
individualized approach provides flexibility in selecting
interim goals based on jurisdiction-specific strategies and
schedules, and provides the framework for a more
accurate assessment of progress towards achieving goals
within each jurisdiction.
There are unknowns related to establishing goals and
associated schedules, including: baseline MS4 discharge
conditions; site specific source pollutant contributions; and
strategy effectiveness. Based on these uncertainties, the
initial established goals and schedules are expected to be
dynamic. As the Responsible Agencies establish baseline
conditions, implement strategies and analyze assessment
data, it is expected that the goals and schedules will
change through an iterative and adaptive management process.
Identified goals are included in each of the Hydrologic Area sections in Section 3 of this WQIP. Some
goals were developed for an individual focus area or groups of focus areas, and some were developed
for waterbodies.
Numeric Goal Example
One of the primary goals identified through the
process is the reduction of anthropogenic dry
weather surface flows from MS4 outfalls. This
goal is prevalent in many of the focus areas of the
WMA. This goal has many overall benefits to
water quality improvements, including, but not
limited to the following:
• Demonstration that programs are
effective at eliminating dry weather
discharges which are generally
prohibited
• Eliminating flow eliminates the
transport mechanism for pollutants to
reach receiving waters
• Eliminating flow eliminates water
necessary for bacteria growth and
regrowth within the MS4 system
Goals
16
2.3 Strategies
Each jurisdiction has developed a suite of strategies as a means to achieving the identified goals. The
term strategies in the WQIP includes:
• Planning Efforts
• Structural Best Management Practices
• Program Best Management Practices and/or Program Core Strategies^
• Requiring Best Management Practices of Regulated Entities
• Incentives
Implemented strategies are intended to achieve the following objectives:
1) Effectively prohibit non-storm water discharges to the MS4;
2) Reduce pollutants in storm water discharges from the MS4 to the MEP;
3) Protect the beneficial uses of receiving waters from MS4 discharges; and/or
4) Achieve the interim and final numeric goals identified by the RAs.
As part of the June 2014 B.2 Report, a list of potential strategies (nonstructural and structural) was
developed by the Responsible Agencies based on public input, previous JRMP and WURMP activities and
effectiveness assessment results, enhancements to JRMP activities, and additional strategies anticipated
to be effective at addressing PWQC. This list was used as a guide by Responsible Agencies to identify
strategies appropriate for their jurisdictions. From the potential strategies identified in the June 2014
B.2 Report the Responsible Agencies selected strategies to implement through their JRMPs. The
combination of strategies has been selected to achieve one or more of the objectives listed above.
Identified strategies for implementation are presented in the Hydrologic Area sections in Section 3 of
this WQIP.
2.3.1 Geographic Characteristics
Although topographic features define watershed areas, characteristics of the watershed areas have
direct influence on non-storm water discharges and pollutants in storm water discharges, and ultimately
the water quality conditions in receiving waters. The Carlsbad WMA Responsible Agencies considered
the following characteristics when selecting and designing strategies to improve water quality:
• Population Demographics
• Infrastructure
• Land Uses
• Potential Pollutant Sources - types and characteristics
• Pollutant Generating Activities
• Soil Conditions
• Receiving Water Types and Features
In the Carlsbad WMA there are six distinct HAs each with their own unique features and characteristics,
which lead the Responsible Agencies to identify PWQCs and associated strategies specific to the HA -
see Figure 1.
^ Program core strategies are base strategies implemented by the Responsible Agencies. These strategies generally
prescribed in the MS4 Discharge Permits. The strategies include but are not limited to: Administrative BMPs;
inspections; enforcement; education; street sweeping; IVIS4 inspections/cleaning; and monitoring.
Strategies
17
^0
2.3.2 Geographic Prioritization
The 2013 Permit states that "Where appropriate, Watershed Management Areas may be separated into
subwatersheds to focus water quality prioritization and jurisdictional runoff management program
implementation efforts by receiving water" (RWQCB, 2013). This represents a paradigm shift from
previous permits where Responsible Agencies implemented the same activities throughout their
jurisdictions. The 2013 Permit allows jurisdictions to prioritize and focus program efforts based on
geographic area characteristics leading to more effective and efficient implementation of strategies to
address priority conditions.
Responsible Agencies may consider the following information when using the geographic prioritization
approach. This list is not exclusive and includes examples of relevant information used in the
prioritization processes.
• Balancing resources for competing priority areas throughout each RAs jurisdictional boundary -
within a hydrologic area or across multiple hydrologic areas or watershed management areas.
• Historical issues with specific sources, manifested in terms of discharges, enforcement or poor
BMP implementation may be an indicator of pollutant discharge sources that can be eliminated.
• Persistently flowing outfalls within specific areas may be caused by unauthorized non-storm
water discharges.
• Historical monitoring data may show areas of concern where pollutant concentrations may be
above action levels and can indicate source contributors that need abatement.
• Older areas may have infrastructure that allows more outdoor/exposed impacts than newer
development areas where more activities are conducted indoors.
• Areas with existing Treatment Control BMPs may be less of a focus because it is implied that
there is adequate treatment for dry weather runoff and smaller wet weather events.
• Housing developments with relatively large amounts of turf or vegetated areas (common areas,
yards, vegetated slopes, etc.) may have higher rates of irrigation runoff than other areas.
• Multi-Family Residential areas have a relatively high intensity of use, for example, there are
more vehicles, parking areas and more litter. These areas usually have shared trash areas and
common landscaped areas. The higher concentration of people can create a higher
concentration of trash and pollutants with the potential to enter the MS4.
• Industrial and Commercial Facilities have a variety of businesses and wastes creating different
types of possible discharges. Some facilities may have areas outside where chemicals or wastes
are stored, creating the potential for pollutants to be washed away into the MS4 during rain
events.
• Municipal Properties may include open areas, parks or street medians. These areas may require
irrigation, creating the potential for irrigation runoff.
• Ability to effectively measure progress towards established goals, e.g., safe and accessible
monitoring locations.
• Amount and distribution of natural open space within each Hydrologic Area.
Responsible Agencies considered a combination of criteria during the final strategy selection process.
The following is an example listing of some criteria the Responsible Agencies considered:
• Preference to strategies that target HPWQCs, and those that provide multiple benefits, e.g.,
benefitting PWQCs and other pollutants
• Geographic focus areas, e.g., land-use, physical characteristics, demographics
• Anticipated effectiveness at addressing sources that may be impacting HPWQCs and PWQCs
• Anticipated social impacts, e.g., strategies that require perceived inconveniences to the general
public may not be effective due to lacking participation
Strategies
18
• Balancing resources for competing priority areas throughout each Responsible Agencies
jurisdictional boundary - within a hydrologic area or across multiple hydrologic areas or
watershed management areas
The Responsible Agencies evaluated their existing programs, the potential for incorporating
enhancements and new administrative programs, and the types of structural BMPs that may be
considered, if warranted and appropriate for the jurisdiction. All aspects of their JRMPs were evaluated,
which provided the necessary baseline for existing nonstructural solutions and suggested areas where
enhanced or restructured activities might be more successful.
Funding for identified strategies may affect the timeline for the development and initiation of the plan.
The proposed schedules reflect the anticipated time needed and a staggered approach for strategy
implementation in order to accommodate uncertainties. At this stage of the WQIP process, the
strategies list may not reflect all strategies that are currently being implemented by Responsible
Agencies or other entities. However, the list does capture most strategies that jurisdictions are currently
focusing efforts and resources.
It is important to note that the suite of strategies (i.e., program core strategies and other water quality
improvement strategies) that will be implemented are generally not pollutant-specific. Therefore, the
collective strategies are expected to have positive impacts on multiple PWQCs identified in addition to
HPWQCs.
Similar to the goals, in the early stages of the WQIP process, the selected strategies and schedules are
expected to be dynamic. As the Responsible Agencies implement the strategies and assess data, it is
expected that strategies and schedules will change through an iterative and adaptive management
process. These changes would be presented in future WQIP reports and updates.
2.3.3 Optional Strategies
The Responsible Agencies have designated some of the selected strategies as optional. These strategies
are considered optional for various reasons including:
• Current funding or resources may not be available for implementation
• Viewed as subsequent in strategy implementation progression - may be implemented if other
strategies are determined to be ineffective or inefficient
• Confirmed approval by governing bodies for implementation is pending
2.3.4 Watershed Management Area Analysis
The Carlsbad WMA Responsible Agencies have participated in the development of a Watershed
Management Area Analysis (WMAA) - see Appendix D. The purpose of the WMAA is to:
1) Characterize the WMA through identification of physical characteristics and compilation of the
data into Geographical Information System (GIS) mapping;
2) Use the WMA characterization as a resource for identification of potential candidate projects for
Offsite Alternative Compliance (OAC) options for fulfilling applicable Land Development
requirements ofthe MS4 permit;
3) Use the WMA characterization as a resource for identifying areas within the WMA where
exemptions from hydromodification management requirements would be appropriate.
Characterization
The attached Carlsbad WMAA provides GIS mapping that characterize the WMAs by providing the
following:
Strategies
19
1) Description of dominant hydrologic processes, such as areas where infiltration or overland flow
likely dominates;
2) Description of existing streams in the watershed, including bed material and composition, and if
they are perennial or ephemeral;
3) Current and anticipated future land uses;
4) Potential coarse sediment yield areas; and
5) Locations of existing flood control structures and channel structures, such as stream armoring,
constrictions, grade control structures, and hydromodification or flood management basins.
Offsite Alternative Compliance
Completion of a WMAA is a required step prior to allowing OAC as an option for
development/redevelopment projects. Although the WMAA has been completed. Responsible Agencies
have not yet developed OAC programs. It is anticipated that those Responsible Agencies that elect to
have OAC programs will develop and implement those programs in the coming years.
The Responsible Agencies are also required to develop a list of candidate projects that could potentially
be used as alternative compliance options in lieu of land development onsite structural BMP
performance requirements. The current candidates list is provided as Appendix E. Since the Responsible
Agencies are not intending to implement OAC programs until 2016 at the earliest, the candidates list is
currently not comprehensive and is anticipated to be amended in coming years.
Exemptions from Hydromodification Management Requirements
The WMAA includes a description of the recommended exemptions from hydromodification
management requirements as summarized below. Future proposed Hydromodification Management
Plan exemptions would need to be approved through the WQIP Annual Update process.
1) Exempt River Reaches
There are no river reaches currently recommended for exemption from hydromodification
management requirements in the Carlsbad WMA. However, Escondido Creek is currently being
evaluated to assess whether a hydromodification management exemption could apply to this
waterbody. Based on the findings ofthe evaluation, the San Elijo Lagoon may also be evaluated. The
results of these studies will be included in future Carlsbad WMAA updates.
2) Stabilized Conveyance Systems Draining to Exempt Water Bodies
There are no stabilized conveyance systems currently recommended for exemption from
hydromodification management requirements in the Carlsbad WMA.
3) Highly Impervious/Highly Urbanized Watersheds and Urban Infill
No areas within the Carlsbad WMA are currently recommended for highly impervious/highly
urbanized watershed or urban infill exemption.
4) Tidally Influenced Lagoons
Based on a City of Carlsbad study^ there are several tidally influenced areas recommended for
exemption including:
a. Areas tributary to Buena Vista Lagoon
b. Several tributary areas to Agua Hedionda Lagoon
c. One tributary area to Batiquitos Lagoon
The San Elijo Lagoon and other tidally influenced waterbodies may also be evaluated for exemption
in future analyses
" Hydromodification Exemption Analyses for Select Carlsbad Watersheds, Chang Consultants (June 10, 2013)
Strategies
20
2.4 Iterative and Adaptive Management Process
As a living document, the Carlsbad WMA Water Quality Improvement Plan
(WQIP) will be updated in subsequent years to accommodate evolving
programs and adaptations to individual or collective components of the
WQIP. Plan adaptations are focused on plan improvements and ultimately
achieving compliance with discharge prohibitions and receiving water
limitations identified in the MS4 Permit.
The cycle for updates includes program planning,
implementation of the planned program, monitoring and
assessment of the implemented program and determining
what has been learned during the cycle to feed into the
planning of the next cycle. This process of repeating cycles
and program improvements constitutes the iterative and
adaptive management process.
Effectiveness: the capability of strategies to have
an intended outcome and meet objectives
Efficiency: strategies producing intended
outcome(s) with minimum amount of waste,
expense or unnecessary effort
The iterative process will use data and information collected from implementation ofthe Carlsbad WQIP
and the Responsible Agencies' JRMPs to improve programs - making them more efficient and effective
through adaptations.
LIGHTER/STRONGER
MATERIALS
ENGINE IMPROVED CLEANER
TECHNOLOGY AERODYNAMICS TECHNOLOGY
Figure 5 illustrates the
continual process of
improvement while
maintaining a focus on
water quality
improvements. Similar
to the iterations of the
development of
locomotive technology,
the WQIP iterative
process will use what is
learned in each cycle to
improve the process
and plan. With each
iteration it is expected
that the plan
implementation is
improved and the
strategies implemented
are more effective at
addressing water
quality issues.
MORE EFFECTIVE AND EFFICIENT STRATEGIES
UPDATED SOURCE INFORMATION
UPDATED WATER OUALITY DATA
UPDATED FOCUS AREAS
UPDATED GOALS AND SCHEDULES
Figure 5: Demonstrated Improvements Using Iterative Process
Iterative and Adaptive Management Process
21
As a result of the monitoring and assessment process, modifications may occur for the following plan
components:
• Priority Water Quality Conditions/ Highest Priority Water Quality Conditions
• Water Quality Numeric Goals and Schedules
• Water Quality Improvement Strategies and Schedules
• Monitoring Program
• Assessment Program
Potential adaptations for each ofthe above components are discussed in the sub-sections below.
Proposed modifications to WQIP components will be supported by rationale to justify the changes.
Responsible Agencies will use a process of data and information collection (monitoring) and evaluation
(assessment) to develop the rationale that supports modifications. Monitoring includes a variety of
activities intended to collect and assemble relevant data and information that can be evaluated for
potential influence on the WQIP components. Assessment includes a variety of calculations,
comparisons and determinations that may or may not support WQIP component modifications.
Monitoring and assessment approaches that support the iterative process are further discussed in
Sections 2.5 and 2.6 below.
A functional balance amongst all WQIP components exists - see Figure 6. When changes occur within
one of the components, it necessitates changes in other components. For example, adaptations in
strategies will require modifications to the data collection (monitoring) for the strategies to assure that
the data is collected appropriately.
>, Assessment
Program
Figure 6: Balance of Water Quality Improvement Plan Components
A similar balance is used when considering resources and looking to optimize available resources for
achieving improved water quality conditions. By using monitoring data and information and assessment
outcomes, the Responsible Agencies can make informed decisions regarding how and where to best
utilize their resources. The results of the decisions will determine program changes necessary to
implement the decisions. However, program changes have the potential to take time and resources to
Iterative and Adaptive Management Process
22
implement and pose unintended consequences. These considerations should also be factored when
evaluating program changes.
2.4.1 Re-evaluation of Water Quality Conditions
Periodically, the Responsible Agencies will re-evaluate
water quality conditions to determine the Priority Water
Quality Conditions based on available data and
information. Receiving water quality conditions do not
change substantially from year to year. However, in each
assessment of available water quality data and
information, the Responsible Agencies will evaluate
Examples of Prompts for Adaptation of Water
Quality Conditions (PWQCs and HPWQCs)
• Beneficial Use(s) in receiving waters are met
• Water quality monitoring data shows MS4 is
not causing or contributing to water quality
conditions in receiving waters
• Regulatory conditions change: new or
developing TMDLs, new policies
whether findings demonstrate a compelling need to re-
evaluate the current Highest Priority Water Quality Conditions (HPWQC)s and Priority Water Quality
Conditions (PWQC)s. In the absence of such findings, the Responsible Agencies maintain that the initial
HPWQCs and PWQCs should remain the focus ofthe WQIP and JRMP implementation.
At a minimum, a re-evaluation of PWQCs and HPWQCs will be performed and reported in the ROWD,
due to the Regional Water Quality Control Board (RWQCB) no later than December 2017.
Re-evaluation of the water quality conditions will consider the best available data and information as
used in the initial water quality evaluation - see Appendix B. In addition to the data and information
collected and evaluated in the initial WQIP development process, the Responsible Agencies will, at a
minimum, consider:
• Whether water quality improvement outcomes were achieved in MS4 discharges and/or
receiving waters
• Data , information and recommendations provided by the public
• Water quality monitoring collected after initial WQIP development including transitional
monitoring data collected in 2013 and 2014
• Special studies results related to water quality conditions or MS4 sources of pollutants and/or
stressors
• New and developing regulations related to water quality conditions, e.g., TMDLs and policies
• Revised 303(d) listings
• Basin plan amendments related to water quality conditions
• RWQCB recommendations
The re-evaluation process will follow a process similar to
that used in the initial water quality evaluation - see
Appendix B. If new or modified processes are used, they
will be presented in the appropriate document, e.g..
Water Quality Improvement Plan Annual Reports or the
ROWD in December 2017.
Examples of Outcomes from Re-Evaluating Water
Quality Conditions
• Adding or removing Priority Water Quality
Conditions
• Adding or removing Highest Priority Water
Quality Conditions
• Changes in Focus Areas within the WMA
Based on the outcomes of the re-evaluation process, the Responsible Agencies will determine whether
adaptations to the Priority Water Quality Conditions are justified. Changes to the PWQCs, HPWQCs and
Focused Priority listings will be made if new conditions are identified or conversely, if assessments
support removal of conditions from the current listings.
Iterative and Adaptive Management Process
23 4>
2.4.2 Adaption of Goals and Schedules
Numeric goals and the associated schedules for meeting interim and final goals are subject to
adaptation. Achieving goals is accomplished through successful implementation of effective strategies
and then appropriately monitoring and assessing the effects ofthe strategies.
At a minimum, a re-evaluation of goals and schedules will be performed and reported in the ROWD, due
to the Regional Water Quality Control Board (RWQCB) no later than December 2017.
Re-evaluation ofthe goals and schedules will consider:
• Quantitative and temporal progress toward achieving interim and final goals
• New and developing regulations related to the established goals
• Water quality and conditions assessments
• Changes to PWQCs, HPWQCs or Focused Priorities based on re-evaluations
• Data , information and recommendations provided by the public
• Special studies results related to goals
• RWQCB recommendations
• Amount of resources applied in areas of associated established goals
• Effectiveness of strategies implemented in areas of associated established goals
The goals and schedules established are based upon existing conditions and many unknowns, e.g.
resources necessary to implement selected water quality improvement strategies, effectiveness of
selected strategies and, in many cases, the baseline water quality conditions the strategies and
associated goals are intended to change. It is anticipated that the goals and schedules may be dynamic
in the first few years of implementation as the Responsible Agencies continue to collect effectiveness
and efficiency data and information. However, through the iterative process, the goals and schedules
are expected to stabilize, along with other components ofthe WQIP.
The rate of progress toward achieving interim and final goals ^ r ..i r- , ^ ^ ^ ^ Examples of Outcomes from Adapting Goals
will be one of the key considerations in evaluating whether and Schedule
goals and schedules should be adjusted. Using a combination • changing timelines to achieve interim
of assessments. Responsible Agencies will compare the and final goals/targets
anticipated (identified in goal schedules) and actual • Modifying goals/targets
, r -x-j-*.*.!. • Change locations of where goals/targets measured rates of progress to determine if adjustments to * ^ ° are focused
the goals or schedules are warranted.
Responsible Agencies may consider the following potential prompts for adaptations to the goals and/or
schedules:
• When the level of effort expended (implemented strategies) does not correlate well with the
rate of progress toward achieving interim and final goals
• When it is determined that the selected goals do not demonstrate progress towards meeting
ultimate goals of eliminating MS4 non-stormwater discharges, eliminating pollutants in MS4
stormwater discharges, or restoring/protecting beneficial uses in downstream receiving waters
In order to adapt goals and schedules, assessed monitoring and strategy data will be necessary to
evaluate the progress toward achieving the interim and final numeric goals. Based upon the type of
goals identified, a variety of monitoring must be conducted and results ofthe monitoring assessed. The
monitoring types and assessment of the collected data and information are described in general in the
monitoring and assessment sections below.
)\ Iterative and Adaptive Management Process
24
2.4.3 Strategies and Schedules
Strategies and associated schedules are subject to adaptation through the iterative process. Modifying
programs to implement the most effective and efficient strategies are an inherent objective of program
improvements. When strategies are more efficient and effective, their application in larger geographic
scales or greater frequencies is expected to yield measureable outcomes identified through the
assessments. However, assessing strategies for the purposes of determining adaptations can be
challenging; linking implementation of strategies to change in water quality conditions.
At a minimum, a re-evaluation of the strategies and schedules will be performed and reported in the
Report of Waste Discharge (ROWD), due to the Regional Water Quality Control Board (RWQCB) no later
than December 2017.
Evaluating strategies and schedules will consider many factors, including:
• Quantitative and temporal progress toward achieving interim and final goals
• Water quality and conditions assessments
• Changes to PWQCs, HPWQCs or Focused Priorities based on re-evaluations
• Data , information and recommendations provided by the public
• Special studies results related to strategies
• RWQCB recommendations
Amount of resources applied in areas of associated established goals
Although the Permit identifies steps to be taken for re-evaluation of strategies (Provision D.4.d.(2)), the
Responsible Agencies will also look beyond those minimum required steps and evaluate the relative
effectiveness and efficiency of implemented strategies. By comparing effectiveness and efficiencies of
strategies. Responsible Agencies will be better equipped to make management decisions related to
prioritization of strategies for implementation.
Modifications to strategies may include, but are not limited to:
• Removal or addition of strategies from the suite of implemented strategies
• Modifications to the methods of strategy implementation, e.g., methods for conducting
inspections
• Implementation of strategies on greater or modified geographical scales
• Modifications to strategy implementation schedules
In order to adapt strategies and schedules, assessed monitoring and strategy data will be necessary to
evaluate strategy effectiveness and efficiencies. The monitoring types and assessment of the collected
data and information are described in general in the monitoring and assessment sections below.
2.4.4 Adaptation of Monitoring and Assessment Programs
As previously stated, the WQIP components are interrelated; changes to one of the components will
impact other components. This interrelatedness also includes the monitoring and assessment programs.
Changes to PWQCs, HPWQCs, focused priorities, goals and/or strategies, affects the monitoring and
assessment approaches. The types of data and information collected will vary which subsequently
affects the manner in which it is assessed.
At a minimum, a re-evaluation of the Monitoring and Assessment Program will be performed and
reported in the ROWD, due to the Regional Water Quality Control Board (RWQCB) no later than
December 2017.
Iterative and Adaptive Management Process
25
Considerations the Responsible Agencies will evaluate when determining whether the Monitoring and
Assessment Program will be modified include:
• Sufficiency of existing monitoring programs to generate required findings, i.e., are there data
gaps preventing assessments from being completed
• Sufficiency of existing monitoring programs to adequately capture changes in water quality
conditions or the established goal metrics, i.e., assessments can be completed, but there is not
enough data to develop significant findings that provide rationale for adaptations or to justify
maintaining plan components
• Sufficiency of existing assessments to provide findings to provide rationale for adaptations or to
justify maintaining plan components
The Responsible Agencies will evaluate the Monitoring and Assessment Program by reviewing the data
collected and the assessments performed. For each assessment identified in the MAP, the following will
be determined: (1) Is there adequate data to perform the assessment?; and (2) Does the outcome ofthe
assessment provide rationale for adaptations or to justify maintaining plan components?
Based on the assessment of the monitoring and assessment programs. Responsible Agencies may elect
to modify monitoring elements (while maintaining consistency with Permit requirements) as well as
assessments.
2.5 Monitoring
Monitoring includes a variety of activities intended to collect data and information that can be evaluated
and assessed to inform the iterative process and the status of water quality related topics. In terms of
the Water Quality Improvement Plan, monitoring includes collecting data and information from:
• Water quality monitoring and analyses results
• Program implementation including JRMP implementation
• Understanding regulatory issues that may impact program function, e.g., permit reissuance,
TMDLs and trash policies
• Understanding new science and technologies
The Responsible Agencies in the Carlsbad Watershed have developed a monitoring program to collect
data and information for the following purposes:
Measure progress toward achieving the goals, strategies, and schedules;
Measure progress toward addressing the Highest Priority Water Quality Condition;
Evaluate each Responsible Agency's overall efforts to implement the Water Quality
Improvement Plan
Evaluate water quality conditions in some receiving waters
Measure MS4 contributions from select outfalls
Provide rationale for program changes through the iterative process
Measure compliance with TMDL(s)
The Municipal Permit supports an outcome-based approach ^^.p Monitoring includes sampling, inspection,
through the Water Quality Improvement Plan. Monitoring and data collection at beaches, creeks, lakes,
data collection and assessment provides the vehicle for estuaries, and storm drain outfalls to observe
determining whether intended outcomes are being realized conditions, improve understanding, and inform
I J 1. 4.- £ n -Ul A • / the management within the watershed to or whether adaptations of Responsible Agencies programs o r- o improve water quality conditions
are necessary. Collection and assessment of monitoring data
will guide future implementation of the Responsible Agencies' management actions as part of the Water
Iterative and Adaptive Management Process/Monitoring
26
Quality Improvement Plan process. Monitoring during wet and dry weather is conducted to collect
observational and analytical data at MS4 outfalls and the receiving waters. The data are utilized to help
Responsible Agencies determine whether discharges from MS4 outfalls are influencing receiving water
conditions. Responsible Agencies assess the data in combination with their management actions to
determine what actions are improving the quality of MS4 outfall discharges and receiving water
conditions and where additional actions are necessary.
This section provides an overview of the Water Quality Improvement Plan Monitoring Program,
including permit required water quality monitoring, tracking of water quality regulations and policy, and
collecting other additional information and data to evaluate strategies.
2.5.1 JRMP Program
Through implementation of the JRMPs, the Responsible Agencies will have the opportunity to record
relevant program implementation data and information aside from water quality data. This data and
information is useful for the purposes of evaluating program implementation and determining
effectiveness and efficiencies of strategies. To assess the effectiveness and efficiency of these strategies.
Responsible Agencies will collect relevant data for assessment.
2.5.2 Regulations and Policy
Responsible Agencies will monitor the progression of relevant water quality regulations and policies.
These regulations and policies may modify the terms and conditions of compliance and influence WQIP
priorities, strategies, and monitoring. These polices directly affect the Responsible Agencies' water
quality programs and effective use of resources.
Example regulations and policies for monitoring include:
• Statewide Nutrient Policy
• USEPA Recreation Water Quality Criteria
• Bacteria TMDL Reopener
• Ocean Plan Amendments
• State-wide Quality Control Plan for Trash
• State-wide Biological Integrity Assessment Implementation Plan
• National Water Quality Criteria for the Protection of Human Health
• USEPA Definition of the "Waters of US"
• Regional Water Quality Control Board
o Resolutions
o Directives
o Enforcement Actions
• Region 9 - Triennial Review
2.5.3 Water Quality Monitoring Program
The Water Quality Monitoring Program includes four major wet Weather is defined as a storm event of
elements: >0.1 inch of rainfall and the following 72 hours
• Monitoring to assess progress toward goals and after the end of rainfall.
h duleS" Dry Weather is defined as all days where the
' preceding 72 hours have been without
• Receiving water monitoring program that measurable precipitation (>o.iinch).
measures the long-term health of the watershed
during dry and wet weather conditions;
Monitoring
27
• MS4 outfall monitoring program that investigates the elimination of dry weather flows from
MS4 outfalls and the improvement in quality of the discharges from storm drains during wet
weather; and
• Special studies that take a further look into the Highest Priority Water Quality Condition.
These program elements will generate data to track priority water quality conditions and general health
and conditions within the watershed. Monitoring is conducted to: characterize overall water quality in
the discharges from MS4 outfalls in addition to bacteria and nutrient levels; identify potential sources;
and assess the effectiveness of strategies. This section provides an overview of each monitoring
program element. The associated monitoring plans for each of the various programs described in the
following sections are separate documents and are posted at the Project Clean Water website,
www.projectcleanwater.org under the Carlsbad Watershed Section of the webpage.
2.5.5.1 Monitoring to Assess Progress toward Achieving Goals and Schedules
Responsible Agencies have selected strategies that are expected to have multi-pollutant benefits,
targeting non-storm water flows and Highest Priority Water Quality Conditions. Each Responsible
Agency has established water quality interim and final goals for focus areas within hydrologic areas
(HAs). In order to measure progress toward meeting established goals, data collection and monitoring
elements are tailored to capture data appropriate for assessment. Descriptions of the monitoring and
assessment approaches for each of the goals are provided for each focus area in Section 3.
2.5.5.2 MS4 Outfall Monitoring
The purpose of the MS4 Outfall Monitoring Program is to evaluate the potential impact from MS4
discharges on the beneficial uses of the waterbody. This program seeks to answer the following
question: Do non-storm water or storm water discharges from the MS4 outfalls contribute to receiving
water quality problems?
Table 7: MS4 Outfall Monitoring
WQIP Monitoring Program Condition Monitoring Element
Permit Schedule
WQIP Monitoring Program Condition Monitoring Element 2013-
2014
2014-
2015
2015-
2016
2016-
2017
2017-
2018
MS4 Field Screening Dry
Visual: flow condition,
presence and assessment of
trash in and around the
station, IC/IDs
• • •
MS4 outfall
Dry
Field parameters,
conventionals, bacteria',
nutrients', metals
--• • •
MS4 outfall
Wet
Field parameters,
conventionals, bacteria',
nutrients', metals
• • •
Bacteria Low Flow Special
Study Dry Bacteria' and flow
monitoring --• • •
IC/ID = illicit connection and/or illicit discharge bacteria = fecal indicator
'Bacteria and nutrient related analytical testing is related to the Highest Priority Water Quality Conditions in the Carlsbad WMA.
^Completed under the Transitional Monitoring Program in accordance with Permit Provisions D.l.a and D.2.a.
Monitoring
28
Table 8 provides the number of major outfalls to be monitored under each component of the MS4
Outfall Monitoring Program by Responsible Agencies. Detailed proposed monitoring methods and
procedures are presented in the MS4 Outfall Monitoring Plan. These methods and procedures may be
modified on the basis of site-specific environmental conditions and updated analytical methodologies.
The number of major outfalls monitored per year as shown in Table 8 are subject to change based on
new information, updates to the Responsible Agencies MS4 outfall inventories, changes in transient or
persistent flow classifications, and/or changes or updates to the priority water quality conditions over
the life of the WQIP. These outfalls are shown in Figure 7 below.
Jurisdiction
Number of Outfalls Monitored Per Year
Jurisdiction
Field Screening Dry Weather Monitoring Wet Weather Monitoring"
City of Carlsbad 144^ 5 1
City of Encinitas 54' 5 1
City of Escondido 87' 5 1
City of Oceanside 57' 5 1
City of San Marcos 39' 5 1
City of Solana Beach 2' 2' 1
City of Vista 52' 5 1
County of San Diego 14' 5 1
'For Responsible Agencies with fewer than 125 major MS4 outfalls in the watershed, 80% of major outfalls must be screened
twice per year.
^For Responsible Agencies with fewer than 500 but more than 125 major MS4 outfalls in the watershed, 100% of major outfalls
must be screened once per year.
^f a Responsible Agency has less than 5 major MS4 outfalls within the watershed, the Responsible Agency will be monitoring all
its major MS4 outfalls with persistent flow.
"At least one wet weather MS4 outfall per Responsible Agency within the watershed.
MS4 Outfall Dry Weather Monitoring
The purpose of the MS4 Outfall Dry Weather Monitoring Program is to evaluate the potential
contribution from MS4 discharges to receiving water quality during dry weather conditions and to assess
the ability of programs to effectively eliminate non-storm water discharges to waterbodies or
waterways. Each Responsible Agency has established a number of major MS4 outfalls that will be
screened once or twice annually. Additionally, the highest priority major MS4 outfalls with persistent dry
weather flows have been selected for further water quality testing to facilitate source investigations for
these outfalls. Each of the selected highest priority major MS4 outfalls will be monitored at least twice
per year during dry weather conditions. During each event, field observations will be recorded, and
when measureable flow is present, in-situ field measurements and analytical data will be collected.
MS4 Outfall Wet Weather Monitoring
The purpose of this program is to identify pollutants in storm water discharges from the MS4, guide
pollutant source identification efforts, and track progress in achieving the goals. The Responsible
Agencies' eight monitoring locations for the wet weather MS4 outfall discharge monitoring component
were chosen to be representative of the residential, commercial, industrial, and mixed-use land uses
within the Carlsbad Watershed. Each selected outfall will be monitored once per year during a storm
Monitoring
29
QD C
event with greater than 0.1 inch of daily rainfall. During each event, rainfall, estimated or measured flow
rates, in-situ field measurements and analytical data will be collected.
2.5.3.3 Special Studies
Special studies have been selected to further investigate the Highest Priority Water Quality Conditions.
The purpose of the special studies is to "address pollutant and/or stressor data gaps and/or develop
information necessary to more effectively address the pollutants and/or stressors that cause or
contribute to Highest Priority Water Quality Conditions identified in the Water Quality Improvement
Plan." The special studies will include regional special studies and special studies specific to the Carlsbad
Watershed. Special studies selected for the Carlsbad Watershed will provide additional information on
the Highest Priority Water Quality Conditions and goals selected by the Carlsbad Watershed's
Responsible Agencies.
WQIP Monitoring Program Condition Monitoring Element
Schedule
WQIP Monitoring Program Condition Monitoring Element 2013-
2014
2014-
2015
2015-
2016
2016-
2017
2017-
2018
San Diego Regional Reference
Streams and Beaches
Dry
Field parameters, conventionals,
bacteria' instantaneous flow
2012-
2014 ---
San Diego Regional Reference
Streams and Beaches
Dry Streams only: nutrients', metals,
algae bioassessment', including
physical habitat and chlorophyll a'
2012-
2014 ----
San Diego Regional Reference
Streams and Beaches
Wet
Field parameters, conventionals,
bacteria'
2012-
2014 • ---
San Diego Regional Reference
Streams and Beaches
Wet Streams only: nutrients', metals,
toxicity, flow and precipitation
(duration of storm)
2012-
2014 • ---
Bight '13 Microbiology
Drainage Water Study Wet, Dry Bacteria', MST' • ----
Loma Alta Slough
Eutrophication Reduction
Study
Dry Nutrients', algae', biomass', flow
monitoring -• • •
Dry Weather Special Study at
Selected Major Persistent
Flow Outfalls
Dry Bacteria' and flow monitoring -• • •
'Bacteria and nutrient related analytical testing is related to the Highest Priority Water Quality Conditions in the Carlsbad
Watershed.
^The Reference Beaches Study dry weather monitoring program will be implemented during 2014-2015. The Reference Streams
Study dry weather monitoring was completed in 2013-2014.
Son Diego Regional Reference Streams and Beaches Studies
Responsible Agencies have elected to participate in the San Diego Regional Reference Streams and
Beaches Studies conducted by the San Diego and Orange County Permittees of Municipal Storm Water
Permits. The studies measure levels of bacteria that account for "natural sources" to establish the
concentrations or loads from streams or beaches minimally disturbed by anthropogenic activities or
"reference" conditions. The Reference Stream Study also collects nutrients, metals, and toxicity data as
Monitoring
31
secondary constituents. This study provides a scientific basis for updating the reference conditions to be
considered in evaluating appropriate compliance levels in the Bacteria TMDL. The results of this study
will be used to support the forthcoming re-evaluation of the adopted Bacteria TMDL and to support
numeric target development in future TMDLs or alternative regulatory approaches for nutrients and
metals.
The San Diego Regional Stream Reference Study will address the following questions (SCCWRP, 2013) in
streams minimally influenced by anthropogenic activities:
• How does the Water Quality Objective (WQO) exceedance frequency vary between summer dry
weather, winter dry weather, and wet weather?
• How does the WQO exceedance frequency vary by hydrologic factors?
• How does the WQO exceedance frequency vary by input factors?
• How does the WQO exceedance frequency vary by biotic and abiotic factors?
The San Diego Regional Reference Beaches Study will address the following questions (SCCWRP, 2013) in
beaches minimally influenced by anthropogenic activities:
• How does the WQO exceedance frequency vary between summer dry weather, winter dry
weather, and wet weather?
• How does the WQO exceedance frequency vary by hydrologic factors, including discharge flow
rate (wet and dry weather)?
• What is the status of estuary mouth (open/closed; dry weather only)?
• What are the wet and dry weather exceedance frequencies of fecal indicator bacteria in
estuaries?
A total of six locations were selected for wet weather monitoring and up to 10 locations were selected
for dry weather monitoring. Sites were selected to represent 95 percent undeveloped land uses
(reference conditions), two major geologic settings, and the target catchment sizes. Wet weather
sampling frequency at the six locations consists of three targeted events throughout the wet season
(October 1 through April 31). Water samples will be analyzed for a combination of conventional
constituents, nutrients, metals, fecal indicator bacteria, microbial source testing, and algae. Of these
constituents, Enterococcus, E. co//, fecal coliform, total coliform, Bacteroides, and in-situ parameters are
of primary importance; all other analytes are considered secondary.
Loma Alta Slough Eutrophication Reduction Study
The Loma Alta Slough has been on the Clean Water Act Section 303(d) list for impairments related to
eutrophication since 1996. The RWQCB has been working with stakeholders since 2008 to develop a
strategy to address the impairment, which occurs during the summer months when macroalgae growth
in the Slough leads to the eutrophic condition. A draft TMDL was calculated for the Slough but has not
yet been put into action; instead, the RWQCB has given the City of Oceanside the opportunity to use the
existing Permit and its own set of strategies to address the impairment. This voluntary study involves a
long-term water quality monitoring program for the Loma Alta Slough to assess the effectiveness of the
City of Oceanside's watershed management efforts through tracking the levels of nutrients and algae
growth during the summer impairment period. It will also utilize monitoring data from MS4 outfalls
discharging to Loma Alta Creek, which is required pursuant to Provision D.2.b ofthe Permit. The study is
directly related to nutrients, the Highest Priority Water Quality Condition in the Loma Alta Creek HSA.
This special study is presented in the Loma Alta Hydrologic Area section of this WQIP - see Section 3.1
for more details.
Monitoring
32
Dry Weather Special Study at Selected Major Persistent Flow Outfalls
A Dry Weather Special Study will be developed to characterize temporal flow and fecal indicator
bacteria patterns at selected persistently flowing major MS4 outfalls during summer dry weather
conditions. This study will include continuous flow monitoring at select outfalls to better understand dry
weather flow profiles at different times of the day. The special study is related to indicator bacteria,
which has been identified as a Highest Priority Water Quality Condition for the City of Carlsbad, City of
Escondido, City of San Marcos, City of Solana Beach, and City of Vista and will be implemented in priority
areas within their respective jurisdictions. The special study will be conducted by the various cities in a
variety of different geographic locations throughout the WMA. The data will be collected and assessed
for each location where data is collected and also collectively with all special study data considered.
This special study is presented in the Buena Vista Creek, Agua Hedionda, San Marcos and Escondido
Creek Hydrologic Area sections of this WQIP - see Sections 3.2, 3.3, 3.5 and 3.6 for more information.
Microbiology Drainage Water Study Plan
MS4 drainages may greatly influence the exceedance frequency of water quality standards for
Enterococcus, a type of fecal indicator bacteria at beaches. However, as stated in the Bight '13
Microbiology Drainage Water Study Work Plan, "because Enterococcus is a non-specific indicator of fecal
material, the extent to which these flows contain human fecal contamination is unclear". The goal of the
study is to assess the extent of human fecal contamination from coastal drainages to the ocean to
inform managers as to the extent of the problem and to assist in prioritizing individual sites for
remediation efforts or adoption of alternative management strategies (Griffith, 2010).
The City of Encinitas will conduct this special study within the local Moonlight Beach area. This special
study is presented in the San Marcos Hydrologic Area section of this WQIP - see Section 3.5 for more
information.
2.5.3.4 Receiving Water Monitoring
The purpose of the receiving water monitoring program is to characterize trends in the chemical,
physical, and biological conditions of a receiving water to determine whether beneficial uses are
protected, maintained, or enhanced. Long-term monitoring occurs during both wet and dry weather
conditions for water quality, along with physical and biological integrity. Sediment quality monitoring
and participation in regional monitoring occur as well. TMDL monitoring is also incorporated into the
receiving water monitoring program. Receiving water monitoring comprises the following programs:
• Long-term receiving water monitoring
• Toxicity identification evaluation/toxicity reduction evaluation, if appropriate
• Regional monitoring participation
• Sediment quality monitoring
• TMDL monitoring
The receiving water programs are designed to answer one or more of the following questions:
• Are conditions in the receiving water protective, or likely protective, of beneficial uses?
• What are the extent and magnitude of the current or potential receiving water problems?
• Are the conditions in the receiving water getting better or worse?
Table 10 on the following page identifies the Receiving Water Monitoring Program for the Carlsbad
WMA. Descriptions of the Receiving Water Monitoring Program elements are provided below starting
with Long-Term Receiving Water Monitoring.
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Long-Term Receiving Water Monitoring
Long-term receiving water monitoring tracks the overall health of the receiving waters. Unless modified,
dry and wet weather monitoring will continue at the historical mass loading station (EC-MLS) located on
Escondido Creek. Responsible Agencies have monitored EC-MLS since 2001 and have selected this
location as the long-term monitoring location for the Carlsbad WMA. The land uses in the surrounding
drainage area for EC-MLS are primarily residential with open space, and commercial. The location of EC-
MLS is shown in Figure 7 above.
Station ID Latitude Longitude Cross Street Description Channel Type Jurisdiction
EC-MLS 33.0482901 -117.226032 El Camino Del Norte Bridge Natural Channel City of Encinitas
Source: Transitional Receiving Water Monitoring Plan (Weston, 2014a)
In each five-year cycle this site, unless modified, will be monitored three times during dry weather and
three times during wet weather. This monitoring program is designed to monitor the Highest Priority
Water Quality Conditions in the receiving water, along with a comprehensive list of constituents based
on the Clean Water Act Section 303(d) list (303(d) list) impairments, non-storm water action levels
(NALs) or storm water action levels (SALs). Toxicity Identification Evaluations (TIE)s Toxicity Reduction
Evaluations (TRE)s will be conducted if necessary (see below). Once per five-year cycle during dry
weather, a bioassessment will be conducted to evaluate chemical, physical, and biological data, and
hydromodification monitoring will record the stream conditions, habitat integrity, and impacts. Detailed
monitoring methods and procedures are presented in the Receiving Water Monitoring Plan. The
methods and procedures may be modified on the basis of site-specific environmental conditions and
updated analytical methodologies.
Toxicity Identification Evaluation/Toxicity Reduction Evaluation
If chronic toxicity is detected in receiving waters, the Copermittees will evaluate the need for conducting
a Toxicity Identification Evaluation (TIE)/Toxicity Reduction Evaluation (TRE). A TIE is a set of procedures
to identify specific chemicals or conditions responsible for toxicity; a TRE is a study designed to identify
causative agents of effluent or ambient toxicity, isolate its sources, evaluate effectiveness of toxicity
control options, and confirm reduction of toxicity. An outline of the process to identify chronic toxicity
and prioritize the need to implement a TIE/TRE on the basis of the magnitude and persistence of chronic
toxicity is presented in the TIE/TRE Work Plan.
Regional Monitoring Participation
Regional monitoring includes separate studies that evaluate various aspects of receiving water health on
a regional scale. The Carlsbad Responsible Agencies participate in three separate regional programs: (1)
Bight Regional Monitoring; (2) Stormwater Monitoring Coalition Regional Monitoring; and (3)
Hydromodification Regional Monitoring Program. Descriptions of each program are provided below.
Bight Regional Monitoring
The Bight regional monitoring program is a multi-agency collaborative effort to assess the ecological
condition of the Southern California Bight from a regional perspective. The core program consists of
monitoring of sediment chemistry, sediment toxicity, and benthic infauna. The goals of past Bight
programs are to answer three primary questions:
• What are the extent and magnitude of direct impact from sediment contaminants?
• How do the extent and magnitude of the environmental impact vary by habitat?
• What is the trend in extent and magnitude of direct impacts from sediment contaminants?
Assessment
Page 35
Sediment quality monitoring was conducted during summer 2013 at a total of 22 sites in 9 estuaries and
lagoons in the San Diego region, including Agua Hedionda, Batiquitos, and San Elijo Lagoons, under the
Southern California Bight 2013 Regional Monitoring Survey (Bight '13) (Weston, 2014c). Responsible
Agencies will participate in planning Bight '18 monitoring programs in coming years.
Stormwater Monitoring Coalition (SMC) Regional Monitoring
Since 2001, Responsible Agencies have partnered with regulated storm water municipalities in southern
California, the RWQCBs of southern California, and the Southern California Coastal Water Research
Project (SCCWRP) to form the Southern California Stormwater Monitoring Coalition (SMC). The goals of
the SMC are to standardize monitoring, improve understanding of storm water mechanics, and identify
receiving water impacts from storm water (SCCWRP, 2002). The Responsible Agencies will continue
participation in the SMC Regional Bioassessment Program.
Hydromodification Regional Monitoring Program
The San Diego County Regional Copermittees have developed a regional Hydromodification
Management Plan (HMP) to address impacts to beneficial uses and stream habitat from increased
erosive force potentially caused by a rise in runoff discharge rates and volume from Priority
Development Projects (County of San Diego, 2011). The HMP was initially developed to meet the
requirements of the 2007 Municipal Permit. The Monitoring Plan is defined in Chapter 8 of the HMP,
and was updated by the Copermittees and accepted by the RWQCB in February 2014. The HMP requires
monitoring with a final report due to the RWQCB in December 2016. Monitoring consists of channel
sediment transport assessments and continuous flow monitoring of pre-project, post-project, and
reference conditions. The Responsible Agencies participate in this regional monitoring program through
cost sharing and collaboration with other regional Copermittees.
Sediment Quality Monitoring
Sediment quality monitoring is designed to assess compliance with the sediment quality receiving water
limits applicable to enclosed bays and estuaries in accordance with the State Water Board's Water
Quality Control Plan for Enclosed Bays and Estuaries of California - Part I Sediment Quality (Sediment
Control Plan). Sediment quality monitoring includes the preparation of a Sediment Quality Monitoring
Plan that satisfies the requirements of the Sediment Control Plan. The requirements of the sediment
quality monitoring are:
• Elements required under Sections VII.D and VILE of the Sediment Control Plan
• Quality Assurance Project Plan
• Schedule for completion of sample collection, analysis, and reporting
The Responsible Agencies propose to conduct one round of sediment sampling during each Permit term.
The second required round of sampling will be satisfied by conducting additional follow-up sampling in
the vicinity of possibly impacted sites identified in the first round. The Sediment Quality Monitoring Plan
and Quality Assurance Project Plan describe detailed proposed monitoring procedures and analytical
methods that are illustrative and may change on the basis of site environmental conditions and updated
methodologies.
TMDL Monitoring
TMDL provisions, schedules, and monitoring requirements are provided in Attachment E of the MS4
Permit. The purpose of the monitoring program is to track progress toward achieving compliance with
interim and final TMDL numeric targets. The Bacteria TMDL in Permit Attachment E.6 is applicable to the
San Marcos HA. Monitoring is designed to meet compliance with the monitoring requirements of the
Assessment
Page 36
TMDL. Compliance monitoring during wet and dry weather will be conducted each year at the AB411
monitoring site (EH-420) located within the Pacific Ocean shoreline segment at Moonlight State Beach.
This TMDL compliance monitoring site is shown on Figure 7 above.
See Section 3.5, San Marcos HA for more information regarding TMDL monitoring.
2.6 Assessment
Assessment is the link between data collection, i.e. water quality monitoring and program
implementation results, and providing rationale for program modifications through the iterative
process. By evaluating data and information from program implementation and then comparing results
to goals, benchmarks and/or previous results. Responsible Agencies can assess their programs'
functionality and effectiveness. Based upon the assessments. Responsible Agencies can make
determinations as to whether adaptations to the programs are appropriate.
Through assessment of collected data and information, the Responsible Agencies intend to answer the
following questions:
• Was the program implemented according to plan?
• What are the overall efforts by each Responsible Agency to implement the WQIP?
• Should PWQCs and/or HPWQCs be modified?
• What is the status of progress toward achieving the numeric goals and schedules?
• Are goals appropriate and useful in measuring progress towards water quality improvements?
• Are Responsible Agencies making progress towards goals at a rate conducive to the schedules
developed?
• Should goals and schedules be modified?
• What is the status of progress toward addressing the HPWQCs?
• Are there program alternatives, including strategies, that are more effective or efficient than
those implemented or planned for implementation?
• Should alternative strategies be implemented?
• Are there current strategies that should be eliminated from the WQIP and JRMPs?
Based on the assessments and answers to these questions, the plan components may need to be
modified to accommodate the feedback received through the monitoring and assessment. These
potential modifications are discussed in Section 2.4.
Descriptions ofthe various assessments are provided below.
2.6.1 JRMP Program Assessments
As Responsible Agencies implement their JRMPs, they implement tracking mechanisms and reporting
systems for collecting a significant amount of data and information for program assessment. JRMP
program assessments can be used to determine how effective and efficient program strategies are with
respect to accomplishing the desired outcome of strategy implementation.
• Using the data and information collected through program monitoring. Responsible Agencies
will determine whether the JRMPs were implemented as planned. When a program is not
implemented as planned, the monitoring (data tracking) and assessments may not be
appropriate forthe strategies implemented.
• Evaluating the effectiveness of strategies has two parts:
o Determining if the strategy achieves its intended function; and
Assessment
Page 37
o Determining if the strategy is effective at improving water quality conditions. Using data
collected during strategy implementation
• Determining the efficiency of implemented strategies for the purposes of prioritizing and
planning for the use of strategies involves two evaluations:
o Cost benefit analyses; and
o Comparisons of relative performance of strategies based on data and information
collected by Responsible Agencies.
The Responsible Agencies will review the data and information collected to assess their JRMP programs
and evaluate effectiveness and efficiencies of the strategies implemented. Where appropriate, findings
will be used to feed into the iterative process to make changes to program implementation as well as in
strategic planning.
2.6.2 Regulatory and Policy Assessment
Information collected on regulatory changes or emerging changes will be assessed to determine
potential impacts to the WQIP. Outcomes of the assessment may include changes to the process in
which Priority Water Quality Conditions and Highest Priority Water Quality Conditions are identified as
well as geographic focus areas. The findings will influence the iterative process.
2.6.3 Storm Drain Discharges Assessments
The MS4 outfall discharge assessments includes evaluating the dry weather monitoring data collected at
the highest priority MS4 outfalls with persistent non-stormwater flows and associated information from
the illicit discharge detection and elimination (IDDE) program and the wet weather MS4 monitoring
program. Details of the dry and wet weather MS4 data assessments are provided below. Each
Responsible Agency will assess its MS4 monitoring programs individually and compile results annually as
part ofthe Carlsbad WMA Water Quality Improvement Plan Annual Report.
2.6.3.1 Dry Weather Outfall Assessments/Illicit Discharges
Each Responsible Agency will assess and report the progress of its Dry Weather MS4 Outfall Monitoring
and IDDE program (required pursuant to Municipal Permit Provision E.2) toward effectively prohibiting
non-storm water and illicit discharges into the MS4s within its jurisdiction. Prior to completing the
assessments, each jurisdiction will compile available relevant data in a regionally consistent format
including, but not limited to, the following:
Monitoring Data
Field screening visual observations
Non-storm water monitoring including water
quality, observations, field measurements, and
flow estimates
Relevant historical dry weather data
Reports or notifications of illicit discharges, illicit
connections, or other sources of non-storm
water from hotlines or other sources
Follow up field investigations of source of flow
Review of MS4 outfall inventories, drainage
areas, or changes in land use
JRMP Information and Data
Field screening visual observations
Non-storm water monitoring including
water quality, observations, field
measurements, and flow estimates
Relevant historical dry weather data
Reports or notifications of illicit discharges,
illicit connections, or other sources of non-
storm water from hotlines or other sources
Follow up field investigations of source of
flow
Review of MS4 outfall inventories, drainage
areas, or changes in land use
Table 12 presents the non-storm water pollutant discharges reduction assessments, suggested
evaluation processes and potential outputs for each element.
Assessment
Page 38
Table 12: Dry Weather MS4 Outfall Assessment Evaluation Process and Potential Outputs
Non-storm water
Assessments Process of Evaluation Potential Output(s)
Assessment 1: Progress
toward effectively
prohibiting non-storm water
and illicit discharges into the
MS4 within each jurisdiction
Categorize flows as dry, persistent, transient, or
undetermined based on historic and current field screening
data.
For transient and persistent flows, identify the known and
suspected controllable sources, as feasible, and which
sources were reduced or eliminated.
Based on two previous steps, evaluate any modifications to
field screening locations or frequency necessary to identify
and eliminate sources of persistent flows. Reprioritization
of outfalls may occur if one of the following conditions is
met:
a. Non-storm water discharges have been
effectively eliminated for three consecutive
monitoring events or
b. Source(s)s of the persistent flows have been
identified as not an illicit or a source of pollutants
or
c. Pollutants in the persistent flow do not exceed
NALs or
d. The threat to water quality has been reduced by
the Responsible Agency
Number of sources reduced and
eliminated.
Updated MS4 outfall inventory to
reflect current flow status, outfalls
removed or added from field
screening program.
List of program modifications.
Assessment 2:
Rank and prioritize MS4
outfalls
3.
Assess threat to receiving water quality from major MS4
outfalls based on available water quality data. Compare dry
weather water quality data to relevant NALs, Highest and
Focused Priorities (water quality objectives, 303(d) List or
ESAs), and discharge prohibitions, as applicable.
Identify pollutants from sources or land uses known to
exist within the area, drainage basin, or watershed that
discharges to the portion of MS4 within its jurisdiction.
Rank MS4 outfalls according to threat to water quality
using the metrics established under the transitional
monitoring program.
Revised prioritized list of major MS4
outfalls.
List of modifications to major MS4
outfalls monitored under Provision
D.2.b.
Revised prioritization metrics, as
applicable.
Assessment 3:
Identify known and
suspected sources
contributing to numeric
action limit exceedances at
highest-ranked MS4 outfalls
Compare dry weather water quality data from major
outfalls to relevant NALs (completed in Assessment 2).
For those exceeding NALs, use visual observation,
inspection data, land use data, complaints, and other
reports to identify potential sources in the outfall drainage
area.
List of known and suspected sources
for each highest-ranked MS4 outfall
Summary of NAL exceedances per HU,
and applicable follow-up actions.
List of follow up actions and whether
those actions have resulted in lower
pollutant concentrations or
identification of confirmed or
suspected sources, if data are
available.
Revise internal follow-up procedures,
as necessary, to increase effectiveness
of follow-up actions as part of
adaptive management.
Assessment
Page 39
Non-Storm water
Assessments Process of Evaluation Potential Output(s)
Assessment 4:
Estimate volumes and loads
of non-storm water
discharges
1. Compile dry weather water quality and flow data from
major MS4 outfalls with persistent flow per jurisdiction.
2. Annual rainfall data representative of the watershed to
define wet versus dry days for the monitored year.
3. Calculate or estimate annual non-storm water volume and
pollutant loads collectively discharged from each
jurisdiction's major MS4 outfalls to receiving waters.
4. Estimate the percent contribution from each known source
for each MS4 outfall (as identified in Assessment 3).
5. Calculate or estimate annual non-storm water volume and
pollutant loads collectively discharged from non-storm
water not subject to the Copermittee's legal authority.
Total estimated volume or load of
non-storm water discharges per
jurisdiction and by HA
Assessment 5:
Identify data gaps
Note:
Review assessment methodology and determine additional data
needed to improve evaluation and identify and eliminate non-
storm water discharges.
Ust of potential modifications to the
monitoring. Jurisdictional Runoff
Management Program activities, or
strategies.
Regional formats, data evaluation processes, and suggested outputs are provided and are subject to change based on program
refinements and lessons learned from implementation of program elements as part ofthe adaptive management process.
2.6.3.2 Wet Weather Outfall Monitoring Assessments
Each Responsible Agency will assess and report the results of its Wet Weather MS4 Outfall Monitoring
and evaluate progress toward reducing pollutant loading during wet weather. Prior to completing the
assessments, each Jurisdiction will compile available relevant data, as applicable, in a regionally
consistent format to complete the storm water discharge assessment.
Table 13 presents the storm water pollutant discharge reduction assessments, example evaluation
processes and suggested outputs for each element.
Assessment
Page 40
Table 13: Wet Weather MS4 Outfall Assessment Evaluation Process and Potential Outputs
Storm Water Assessments Process of Evaluation Potential Output(s)
Assessment 1:
Estimate volumes and loads of
storm water discharges
Compile wet weather water quality and flow data
from monitored outfalls for the monitoring year and
compare across multiple years of data.
Use rainfall data representative ofthe watershed to
define wet versus dry days for each monitored year.
Calculate or estimate annual non-storm water
volume and pollutant loads collectively discharged
from each jurisdiction's monitored MS4 outfalls to
receiving waters for each storm event.
Estimate the percent contribution of stormwater
volumes and pollutant loads discharged from each
land use type within each hydrologic subarea or
within each major MS4 outfall to receiving waters.
Evaluate modifications to wet weather MS4
monitoring locations or frequency necessary to
identify pollutants in storm water discharges in the
WMA.
Total estimated volumes and loads of
storm water discharges per jurisdiction
and for the Carlsbad WMA.
Estimated percent contribution from
each land use type within each HAS or
major MS4 outfall.
Modifications to the wet weather MS4
outfall monitoring locations and
frequencies, as needed and based on
factors such as funding, safety and site
accessibility.
Assessment 2:
Identify known and suspected
sources contributing to SAL
exceedances at highest-ranked
MS4 outfalls
Compare wet weather water quality data from
monitored outfalls to relevant SALs.
For those exceeding SALs, use relevant visual
observation, inspection data, land use data, IC/ID
reports to identify potential sources present in the
outfall drainage area in the wet season.
Re-evaluate strategies and update other assumptions
used to develop the WQIP under the adaptive
management approach.
Summary of SAL exceedances within the
WMA, and applicable follow-up actions.
Ust of known and suspected wet
weather point sources for each highest-
ranked MS4 outfall, as applicable
Ust of follow up actions and whether
those actions have resulted in lower
pollutant concentrations or
identification of confirmed or suspected
sources, if data are available.
Revise internal follow-up procedures, as
necessary, to increase effectiveness of
follow-up actions as part of adaptive
management.
Assessment 3:
Identify data gaps
Note:
Review assessment methodology and determine
additional data needed to improve evaluation of non-
storm water discharges.
List of potential modifications to the
monitoring, Jurisdictional Runoff
Management Program activities and
response actions, or strategies.
Regional formats, data evaluation processes, and suggested outputs are provided and are subject to change based on program
refinements and lessons learned from implementation of program elements as part of the adaptive management process.
2.6.3.3 Report of Waste Discharge
As part of the ROWD, Responsible Agencies will evaluate dry and wet weather MS4 outfall monitoring
data collected. Table 14 presents the evaluation process and potential output for each element.
Assessment
Page 41
Table 14: ROWD Assessments Evaluation Process and Potential Outputs
ROWD Assessments Process of Evaluation Potential Output(s)
Assessment 1: Identification of reductions
and progress in achieving reduction in
non-storm water and illicit discharges
from the MS4
Compile number of sources of non-storm water
and illicit discharges reduced and eliminated by
all jurisdictions in the WMA over the permit term.
Assess progress by comparing to previous permit
terms.
% increase or decrease in number of sources
reduced or abated for the entire WMA this
permit term.
Assessment 2: Assess effectiveness of
strategies toward reducing or eliminating
non-storm water and pollutant loads from
the MS4 to receiving waters by
Jurisdiction
Compare data from pre- and post- project or
focused area to evaluate potential effects of
enhanced Water Quality Improvement Plan
strategies, as available
If possible, estimate the pollutant load reduction
attributable to specific water quality strategies.
Summary of pre-project (baseline) data and
post-project data
Summary of load reductions per jurisdiction by
HU for highest and focused priorities.
List of strategies that may support pollutant load
reductions and those that don't, based on data
collected.
Assessment 3: Identify modifications
necessary to increase the effectiveness of
strategies toward reducing or eliminating
non-storm water and pollutant loads from
the MS4 to receiving waters by
Jurisdiction
Review assessment methodology and determine
additional data needed to improve evaluation and
identify and eliminate non-storm water discharges.
List of potential modifications to the Monitoring
and Assessment Program, Jurisdictional Runoff
Management Program activities, or strategies.
Recommendations for programmatic
adjustments of strategies and schedules.
Assessment 1: Identification of reductions
and progress in achieving pollutant load
reductions from different land uses
and/or drainage areas discharging from
the MS4
Compile total estimated volume or load of non-
storm water discharges by drainage area, land
use, or other relevant assessment metric for the
WMA over the permit term
Assess progress by comparing pollutant loads by
land use and/or drainage areas over a minimum
of three years to determine short-term trends
over the five years of implementation.
% allocation of volume or load based on % of
land use per HA and by WMA.
Trend analysis, if sufficient data points are
available, based on % allocation of volume or
load.
Assessment 2: Identify modifications
necessary to increase the effectiveness of
strategies tow/ard reducing pollutants in
storm water discharges from the MS4 to
receiving waters in the WMA to the MEP
Compare data from pre-post project or focused
area to control area in order to evaluate potential
effects of enhanced V^ater Quality Improvement
Plan strategies.
If possible, estimate the pollutant load reductions
attributable to specific water quality strategies.
Summary of pre-project (baseline) data and
post-project data.
Summary of load reductions per jurisdiction by
HA for highest and focused priorities.
List of strategies that may support pollutant load
reductions and those that don't, based on data
collected.
Assessment 3:ldentify modifications
necessary to increase the effectiveness of
the water quality improvement strategies
implemented in the WMA toward
reducing pollutants in storm water
discharges from the MS4s to receiving
waters to MEP
Review assessment methodology and determine
additional data needed to improve evaluation and
identify and eliminate storm water discharges.
List of potential modifications to the monitoring
Jurisdictional Runoff Management Program
activities, or strategies.
Recommendations for programmatic
adjustments of strategies and schedules.
Note: Regional formats, data evaluation processes, and suggested outputs are provided and are subject to change based on
program refinements and lessons learned from implementation of program elements as part of the adaptive management
process.
2.6.4 Special Studies Assessments
As part of the Water Quality Improvement Plan Annual Report, the Responsible Agencies will evaluate
the results and findings from the special studies. Results from each special study will be reported
individually based on its implementation schedule. Findings from each active special study will be
compiled annually as part of the Carlsbad WMA Water Quality Improvement Plan Annual Report to
Assessment
Page 42
complete the special study assessments described below. If a special study is not being implemented
then a status update and schedule for implementation will be provided in the Annual Report.
Table 15 presents the special study assessments, the planned special studies that may be implemented
and potential outputs for each element.
Table
Special Studies Assessments Planned Special Studies Potential Outputs
(dependent on study schedule of implementation)
Assessment 1:
Assess relevance of each
special study to the
Participating Agencies'
characterization of receiving
water conditions
Regional Reference Studies will characterize
natural 'reference' concentrations of bacteria
in streams and beaches.
Data to support modification of TMDL compliance such
as numeric targets including water quality objectives or
the allowable percent exceedance frequency. Assessment 1:
Assess relevance of each
special study to the
Participating Agencies'
characterization of receiving
water conditions
Loma Alta Nutrient Special Study will
characterize receiving water conditions
during the critical condition.
Loma Alta Nutrient Special Study data will be used to
track change in receiving water conditions.
Assessment 1:
Assess relevance of each
special study to the
Participating Agencies'
characterization of receiving
water conditions Bight '13 - San Marcos HA Microbiology
Drainage Water Special Study will monitor
San Marcos HA paired with Moonlight Beach.
Bight '13 - San Marcos HA Microbiology Drainage
Water Special Study will evaluate the relationship
between beach water quality and input from the
watershed.
Assessment 2:
Understand sources of
pollutants and/or stressors
Regional Reference Studies will characterize
natural 'reference' concentrations of bacteria
in streams and beaches during wet and dry
weather conditions.
Regional Reference Studies data may be used to
understand how natural background levels of bacteria
during wet and dry weather conditions may contribute
to exceedances.
Assessment 2:
Understand sources of
pollutants and/or stressors
Dry Weather Special Study will characterize
persistent dry weather flows from high
priority major MS4 outfalls.
Dry Weather Special Study data may be used to guide
further investigations of sources.
Assessment 2:
Understand sources of
pollutants and/or stressors Loma Alta Nutrient Special Study will
characterize watershed input via Loma Alta
Creek to Loma Alta Slough.
Loma Alta Nutrient Special Study will characterize the
magnitude and extent of nutrient loading from Loma
Alta Creek. After multiple years of implementation,
data may be used to guide investigations of potential
controllable versus uncontrollable sources.
Assessment 2:
Understand sources of
pollutants and/or stressors
Bight '13 - San Marcos HA Microbiology
Drainage Water Special Study will
characterize potential watershed inputs of
human fecal contamination.
Bight '13 - San Marcos HA Microbiology Drainage
Water Special Study will characterize the frequency
and magnitude of human signal during wet and dry
weather conditions.
Assessment 3:
Control and reduce the
discharges of pollutants
from the MS4 outfalls to
receiving waters
Dry Weather Special Study will characterize
persistent dry weather flows from MS4.
Dry Weather Special Study data may be used to
develop an action plan to reduce or control identified
sources. Assessment 3:
Control and reduce the
discharges of pollutants
from the MS4 outfalls to
receiving waters
Loma Alta Nutrient Special Study will
characterize Loma Alta Creek.
Loma Alta Creek data may be used to guide monitoring
of MS4 outfalls located upstream.
Assessment 3:
Control and reduce the
discharges of pollutants
from the MS4 outfalls to
receiving waters
Bight '13 - San Marcos HA Microbiology
Drainage Water Special Study will assess
human fecal contamination at a location in
the San Marcos HA.
Bight'13-San Marcos HA Microbiology Drainage
Water Special Study data may be used to guide follow
up source investigations in the San Marcos HA.
Assessment 4:
Identify any necessary
modifications or updates to
the WQIP based on Special
Study results or findings
Regional Reference Studies
Dry Weather Special Study
Loma Alta Nutrient Special Study
Bight '13 - San Marcos HA Microbiology
Drainage Water Special Study
Data may be used to guide modifications to
monitoring, source investigations, JURMP activities or
response actions, or strategies.
2.6.5 Receiving Waters Assessment
The assessment of receiving waters involves evaluating the physical, chemical, and biological conditions
of the receiving waters and sediments. The Responsible Agencies will assess the status and trends of
receiving water quality conditions in coastal waters, enclosed bays, harbors, estuaries, and streams in
Assessment
Page 43 ^3
the Carlsbad WMA once per permit cycle. The results from these assessments may be presented as part
of a Water Quality Improvement Plan Annual Report or in the ROWD. Prior to completing the
assessments, each jurisdiction will compile relevant data in a regionally consistent format including, but
not limited to, the following:
• Wet and dry weather chemical, biological, and physical data collected under Long-term
receiving water, regional monitoring, and sediment monitoring programs
Other available and relevant wet and dry weather data at receiving water locations collected
under programs such as TMDL Monitoring or Special studies
Relevant historical wet and dry weather data at receiving water locations
• Results of Toxicity Identification Evaluations (TIEs) and/or Toxicity Reduction Evaluations (TREs),
if applicable
Once the jurisdictional data is collected into regionally consistent formats, the data will be compiled for
the watershed assessment. Table 16 presents the receiving water quality assessments, evaluation
processes and potential outputs for each element.
Table 16: Receiving Water Assessment Evaluation Process and Potential Outputs
Receiving Water Assessments Process of Evaluation Potential Output(s)
Assessment 1:
Determine whether or not the
conditions ofthe receiving waters
are meeting the numeric goals
established
Compare water quality data from Bacteria TMDL compliance
locations collected during current and past monitoring years
to TMDL interim and final numeric goals
Categorize goals as met, partially
met, or currently not met, or
alternative categories more
specific to the relevant goal(s)
Assessment 2:
Identify the most critical beneficial
uses that must be protected to
ensure the overall health ofthe
receiving water
Use multiple lines of evidence prioritization methodology from
applicable Water Quality Improvement Plan section to
evaluate current state of receiving water quality conditions
using more recent and updated data, including:
a. Compare receiving waters water quality data
collected during current and past monitoring years
to water quality benchmarks.
b. Consider publicly available data
c. Consider current regulatory drivers
d. Evaluate MS4 contribution.
Identify most critical beneficial
uses
Status of and potential changes to
Priority Conditions, High Priority
Conditions, and Focused Priority
Conditions
Assessment 3:
Evaluate whether or not the
critical beneficial uses identified
under Assessment 3 are being
protected
1. For Priority Water Quality Conditions and High Priority
Water Quality Conditions, compare current and historical
data to water quality benchmarks and calculate a
frequency of exceedances.
2. Evaluate seasonal or temporal patterns in available water
quality and flow data to determine when those critical
beneficial uses are supported or impaired.
Categorize Priority Conditions,
High Priority Conditions, and
Focused Priority Conditions as
protected, likely protected,
possibly impacted, likely impacted,
or clearly impacted, or alternative
categories depending on type of
beneficial use.
Assessment 4:
Identify short-term and/or long-
term improvements or
degradation of those critical
beneficial uses
1. Compare current and historical data to water quality
benchmarks.
2. Calculate a frequency of exceedances for each
monitoring year. For short-term trends, use a minimum
of three years of data and a minimum of five years to
evaluate long-term trends.
Statistical analysis of trends and
recommended programmatic
changes or enhancements
Assessment
Page 44
Receiving Water Assessments Process of Evaluation Potential Output(s)
Assessment 5:
Determine whether or not the
strategies established in the WQIP
contribute towards progress in
achieving the interim and final
numeric goals of the WQIP
Evaluate progress toward achieving interim and final numeric
goals by HA or focus area as described in Section 3.
Evaluate efficacy of strategies listed in Section 3.
Identify interim and final goals
met, partially met, or not met by
HA.
Ust of potential modifications to
monitoring or strategies.
Assessment 6:
Identify data gaps in the
monitoring data needed to
conduct the above assessments
Review assessment methodology and determine additional
data needed to improve evaluation and better characterize
general health of beneficial uses.
Ust of potential modifications to
the monitoring. Jurisdictional
Runoff Management Plan
activities, or strategies
Note:
Regional formats, data evaluation processes, and suggested outputs are provided and are subject to change based on program
refinements and lessons learned from implementation of program elements as part ofthe adaptive management process.
2.6.6 Integrated Assessment
In order to make determinations of potential program changes, the iterative process needs to have a
comprehensive assessment completed that integrates data from program implementation, water
quality data, special studies and regulatory issues. The integrated assessment is intended to evaluate all
of the moving parts of the WQIP together.
The Responsible Agencies will utilize appropriate data and information collected to assess the following:
• Priority Water Quality Conditions
• Numeric Goals and Schedules
• Water Quality Improvement Strategies and Schedules
• Water Quality Monitoring Program
• Assessment Program
The outcomes of the integrated assessment will provide the iterative process the basis for appropriate
and necessary modifications to the WQIP.
Assessment
Page 45
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Assessment
Page 46
3 Hydrologic Area Implementation
Through the development and implementation of the Carlsbad WQIP, the Carlsbad WMA Responsible
Agencies have identified HPWQCs and PWQCs to address focus efforts. The conditions are discussed in
Section 2.1.
Through the WQIP and adaptive management process. Responsible Agencies are expected to analyze
decision making and resource allocation and adapt goals, strategies and associated schedules, where
needed, to improve upon program effectiveness. The iterative process is discussed in Section 2.4.
Figure 8 below shows the HPWQCs in the Carlsbad WMA and focus areas the Responsible Agencies have
determined to concentrate their WQIP efforts through JRMP implementation.
Figure 8: Carlsbad Watershed Management Area - Highest Priority Water Quality Conditions
The remainder of the document includes the: interim and final numeric goals; strategies and schedules
established by the Responsible Agencies to address the HPWQCs and PWQCs; and HA specific
discussions of monitoring and assessment. The goals, strategies, monitoring and assessment are
discussed by HA within this section.
The following guide is provided to orient the reader to the structure of the remainder of the document.
Hydrologic Area Implementation
Page 47
Each section introduces one of the six HAs. Included in the description is a listing of the HPWQCs and
PWQCs for the particular HA. The reader is provided with a map of the HA showing where program core
strategies will be implemented and also focus areas where Responsible Agencies will implement
modified or additional strategies - see Figure 9 below for an example.
HYDROLOGIC AREA OVERVIEW
Major Roadways Rivers and Creeks Waterbodies
•
Municipal Boundaries Hydrologic Area Boundary Hydrologic Area
Figure 9: Example Hydrologic Area Map
A table of known potential sources of pollutants and stressors associated with the HPWQCs is provided
as reference. Each table identifies the inventoried sites and facilities and their associated pollutant
loading potential^. As a part of the iterative process. Responsible Agencies will continue to conduct
assessments of the sources and their pollutant loading potential and update these tables as data and
information is available.
As determined in the 2005 and 2011 Long-Term Effectiveness Assessments (MOE)
Hydrologic Area Implementation
Page 48
Following the HA source inventory and pollutant loading table, applicable goals are presented in tabular
format. Any interim and final numeric goals that are applicable to the entire HA are presented along
with their associated schedules. See the example goals table below (this table could be applicable at the
HA or focus area levels).
Goals Schedule
Interim Goals
If
Final Goals
Interim Goal
2018
(2013-2018)
Interim Goal
2023
(2013-2018)
Interim Goal
2028
(2023-2028)
Interim Goal
2033
(2028-2033)
Final Goal
2038
(2033-2038)
10% reduction in
anthropogenic
surface water runoff
at selected outfalls
20% reduction in
anthropogenic
surface water runoff
at selected outfalls
40% reduction in
anthropogenic
surface water runoff
at selected outfalls
60% reduction in
anthropogenic
surface water runoff
at selected outfalls
80% reduction in
anthropogenic
surface water runoff
at selected outfalls
Figure 10: Example Goals Table
For each HA, the document presents strategies to be implemented throughout the HA in tabular format.
These are strategies that the Responsible Agencies will either implement on a hydrologic area-wide
basis (within their respective jurisdiction) or within specific focus areas. Target pollutants, target sources
and planned implementation schedules are included in the table as well. See Figure 11 below for an
example strategy table.
Hydrologic Area Implementation
Page 49
WATER QUALITY IMPROVEMENT STRATEGIES
strategies: Listof strategies to be implemented in Hydrologic Area
^ Jurisdictions: Jurisdictions implementation strategy and location
^ Target Sources: Identified sources addressed by strategies
^ Target Pollutants: Pollutant categories addressed by strategies
^ Implementation Schedule: When strategy will be implemented
^ Location Details: More specific descnption of where strategies will be implemented - could be specific basins
Location Details: More specific descnption of where strategies will be implemented - could be throughout the
entire hydrologic area (HA)
^ Optional Strategies: Strategies that may be implemented, but cun^ently do not have specific timeframes for
implementation
Figure 11: Example Hydrologic Area Strategy Table
In each of the Hydrologic Area Strategy tables, the location detail "HA Wide" means that the
Responsible Agency plans to implement that particular strategy throughout their own jurisdictional
boundaries within the HA.
Hydrologic Area Implementation
Page 50
The document then moves into specific focus areas within a HA. Discussion of strategies and goals to
address HPWQCs are presented. Individual focus area maps (Figure 12) are presented showing the
boundaries of the identified area where focus area strategies will be implemented.
FOCUS AREA SPECIFIC INFORMATION
Major Roadways Rivers and Creeks Waterbodies
•
Municipal Boundaries n
Hydrologic Area Boundary
Hydrologic Area
Figure 12: Example Focus Area
Numeric goals associated with focus areas are presented in a tabular format, as shown in Figure 10
above. Lastly, brief descriptions of the focus area strategies are provided.
Hydrologic Area Implementation
Page 51
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Hydrologic Area Implementation
Page 52
3.1 Loma Alta HA (904.1)
The Loma Alta HA is the northernmost HA ofthe Carlsbad WMA. It is approximately 6,300 acres in area,
comprising 5% of the WMA. The HA extends inland about 7.3 miles and the highest elevation within the
drainage area is 460 feet above mean sea level. The primary receiving waters in the HA are Loma Alta
Creek which drains into the Loma Alta Slough and the Pacific Ocean. The HA is located almost entirely
inside the City of Oceanside with less than 4% in the City of Vista and a portion of two parcels in the
County of San Diego.
During the initial phase of the WQIP process, assessment of existing data determined that PWQCs within
the Loma Alta HA include: eutrophic conditions at the Loma Alta Slough; indicator bacteria in the Loma
Alta Slough; Indicator bacteria at the Pacific Ocean shoreline at Loma Alta Creek Mouth; and Toxicity in
Loma Alta Creek. Of these PWQCs, the HPWQC in the Loma Alta HA was determined to be eutrophic
conditions (dry weather conditions) at the Loma Alta Slough (June 2014 B.2 Report).
Figure 13 below, shows the Loma Alta HA, HPWQC and focus areas. The focus areas and their associated
strategies and goals are described below.
Figure 13: Loma Alta Hydrologic Area Highest Priority Water Quality Conditions and Focus Areas
Loma Alta HA (904.1)
Page 53
3.1.1 Loma Alta HA Sources
The following table presents a list of inventoried sources and their association with HPWQCs and PWQCs
and pollutant loading potential (2011 LTEA).
Table 17: Pollutant Generating Sources - 904.1 Loma Alta Hydrologic Area
Pollutant Source Loading Potential^
Inventory Sites/Facilities^ Quantities^ Metals Oil & Grease Sediment Pesticides Nutrients Bacteria/Pathogens Dissolved Minerals Organics Toxicity Animal Facilities 10 N UL L UK L L N L UK
Auto Repair, Fueling, or Cleaning 92 L L UL UL UK UL L L UK
Auto Parking Lots or Storage 6 L L L UK UK UK UL L UK
Auto Body Repair or Painting 28 L L UL UL UL UL L L UK
Nurseries/Greenhouses 4 L UL L L L L UL UL UK
Building Materials Retail 2 L L L UL UL UL UL L UK
Cliemical and Allied Products 4 UK UK UK UK UK UL N L UK
Concrete Manufacturing 6 L L L UL UL UL UL L UK
Eating or Drinking Establishments 123 N L UL UK UK L UL L UK
Equipment Repair or Fueling 14 L L UL UL UK UL UL L UK
Fabricated Metal 17 L L UK UK UK UL UL L UK
Food Manufacturing 8 UL UL UL UL UL UL UL UL UK
General Contractors 54 UL UL L UL UL UL UL UL UK
General Industrial 62 L L UK UK UK UK UK L UK
General Retail 125 UL UL L UL UL UL UL UL UK
Institutional 6 L UK UK UK UK UL UK UK UK
Motor Freight 12 L L UK UK UK UK UL L UK
Offices 70 UK UK UK UK UK UK UK UK UK
Parks and Rec (incl. Golf, Cemetery) 1 UK UK UK UK L UK UL UK UK
Pest Control Services 6 N UK N L N UK N UK UK
Pool and Fountain Cleaning 2 N N N N UK N N UK UK
Primary Metal 8 L UK UK UK UK UL N UK UK
Stone/Glass Manufacturing 8 L L L UL UL UL UL L UK
Storage/Warehousing 14 L L L UL UL UL UL L UK
Municipal 34 N N L N N UK UL N UK
Construction Varies" UL UL L UL UL UL L UL UK
Residential 2,025 acres L L L L L L L L UK
The highest threat-to-water-quality (TTWQ) rated sources within each HA based on the HPWQC are identified in the table (yellow highlight
signifies HPWQC). The HPWQC is associated with the sources that are likely to generate those pollutants (blue highlight). The PWQC is
highlighted in green and the associated sources that are likely to generate those pollutants are depicted with an "I".
1: other sources are not reported in this table including: Land Development and Non-inventoried Businesses
2: Quantities based on the Responsible Agencies FY 2012 JURMP Annual Reports
3: Pollutant Source Loading Potential taken from LTEA 2011; N = None, UK = Unknown, UL = Unlikely, L = Ukely
4: The quantity of construction sites is dynamic due to projects starting and completing at any given time.
Loma Alta HA (904.1)
Page 54
3.1.2 Loma HA Area Goals and Strategies
3.1.2.1 Loma Alta HA Goals
Based on the objectives for improving water quality conditions in the Loma Alta HA, the Responsible
Agencies have established the following goals for the Hydrologic Area:
Table 18: Loma Alta HA Interim and Final Numeric Goals
Interim Goal Interim Goal Final Goal
(2013-2018)
2018^ (2018-2023)^ 2023
10% reduction in anthropogenic
persistent^ dry weather flows from
three major MS4 outfalls discharging to
Loma Alta Creek and/or tributary
Loma Alta Slough Conditions Between
May-October:
1) 50% reduction in anthropogenic
persistent dry weather flows at
the three outfalls addressed
through 2018
2) 25% reduction in additional (other
outfalls in watershed)
anthropogenic persistent flows
identified during dry weather
monitoring program implemented
in 2015 and in subsequent years
^ Flow reduction goals are currently based on best professional judgment as current flow data is not available. The goals may be
adapted as monitoring data/information is gathered, analyzed and baselines are established.
^ Persistent flows are defined in the Permit (Order No. R9-2013-0001) as: the presence of flowing, pooled, or ponded water
more than 72 hours after a measurable rainfall event of 0.1 inch or greater during three consecutive monitoring and/or
inspection events. All other flowing, pooled, or ponded water is considered transient.
1)
2)
Macroalgal Biomass less than
90g dry wt./m^
Macroalgal cover less than 50%
The means for achieving these goals are identified in the strategies discussion below. Mechanisms for
measuring progress towards and ultimately achieving these goals are discussed in the monitoring and
assessment sections.
3.1.2.2 Loma Alta HA Strategies
The following table identifies the Water Quality Improvement Strategies to be implemented throughout
the entire Loma Alta HA and in specific focus areas of the HA. In addition to the planned strategies,
optional strategies are identified that may be implemented based on circumstances related to the
progress Responsible Agencies make towards numeric goals and funding. The strategies associated with
the focus areas are described further in the sub-sections below.
As the Responsible Agencies implement strategies and analyze assessment data, it is expected that
these strategies and schedules may change through an iterative and adaptive management process.
Loma Alta HA (904.1)
Page 55
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3.1.3 Loma Alta HA Focus Areas
Concentrating program efforts in specific geographic areas to address known or suspected sources of
discharges and pollutants are expected to improve the effectiveness of the strategies and activities.
Based on the Responsible Agencies review of the characteristics of the Loma Alta HA, several areas of
focus were selected for concentrated program efforts. These focus areas include the Oceanside
jurisdiction within the HA (Figure 14), the Collins Basin Drainage Area, the Temple Heights Business Park
Drainage Area, and an Oceanside/Vista Residential Area. The goals and strategies for these focus areas
are summarized below.
3.1.3.1 City of Oceanside
The City of Oceanside covers approximately 97% of the entire Loma Alta HA. Within the Oceanside
jurisdictional boundaries, there are many areas where landscapers/gardeners provide landscape
services, including fertilizer and pesticide applications, trimming and planting. Addressing this target
audience on an HA basis will concentrate resources towards addressing practices associated with
nutrients that may be contributing to eutrophic conditions at the Loma Alta Slough.
Figure 14: Oceanside Jurisdiction within Loma Alta HA
Loma Alta HA (904.1)
Page 58
Oceanside Jurisdiction in Loma Alta HA Interim and Final Numeric Goals
Although there are not specific interim and final numeric goals established for this focus area, the
strategies are anticipated to works towards the goals presented in Section 2.1.2.1. that are applicable to
the entire Loma Alta HA.
Oceanside Jurisdiction in Loma Alta HA Strategies
The City of Oceanside will implement its program core strategies throughout its jurisdictional boundaries
of the Loma Alta HA. In addition to the core jurisdictional strategies, the following summarizes
supplemental or modified core strategies planned for implementation in the Loma Alta HA to target
sources of pollutants and discharges.
The selected strategies are expected to have multi-pollutant benefits and intended to address non-
stormwater flows and reducing the source loading of nutrients and other pollutants related to the
priority water quality conditions. Reducing non-stormwater flows: (1) reduces the loading of pollutants
discharged through the MS4 system; (2) reduces the amount of indicator bacteria regrowth and
contributions that occurs with accumulated biofilm in MS4 systems that requires water; and (3) reduces
the wet-weather contribution of indicator bacteria from scoured biofilm under higher velocity flows
from storm discharges.
To accomplish the multi-benefit objectives, the City of Oceanside will supplement its core jurisdictional
program by implementing the following strategies:
1) Community Based Social Marketing - Private Landscapers
Observation Research
This project would begin with observational research to identify target behaviors of landscape
workers which may be linked to polluted non-storm water discharges and runoff from a selected
MS4 draining a residential neighborhood in the Loma Alta watershed. The targeted neighborhood
would be selected based on long-term water quality and observational monitoring where a
persistently flowing outfall has been identified. The observations would focus on identifying
concrete behaviors by observing what is happening in the target community. Examples of these
behaviors could be fertilizer application practices and how green waste is gathered and disposed.
Thirty observation visits are proposed which will provide minimum statistical validity and adequately
represent all times ofthe day (AM/mid-day/PM) and weekdays/weekends. Enforcement actions will
be implemented if an activity is an immediate threat to water quality and human health. If it is
determined that the behaviors are not contributing to anthropogenic persistent flows, sources of
the flows will be further researched to determine if the flows are a groundwater source or other
permitted discharge allowed within that outfall drainage area.
Improvements in MS4 discharge water quality and/or reductions in pollutant loading at the outfall
will be quantified using a combination of flow measurements and grab sample collections. Baseline
measurements will be taken prior to implementing any outreach programs within the upstream
drainage area. Samples will be analyzed by a qualified laboratory for constituents related to
impairments in the receiving water. Measurements collected during and after the outreach
implementation period will be used to assess the relative effectiveness ofthe program on reducing
pollutant loadings and/or non-stormwater flows from the selected MS4 outfall. Both the baseline
and post-implementation periods will require an adequate number of sampling points to ensure
statistical significance in establishing whether the program implementation correlates with changes
in discharge water quality.
Loma Alta HA (904.1)
Page 59
focus groups with landscape gardeners
Focus groups offer an additional opportunity to survey the target audience face-to-face and identify
the barriers that impede those individuals from engaging in behaviors that protect water quality.
This approach enhances the likelihood of developing programs that maximize behavior change
among the target audience. This task would involve recruiting five landscape gardeners to conduct a
30-minute interview. To encourage participation in the focus groups, an incentive will be offered to
the target audience such as a specific dollar amount to participate in the interview and/or a light
lunch.
Landscape gardeners would be recruited in collaboration with the local compost facility Agri-Service.
This facility accepts green waste from landscape gardeners in the City of Oceanside as well as other
commercial landscape operators. When gardeners deliver their materials to the compost facility,
they would be handed a recruitment piece requesting their participation in the focus group. All
materials would be provided in Spanish and a Spanish speaker would conduct the interviews.
Implementation
Based on the results from the observation research and the focus group component, behavior
change tools will be selected based on their fit with the identified barriers and benefits. This
information will drive the development ofthe overall outreach campaign for pilot testing.
Once the appropriate methodologies for pilot testing the developed strategies are designed, the
target audience will be provided with detailed protocols and instructions for pilot implementation.
This information will be distributed by Agri-Service staff to the target audience during normal
operating hours.
Based on the successful strategies identified during pilot testing a series of strategies or toolkits will
be applied more broadly to groups that share similar barrier and benefit profiles for the target
behavior. Improvements in MS4 discharge water quality and/or reductions in pollutant loading at
the outfall will be quantified using a combination of flow measurements and grab sample collections
as described above.
It will also be determined if the target audience can be a conduit to providing homeowners with
water efficient landscape incentive programs being offered by Metropolitan Water District (MWD)
and the San Diego County Water Authority.
2) Ultraviolet Bacteria Treatment Facility
The City of Oceanside will continue to operate the ultraviolet (UV) treatment system just upstream
of Buccaneer Beach between May and September each year. The system actively eliminates 99% of
the indicator bacteria passing through the system.
The treatment facility consists of piping flows from an existing diversion structure by gravity from
the lagoon through a 2 micron fine screen to a wet well where the flow is pumped into two large
sand filters followed by two UV disinfection units housed in a reinforced concrete building. The
treated water is discharged through a pipe extended along the existing section of rip-rap that runs
along the north side of the Loma Alta Creek outlet at Buccaneer Beach. During wet weather months
(November through April), with increased flow in the creek, the lagoon is periodically open to the
ocean and the UV system is bypassed.
Loma Alta HA (904.1)
Page 60
3.1.3.2 Collins Basin and Temple Heights Drainage Areas
The City of Oceanside has identified two drainage basins as focus areas with similar planned strategies:
Collins Basin Drainage Area and Temple Heights Drainage Area. Both are described in more detail below.
Collins Basin Drainage Area
The Collins Basin Drainage Area is located mid-watershed and conveys discharges from surrounding
commercial and light industrial properties to a series of detention basins, prior to discharging to Loma
Alta Creek. The Collins Basin drainage includes commercial and industrial land uses, streets, buildings,
parking lots and landscaped areas - see Figure 15 below.
IMilet
0 0 05 01 0 2
Figure 15: Collins Basin Drainage Area/Focus Area
Temple Heights Drainage Area
The Temple Heights Drainage Area is a commercial and industrial area located at the headwaters of the
watershed that discharges to two MS4 outfalls prior to discharging to Loma Alta Creek. Temple Heights
is primarily office buildings and light industrial land uses and includes streets, buildings, parking lots and
landscaped areas, see Figure 16 below.
Loma Alta HA (904.1)
Page 61
Figure 16: Temple Heights Drainage Area/Focus Area
Collins Basin and Temple Heights Drainage Area Interim and Final Numeric Goals
Although there are not specific interim and final numeric goals established for these focus areas, the
strategies are anticipated to work towards the goals presented in Section 3.1.2.1. that are applicable to
the entire Loma Alta HA.
Collins Basin and Temple Heights Drainage Area Strategies
The City of Oceanside will implement its program core strategies within the Collins Basin and Temple
Heights Drainage Area. In addition to the core jurisdictional strategies, the following summarizes
supplemental or modified core strategies planned for implementation in the Collins Basin and Temple
Heights areas to address the sources of pollutants and discharges.
The selected strategies are expected to have multi-pollutant benefits and intended to address non-
stormwater flows and reducing the source loading of nutrients. Reducing non-stormwater flows: (1)
reduces the loading of pollutants such as nutrients, pesticides, bacteria and trash discharged through
MS4 system; (2) reduces the amount of indicator bacteria regrowth and contributions that occurs with
accumulated biofilm in MS4 systems that requires water; and (3) reduces the wet-weather contribution
of indicator bacteria from scoured biofilm under higher velocity flows from storm discharges.
Loma Alta HA (904.1)
Page 62
To accomplish the multi-benefit objectives in the two areas, the City of Oceanside will supplement its
core jurisdictional program by implementing the following strategies in these focus areas:
1) Runoff and Nutrients Source Reduction
Preliminary Assessment
During Fiscal Years (FY)s 2015 and 2016, the City of Oceanside will:
• Conduct observations to confirm the flows from these focus areas are persistent - FY 2015
and FY 2016;
• Identify, through observations, the common categories of non-storm water discharges to
the MS4 in the first year of assessment - FY 2015;
• Identify, through observations, the greatest dischargers of non-storm water within the focus
area-FY 2015; and
• Categorize and prioritize the discharges to inform the education programs and/or
enforcement mechanisms to focus on the specific problems or issues.
Source Reductions
Based on findings from the preliminary assessment, the City of Oceanside will make determinations
of the most appropriate strategies to implement in subsequent years. The following strategies may
be implemented to address identified issues:
• Irrigation runoff reduction strategies;
• Fertilizer use and application timing/frequency surveys;
• Water conservation rebate programs for commercial properties;
• Inspection of Treatment Control BMPs and verification of maintenance records from
properties within this drainage that have these engineered BMPs installed.
• Incorporate detailed education information specific to nutrients and bacteria during
commercial and industrial facility inspections to prevent illegal discharges to the MS4 based
on non-storm water discharge findings. Potential outreach tasks and materials could
include:
o Potential outreach tasks and materials could include mailing lists, door-to-door
handouts, collaboration with Homeowners Association (HOA) board of directors or
property management companies
o Community meetings with City of Oceanside staff, presentations at regular HOA
briefings
o Offer irrigation incentive programs for homeowners within the focus area - Leverage
existing rebates through San Diego County Water Authority (SDCWA), MWD, and
Vista Irrigation District (VID)
• Implement an enhanced inspection program within the commercial and industrial area to
identify potential illegal discharges
2) Optional Strategies
• Develop a list of potential structural (engineered) BMPs or retrofitting existing structural
BMPs to address flow and/or pollutant issues if the non-structural methods prove
ineffective
• Implement an enhanced treatment control BMP inspection program for the properties
within the assessment drainage area.
o Increase inspection frequency to ensure proper operation and maintenance of
BMPs
Loma Alta HA (904.1)
Page 63
o Classify which BMPs specifically address the target pollutants (nutrients & bacteria)
and ensure proper functioning.
3.1.3.3 Oceanside/Vista Residential Area Near North Avenue
The Oceanside/Vista Residential focus area is located near the headwaters of the watershed that
discharges to an MS4 outfall prior to discharging to Loma Alta Creek. This residential area is primarily
single family residential land uses and includes some common areas and recreational park areas that
include landscaping and turf - see Figure 17 below.
City of Vista
Oceanslde/Vlsta Residential Area
Municipal Boundary
] Loma Alta HA
Oceanside/Vista Residential Area
iigiialGioDe OeoEye .•
Figure 17: Oceanside/Vista Residential Focus Area
Oceanside/Vista Residential Area Interim and Final Numeric Goals
Although there are not specific interim and final numeric goals established for this focus area, the
strategies are anticipated to works towards the goals presented in Section 3.1.2.1. that are applicable to
the entire Loma Alta HA.
Oceanside/Vista Residential Area Strategies
The Cities of Oceanside and Vista will implement their program core strategies within the residential
focused area. In addition to the core jurisdictional strategies, the following summarizes supplemental or
modified core strategies planned for implementation in the residential focus area to address the sources
of pollutants and discharges.
Loma Alta HA (904.1)
Page 64
The supplemental strategies are expected to have multi-pollutant benefits and are intended to address
non-stormwater flows and reduce the source loading of nutrients. Reducing non-stormwater flows: (1)
reduces the loading of pollutants such as nutrients, pesticides, bacteria and trash discharged through
MS4 system; (2) reduces the amount of indicator bacteria regrowth and contributions that occurs with
accumulated biofilm in MS4 systems that requires water; and (3) reduces the wet-weather contribution
of indicator bacteria from scoured biofilm under higher velocity flows from storm discharges.
To accomplish the multi-benefit objectives in the focus area, the Cities of Oceanside and Vista (Cities)
will supplement their core jurisdictional program by implementing the following strategies in these
focus areas:
1) Runoff and Nutrients Source Reduction
Preliminary Assessment
During FYs 2015 and 2016, the Cities will:
• Conduct observations to confirm the flows from this focus area are persistent and from
anthropogenic sources - FY 2015 and FY 2016;
• Identify, through observations, the common categories of non-storm water discharges to
the MS4 in the first year of assessment - FY 2015;
• Identify, through observations, repeat non-storm water violators within the focus area - FY
2015; and
• Categorize and prioritize the discharges to inform the education programs and/or
enforcement mechanisms to focus on the specific problems or issues.
Source Reductions
Based on findings from the preliminary assessment, the Cities will make determinations of the most
appropriate strategies to implement in subsequent years. The following strategies may be
implemented to address identified issues:
• Irrigation runoff reduction strategies;
• Water conservation rebates, free home irrigation conversion consultations
• Smart gardening practices, compost use, proper fertilizer applications
• Shared drainage outreach to identify measurable improvements
o Focus on residential properties
o Continue baseline monitoring at shared drainage area outfalls
o Regular dry-season monitoring aligned with outreach strategies
• Implement educational activities within the upstream residential drainage to prevent illegal
discharges to the MS4 based on non-storm water discharge findings
o Potential outreach tasks and materials could include mailing lists, door-to-door
handouts, collaboration with HOA board of directors or property management
companies
o Community meetings with Cities' staff, presentations at regular HOA briefings
o Offer irrigation incentive programs for homeowners within the focus area - Leverage
existing rebates through SDCWA, MWD, and VID
• Conduct routine code enforcement drive-by inspections of the drainage for other illegal
discharges
Loma Alta HA (904.1)
Page 65
2) Optional Strategies
• Develop a list of potential structural (engineered) BMPs or retrofitting existing structural
BMPs to address flow and/or pollutant issues if the non-structural methods prove
ineffective, e.g., catch basin filters or engineered infiltration devices.
3.1.4 Loma Alta HA Monitoring and Assessment
The Responsible Agencies will conduct the following monitoring in the Loma Alta HA including the
collective watershed-wide monitoring activities described in Section 2.5 :
• Progress Toward Interim and Final Goals
• Loma Alta Special Study
• MS4 Outfall Monitoring (as described in Section 2.5)
• JRMP Implementation (as described in Section 2.5)
• Regulations and Policy (as described in Section 2.5)
Progress Toward Interim and Final Goals
To assess progress toward achieving the interim and final goals, the Loma Alta HA Responsible Agencies
will monitor selected outfalls periodically specifically for flow conditions, e.g., rates and volumes. At
select outfalls, in addition to flow conditions, the Responsible Agencies will collect the following data as
part of the MS4 Outfall Monitoring Program, at minimum, during dry weather conditions:
• Total Dissolved Solids • Nitrate • Zinc
• Total Suspended Solids • Total Kjeldhal Nitrogen • Total Coliform
• Total Hardness • Ammonia • Fecal Coliform (or E. Coli)
• Total Phosphorus • Cadmium • Enterococcus
• Orthophosphate • Copper
• Nitrite • Lead
In addition, the selected outfalls will collect data to evaluate applicable NALs and 303d listed
constituents as proposed in the MS4 Outfall Monitoring Plan that provides a tailored analyte list per HA.
In order to assess program impacts, the Responsible Agencies will establish baseline flow conditions. It is
anticipated that this will occur during the dry weather season of 2015. Future monitoring will provide
flow conditions periodically to calculate percent change from baseline conditions. These calculated
percent changes in flow conditions will be the assessment used to determine the progress towards
achieving interim goals in the Loma Alta HA.
The City of Oceanside, with participating agencies, will also conduct a special study that will inform the
data collection and assessment for determining progress towards achieving the final goals for the Loma
Alta HA. Details ofthe special study are below.
Loma Alta HA Special Study
This study involves a long-term water quality monitoring program forthe Loma Alta Slough to assess the
effectiveness of the City of Oceanside's watershed management efforts through tracking the levels of
nutrients and algae growth during the summer impairment period. It will also utilize monitoring data
from MS4 outfalls discharging to Loma Alta Creek. The study is directly related to nutrients, the Highest
Priority Water Quality Condition in the Loma Alta Creek HSA. The study:
• Will address data gaps related to variability in the extent and magnitude of the eutrophic
condition as well as nutrient levels entering Loma Alta Slough.
Loma Alta HA (904.1)
Page 66
• Is directly related to nutrients and the effects they have on the receiving water, which is the
Highest Priority Water Quality Condition in the Loma Alta Creek HSA.
• Will help develop information necessary to more effectively address sources contributing to the
Highest Priority Water Quality Condition.
The objectives of the study are as follows:
• Develop a water quality monitoring program for the Loma Alta Slough (Slough Monitoring Plan)
that will allow the City of Oceanside to track progress toward reducing nutrient discharges into
the Slough and eliminate the eutrophication impairment. The plan will also be accompanied by a
Quality Assurance Project Plan (QAPP). The County of San Diego will participate in an advisory
role, reviewing the work plan, developing QAPP, and monitoring plan.
• Perform annual water quality monitoring activities per the Slough Monitoring Plan. This includes
a watershed nutrient loading and macroalgae monitoring component. The monitoring will occur
every summer from 2016 to 2022.
• Prepare annual monitoring reports summarizing the monitoring activities, data analyses, and
assessments from each annual monitoring period.
• Perform an effectiveness assessment at the end of the Slough monitoring program, comparing
both data from the City of Oceanside's MS4 outfall monitoring and the receiving water
component. Comparisons will help determine whether reductions in MS4 discharges or
pollutant loading, as a result of the City of Oceanside's watershed management strategies, has
resulted in measurable improvements to the eutrophication impairment.
The Loma Alta Slough monitoring program will involve two main components. The first component uses
watershed loading methods to monitor the contribution of nutrients into the Slough from Loma Alta
Creek. Ambient creek water monitoring data will be coupled with the City of Oceanside's persistent non-
storm water flow MS4 monitoring information to assess the total anthropogenic contribution of
nutrients to the system. The second component involves collecting data directly related to the Slough's
response to the nutrient loading, specifically macroalgae biomass and cover data. Additional water
quality monitoring for dissolved oxygen will also serve as a secondary metric to identify trends in the
eutrophication impairment. The City of Oceanside anticipates that together these components will
provide a tangible measure of improvement of the impairment and show progress toward achieving the
final numeric goals set forth in the WQIP for the Loma Alta HSA. The assessment and reporting will be
scheduled to allow for inclusion in the WQIP Annual Reports, including an interim assessment at the
time of the ROWD/Munlclpal Permit renewal In 2018. Data collection will occur every summer from
2016 to 2022. Each annual event will be conducted for one period in July and one period in August.
Watershed nutrient loading information will be collected by establishing a long-term monitoring station
at the boundary of Loma Alta Creek and the Slough. The City of Oceanside may utilize historical receiving
water monitoring locations for the sake of data comparability and consistency. Algae data will be
collected at multiple transect sampling locations within the Slough and will be consistent between
monitoring years to establish a baseline of data during the impairment period. Specific flow
measurement methods, and sample collection and laboratory analysis information will be described in
the detailed work plan and associated QAPP.
Assessment
The Loma Alta HA Responsible Agencies will perform assessments ofthe following elements:
• Progress Toward Interim and Final Goals
• Loma Alta Special Study
Loma Alta HA (904.1)
Page 67
As new data and information becomes available, the Responsible Agencies will perform an integrated
assessment of the findings from the identified focused areas. The integrated assessment will evaluate
the JRMP program implementation in relationship to the findings of the assessment for progress toward
interim and final goals. This integrated assessment would be performed at this scale to identify
relationships between the strategies implemented in the focus areas and outcomes related to the
interim and final goals. The outcomes of this assessment could be used to help determine the
effectiveness and efficiency of selected the strategies implemented.
Longer-term assessments will be performed at the WMA scale as appropriate data and information is
collected and assessed.
Loma Alta HA (904.1)
Page 68
3.2 Buena Vista Creek HA (904.2)
The Buena Vista Creek HA is the fourth largest system within the WMA. The HA extends approximately
10.6 miles inland from the coast and totals approximately 14,400 acres in area, comprising 11% of the
WMA. Buena Vista Creek originates on the western slopes ofthe San Marcos Mountains and discharges
into the Pacific Ocean via Buena Vista Lagoon. The primary receiving waters in the HA are Buena Vista
Creek, the Buena Vista Lagoon, and the Pacific Ocean. The largest portion ofthe HA is in the City of Vista
(45%), with the remaining in Oceanside, Carlsbad, and San Diego County.
During the initial phase of the WQIP process, assessment of existing data determined that the PWQCs
within the Buena Vista Creek HA include: indicator bacteria at the Buena Vista Lagoon;
sediment/siltation in Buena Vista Lagoon; and nutrients in Buena Vista Lagoon. Of these PWQCs, the
HPWQC in the Buena Vista Creek HA was determined to be indicator bacteria (dry and wet weather
conditions) at the Buena Vista Lagoon (June 2014 B.2 Report).
Figure 18 below, shows the Buena Vista Creek HA, HPWQC and focus areas. The focus areas and their
associated strategies and goals are explained in more detail below.
Buena Vista Creek HA (904.2)
Page 69
Boe,
Buena Vista Lagoon
HPWQC Indicator Bactena I
CB-PAl Focus Area
904.22
;B-PA3 FOCUS Area
904.21
CB-PA2 Focus Area
i Buena Vista Hydrologic Area
Carlsbad WMA CB-PAl Focus Area &
Hydrologic Subareas CB-PA2 Focus Area |
1 Municipal Boundary CB-PA3 Focus Area 1
1 Buena Vista Creek HA BV 06 Basin
HPWQC Open Space
Lakes and Estuaries
Figure 18: Buena Vista Creek Hydrologic Area Highest Priority Water Quality Conditions and Focus Areas
3.2.1 Buena Vista Creek HA Sources
The following table presents a listing of inventoried sources in the Buena Vista Creek HA and their
association with HPWQCs and PWQCs based on source loading potential (2011 LTEA).
0^
Buena Vista Creek HA (904.2)
Page 70
Table 20: Pollutant Generating Sources - 904.2 Buena Vista Creek Hydrologic Area
Pollutant Source Loading Potential^
Inventory Sites/Facilities^ Quantities^ Metals Oil & Grease Sediment Pesticides Nutrients Bacteria/Pathogens Dissolved Minerals Organics roxicity Aggregates/Mining 1 L L L UL UL UL UL L UK
Agriculture 1 L UL L L L L UK UL UK
Animal Facilities 5 N UL L UK L L N L UK
Auto Repair, Fueling, or Cleaning 131 L L UL UL UK UL L L UK
Auto Parking Lots or Storage 16 L L L UK UK UK UL L UK
Auto Body Repair or Painting 19 L L UL UL UL UL L L UK
Nurseries/Greenhouses 28 L UL L L L L UL UL UK
Concrete Manufacturing 1 L L L UL UL UL UL L UK
Eating or Drinking Establishments 391 N L UL UK UK L UL L UK
Equipment Repair or Fueling 8 L L UL UL UK UL UL L UK
Fabricated Metal 6 L L UK UK UK UL UL L UK
Food Manufacturing 3 UL UL UL UL UL UL UL UL UK
General Contractors 26 UL UL L UL UL UL UL UL UK
General Industrial 10 L L UK UK UK UK UK L UK
General Retail 94 UL UL L UL UL UL UL UL UK
Health Services 2 N UL L UK L UL UK L UK
Institutional 2 L UK UK UK UK UL UK UK UK
Motor Freight 3 L L UK UK UK UK UL L UK
Offices 36 UK UK UK UK UK UK UK UK UK
Parks and Rec (incl. Golf, Cemetery) 3 UK UK UK UK L UK UL UK UK
Pest Control Services 1 N UK N L N UK N UK UK
Pool and Fountain Cleaning 1 N N N N UK N N UK UK
Recycling & Junk Yards 2 L L L UL UL UL L L UK
Stone/Glass Manufacturing 3 L L L UL UL UL UL L UK
Storage/Warehousing 9 L L L UL UL UL UL L UK
Municipal 81 N N L N N UK UL N UK
Construction Varies" UL UL L UL UL UL L UL UK
Residential 7,345 acres L L L L L L L L UK
The highest TTWQ rated sources within each HA based on the HPWQC are identified in the table (yellow highlight signifies HPWQC). The
HPWQC is associated with the sources that are likely to generate those pollutants (blue highlight). The PWQC is highlighted in green and the
associated sources that are likely to generate those pollutants are depicted with an "L".
1: other sources are not reported in this table including: Land Development and Non-inventoried Businesses
2: Quantities based on the Responsible Agencies FY 2012 JURMP Annual Reports
3; Pollutant Source Loading Potential taken from LTEA 2011; N = None, UK = Unknown, UL = Unlikely, L = Ukely
4: The quantity of construction sites is dynamic due to projects starting and completing at any given time
Buena Vista Creek HA (904.2)
Page 71 ^1
3.2.2 Buena Vista Creek HA Goals and Strategies
3.2.2.1 Buena Vista Creek HA Goals
Goals have not been established that apply to the entire Buena Vista Creek HA. Separate goals have
been established for each focus area and are presented in the sub-sections below.
5.2.2.2 Buena Vista Creek HA Strategies
The following table identifies the Water Quality Improvement Strategies to be implemented throughout
the entire Buena Vista Creek HA and in specific focus areas of the HA. In addition to the planned
strategies, optional strategies are identified that may be implemented based on circumstances related
to the progress Responsible Agencies make towards numeric goals and funding. The strategies
associated with the focus areas are described further in the sub-sections below.
As the Responsible Agencies implement strategies and analyze assessment data, it is expected that
these strategies and schedules may change through an iterative and adaptive management process.
Buena Vista Creek HA (904.2)
Page 72
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3.2.3 Buena Vista Creek HA Focus Areas
Concentrating program efforts in specific geographic areas to address known or suspected sources of
discharges and pollutants is expected to improve the effectiveness of the strategies and activities.
Based on the Responsible Agencies review of the characteristics of the Buena Vista Creek HA, several
focus areas were selected for concentrating program efforts. These focus areas include CB-PAl, CB-PA2,
CB-PA3, and Buena Vista Basin (BV06). The goals and strategies for these focus areas are summarized
below.
3.2.3.1 CB-PAl Focus Area
The CB-PAl focus area is located immediately south of the Buena Vista Lagoon. This area is a mixture of
single family residential, commercial and multi-family land uses and includes homes, commercial
buildings, apartment complexes, common areas, a school and recreational park areas that include
landscaping and turf, see Figure 19 below.
CB-PA1 Focus Area
I I Carlsbad WMA
r • Hydrologic Subareas
^ Buena Vista Creek HA
CB-PAl
I I HPWQC
•! Pacific Ocean
Figure 19: CB-PAl Focus Area - Buena Vista Creek HA
CB-PAl Interim and Final Numeric Goals
Goals associated with this focus area are summarized in the Table 22 below. These goals have been
established as a part of the initial WQIP development process. As the Responsible Agencies progress
Buena Vista Creek HA (904.2)
Page 75 06
through the first several years of implementation and learn through data collection and analysis, it is
expected that these goals and schedules will likely change. As goals and schedules are adapted, they will
be presented in future WQIP annual reports or updates to the WQIP document.
Table 22: CB-PAl Focus Area, Interim and Final Numeric Goals
interim Goal
(2013-2018)
2018'
Interim Goal
(2018-2023)
2023'
Interim Goal
(2023-2028)
2028'
Interim Goal
(2028-2033)
2033'
Final Goal
(2033-2038)
2038'
10% reduction in
anthropogenic
surface water
runoff
20% reduction in
anthropogenic
surface water
runoff
40% reduction in
anthropogenic
surface water
runoff
60% reduction in
anthropogenic
surface water
runoff
80% reduction in
anthropogenic
surface water
runoff
adapted as monitoring data/information is gathered, analyzed and baselines are established.
The means for achieving these goals are identified in the strategies discussion below. Mechanisms for
measuring progress towards and ultimately achieving these goals are included in the monitoring,
assessment and iterative process sections.
CB-PAl Focus Area Strategies
The City of Carlsbad will implement their program core strategies within the focus area. In addition to
the core jurisdictional strategies, the following summarizes supplemental or modified core strategies
planned for implementation in the focus area to address the sources of pollutants and discharges.
The selected strategies are expected to have multi-pollutant benefits and intended to address non-
stormwater flows and reducing the source loading of bacteria. Reducing non-stormwater flows: (1)
reduces the loading of pollutant constituent discharged through MS4 system; (2) reduces the amount of
indicator bacteria regrowth and contributions that occurs with accumulated biofilm in MS4 systems that
requires water; and (3) reduces the wet-weather contribution of indicator bacteria from scoured biofilm
under higher velocity flows from storm discharges. Removing trash and sediment reduces the bacteria
loading that is attached to the trash and sediment.
To accomplish the multi-benefit objectives in the CB-PAl, the City of Carlsbad will supplement its core
jurisdictional program by implementing the following strategies:
1) Targeted street sweeping in the focus area will be a minimum frequency of every two weeks.
2) Perform pro perty-based inspections/patrol inspections of each property in the CB-PAl at least
once annually. These inspections will include:
a. Visual inspection of all public streets
b. Inspections of each existing development property:
i. Municipal facilities and areas
ii. Each commercial/industrial property
iii. Each residential property
3) Maintain a maximum response time to focus areas for complaints received via Storm Water
Hotline, or other mechanism. The City will respond and arrive on-site within 45 minutes of
notification to eliminate any unauthorized discharge, identify the responsible party and
minimize impacts to receiving waters. This response time is expected to eliminate discharges
Buena Vista Creek HA (904.2)
Page 76
while they are occurring and provide an opportunity to immediately educate or enforce as
necessary.
4) Enhancements to education program to include:
a. Bacteria and other priority pollutant specific education and outreach program to be
conducted in the CB-PAl for residents and commercial facilities related to bacteria and
other priority pollutants. The materials will have an emphasis on discharges to the City's
MS4 and the receiving waters impacts.
b. Developing and implementing a training/seminar for property managers and others that
have direct responsibility for common areas within HOAs and commercial properties.
Educational materials and information will be developed and provided to the managers
for them to distribute to their residents and tenants.
c. As the CB-PAl focus area is a high-tourist area, the City will develop outreach materials
directed specifically to out-of-jurisdiction visitors, including materials for distribution
through hotels, long-term rental properties and commercial businesses.
d. As part of the residential outreach program, the City of Carlsbad will work with residents
and property owners to educate through various means, which may include school
programs, block parties or one-on-one meetings.
5) Implement Technological Program Efficiencies - The City is implementing a new computer
database which will allow for use with mobile devices which will increase the City's response
time to Illicit Discharge Detection and Elimination (IDDE) reports, discoveries, complaints and
monitoring investigations. This new computer database will also streamline inspections and
allow for review of previous information while in the field. It is also anticipated to speed the
enforcement process as well expedite the capture of data for field follow-up. These increases in
the speed at which data is collected and assimilated will improve the efficiencies of the City's
stormwater program.
6) Optional Strategies
• Implement structural (engineered) BMPs or retrofitting existing structural BMPs to address
flow and/or pollutant issues
• Implement offsite alternative compliance program to place water quality improvement
projects in the CB-PAl focus area
3.2.3.2 CB PA2 Focus Area
The CB-PA2 focus area is split into two drainage areas located south of Carlsbad Village Drive and CB-
PAl. The northern portion of the focus area drains to the north towards Buena Vista Lagoon. The
southern portion drains south towards Agua Hedionda Lagoon. This area is a mixture of single family
residential properties, commercial and multi-family land uses and includes homes, commercial buildings,
apartment complexes, common areas, a school and recreational park areas that include landscaping and
turf, see Figure 20 below.
luena Vista Creek HA (904.2)
Page 77
CB-PA2 Focus Area
I I Buena Vista Creek HA
CB-PA2
Pacific Ocean
I Miles
0.15 star Geog'aphics C
anj il'ie G'S iJ4*t Co
Figure 20: CB-PA2 Focus Area - Buena Vista Creek
CB-PA2 Focus Area Interim and Final Numeric Goals
Goals associated with this focus area are summarized in Table 23 below. These goals have been
established as a part of this initial WQIP development process. As the Responsible Agencies progress
through the first several years of implementation and learn through data collection and analysis, it is
expected that these goals and schedules will likely change. As goals and schedules are adapted, they will
be presented in future WQIP annual reports or updates to the WQIP document.
Table 23: CB-PA2 Focus Area, Interim and Final Numeric Goals
Interim Goal
(2013-2018)
2018'
interim Goal
(2018-2023)
2023'
Interim Goal
(2023-2028)
2028'
Interim Goal
(2028-2033)
2033'
Final Goal
(2033-2038)
2038'
10% reduction in
anthropogenic
surface water
runoff
20% reduction in
anthropogenic
surface water
runoff
40% reduction in
anthropogenic
surface water
runoff
60% reduction in
anthropogenic
surface water
runoff
80% reduction in
anthropogenic
surface water
runoff
adapted as monitoring data/information is gathered, analyzed and baselines are established.
Buena Vista Creek HA (904.2)
Page 78
The means for achieving these goals are identified in the strategies discussion below. Mechanisms for
measuring progress towards and ultimately achieving these goals are included in the monitoring,
assessment and iterative process sections.
CB-PA2 Focus Area Strategies
The City of Carlsbad will implement their program core strategies within the focus area. In addition to
the core jurisdictional strategies, the following summarizes supplemental or modified core strategies
planned for implementation in the focus area to address the sources of pollutants and discharges.
The selected strategies are expected to have multi-pollutant benefits and intended to address non-
stormwater flows and reducing the source loading of bacteria. Reducing non-stormwater flows: (1)
reduces the loading of pollutant constituent discharged through MS4 system; (2) reduces the amount of
indicator bacteria regrowth and contributions that occurs with accumulated biofilm in MS4 systems that
requires water; and (3) reduces the wet-weather contribution of indicator bacteria from scoured biofilm
under higher velocity flows from storm discharges. Removing trash and sediment reduces the bacteria
loading that is attached the trash and sediment.
To accomplish the multi-benefit objectives in the CB-PA2, the City of Carlsbad will supplement its core
jurisdictional program by implementing the following strategies:
1) Targeted street sweeping in the focus area will be a minimum frequency of every two weeks.
2) Perform property-based inspections/patrol inspections of each property in the CB-PA2 focus
area at least once annually. These inspections will include:
a. Visual inspection of all public streets
b. Inspections of each existing development property:
i. Municipal facilities and areas
ii. Each commercial/industrial property
iii. Each residential property
3) Maintain a maximum response time for complaints received via Storm Water Hotline, or other
mechanism. The City will respond and arrive on-site within 45 minutes of notification to
eliminate any unauthorized discharge, identify the responsible party and minimize impacts to
receiving waters. This response time is expected to eliminate discharges while they are
occurring and provide an opportunity to immediately educate or enforce as necessary.
4) Enhancements to education program to include:
a. Bacteria and other priority pollutant specific education and outreach program to be
conducted in the CB-PA2 focus area for residents and commercial facilities related to
bacteria and other priority pollutants. The materials will have an emphasis on discharges
to the City's MS4 and the receiving waters impacts.
b. Developing and implementing a training/seminar for property managers and others that
have direct responsibility for common areas within HOAs and commercial properties.
Educational materials and information will be developed and provided to the managers
for them to distribute to their residents and tenants.
c. As part of the residential outreach program, the City of Carlsbad will work with residents
and property owners to educate through various means, which may include school
programs, block parties or one-on-one meetings.
Buena Vista Creek HA (904.2)
Page 79
5) Implement Program Efficiencies - The City is implementing a new computer database which will
allow for use with mobile devices which will increase the City's response time to IDDE reports,
discoveries, complaints and monitoring investigations. This new computer database will also
streamline inspections and allow for review of previous information while in the field.
6) Optional Strategies
• Implement structural (engineered) BMPs or retrofitting existing structural BMPs to address
flow and/or pollutant issues
• Implement offsite alternative compliance program to place water quality improvement
projects in the CB-PA2 focus area
3.2.3.3 CB-PA3 Focus Area
The CB-PA3 focus area is located approximately one-third of the way up the Buena Vista Creek HA. This
area is a mix of single family residential properties and a portion of the Carlsbad Mall with a single
outfall, see Figure 21 below. Monitoring has identified persistent flow and bacteria exceedances from
the outfall.
Figure 21: CB-PA3 Focus Area - Buena Vista Creek
Buena Vista Creek HA (904.2)
Page 80
CB-PA3 Focus Area Interim and Final Numeric Goals
Goals associated with this focus area are summarized in Table 24 below. These goals have been
established as a part of this initial WQIP development process. As the Responsible Agencies progress
through the first several years of implementation and learn through data collection and analysis, it is
expected that these goals and schedules will likely change. As goals and schedules are adapted, they will
be presented in future WQIP annual reports or updates to the WQIP document.
Table 24: CB-PA3 Focus Area, Interim and Final Numeric Goals
Interim Goal
(2013-2018)
2018'
Interim Goal
(2018-2023)
2023'
Interim Goal
(2023-2028)
2028'
Interim Goal
(2028-2033)
2033'
Final Goal
(2033-2038)
2038'
10% reduction in
anthropogenic
surface water
runoff
20% reduction in
anthropogenic
surface water
runoff
40% reduction in
anthropogenic
surface water
runoff
60% reduction in
anthropogenic
surface water
runoff
80% reduction in
anthropogenic
surface water
runoff
adapted as monitoring data/information is gathered, analyzed and baselines are established.
The means for achieving these goals are identified in the strategies discussion below. Mechanisms for
measuring progress towards and ultimately achieving these goals are included in the monitoring,
assessment and iterative process sections.
CB-PA3 Focus Area Strategies
The City of Carlsbad will implement their program core strategies within the focus area. In addition to
the core jurisdictional strategies, the following summarizes supplemental or modified core strategies
planned for implementation in the focus area to address the sources of pollutants and discharges.
The selected strategies are expected to have multi-pollutant benefits and intended to address non-
stormwater flows and reducing the source loading of bacteria. Reducing non-stormwater flows: (1)
reduces the loading of pollutant constituent discharged through MS4 system; (2) reduces the amount of
indicator bacteria regrowth and contributions that occurs with accumulated biofilm in MS4 systems that
requires water; and (3) reduces the wet-weather contribution of indicator bacteria from scoured biofilm
under higher velocity flows from storm discharges. Removing trash and sediment reduces the bacteria
loading that is attached the trash and sediment.
To accomplish the multi-benefit objectives in the CB-PA3, the City of Carlsbad will supplement its core
jurisdictional program by implementing the following strategies:
1) Targeted street sweeping in the focus area will be a minimum frequency of every two weeks.
2) Perform property-based inspections/patrol inspections of each property in the CB-PA3 focus
area at least once annually. These inspections will include:
c. Visual inspection of all public streets
d. Inspections of each existing development property:
i. Municipal facilities and areas
ii. Each commercial/industrial property
iii. Each residential property
3) Maintain a maximum response time for complaints received via Storm Water Hotline, or other
mechanism. The City will respond and arrive on-site within 45 minutes of notification to
\uena Vista Creek HA (904.2)
Page 81
eliminate any unauthorized discharge, identify the responsible party and minimize impacts to
receiving waters. This response time is expected to eliminate discharges while they are
occurring and provide an opportunity to immediately educate or enforce as necessary.
4) Enhancements to education program to include:
a. Bacteria and other priority pollutant specific education and outreach program to be
conducted in the CB-PA3 focus area for residents and commercial facilities related to
bacteria and other priority pollutants. The materials will have an emphasis on discharges
to the City's MS4 and the receiving waters impacts.
b. Developing and implementing a training/seminar for property managers and others that
have direct responsibility for common areas within HOAs and commercial properties.
Educational materials and information will be developed and provided to the managers
for them to distribute to their residents and tenants.
c. As part of the residential outreach program, the City of Carlsbad will work with residents
and property owners to educate through various means, which may include school
programs, block parties or one-on-one meetings.
5) Implement Program Efficiencies - The City is implementing a new computer database which will
allow for use with mobile devices which will increase the City's response time to IDDE reports,
discoveries, complaints and monitoring investigations. This new computer database will also
streamline inspections and allow for review of previous information while in the field.
6) Optional Strategies
• Implement structural (engineered) BMPs or retrofitting existing structural BMPs to address
flow and/or pollutant issues
• Implement offsite alternative compliance program to place water quality improvement
projects in the CB-PA3 focus area
3.2.3.4 City of Vista -Buena Vista 06 (BV06) Basin
The Buena Vista 06 (BV06) Basin is a large sub-basin in the upper one-third ofthe Buena Vista Creek HA.
The basin is completely within the City of Vista jurisdictional boundaries. The basin has high-density land
use with a mixture of single family residential, commercial and multi-family land uses and includes
homes, commercial buildings, apartment complexes, common areas, several schools and recreational
park areas that include landscaping and turf, see Figure 22 below.
The majority of this basin was developed prior to implementation of the City's Standard Urban
Stormwater Mitigation Plan (SUSMP); therefore there relatively few treatment control BMPs have been
established.
Buena Vista Creek HA (904.2)
Page 82
Figure 22: BV06 Basin Focus Area
BV06 Basin Focus Area Interim and Final Numeric Goals
Goals associated with this focus area are summarized in Table 25 below. These goals have been
established as a part of this initial WQIP development process. As the Responsible Agencies progress
through the first several years of implementation and learn through data collection and analysis, it is
expected that these goals and schedules will likely change. As goals and schedules are adapted, they will
be presented in future WQIP annual reports or updates to the WQIP document.
Table 25: BVOG Basin Focus Area, Interim and Final Numeric Goals
Interim Goal
(2013-2018)
2018
Interim Goal
(2018-2023)
2023
Interim Goal
(2023-2028)
2028
Interim Goal
(2028-2033)
2033
Final Goal
(2033-2038)
2038
5% reduction in
anthropogenic dry-
weather surface
water runoff
10% reduction in
anthropogenic dry-
weather surface
water runoff
35% reduction in
anthropogenic dry-
weather surface
water runoff
60% reduction in
anthropogenic dry-
weather surface
water runoff
80% reduction in
anthropogenic dry-
weather surface
water runoff
^ Flow reduction goals are currently based on best professional judgment as current flow data is not available. The goals may be
adapted as monitoring data/information is gathered, analyzed and baselines are established.
The means for achieving these goals are identified in the strategies discussion below. Mechanisms for
measuring progress towards and ultimately achieving these goals are included in the monitoring,
assessment and iterative process sections.
Buena Vista Creek HA (904.2)
Page 83
BV06 Basin Focus Area Strategies
In addition to the core jurisdictional strategies, the following summarizes supplemental or modified core
strategies planned for implementation in the focus area to address the sources of pollutants and
discharges.
The selected strategies are expected to have multi-pollutant benefits and intended to address non-
stormwater flows and reduce the source loading of bacteria. Reducing non-stormwater flows: (1)
reduces the loading of pollutant constituent discharged through MS4 system; (2) reduces the amount of
indicator bacteria regrowth and contributions that occurs with accumulated biofilm in MS4 systems that
requires water; and (3) reduces the wet-weather contribution of indicator bacteria from scoured biofilm
under higher velocity flows from storm discharges.
To accomplish the multi-benefit objectives in the BV06 Basin, the City of Vista will supplement its core
jurisdictional program by implementing the following strategies:
1) Irrigation Runoff Reduction Program
The objective of the Irrigation Runoff Reduction Program (IRRP) is to eliminate or reduce dry
weather flow contributions coming from irrigation runoff, regardless of the time of day the
discharges occur. Core program elements include:
Developing municipal codes that prohibit irrigation runoff
Developing educational materials and outreach program specific towards irrigation runoff
Assessing dry weather flows at outfall(s)
Identifying key times to perform site observations
Perform site observations to identify sources of irrigation runoff
Collaboration with City Public Works Department to address municipal property irrigation
systems
Collaboration with VID to identify sources and coordinate programs/outreach
Initiating contact and correspondence with property managers/owners
Periodically assessing flows
Optionally developing and implementing an incentive program
2) Property-Based/Patrol Inspections
The objective of this program is to reduce discharges to the MS4 and provide inspection of existing
development in a more cost-efficient and effective manner. Features include:
• Developing patrol and inspection protocols
• Developing and conducting staff training
• Conducting property-based/patrol inspections
3) Optional Strategies
• Implement structural (engineered) BMPs or retrofitting existing structural BMPs to address
flow and/or pollutant issues
• Implement offsite alternative compliance program to place water quality improvement
projects in the BV06 Basin
3.2.4 Buena Vista Creek HA Monitoring and Assessment
The Responsible Agencies will conduct the following monitoring in the Buena Vista Creek HA including
the collective watershed-wide monitoring activities described in Section 2.5:
• Progress Toward Interim and Final Goals
Buena Vista Creek HA (904.2)
Page 84
• Dry Weather Special study
• MS4 Outfall Monitoring (as described in Section 2.5)
• JRMP Implementation (as described in Section 2.5)
• Regulations and Policy (as described in Section 2.5)
Progress Toward Interim and Final Goals
To assess progress toward achieving the interim and final goals, the Buena Vista Creek HA Responsible
Agencies will monitor selected outfalls periodically specifically for flow conditions, e.g., rates and
volumes. At select outfalls, in addition to flow conditions, the Responsible Agencies will collect the
following data as part of the MS4 Outfall Monitoring Program, at minimum, during dry weather
conditions:
Total Dissolved Solids • Nitrate • Zinc
Total Suspended Solids • Total Kjeldhal Nitrogen • Total Coliform
Total Hardness • Ammonia • Fecal Coliform (or E. Coli)
Total Phosphorus • Cadmium • Enterococcus
Orthophosphate • Copper
Nitrite • Lead
In addition, the selected outfalls will collect data to evaluate applicable NALs and 303d listed
constituents as proposed in the MS4 Outfall Monitoring Plan that provides a tailored analyte list per HA.
In order to assess program impacts, the Responsible Agencies will establish baseline flow conditions. It is
anticipated that this will occur during the dry weather season of 2015. Future monitoring will provide
flow conditions periodically to calculate percent change from baseline conditions. These calculated
percent changes in flow conditions will be the assessment used to determine the progress towards
achieving interim goals in the Buena Vista Creek HA.
Responsible Agencies will also conduct a special study that will inform the data collection and
assessment for determining progress towards achieving the final goals for the Buena Vista Creek HA.
Details of the special study are below.
Buena Vista Creek HA Special Study
A Dry Weather Special Study will be developed to characterize temporal flow and fecal indicator
bacteria patterns at selected persistently flowing major MS4 outfalls during summer dry weather
conditions. The special study is related to indicator bacteria, which has been identified as a Highest
Priority Water Quality Condition for the City of Carlsbad, City of Escondido, City of San Marcos, City of
Solana Beach, and City of Vista and will be implemented in priority areas within their respective
jurisdictions.
The Dry Weather Special Study will address the following questions:
• What is the baseline flow at the specified major MS4 outfalls during summer dry weather
conditions?
• What are the temporal flow patterns at specified major MS4 outfalls during summer dry
weather conditions?
• Are summer dry weather flows at the specified major MS4 outfalls contributing fecal indicator
bacteria to the receiving water(s)?
• What are the temporal patterns of indicator bacteria concentrations at specified major MS4
outfalls?
Buena Vista Creek HA (904.2)
Page 85
The study will:
• Address data gaps related to temporal flow and FIB patterns at selected persistently flowing
major MS4 outfalls during summer dry weather conditions.
• Allow the Responsible Agencies to understand potential sources of flow and therefore more
effectively target and control sources contributing to the Highest Priority Water Quality
Condition.
• Establish a baseline for flow during summer dry weather conditions with which to measure
subsequent flow reductions.
The Responsible Agencies will conduct the special study within the Buena Vista Creek HA to assess at an
outfall level as well as collectively with other outfall data collected under the same special study
throughout the WMA. The following components of the special study will be conducted:
• Collect continuous flow monitoring data at specified major outfalls using automated flow meter
and data logger.
• Conduct monitoring events at selected major outfalls specified in Table 26:
• Collect grab samples and analyze for fecal indicator bacteria (total coliform, fecal coliform, and
Enterococcus) to identify critical conditions for bacteria
• Record visual observations consistent with the transitional outfall monitoring program.
• Collect in-situ physical parameters for pH, temperature, and specific conductivity.
• Perform site observations at key times within the catchment areas and record all observed areas
and/or sources with non-storm water flow.
• Track flow patterns to sources for abatement or further investigation.
Table 26: Dry Weather Data Collection by Jurisdiction for the Buena Vista Creek HA
Item City of
Carlsbad
City of
Vista
Number of Focus Areas in Buena Vista Creek HA 3 1
Number of Outfalls for Continuous Flow Monitoring 3 1
Minimum Time for Continuous Flow Monitoring 2 weeks 2 weeks
Minimum Number of Fecal Indicator Bacteria Samples at
Each Outfall Where Flow is Measured 4 4
Total Number of Bacteria Samples 12 4
Assessment
The Buena Vista Creek HA Responsible Agencies will perform assessments ofthe following elements:
• Progress Toward Interim and Final Goals
• Dry Weather Special Study
As new data and information becomes available, the Responsible Agencies will perform an integrated
assessment of the findings from the identified focused areas. The integrated assessment will evaluate
the JRMP program implementation in relationship to the findings of the assessment for progress toward
interim and final goals. This integrated assessment would be performed at this scale to identify
relationships between the strategies implemented in the focus areas and outcomes related to the
interim and final goals. The outcomes of this assessment could be used to help determine the
effectiveness and efficiency of selected the strategies implemented.
Longer-term assessments will be performed at the WMA scale as appropriate data and information is
collected and assessed.
Buena Vista Creek HA (904.2)
Page 86
3.3 Agua Hedionda HA (904.3)
The Agua Hedionda HA is the third largest within the CaHsbad WMA. The HA, dominated by Agua
Hedionda Creek, extends approximately 10.6 miles inland from the coast and is about 18,800 acres in
area, comprising 14% of the WMA. Agua Hedionda Creek originates on the southwestern slopes of the
San Marcos Mountains in west central San Diego County and discharges into the Pacific Ocean via Agua
Hedionda Lagoon. The primary water bodies in the HA include Aqua Hedionda Creek, Buena Creek,
Letterbox Canyon, Agua Hedionda Lagoon and the Pacific Ocean. Most of the HA is in the City of
Carlsbad (41%); the remainder is in Vista (24%) and San Diego County (24%) and small amounts in
Oceanside and San Marcos.
During the initial phase of the WQIP process, assessment of existing data determined that PWQC within
the Agua Hedionda HA include: indicator bacteria in Agua Hedionda Creek; toxicity in Agua Hedionda
Creek; nutrients in Agua Hedionda Creek; hydromodification impacts in Agua Hedionda Creek; and
nitrate and nitrite in Buena Creek. Of these PWQCs, the HPWQC in the Agua Hedionda HA was
determined to be indicator bacteria (dry and wet weather conditions) in Agua Hedionda Creek (June
2014 Carlsbad WMA WQIP submittal to RWQCB).
Figure 23 below, shows the Agua Hedionda HA, HPWQC and focus areas. The focus areas and their
associated strategies and goals are explained in more detail below.
—~
^^^^^^^^^^^^
Figure 23: Agua Hedionda Hydrologic Area Highest Priority Water Quality Conditions and Focus Areas
Agua Hedionda HA (904.3)
Page 87
3.3.1 Agua Hedionda HA Sources
The following Table 27 presents a listing of inventoried sources in the Agua Hedionda HA and their
association with HPWQCs and PWQCs based on source loading potential (2011 LTEA). It is important to
note that the PWQC hydromodification is not presented in the table below. Hydromodification impacts
occur as a result of general land development and not specific sources.
Table 27: Pollutant Generating Sources - 904.3 Agua Hedionda Hydrologic Area
Pollutant Source Loading Potential^
Inventory Sites/Facilities Quantities^ Metals Oil & Grease Sediment Pesticides Nutrients Bacteria/Pathogens Dissolved Minerals Organics >•
_*j ]o "x o ^-
Agriculture 4 L UL L L L L UK UL UK
Animal Facilities 5 N UL L UK L L N L UK
Auto Repair, Fueling, or Cleaning 67 L L UL UL UK UL L L UK
Auto Parking Lots or Storage 27 L L L UK UK UK UL L UK
Auto Body Repair or Painting 12 L L UL UL UL UL L L UK
Nurseries/Greenhouses 59 L UL L L L L UL UL UK
Building Materials Retail 2 L L L UL UL UL UL L UK
Chemical and Allied Products 4 UK UK UK UK UK UL N L UK
Eating or Drinking Establishments 162 N L UL UK UK L UL L UK
Equipment Repair or Fueling 40 L L UL UL UK UL UL L UK
Fabricated Metal 42 L L UK UK UK UL UL L UK
Food Manufacturing 21 UL UL UL UL UL UL UL UL UK
General Contractors 51 UL UL L UL UL UL UL UL UK
General Industrial 98 L L UK UK UK UK UK L UK
General Retail 58 UL UL L UL UL UL UL UL UK
Motor Freight 10 L L UK UK UK UK UL L UK
Parks and Rec (incl. Golf,
Cemetery) 4 UK UK UK UK L UK UL UK UK
Pest Control Services 4 N UK N L N UK N UK UK
Publicly Owned Treatment Works 1 UK UK UK N UK L UL UK UK
Primary Metal 5 L UK UK UK UK UL N UK UK
Recycling & Junk Yards 6 L L L UL UL UL L L UK
Stone/Glass Manufacturing 10 L L L UL UL UL UL L UK
Storage/Warehousing 48 L L L UL UL UL UL L UK
Municipal 69 N N L N N UK UL N UK
Construction Varies* UL UL L UL UL UL L UL UK
Residential 6,613 acres L L L L L L L L UK
The highest TTWQ rated sources within each HA based on the HPWQC are identified in the table (yellow highlight signifies HPWQC). The
HPWQC is associated with the sources that are likely to generate those pollutants (blue highlight). The PWQP is highlighted in green and the
associated sources that are likely to generate those pollutants are depicted with an "L".
1: Other sources are not reported in this table including: Land Development and Non-inventoried Businesses
2: Quantities based on the Responsible Agencies FY 2012 JURMP Annual Reports
3: Pollutant Source Loading Potential taken from LTEA 2011; N = None, UK = Unknown, UL = Unlikely, L = Ukely
4: The quantity of construction sites is dynamic due to projects starting and completing at any given time.
Agua Hedionda HA (904.3)
Page 88
3.3.2 Agua Hedionda HA Goals and Strategies
3.3.2.1 Agua Hedionda HA Goals
Goals have not been established that apply to the entire Agua Hedionda HA. Separate goals have been
established for each focus area and are presented in the sub-sections below.
3.3.2.2 Agua Hedionda HA Strategies
The Table 28 identifies the Water Quality Improvement Strategies to be implemented throughout the
entire Agua Hedionda HA and in some specific focus areas of the HA. In addition to the planned
strategies, optional strategies are identified that may be implemented based on circumstances related
to the progress Responsible Agencies make towards numeric goals and funding. The strategies
associated with the focus areas are described further in the sub-sections below.
As the Responsible Agencies implement strategies and analyze data, it is expected that these strategies
and schedules may change through an iterative and adaptive management process. The adaptive
management process is presented in Section 2.4.
Agua Hedionda HA (904.3)
Page 89
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3.3.3 Agua Hedionda HA Focus Areas
Concentrating program efforts in specific geographic areas to address known or suspected sources of
discharges and pollutants is expected to improve the effectiveness ofthe strategies and activities.
Based on the Responsible Agency review of the characteristics of the Agua Hedionda HA, several focus
areas were selected for concentrated program efforts. These focus areas include the AH04 Basin and
San SM-AH Basin. The goals and strategies for these focus areas are summarized below.
3.3.3.1 City of Vista -Agua Hedionda 04 (AH04) Basin
The Agua Hedionda 04 (AH04) Basin is a large sub-basin located mid-watershed in the Agua Hedionda
HA and discharges through a single outfall to a tributary channel approximately 2,000 feet upstream of
Agua Hedionda Creek. The City of Vista identified the AH04 Basin as a focus area to concentrate strategy
implementation. This focus area is completely within the City of Vista jurisdictional boundaries and has a
mixture of single family residential, commercial and multi-family land uses. Land uses include homes,
commercial buildings, apartment complexes, common areas, a high school and recreational park areas
and a golf course that include landscaping and turf. The AH04 Basin is show in Figure 24 below.
The majority of this basin was developed prior to implementation of the City's SUSMP; therefore
relatively few treatment control BMPs have been established.
Figure 24: AH04 Basin Focus Area
Agua Hedionda HA (904.3)
Page 92
AH04 Basin Focus Area Interim and Final Numeric Goals
Goals associated with this focus area are summarized in Table 29 below. These goals have been
established as a part of this initial WQIP development process. As the Responsible Agencies progress
through the first several years of implementation and learn through data collection and analysis, it is
expected that these goals and schedules will likely change. As goals and schedules are adapted, they will
be presented in future WQIP annual reports or updates to the WQIP document.
Table 29: AH04 Basin Focus Area, Interim and Final Numeric Goals
Interim Goal
(2013-2018)
2018^
Interim Goal
(2018-2023)
2023^
Interim Goal
(2023-2028)
2028'
Interim Goal
(2028-2033)
2033'
Final Goal
(2033-2038)
2038'
10% reduction in
anthropogenic dry-
weather surface
water runoff
20% reduction in
anthropogenic dry-
weather surface
water runoff
40% reduction in
anthropogenic dry-
weather surface
water runoff
60% reduction in
anthropogenic dry-
weather surface
water runoff
80% reduction in
anthropogenic dry-
weather surface
water runoff
adapted as monitoring data/information is gathered, analyzed and baselines are established.
The means for achieving these goals are identified in the strategies discussion below. Mechanisms for
measuring progress towards and ultimately achieving these goals are included in the monitoring,
assessment and iterative process sections.
AH04 Basin Focus Area Strategies
In addition to the core jurisdictional strategies, the following summarizes supplemental or modified core
strategies planned for implementation in the focus area to address the sources of pollutants and
discharges.
The selected strategies are expected to have multi-pollutant benefits and intended to address non-
stormwater flows and reducing the source loading of bacteria. Reducing non-stormwater flows: (1)
reduces the loading of pollutant constituent discharged through MS4 system; (2) reduces the amount of
indicator bacteria regrowth and contributions that occurs with accumulated biofilm in MS4 systems that
requires water; and (3) reduces the wet-weather contribution of indicator bacteria from scoured biofilm
under higher velocity flows from storm discharges.
To accomplish the multi-benefit objectives in the AH04 Basin, the City of Vista will supplement its core
jurisdictional program by implementing the following strategies in this focus area:
1) Irrigation Runoff Reduction Program
The objective of the IRRP is to eliminate or reduce dry weather flow contributions coming from
irrigation runoff, regardless ofthe time of day the discharges occur. Core elements include:
• Developing educational materials and outreach program specific towards irrigation runoff
• Assessing dry weather flows at outfall(s)
• Identifying key times to perform site observations
• Perform site observations to identify sources of irrigation runoff
• Collaboration with City Public Works Department to address municipal property irrigation
systems
• Initiating contact and correspondence with property managers/owners
• Periodically assessing flows
• Optionally developing and implementing an incentive program
• Developing municipal codes that prohibit irrigation runoff
Agua Hedionda HA (904.3)
Page 93
2) Property-Based/Patrol Inspections
The objective of this program is to reduce discharges to the MS4 and provide inspection of existing
development in a more cost efficient and effective manner. Features include:
• Developing patrol and inspection protocols
• Developing and conducting staff training
• Conducting property-based/patrol inspections
3) Optional Strategies
• Implement structural (engineered) BMPs or retrofitting existing structural BMPs to address
flow and/or pollutant issues
• Implement offsite alternative compliance program to place water quality improvement
projects in the AH04 Basin focus area
3.3.3.2 City of San Marcos - Agua Hedionda HA, SM-AH Focus Area
The Agua Hedionda HA extends into the western portion of the City of San Marcos. The City of San
Marcos identified SM-AH focus area to concentrate strategy implementation. The SM-AH focus area has
a mixture of single family residential, commercial, industrial and multi-family land uses and includes
homes, commercial buildings, mobile home park, nurseries, common areas that include landscaping and
turf-see Figure 25 below.
The majority of this basin was developed prior to implementation of the City's SUSMP; therefore
relatively few treatment control BMPs have been established.
SM-AH Focus Area
^ Agua Hedionda HA
SM- AH Focus Area
HPWQC
Figure 25: SM-AH Focus Area
Agua Hedionda HA (904.3)
Page 94
Interim Goal
Table 30: SM-AH F ocus Area, interim anc hinai Numeric vaoais
Hilil IBI 10% reduction in 20% reduction in 40% reduction in 60% reduction in
anthropogenic dry-anthropogenic dry-anthropogenic dry-anthropogenic dry-
weather surface weather surface weather surface weather surface
water runoff at water runoff at water runoff at water runoff at
selected outfalls selected outfalls selected outfalls selected outfalls
SM-AH Focus Area Interim and Final Numeric Goals
Goals associated with this focus area are summarized in Table 30 below. These goals have been
established as a part of this initial WQIP development process. As the Responsible Agencies progress
through the first several years of implementation and learn through data collection and analysis, it is
expected that these goals and schedules will likely change. As goals and schedules are adapted, they will
be presented in future WQIP annual reports or updates to the WQIP document.
Final Goal
'2033-2038'
2038'
80% reduction in
anthropogenic dry-
weather surface
water runoff at
selected outfalls
adapted as monitoring data/information is gathered, analyzed and baselines are established.
The means for achieving these goals are identified in the strategies discussion below. Mechanisms for
measuring progress towards and ultimately achieving these goals are included in the monitoring,
assessment and iterative process sections.
SM-AH Focus Area Strategies
The City of San Marcos will implement their program core strategies within the focus area. In addition to
the core jurisdictional strategies, the following summarizes supplemental or modified core strategies
planned for implementation in the focus area to address the sources of pollutants and discharges.
The selected strategies are expected to have multi-pollutant benefits and intended to address non-
stormwater flows and reducing the source loading of bacteria. Reducing non-stormwater flows: (1)
reduces the loading of pollutant constituent discharged through MS4 system; (2) reduces the amount of
indicator bacteria regrowth and contributions that occurs with accumulated biofilm in MS4 systems that
requires water; and (3) reduces the wet-weather contribution of indicator bacteria from scoured biofilm
under higher velocity flows from storm discharges.
To accomplish the multi-benefit objectives in the SM-AH focus area, the City of San Marcos will
supplement its core jurisdictional program by implementing the following strategies:
1) Irrigation Runoff Reduction Program
The objective of the IRRP is to eliminate or reduce dry weather flow contributions coming from
irrigation runoff, regardless of the time of day the discharges occur. Core elements include:
• Developing municipal codes that prohibit irrigation runoff
• Developing educational materials and outreach program specific towards irrigation runoff
• Assessing dry weather flows at outfall(s)
• Identifying key times to perform site observations
• Perform site observations to identify sources of irrigation runoff
• Collaboration with the City of San Marcos Public Works Department to address municipal
property irrigation systems
• Initiating contact and correspondence with property managers/owners
Agua Hedionda HA (904.3)
Page 95
.No
• Periodically assessing flows
• Optionally developing and implementing an incentive program
2) Property-Based/Patrol Inspections
The objective of this program is to reduce discharges to the MS4 and provide inspection of existing
development in a more cost efficient and effective manner. Features include:
• Developing patrol and inspection protocols
• Developing and conducting staff training
• Conducting property-based/patrol inspections
The City of San Marcos will perform these property-based/patrol inspections multiple times per year
at various times of the day to capture irrigation runoff and other non-authorized discharges as well
as identify BMP issues.
3) City of San Marcos & Vallecitos Water District (VWD) Irrigation Runoff/Water Waster Program
• The City of San Marcos and VWD staff collaborate and communicate regularly to share
information regarding reports and complaints
• Public water waster reporting is available on both the City of San Marcos and VWD websites
• The City of San Marcos utilizes VWD developed door hangers for City field staff to distribute
if water wasting is reported or observed at a property
• The City of San Marcos developed template response letters identifying both the City of San
Marcos and VWD requirements
4) City of San Marcos & VWD Fats, Oils, and Grease (FOG) Program Collaboration
• Continue coordination between the City of San Marcos and VWD programs. The City of San
Marcos anticipates a collaborative work effort between the City of San Marcos' inspection
program and VWD's FOG program in order to reduce sewer backups and overflows that
result from accumulation of FOG in the sewer system
• VWD established an Ordinance to regulate FOG
• VWD visited all of the Food Service Establishments (FSEs) within the City of San Marcos to
provide an overview of the program and expectations
• VWD created a guidance manual provided to each FSE that includes BMP information,
maintenance requirements, and record keeping documents. The City of San Marcos is
prepared to utilize these documents during independent inspections or investigations
• VWD will inspect all FSEs at least once a year and collaborate with the City of San Marcos to
perform dual inspections when needed
• Inspection results for both parties will be shared regularly to better identify problem areas
more efficiently
5) Home Owners Association (HOA) and Property Manger Outreach Program
• The City of San Marcos will implement an education and outreach program that encourages
and/or incentivizes HOAs and business property managers to implement measures to
reduce dry weather and/or wet weather flows leaving their properties. Practices could
include proper installation and maintenance of irrigation systems, conversion to drought
tolerant landscaping, downspout disconnection, etc.
6) Enhancements to Education Program
Agua Hedionda HA (904.3)
Page 96
• Bacteria and other priority pollutant specific education and outreach program to be
conducted in the SM-AH focus area for residents and commercial facilities related to
bacteria and other priority pollutants. The materials will have an emphasis on discharges to
the City of San Marcos' MS4 and the receiving waters impacts.
• Developing and implementing a training/seminar for property managers and others that
have direct responsibility for common areas within HOAs and commercial properties.
Educational materials and information will be developed and provided to the managers for
them to distribute to their residents and tenants.
• As part of the residential outreach program, the City of San Marcos will work with residents
and property owners to educate through various means, which may include school
programs, block parties or one-on-one meetings.
7) Filter Retrofit Program
• The City of San Marcos will continue to implement the filter upgrade program provided
through an existing grant program.
• Aging filters located within public facilities in need repair are retrofitted with new
proprietary filter systems that contain media filters to treat dissolvable pollutants including
nutrients and bacteria.
8) Optional Strategies
• Implement structural (engineered) BMPs or retrofitting existing structural BMPs to address
flow and/or pollutant issues
• Implement offsite alternative compliance program to place water quality improvement
projects in the SM-AH Basins
3.3.3.3 CB-PA2 Focus Area
The CB-PA2 focus area is split into two drainage areas located south of Carlsbad Village Drive and CB-
PAl. The northern portion of the focus area drains to the north towards Buena Vista Lagoon. The
southern portion drains south towards Agua Hedionda Lagoon. This area is a mixture of single family
residential, commercial and multi-family land uses and includes homes, commercial buildings,
apartment complexes, common areas, a school and recreational park areas that include landscaping and
turf - see Figure 26 below.
Agua Hedionda HA (904.3)
Page 97
I Miles
0 0.075 0.15
CB-PA2 Focus Area
Agua Hedionda HA
CB-PA2
Pacific Ocean
rsC-^'Airbus DS USDA USGS
Figure 26: CB-PA2 Focus Area
CB-PA2 Focus Area Interim and Final Numeric Goals
Goals associated with this focus area are summarized in Table 31 below. These goals have been
established as a part of this initial WQIP development process. As the Responsible Agencies progress
through the first several years of implementation and learn through data collection and analysis, it is
expected that these goals and schedules will likely change. As goals and schedules are adapted, they will
be presented in future WQIP annual reports or updates to the WQIP document.
Table 31: CB-PA2 Focus Area, Interim and Final Numeric Goals
Interim Goal
(2013-2018)
2018'
Interim Goal
(2018-2023)
2023'
Interim Goal
(2023-2028)
2028'
Interim Goal
(2028-2033)
2033'
Final Goal
(2033-2038)
2038'
10% reduction in
anthropogenic
surface water
runoff
20% reduction in
anthropogenic
surface water
runoff
40% reduction in
anthropogenic
surface water
runoff
60% reduction in
anthropogenic
surface water
runoff
80% reduction in
anthropogenic
surface water
runoff
adapted as monitoring data/information is gathered, analyzed and baselines are established.
Agua Hedionda HA (904.3)
Page 98
The means for achieving these goals are identified in the strategies discussion below. Mechanisms for
measuring progress towards and ultimately achieving these goals are included in the monitoring,
assessment and iterative process sections.
CB-PA2 Focus Area Strategies
The City of Carlsbad (Carlsbad) will implement their program core strategies within the focus area. In
addition to the core jurisdictional strategies, the following summarizes supplemental or modified core
strategies planned for implementation in the focus area to address the sources of pollutants and
discharges.
The selected strategies are expected to have multi-pollutant benefits and intended to address non-
stormwater flows and reducing the source loading of bacteria. Reducing non-stormwater flows: (1)
reduces the loading of pollutant constituent discharged through MS4 system; (2) reduces the amount of
indicator bacteria regrowth and contributions that occurs with accumulated biofilm in MS4 systems that
requires water; and (3) reduces the wet-weather contribution of indicator bacteria from scoured biofilm
under higher velocity flows from storm discharges. Removing trash and sediment reduces the bacteria
loading that is attached the trash and sediment.
To accomplish the multi-benefit objectives in the CB-PA2, the Carlsbad will augment its core
jurisdictional program by making the following changes to its core program in this focus area:
1) Targeted street sweeping in the focus area will be a minimum frequency of every two weeks.
2) Perform property-based inspections/patrol inspections of each property in the CB-PA2 at least
once annually. These inspections will include:
a. Visual inspection of all public streets
b. Inspections of each existing development property:
Municipal facilities and areas
Each commercial/industrial property
Each residential property
3) Maintain a maximum response time for complaints received via Storm Water Hotline, or other
mechanism. Carlsbad will have an Environmental Specialist respond and arrive on-site within 45
minutes of notification to eliminate any unauthorized discharge, identify the responsible party
and minimize impacts to receiving waters. This response time is expected to eliminate
discharges while they are occurring and provide an opportunity to immediately educate or
enforce as necessary.
4) Enhancements to education program to include:
a. Bacteria and other priority pollutant specific education and outreach program to be
conducted in the CB-PA2 for residents and commercial facilities related to bacteria and
other priority pollutants. The materials will have an emphasis on discharges to the
Carlsbad's MS4 and the receiving waters impacts.
b. Developing and implementing a training/seminar for property managers and others that
have direct responsibility for common areas within HOAs and commercial properties.
Educational materials and information will be developed and provided to the managers
for them to distribute to their residents and tenants.
c. As CB-PA2 has a high concentration of Spanish speaking residents, the Carlsbad will
focus on distributing Spanish language outreach materials.
Agua Hedionda HA (904.3) \ \ ^
Page 99 \ ^
d. As part of the residential outreach program, the CaHsbad will work with residents and
property owners to educate through various means, which may include school
programs, block parties or one-on-one meetings.
5) Implement Program Efficiencies - The Carlsbad's new computer database allows for use with
mobile devices which will increase the Carlsbad's response time to IDDE reports, discoveries,
complaints and monitoring investigations. This new computer database will also streamline
inspections and allow for review of previous information while in the field.
6) Residential Area Strategies:
a. At a minimum, biannual inspections will be conducted across the entire focus area
b. Increased proactive monitoring of the area
c. More focused education materials and outreach events
7) Optional Strategies
• Implement structural (engineered) BMPs or retrofitting existing structural BMPs to address
flow and/or pollutant issues
• Implement offsite alternative compliance program to place water quality improvement
projects in the CB-PA2 focus area
3.3.4 Agua Hedionda HA Monitoring and Assessment
The Responsible Agencies will conduct the following monitoring in the Agua Hedionda HA including the
collective watershed-wide monitoring activities described in Section 2.5:
Progress Toward Interim and Final Goals
Dry Weather Special Study
MS4 Outfall Monitoring (as described in Section 2.5)
JRMP Implementation (as described in Section 2.5)
Regulations and Policy (as described in Section 2.5)
Progress Toward Interim and Final Goals
To assess progress toward achieving the interim and final goals, the Agua Hedionda HA Responsible
Agencies will monitor selected outfalls periodically specifically for flow conditions, e.g., rates and
volumes. At select outfalls, in addition to flow conditions, the Responsible Agencies will collect the
following data as part of the MS4 Outfall Monitoring Program, at minimum, during dry weather
conditions:
• Nitrate
• Total Kjeldhal Nitrogen
• Ammonia
• Cadmium
• Copper
• Lead
Total Dissolved Solids
Total Suspended Solids
Total Hardness
Total Phosphorus
Orthophosphate
Nitrite
Zinc
Total Coliform
Fecal Coliform (or E. Coli)
Enterococcus
In addition, the selected outfalls will collect data to evaluate applicable NALs and 303d listed
constituents as proposed in the MS4 Outfall Monitoring Plan that provides a tailored analyte list per HA.
In order to assess program impacts, the Responsible Agencies will establish baseline flow conditions. It is
anticipated that this will occur during the dry weather season of 2015. Future monitoring will provide
flow conditions periodically to calculate percent change from baseline conditions. These calculated
Agua Hedionda HA (904.3)
Page 100
percent changes in flow conditions will be the assessment used to determine the progress towards
achieving interim goals in the Agua Hedionda HA.
Responsible Agencies will also conduct a special study that will inform the data collection and
assessment for determining progress towards achieving the final goals for the Agua Hedionda HA.
Details ofthe special study are below.
Agua Hedionda HA Special Study
A Dry Weather Special Study will be developed to characterize temporal flow and fecal indicator
bacteria patterns at selected persistently flowing major MS4 outfalls during summer dry weather
conditions. The special study is related to indicator bacteria, which has been identified as a Highest
Priority Water Quality Condition for the City of Carlsbad, City of Escondido, City of San Marcos, City of
Solana Beach, and City of Vista and will be implemented in priority areas within their respective
jurisdictions.
The Dry Weather Special Study will address the following questions:
• What is the baseline flow at the specified major MS4 outfalls during summer dry weather
conditions?
• What are the temporal flow patterns at specified major MS4 outfalls during summer dry
weather conditions?
• Are summer dry weather flows at the specified major MS4 outfalls contributing fecal indicator
bacteria to the receiving water(s)?
• What are the temporal patterns of indicator bacteria concentrations at specified major MS4
outfalls?
The study will:
• Address data gaps related to temporal flow and fecal indicator bacteria patterns at selected
persistently flowing major MS4 outfalls during summer dry weather conditions.
• Allow the Responsible Agencies to understand potential sources of flow and therefore more
effectively target and control sources contributing to the Highest Priority Water Quality
Condition,
• Establish a baseline for flow during summer dry weather conditions with which to measure
subsequent flow reductions.
The Responsible Agencies will conduct the special study within the Agua Hedionda HA to assess at an
outfall level as well as collectively with other outfall data collected under the same special study
throughout the WMA. The following components ofthe special study will be conducted:
• Collect continuous flow monitoring data at specified major outfalls using automated flow meter
and data logger.
• Conduct monitoring events at selected major outfalls specified in Table 32
• Collect grab samples and analyze for fecal indicator bacteria (total coliform, fecal coliform, and
Enterococcus) to identify critical conditions for bacteria
• Record visual observations consistent with the transitional outfall monitoring program.
• Collect in-situ physical parameters for pH, temperature, and specific conductivity.
• Perform site observations at key times within the catchment areas and record all observed areas
and/or sources with non-storm water flow.
• Track flow patterns to sources for abatement or further investigation.
Agua Hedionda HA (904.3) ^ \
Page 101 J
Table 32: Dry Weather Data Collection by Jurisdiction for the
Item City of
Carlsbad
City of
Vista
City of
San Marcos
Number of Focus Areas in Agua Hedionda HA 1 1 1
Number of Outfalls for Continuous Flow Monitoring 1 1 1
Minimum Time for Continuous Flow Monitoring 2 weeks 2 weeks 2 weeks
Minimum Number of Fecal Indicator Bacteria Samples at
Each Outfall Where Flow is Measured 4 4 4
Total Number of Bacteria Samples 4 4 4
Assessment
The Agua Hedionda HA Responsible Agencies will perform assessments ofthe following elements:
• Progress Toward Interim and Final Goals
• Dry Weather Special Study
As new data and information becomes available, the Responsible Agencies will perform an integrated
assessment of the findings from the identified focused areas. The integrated assessment will evaluate
the JRMP program implementation in relationship to the findings of the assessment for progress toward
interim and final goals. This integrated assessment would be performed at this scale to identify
relationships between the strategies implemented in the focus areas and outcomes related to the
interim and final goals. The outcomes of this assessment could be used to help determine the
effectiveness and efficiency of selected the strategies implemented.
Longer-term assessments will be performed at the WMA scale as appropriate data and information is
collected and assessed.
Agua Hedionda HA (904.3)
Page 102
3.4 Encinas HA (904.4)
The Encinas HA is 3,400 acres in size, making it the second smallest within the WMA. The HA extends
inland from the coast 2.4 miles and the highest elevation within the drainage is approximately 430 feet
above mean sea level. The HA begins as a small drainage behind an industrial area where it is
immediately channelized. The Encinas Creek continues down through industrial and office parks
associated with Palomar Airport until it reaches the lower valley area. It then makes its way to the
Pacific Ocean after crossing Interstate 5 and Pacific Coast Highway. The Encinas HA is entirely within
CaHsbad and is located between the Agua Hedionda and San Marcos HAs (Figure 27). The only
significant receiving water body within Encinas HA is the Pacific Ocean.
0 01 0.2 0.4
Figure 27: Encinas Hydrologic Area
Encinas HA (904.4)
Page 103
3.4.1 Encinas HA Sources
The following table presents a listing of inventoried sources in the Encinas HA
Table 33: Pollutant Generating Sources - 904.4 Encinas Hydrologic Area
Pollutant Source Loading Potential^
Inventory Sites/Facilities' Quantities^ Metals Oil &. Grease Sediment Pesticides Nutrients Bacteria/Pathogens Dissolved Minerals Organics Toxicity Agriculture 4 L UL L L L L UK UL UK
Animal Facilities 5 N UL L UK L L N L UK
Auto Repair, Fueling, or Cleaning 67 L L UL UL UK UL L L UK
Auto Parking Lots or Storage 27 L L L UK UK UK UL L UK
Auto Body Repair or Painting 12 L L UL UL UL UL L L UK
Nurseries/Greenhouses 59 L UL L L L L UL UL UK
Building Materials Retail 2 L L L UL UL UL UL L UK
Chemical and Allied Products 4 UK UK UK UK UK UL N L UK
Eating or Drinking Establishments 162 N L UL UK UK L UL L UK
Equipment Repair or Fueling 40 L L UL UL UK UL UL L UK
Fabricated Metal 42 L L UK UK UK UL UL L UK
Food Manufacturing 21 UL UL UL UL UL UL UL UL UK
General Contractors 51 UL UL L UL UL UL UL UL UK
General Industrial 98 L L UK UK UK UK UK L UK
General Retail 58 UL UL L UL UL UL UL UL UK
Motor Freight 10 L L UK UK UK UK UL L UK
Parks and Rec (incl. Golf,
Cemetery) 4 UK UK UK UK L UK UL UK UK
Pest Control Services 4 N UK N L N UK N UK UK
Publicly Owned Treatment Works 1 UK UK UK N UK L UL UK UK
Primary Metal 5 L UK UK UK UK UL N UK UK
Recycling & Junk Yards 6 L L L UL UL UL L L UK
Stone/Glass Manufacturing 10 L L L UL UL UL UL L UK
Storage/Warehousing 48 L L L UL UL UL UL L UK
Municipal 69 N N L N N UK UL N UK
Construction Varies" UL UL L UL UL UL L UL UK
Residential 6,613 acres L L L L L L L L UK
The highest TTWQ rated sources within each HA based on the HPWQC are identified in the table (yellow highlight signifies HPWQC). The
HPWQC is associated with the sources that are likely to generate those pollutants (blue highlight). The PWQP is highlighted in green and the
associated sources that are likely to generate those pollutants are depicted with an "L".
1: other sources are not reported in this table including: Land Development and Non-inventoried Businesses
2: Quantities based on the Responsible Agencies FY 2012 JURMP Annual Reports
3: Pollutant Source Loading Potential taken from LTEA 2011; N = None, UK = Unknown, UL = Unlikely, L = Ukely
4: The quantity of construction sites is dynamic due to projects starting and completing at any given time.
3.4.2 Encinas HA Goals and Strategies
3.4.2.1 Encinas HA Goals
Goals have not been established that apply throughout the entire Encinas HA.
Encinas HA (904.4)
Page 104
3.4.2.2 Encinas HA Strategies
The following Table 34 identifies the Water Quality Improvement Strategies to be implemented
throughout the entire Encinas HA.
As the City of Carlsbad implements strategies and analyze data, it is expected that these strategies and
schedules may change through the iterative and adaptive management process.
3.4.3 Encinas HA Monitoring and Assessment
Monitoring
The City of Carlsbad will conduct the following monitoring in the Encinas HA:
• MS4 Outfall Monitoring (as described in Section 2.5)
• JRMP Implementation (as described in Section 2.5)
• Regulations and Policy (as described in Section 2.5)
Assessment
The City of CaHsbad will perform assessments on the data and information collected
Encinas HA (904.4)
Page 105
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3.5 San Marcos HA (904.5)
The San Marcos Hydrologic Area is the second largest within the WMA. The HA is about 36,000 acres in
area and comprises approximately 28% ofthe Carlsbad WMA. The major receiving waters within the HA
are San Marcos Creek, Encinitas Creek, Batiquitos Lagoon, and the Pacific Ocean. San Marcos Creek
originates on the western slopes of the Merriam Mountains in west central San Diego County and
discharges in to the Pacific Ocean, 14.6 miles away, via Batiquitos Lagoon. Encinitas Creek is another one
of the major tributaries in the HA, originating in the hills southwest of Questhaven Road and paralleling
El Camino Real before it converges with San Marcos Creek at the southeastern corner of Batiquitos
Lagoon. The highest elevation within the HA is approximately 1,540 feet above mean sea level. Lake San
Marcos is the largest impoundment within the HA. The Cottonwood Creek sub-basin is also located in
this HA which drains a portion of Encinitas directly into the Pacific Ocean. The San Marcos HA is
primarily located in the cities of San Marcos, Carlsbad, Encinitas, and the County of San Diego, with a
small portion in Escondido.
The San Marcos HA has two distinctive areas separated by the Lake San Marcos impoundment - the
Upper and Lower San Marcos HA areas. The Upper Hydrologic Area includes drainage areas in the
County of San Diego, and the cities of San Marcos and Escondido, that runoff through Upper San Marcos
Creek to Lake San Marcos. The Lower Hydrologic Area consists of portions of the cities of Carlsbad,
Encinitas, San Marcos and Vista.
During the initial phase of the WQIP process, assessment of existing data determined that the PWQCs
within the San Marcos HA include: indicator bacteria at the Pacific Ocean Shoreline at Moonlight Beach;
phosphorous in San Marcos Creek; toxicity in San Marcos Creek; and nutrients in San Marcos Lake. Of
these PWQC, the HPWQC in the San Marcos HA was determined to be indicator bacteria (dry and wet
weather conditions) at the Pacific Ocean Shoreline at Moonlight Beach (June 2014 Carlsbad WMA WQIP
submittal to RWQCB).
Figure 28 below, shows the San Marcos HA, HPWQC and focus areas. The focus areas and their
associated strategies and goals are explained in more detail below.
Regulatory Drivers
The Pacific Ocean Shoreline of the San Marcos HA has been identified as a waterbody subject to the
requirements of San Diego Beaches and Creeks Project I Bacteria TMDL. The TMDL is for REC-1 beneficial
use impairments of waterbodies throughout San Diego County. Based on analysis conducted in 2012^ it
was determined that the Pacific Ocean shoreline at San Marcos HA would not have qualified for REC-1
beneficial use impairment at any time. Therefore, the HA was inappropriately included in the TMDL. The
San Marcos HA Responsible Agencies are not responsible for any further Bacteria TMDL action, including
preparation and submittal of a Load Reduction Plan or Monitoring Plan, as long as monitoring data
continues to support compliance with water quality standards. However, if at any time, the Pacific
Ocean Shoreline becomes impaired under the Listing Policy^ the Responsible Agencies will make
appropriate modifications to the WQIP to meet the requirements ofthe Bacteria TMDL. The Responsible
Agencies will monitor the Pacific Ocean receiving waters and assess the potential for further TMDL
actions.
^ San Marcos Hydrologic Area Responsible Parties analyzed available monitoring data in 2012 and presented to RWQCB
' California Water Quality Control Policy for Developing California's Clean Water Act Section 303(d) List
San Marcos HA (904.5)
Page 107
The agencies in the upper portion of the San Marcos HA, tributary to Lake San Marcos, are currently
involved in participation agreements with the RWQCB^. The intent of the participation agreement is to
develop solutions to water quality impairments in Lake San Marcos and for the portion of San Marcos
Creek upstream of Lake San Marcos. The process is currently on-going and when results are finalized,
they will be incorporated into the Carlsbad WQIP, if appropriate.
Figure 28: San Marcos Hydrologic Area Highest Priority Water Quality Conditions and Focus Areas
3.5.1 San Marcos HA Sources
The following Table 35 presents a listing of inventoried sources in the San Marcos HA and their
association with HPWQCs and PWQCs based on source loading potential (2011 LTEA).
Lake San Marcos voluntary
marcos.ca.us/index.aspx?paRe-529
participation agreement: for more information see http://www.ci.san-
San Marcos HA (904.5)
Page 108
Table 35: Pollutant Generating Sources - 904.5 San Marcos Hydrologic Area
Pollutant Source Loading Potential^
Inventory Sites/Facilities^ Quantities'' Metals Oil & Grease Sediment Pesticides Nutrients Bacteria/Pathogens Dissolved Minerals Organics foxicity Aggregates/Mining 1 L L L UL UL UL UL L UK
Animal Facilities 45 N UL L UK L L N L UK
Auto Repair, Fueling, or Cleaning 136 L L UL UL UK UL L L UK
Auto Parking Lots or Storage 4 L L L UK UK UK UL L UK
Auto Body Repair or Painting 48 L L UL UL UL UL L L UK
Nurseries/Greenhouses 96 L UL L L L L UL UL UK
Building Materials Retail 30 L L L UL UL UL UL L UK
Chemical and Allied Products 4 UK UK UK UK UK UL N L UK
Concrete Manufacturing 4 L L L UL UL UL UL L UK
Eating or Drinking Establishments 501 N L UL UK UK L UL L UK
Equipment Repair or Fueling 87 L L UL UL UK UL UL L UK
Fabricated Metal 39 L L UK UK UK UL UL L UK
Food Manufacturing 30 UL UL UL UL UL UL UL UL UK
General Contractors 129 UL UL L UL UL UL UL UL UK
General Industrial 76 L L UK UK UK UK UK L UK
General Retail 65 UL UL L UL UL UL UL UL UK
Health Services 1 N UL L UK L UL UK L UK
Motor Freight 23 L L UK UK UK UK UL L UK
Offices 2 UK UK UK UK UK UK UK UK UK
Parks and Rec (incl. Golf, Cemetery) 9 UK UK UK UK L UK UL UK UK
Pest Control Services 1 N UK N L N UK N UK UK
Pool and Fountain Cleaning 5 N N N N UK N N UK UK
Publicly Owned Treatment Works 3 UK UK UK N UK L UL UK UK
Primary Metal 1 L UK UK UK UK UL N UK UK
Recycling &. Junk Yards 4 L L L UL UL UL L L UK
Roads, Streets & Parking 1 L L L UL L L L L UK
Stone/Glass Manufacturing 10 L L L UL UL UL UL L UK
Storage/Warehousing 108 L L L UL UL UL UL L UK
Municipal 119 N N L N N UK UL N UK
Construction Varies" UL UL L UL UL UL L UL UK
Residential 12,977 acres L L L L L L L L UK
The highest TTWQ rated sources within each HA based on the HPWQC are identified in the table (yellow highlight signifies HPWQC). The
HPWQC is associated with the sources that are likely to generate those pollutants (blue highlight). The PWQP is highlighted in green and the
associated sources that are likely to generate those pollutants are depicted with an "I".
1: other sources are not reported in this table including: Land Development and Non-inventoried Businesses
2: Quantities based on the Responsible Agencies FY 2012 JURMP Annual Reports
3: Pollutant Source Loading Potential taken from LTEA 2011; N = None, UK = Unknown, UL = Unlikely, L = Ukely
4: The quantity of construction sites is dynamic due to projects starting and completing at any given time.
San Marcos HA (904.5)
Page 109
3.5.2 San Marcos HA Goals and Strategies
3.5.2.1 San Marcos HA Goals
While the San Marcos HA is not currently impaired for REC-1 beneficial uses along the Pacific Ocean
Shoreline, the area is still included as part of the TMDL requirements of the MS4 Permit Attachment E,
Section 6. As a result, the Responsible Agencies have established both interim and final goals for wet
and dry weather in the HA that are consistent with the TMDL requirements for indicator bacteria. The
goals identify both receiving water and MS4 targets in order to provide opportunities to demonstrate
progress toward or achievement of the goals. The goals, although technically required of the entire HA
that ultimately drains to the Pacific Ocean Shoreline, are primarily related to the Lower Hydrologic Area
(downstream of Lake San Marcos). These goals are outlined in Table 36 and Table 37.
There are proposed changes to the interim goals, as allowed in the Permit. These changes are justified
by the RAs having not been required to develop and implement a Load Reduction Plan (LRP) to date -
see discussion in Section 2.5 Regulatory Drivers above. Since the RAs have not had to develop and
implement a LRP, the WQIP will act as the planning and implementation document to address the TMDL
in this HA. The WQIP will not become effective until years after the original LRP would have been
developed and implemented, therefore creating a time gap and justification for differing interim
compliance schedules.
The means for achieving these goals are identified in the strategies discussion below. Mechanisms for
measuring progress towards and ultimately achieving these goals are included in the monitoring,
assessment and iterative process sections.
San Marcos HA (904.5)
Page 110
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The following Table 38 identifies the Water Quality Improvement Strategies to be implemented
throughout the entire San Marcos HA and in some specific focus areas of the HA. In addition to the
planned strategies, optional strategies are identified that may be implemented based on circumstances
related to the progress Responsible Agencies make towards numeric goals and funding. The strategies
associated with the focus areas are described further in the sub-sections below.
As the Responsible Agencies implement strategies and analyze data, it is expected that these strategies
and schedules may change through an iterative and adaptive management process. The adaptive
management process is presented in Section 2.4.
San Marcos HA (904.5)
Page 113
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San Marcos HA (904.5)
Page 114
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3.5.3 San Marcos HA Focus Areas
Concentrating program efforts in specific geographic areas to address known or suspected sources of
discharges and pollutants are expected to improve the effectiveness of the strategies and activities.
Based on the Responsible Agencies review of the characteristics of the San Marcos HA, several areas of
focus were selected for concentrated program efforts. The focus areas in the Lower HA include the
Cottonwood Creek Drainage Area and Second Street Drainage Area (within the Cottonwood Creek
Drainage Area). In the Upper HA the focus areas include the City of San Marcos jurisdiction within the
San Marcos HA and the County's Lake San Marcos drainage areas: CAR 068, CAR 069, CAR 070 and CAR
072. The goals, targeted outcomes, and strategies for these focus areas are summarized below.
3.5.3.1 Cottonwood Creek Drainage Area
The Cottonwood Creek Drainage Area is located in the lower San Marcos HA. The City has identified this
drainage area and a sub-area, the 2"^^ Street Drainage Areas to focus additional strategies. Both focus
areas are completely within the City of Encinitas jurisdictional boundaries and have a variety of land uses
including a mixture of single-family residential, commercial and multi-family, commercial buildings,
apartment complexes, nurseries, common areas and recreational park areas that include landscaping
and turf. The focus areas are show in Figure 29 below.
Cottonwood Creek Drainage Area
I I Carisbad WMA
j Cottonwood Creek Drarnage Area
I Second Street Drainage Area
,; Pacific Ocean
0 0.1 02 0.4 Sou'ce Es" DigiiaiGloDe Geof,-p
Figure 29: Cottonwood Creek and 2nd Street Drainage Areas
San Marcos HA (904.5)
Page 117
V
Cottonwood Creek Drainage Basin Interim and Final Numeric Goals
Goals have not been established separately for Cottonwood Creek and Second Street Drainage Basins.
The goals associated with these focus areas are the same goals that apply throughout the entire San
Marcos Hydrologic Area, as shown in Table 36 and Table 37 above.
Cottonwood Creek and 2""^ Street Drainage Basin Strategies
The City of Encinitas (Encinitas) has been implementing program strategies throughout its jurisdiction to
control pollutants and non-stormwater discharges from its MS4 system, including the Cottonwood Creek
drainage basin.
Encinitas will implement their program core strategies within the focus area. In addition to the core
jurisdictional strategies, the following summarizes supplemental or modified core strategies planned for
implementation in the focus area to address the sources of pollutants and discharges.
The selected strategies are specifically intended to address non-stormwater flows and thereby expected
to have multi-pollutant benefits as well as reduce the source loading of bacteria. Reducing non-
stormwater flows: (1) reduces the loading of pollutant constituents discharged through the MS4 system;
(2) reduces the amount of indicator bacteria regrowth in the enclosed portion of the MS4 system; and
(3) reduces the wet-weather contribution of indicator bacteria from scoured biofilm during high velocity
storm flows.
To accomplish the multi-benefit objectives in the Cottonwood Creek Basin, the Encinitas will supplement
its core jurisdictional program by implementing the following strategies in the focus areas:
1) Operation of the Ultraviolet Bacteria Treatment Facility
Encinitas has operated an UV treatment system just upstream of Cottonwood Creek since 2005.
Encinitas will continue to operate and maintain the treatment facility during dry weather conditions.
The system effectively eliminates 99% of the indicator bacteria passing through the system.
2) Ultraviolet Bacteria Treatment Facility Upgrade Feasibility Study
Encinitas will perform a feasibility study to determine if modifications to the operations of the
treatment facility would yield beneficial results from wet weather operation. The study will evaluate
whether operating the UV facility outside the typical dry season would affect water quality
downstream. The results of this study will be used in conjunction with a bacteria monitoring study
to assess compliance with current water quality standards. The resulting analysis will inform the
Encinitas of options for modifying treatment facility operations to improve effectiveness. After
evaluating the feasibility and monitoring studies, the Encinitas may initiate changed operations at its
UV treatment facility as an optional strategy.
3) Low Impact Development Retrofit Program
Encinitas is currently preparing a Low Impact Development (LID) Retrofit program specific to the
Cottonwood Creek Drainage Basin. The LID Retrofit program consists of a two pronged
implementation approach with a goal of improved source control and treatment control throughout
the watershed. The program will include a) concept designs for proposed LID retrofit projects, and
b) public education designed to compel residents to become watershed stewards by installing LID
features in their yards.
San Marcos HA (904.5)
Page 118
Encinitas is siting and preparing conceptual designs for four (4) LID retrofit projects. One of the
criterion for site selection is the opportunity to intercept and redirect non-storm water flows from
the Encinitas's MS4 system. Once the designs have been completed, Encinitas will seek funding
opportunities to construct these optional strategies in this basin.
To further the public's understanding and knowledge of LID as an effective mechanism for water
quality improvements, Encinitas will implement a pilot project to educate and motivate
homeowners to reduce irrigation runoff and/or wet weather flows by implementing:
• Landscape water conservation practices (drip irrigation, turf reduction, etc.)
• Small-scale LID features (downspout disconnects, bioretention basins, etc.).
Existing water conservation incentives will be promoted through the program. Existing incentives
include rebates for turf removal and installation of drip irrigation, both of which reduce overall
water use and irrigation runoff. The pilot project will focus on the neighborhoods along Pacific View
Lane and Sea View Court within the Cottonwood Creek Drainage Basin. This neighborhood was
targeted due to observed presence of irrigation runoff. Based on lessons learned from the pilot
project, Encinitas may choose to expand the program to cover additional neighborhoods within the
Cottonwood Creek Drainage Area.
4) Evaluate Sanitary Sewer Maintenance and Overflow Prevention
Encinitas will evaluate sewer system maintenance frequencies and FOG program policies, including
procedures targeted at private laterals, to protect the Moonlight Beach Shoreline. While Encinitas
has not had sanitary sewer overflows (SSO)s recently, evaluating Encinitas 's Sanitary Sewer
Maintenance Plan is important as a proactive step. Based on the findings ofthe evaluation, Encinitas
may make modifications to its maintenance program to prevent SSOs.
5) Home Owners Association and Property Manager Outreach Program
Encinitas will implement an education and outreach program that encourages and/or incentivizes
HOAs and business property managers to implement measures to reduce dry weather and/or wet
weather flows leaving their properties. Practices could include proper installation and maintenance
of irrigation systems, conversion to drought tolerant landscaping, downspout disconnection, etc.
6) Plastic Bag Ban
Encinitas passed an ordinance banning distribution of single use plastic bags on August 20, 2014.
The ban applies to large retailers, grocery stores, drug stores, convenience stores, and mini-markets
in spring 2015 and to farmers markets and all other retailers in fall 2015.
2"" Street Sub-Basin
In the 2""* Street sub-basin, where there is a relatively higher concentration of commercial businesses
including restaurants. In addition to the strategies listed above, Encinitas will implement the following:
Increased Inspection Frequency for Highest Pollutant Potential Commercial Sources
More frequent inspections will be targeted at specific high-threat areas or activities in the 2nd
Street sub-basin. High priority sites will be inspected twice per year, which is two times more than
the minimum commercial inspection requirements mandated in the Municipal Permit.
San Marcos HA (904.5)
Page 119
3.5.3.2 City of San Marcos - San Marcos HA Focus Area
The San Marcos HA extends into the center portion of the City of San Marcos near the upper portion of
the HA. Within the City of San Marcos there are four sub-basins that are a part of the San Marcos HA.
The basins have a mixture of commercial, industrial, single-family residential, and multi-family land uses.
Nearly all of the four sub-basins drain through Upper San Marcos Creek to Lake San Marcos.
Within the four sub-basins, the City of San Marcos has identified B, C, and D Drainage Areas as their
focus areas. These focus areas are considered a higher threat to water quality due to their proximity to
tributary channels to San Marcos Creek and the business nature of the land uses (commercial and
industrial) coupled with various residential land uses in each basin. The focus areas are shown below in
Figures Figure 30, Figure 31Figure 32 below. These focus areas were selected to specifically address the
PWQCs of nutrients and phosphorous in San Marcos Creek and Lake San Marcos.
San Marcos Drainage Basin B
San Marcos HA
San Marcos Drainage Basin B
0 0.2 0.4
Figure 30: San Marcos Drainage Basin B
San Marcos HA (904.5)
Page 120
Figure 32: San Marcos Drainage Basin D
San Marcos HA (904.5)
Page 121
Son Marcos B, C and D Drainage Basin Interim and Final Numeric Goals
Numeric goals have not been established separately for San Marcos B, C and D Drainage Basins.
However, the City of San Marcos is focused on targeted outcomes in the four focused areas. For each of
the focus areas, the City of San Marcos has developed the following targeted outcomes:
Interim Targeted Interim Targeted
Focus Areas, interim a id Final Targeted Outc
Final Targeted
Outcome Outcome Outcome Outcome Outcome
(2013-2018)
——. ....1
(2018-2023) (2023-2028) (2028-2033)
1
(2033-2038)
1
2018 2023^ 2028^ 2033^ 2038
10% reduction in 20% reduction in 40% reduction in 60% reduction in 80% reduction in
anthropogenic dry-anthropogenic dry-anthropogenic dry-anthropogenic dry-anthropogenic dry-
weather surface weather surface weather surface weather surface weather surface
water runoff at water runoff at water runoff at water runoff at water runoff at
selected outfalls selected outfalls selected outfalls selected outfalls selected outfalls
adapted as monitoring data/information is gathered, analyzed and baselines are established.
Son Marcos B, C and D Drainage Basin Strategies
The City of San Marcos will implement its program core strategies within these focus areas. In addition
to the core jurisdictional strategies, the following summarizes supplemental or modified core strategies
planned for implementation in the focus area to address the sources of pollutants and discharges.
The selected strategies are expected to have multi-pollutant benefits and intended to address non-
stormwater flows and reducing the source loading of nutrients. Reducing non-stormwater flows: (1)
reduces the loading of pollutant constituent discharged through MS4 system; (2) reduces the amount of
indicator bacteria regrowth and contributions that occurs with accumulated biofilm in MS4 systems that
requires water; and (3) reduces the wet-weather contribution of indicator bacteria from scoured biofilm
under higher velocity flows from storm discharges.
To accomplish the multi-benefit objectives in the San Marcos B, C and D Basins, the City of San Marcos
will supplement its core jurisdictional program by implementing the following strategies in these focus
areas:
1) Irrigation Runoff Reduction Program
The objective of the IRRP is to eliminate or reduce dry weather flow contributions coming from
irrigation runoff, regardless of the time of day the discharges occur. Core elements include:
• Developing municipal codes that prohibit irrigation runoff
• Developing educational materials and outreach program specific towards irrigation runoff
• Assessing dry weather flows at outfall(s)
• Identifying key times to perform site observations
• Perform site observations to identify sources of irrigation runoff
• Collaboration with the City of San Marcos Public Works Department to address municipal
property irrigation systems
• Initiating contact and correspondence with property managers/owners
• Periodically assessing flows
• Optionally developing and implementing an incentive program
2) Property-Based/Patrol Inspections
San Marcos HA (904.5)
Page 122
The objective of this program is to reduce discharges to the MS4 and provide inspection of existing
development in a more cost efficient and effective manner. Features include:
• Developing patrol and inspection protocols
• Developing and conducting staff training
• Conducting property-based/patrol inspections
The City of San Marcos will perform these property-based/patrol inspections multiple times per year
at various times of the day to capture irrigation runoff and other non-authorized discharges as well
as identify BMP issues.
3) City of San Marcos & Vallecitos Water District (VWD) Irrigation Runoff/Water Waster Program
• The City of San Marcos and VWD staff collaborate and communicate regularly to share
information regarding reports and complaints
• Public water waster reporting is available on both the City of San Marcos and VWD websites
• The City of San Marcos utilizes VWD developed door hangers for City field staff to distribute
if water wasting is reported or observed at a property
• The City of San Marcos developed template response letters identifying both the City of San
Marcos and VWD requirements
4) City of San Marcos & VWD FOG Program Collaboration
• Continue coordination between the City of San Marcos and VWD programs. The City of San
Marcos anticipates a collaborative work effort between the City of San Marcos' inspection
program and VWD's FOG program in order to reduce sewer backups and overflows that
result from accumulation of FOG in the sewer system
• VWD established an Ordinance to regulate FOG
• VWD visited all of the FSEs within the City of San Marcos to provide an overview of the
program and expectations
• VWD created a guidance manual provided to each FSE that includes BMP information,
maintenance requirements, and record keeping documents. The City of San Marcos is
prepared to utilize these documents during independent inspections or investigations
• VWD will inspect all FSEs at least once a year and collaborate with the City of San Marcos to
perform dual inspections when needed
• Inspection results for both parties will be shared regularly to better identify problem areas
more efficiently
5) HOA and Property Manger Outreach Program
• The City of San Marcos will implement an education and outreach program that encourages
and/or incentivizes HOAs and business property managers to implement measures to
reduce dry weather and/or wet weather flows leaving their properties. Practices could
include proper installation and maintenance of irrigation systems, conversion to drought
tolerant landscaping, downspout disconnection, etc.
6) Enhancements to Education Program
• Bacteria and other priority pollutant specific education and outreach program to be
conducted in the B, C and D focus areas for residents and commercial facilities related to
bacteria and other priority pollutants. The materials will have an emphasis on discharges to
the City of San Marcos' MS4 and the receiving waters impacts.
San Marcos HA (904.5)
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• Developing and implementing a training/seminar for property managers and others that
have direct responsibility for common areas within HOAs and commercial properties.
Educational materials and information will be developed and provided to the managers for
them to distribute to their residents and tenants.
• As part of the residential outreach program, the City of San Marcos will work with residents
and property owners to educate through various means, which may include school
programs, block parties or one-on-one meetings.
7) Civic Center Landscape Conversion Demonstration Project
• This program's objectives are to:
o Provide measurable water use efficiency and water quality benefits in receiving
waters.
o Demonstrate the link between irrigation runoff reduction and associated reductions
in pollutant concentrations and loading.
• To meet the objectives, this program will use landscape renovation, advances in irrigation
technology, flow and water quality monitoring prior to and post renovation, and an
education/outreach program.
8) Filter Retrofit Program
• The City of San Marcos will continue to implement the filter upgrade program provided
through an existing grant program.
• Aging filters located within public facilities in need repair are retrofitted with new
proprietary filter systems that contain media filters to treat dissolvable pollutants including
nutrients and bacteria.
9) Optional Strategies
• Implement structural (engineered) BMPs or retrofitting existing structural BMPs to address
flow and/or pollutant issues
• Implement offsite alternative compliance program to place water quality improvement
projects in the San Marcos B, C and D Drainage Basins
3.5.3.3 County of San Diego -San Marcos HA Focus Areas
four of the County of San Diego's (County) major storm drain outfalls in the San Marcos HA have
persistent flows and are tributary to Lake San Marcos. The unincorporated area that makes up the four
drainage areas have a range of land use types (residential, residential with some agriculture, commercial
businesses, roads, etc.) which includes activities with likely potential for pollutant source loading. The
focus areas are shown below in Figure 33 below.
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Figure 33: County of San Diego San Marcos HA Focus Areas
County of San Diego CAR 068, CAR 069, CAR 070 and CAR 072 Interim and Final Targeted Outcomes
These targeted outcomes are in conjunction with the numeric goals established in the County's focus
areas within the Escondido Creek HA. Numeric goals have not been established separately for the
County's San Marcos HA Focus Areas. However, the County is focused on targeted outcomes in the four
focused areas. These targeted outcomes have been established as a part of this initial WQIP
development process. As the County progresses through the first several years of implementation and
learns through data collection and analysis, it is expected that these targeted outcomes and schedules
will likely change. As targeted outcomes and schedules are adapted, they will be presented in future
WQIP annual reports or updates to the WQIP document.
The dry weather targeted outcomes were established to reduce dry weather flow in storm drains, in
order to reduce pollutant loading to water bodies during dry weather. This will be accomplished through
the implementation of JRMP strategies to reduce dry weather runoff, as described in the County JRMP.
For the grouping of seven identified persistently flowing major MS4 outfalls in the County's jurisdiction
within the entire Carlsbad WMA, the County has set targeted outcomes of eliminating anthropogenic
flows from one major storm drain outfall that discharges to receiving waters, during each Permit term,
until all anthropogenic flows have been effectively eliminated. Targeted outcomes are expressed in
Table 40 below.
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Table 40: County of San Diego San Marcos HA Focus Areas, Interim and Final Targeted Outcomes
Interim Targeted Outcome
(2013-2018)
2018'
Interim Targeted Outcomes
(2018-2043)
2023^ and each subsequent five
year period
Final Targeted Outcome
(2043-2048)
2048'
Effectively eliminate
anthropogenic dry weather
flows''^ from one persistently
flowing outfall^
Effectively eliminate anthropogenic
dry weather flows''^ from one
additional persistently flowing
outfall'
Effectively eliminate anthropogenic
dry weather flows''^ from one
additional persistently flowing
outfall^ each subsequent permit
term, until all flows have been
effectively eliminated
persistent flow. The targeted outcomes may be adapted as monitoring data is collected and analyzed.
^ Here and throughout this table, the term "dry weather flows" excludes groundwater, other exempt or permitted non-
stormwater flows, and sanitary sewer overflows.
^ The County of San Diego is concerned that a long-term funding source is not identified for constructing and maintaining
structural BMPs, if structural BMPs are needed to meet compliance. The implementation of strategies to achieve goals will
depend upon approval of funding in future annual budgets.
County of San Diego CAR 068, CAR 069, CAR 070 and CAR 072 Drainage Basin Strategies
The County of San Diego Watershed Protection Program (WPP) will shift to a more active field program
to better locate and abate dry weather flow. WPP Stormwater Staff will increase the amount of time
spent in unincorporated communities, identifying nuisance anthropogenic flows and addressing them
through appropriate education and enforcement strategies. County staff will continue to be trained to
identify and report illicit discharges and illicit connections during required annual stormwater training.
This training has been updated to reflect recent Permit changes.
In addition to the increase in County staff field surveillance, WPP will also implement a focused program
to reduce flows at targeted MS4 outfalls that have demonstrated persistent dry weather flow
conditions. Using collected dry weather monitoring data collected, the County has identified priority
outfalls in the Carlsbad Watershed that will be monitored regularly for dry weather flow. If dry weather
flows are detected, staff will initiate a field investigation to seek out and abate the source of flow.
The County will implement their core jurisdictional program strategies within the focus area. In addition
to the core jurisdictional strategies, the following summarizes supplemental or modified core strategies
planned for implementation in the focus area to address the sources of pollutants and discharges.
The selected strategies are expected to have multi-pollutant benefits and intended to address non-
stormwater flows and reducing the source loading of bacteria. Addressing non-stormwater flows: (1)
reduces the loading of pollutant constituent discharged through MS4 system; (2) reduces the amount of
indicator bacteria regrowth and contributions that occurs with accumulated biofilm in MS4 systems that
requires water; and (3) reduces the wet-weather contribution of indicator bacteria from scoured biofilm
under higher velocity flows from storm discharges.
To accomplish the multi-benefit objectives, the County will supplement its core jurisdictional program
by implementing the following strategies in these focus areas:
1) Active Field Program to Identify and Address Dry Weather Flows - The focused area was
selected based on strategic assessments, including review of 303(d) listings, monitoring data,
and persistent flows. Field staff will conduct surveillance and may employ various tools to
reduce pollutant loads and non-stormwater flows, including outreach efforts including over-
V
San Marcos HA (904.5)
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irrigation focus, pet waste, HOA, and landscaper outreach. New outreach materials will be
developed for use in focused inspections.
2) Updated Focused Training for County Field Staff - Field Staff training to be updated with
information on HPWQCs identified in WQIP and the pollutant sources and pollutant generating
activities that may be associated with the HPWQCs.
3) BMP Manual Training - External - The BMP Manual for new and redevelopment will be updated
and training/outreach will be provided to the development industry.
4) Promote Rain Barrel Incentive Programs - Promoting partners programs for rainwater
harvesting rebates. Partner agencies including the MWD, local water districts, and the SDCWA.
Example: MWD - www.socalwatersmart.com
5) Collaborate with Partner Agencies to Promote Incentive Programs for BMP Retrofits -
Promoting incentives for water conservation and landscape retrofits through partner agencies
(same as above) such as turf replacement, sprinkler head nozzle replacements, smart irrigation
controllers, etc. Incentive programs may be developed for this program if funding is available.
6) Promote Live Turf Replacement Incentive Program - Promote turf replacement programs for
replacement with California Friendly plants.
7) Promote Water-Smart Incentive for Outdoor Water Efficiency as part of the public-private
partnership - Development of Sustainable Landscape Program is underway with partners
including: SDCWA, City of San Diego, Surfrider Foundation, the Association of Compost
Producers, and the County. Developing guidelines will promote water conservation, the building
healthy soils, and sustainable practices.
8) Develop, Improve, Distribute Outreach Materials for Existing Development - Develop outreach
materials to raise awareness of stormwater and urban runoff concerns. Materials would
promote behaviors that will improve water quality downstream.
9) Educational Workshops - Continue to sponsor workshops for specific target audiences and
pollutants of concern, including: manure management and composting workshops for horse
owners; integrated pest management and gardening workshops for residents interested in
gardening and more sustainable landscape practices; and rain water harvesting classes to
encourage capturing rain from roofs for landscape use.
10) Education & Outreach Effectiveness Surveys - A baseline survey was completed by the County
of registered voters in the unincorporated area to gauge stormwater knowledge and awareness.
Additionally, pre- and post-surveys will be conducted during educational workshops to ensure
that programs are effectively reaching the attendees demonstrating an improvement in
knowledge, awareness, and likely-hood of changing behaviors to be less polluting.
11) Optional Strategies-
• Consider feasibility of developing an alternative compliance program, and if developed
consider constructing structural controls to reduce priority water pollutants.
• Investigate feasibility of developing a Green Streets Program
San Marcos HA (904.5)
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Consider improvements to tracking watershed-based inventories via consolidated database
Develop an Equestrian BMP Handbook
Investigate the feasibility of an inspections tracking program via mobile platform - miles,
violations, etc.
Investigate the feasibility of improvements to inspections data tracking through mobile
phone
Investigate the feasibility of developing and implementing an incentive program for BMP
Retrofits in areas of existing development
Develop Sustainable Landscapes Outreach Program based on available grant funding
Investigate feasibility of stream, channel, and/or habitat rehabilitation projects and identify
project partners
Consider development of incentive programs for water conservation (turf replacement,
smart irrigation controllers, irrigation modifications, sustainable landscapes, rain barrels), in
collaboration with water agencies and others, to reduce priority pollutants
Consider development of incentive programs, in collaboration with the Department of
Environmental Health, for pumping septic systems in high risk areas adjacent to waterways
(within 600 ft.) or stormwater system; subject to grant funding availability
Consider partnerships with Master Gardeners to provide education opportunities on water
use and practices for gardening
Consider collaboration with community groups to provide "boots on the ground" local
information to focus implementation efforts on reducing bacteria and other pollutants,
close to the source
Consider collaboration with County internal departments to leverage mutually beneficial
projects to promote retrofits to include installation of controls to address priority pollutants,
or land acquisition efforts to preserve open space, if feasible
Consider collaboration with watershed partners to encourage consistent messaging to
specific targeted audiences (commercial, residents, and others) to conserve water and
mitigate dry weather flows
Consider collaboration with watershed partners on Round 4 of Proposition 84 Integrated
Regional Water Management (IRWM) grant opportunities to fund targeted educational
programs, building of structural controls (brick and mortar projects), or incentive programs
to reduce runoff from the stormwater conveyance system
Consider collaboration with watershed partners and Regional Water Quality Control Board
on effective measures to reduce potential impact of pollutant loads to waterways from
unauthorized encampments
Consider collaboration with wastewater agencies to identify where sewer and stormwater
infrastructure are in close proximity and confirm the absence of flow at nearby stormwater
conveyance outfalls during dry weather, conduct additional investigations to identify and
mitigate flow if present
Consider collaboration with watershed partners to remove invasive non-native plants
(Arundo) upstream areas of rivers or tributaries to increase flood and fire protection and
reduce the number of unauthorized encampments on the river bottom
In collaboration with the Department of Environmental Health, consider developing
program for on-site wastewater treatment (septic) systems. May include mapping and risk
assessment, inspection, or maintenance practices.
Consider the implementation of focused pet waste projects to reduce bacteria pollution
V
San Marcos HA (904.5)
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• Consider investigating diverting persistent dry weather flows from storm drains to sanitary
sewer, where feasible
• Consider the design of structural controls for persistent unpermitted dry weather flows
where outreach has been unsuccessful and groundwater or other non-MS4 sources has
been ruled out
• Consider developing a strategy to evaluate opportunities to naturalize concrete stormwater
conveyances, and identify potential funding sources (such as grants) for design and
implementation
• Consider collaboration with the Department of Agriculture, Weights and Measures (AWM)
to evaluate and reprioritize the AWM's stormwater program to determine inspection
priorities.
3.5.4 San Marcos HA Monitoring and Assessment
The Responsible Agencies will conduct the following monitoring in the San Marcos HA including the
collective watershed-wide monitoring activities described in Section 2.5:
Progress Toward Interim and Final Goals
Bacteria TMDL Monitoring at Moonlight Beach
Dry Weather Special Study
Bacteria Special Study (Bight 13)
MS4 Outfall Monitoring (as described in Section 2.5)
JRMP Implementation (as described in Section 2.5)
Regulations and Policy (as described in Section 2.5)
Progress Toward Interim and Final Goals
To assess progress toward achieving the interim and final goals, the San Marcos HA Responsible
Agencies will monitor selected outfalls periodically specifically for flow conditions, e.g., rates and
volumes. At select outfalls, in addition to flow conditions, the Responsible Agencies will collect the
following data as part of the MS4 Outfall Monitoring Program, at minimum, during dry weather
conditions:
Total Dissolved Solids • Nitrate • Zinc
Total Suspended Solids • Total Kjeldhal Nitrogen • Total Coliform
Total Hardness • Ammonia • Fecal Coliform (or E. Coli)
Total Phosphorus • Cadmium • Enterococcus
Orthophosphate • Copper
Nitrite • Lead
In addition, the selected outfalls will collect data to evaluate applicable NALs and 303d listed
constituents as proposed in the MS4 Outfall Monitoring Plan that provides a tailored analyte list per HA.
In order to assess program impacts, the Responsible Agencies will establish baseline flow conditions. It is
anticipated that this will occur during the dry weather season of 2015. Future monitoring will provide
flow conditions periodically to calculate percent change from baseline conditions. These calculated
percent changes in flow conditions will be the assessment used to determine the progress towards
achieving interim goals in the San Marcos HA.
Responsible Agencies will also conduct a special study that will inform the data collection and
assessment for determining progress towards achieving the final goals for the San Marcos HA. Details of
the special study are below.
San Marcos HA (904.5)
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Bacteria TMDL Compliance Monitoring
Compliance monitoring during wet and dry weather will be conducted each year at the AB411
monitoring site (EH-420) located within the Pacific Ocean shoreline segment at Moonlight State Beach.
The data generated will be used to address the following questions:
• Are TMDL numeric targets for fecal indicator bacteria (FIB) being met at the compliance
monitoring locations?
• Are levels of FIB decreasing at the compliance monitoring locations?
Dry weather monitoring will be conducted by the City of Encinitas on dry weather days, after an
antecedent dry period of 72 hours with less than 0.1 inch of rainfall, in accordance with the MS4 Permit.
Consistent with historical AB 411 Program requirements, dry weather sampling will be conducted
weekly between April 1 and October 31, when recreational activities are more likely to occur. Weekly
dry weather samples will be collected so that at least five samples are collected in each calendar month
(30 days).
During the wet season (October 1 through April 30), the City of Encinitas will conduct monthly dry
weather monitoring (at a minimum) and wet weather monitoring during one to three storm events. Wet
weather samples will be collected within 72 hours after end of rainfall. Storms resulting in greater than
0.1 inch of precipitation will be targeted for sample collection. Fecal indicator bacteria (FIB) are the
target constituents for the Pacific Ocean Shoreline at Moonlight State Beach, as indicated in Attachment
E ofthe MS4 Permit.
The proposed Bacteria TMDL Monitoring Plan describes detailed monitoring procedures and analytical
methods that are illustrative and may be revised on the basis of site-specific environmental conditions
and updated methodology.
Son Marcos HA Dry Weather Special Study
A Dry Weather Special Study will be developed to characterize temporal flow and fecal indicator
bacteria patterns at selected persistently flowing major MS4 outfalls during summer dry weather
conditions. The special study is related to indicator bacteria, which has been identified as a Priority
Water Quality Condition for this HA and the City San Marcos will implement this study in priority areas
within their jurisdiction.
The Dry Weather Special Study will address the following questions:
• What is the baseline flow at the specified major MS4 outfalls during summer dry weather
conditions?
• What are the temporal flow patterns at specified major MS4 outfalls during summer dry
weather conditions?
• Are summer dry weather flows at the specified major MS4 outfalls contributing fecal indicator
bacteria to the receiving water(s)?
• What are the temporal patterns of indicator bacteria concentrations at specified major MS4
outfalls?
The study will:
• Address data gaps related to temporal flow and fecal indicator bacteria patterns at selected
persistently flowing major MS4 outfalls during summer dry weather conditions.
^^X^ San Marcos HA (904.5)
\ - Page 130
• Allow the City of San Marcos to understand potential sources of flow and therefore more
effectively target and control sources contributing to the Highest Priority Water Quality
Condition.
• Establish a baseline for flow during summer dry weather conditions with which to measure
subsequent flow reductions.
The City of San Marcos will conduct the special study at an outfall level as well as collectively with other
outfall data collected under the same special study throughout the WMA. The following components of
the special study will be conducted:
• Collect continuous flow monitoring data at specified major outfalls using automated flow meter
and data logger.
• Conduct monitoring events at selected major outfalls specified in Table 41
• Collect grab samples and analyze for fecal indicator bacteria (total coliform, fecal coliform, and
Enterococcus) to identify critical conditions for bacteria
• Record visual observations consistent with the transitional outfall monitoring program.
• Collect in-situ physical parameters for pH, temperature, and specific conductivity.
• Perform site observations at key times within the catchment areas and record all observed areas
and/or sources with non-storm water flow.
• Track flow patterns to sources for abatement or further investigation.
Table 41: Dry Weather Data Collection by Jurisdiction for the San Marcos HA
Item City of San Marcos
Number of Focus Areas in San Marcos HA 3
Number of Outfalls for Continuous Flow Monitoring 3
Minimum Time for Continuous Flow Monitoring 2 weeks
Minimum Number of Fecal Indicator Bacteria Samples at Each Outfall Where
Flow is Measured 4
Total Number of Bacteria Samples 12
Son Marcos HA Microbiology Drainage Water Special Study
MS4 drainages may greatly influence the exceedance frequency of water quality standards for
Enterococcus, a type of fecal indicator bacteria at beaches. However, as stated in the Bight '13
Microbiology Drainage Water Study Work Plan, "because Enterococcus is a non-specific indicator of fecal
material, the extent to which these flows contain human fecal contamination is unclear". The goal of the
study is to assess the extent of human fecal contamination from coastal drainages to the ocean to
inform managers as to the extent of the problem and to assist in prioritizing individual sites for
remediation efforts or adoption of alternative management strategies (Griffith, 2010).
The City of Encinitas has elected to participate in the Bight '13 Microbiology Drainage Water Study as it
will generate data to characterize the potential contribution of human fecal contamination from the San
Marcos HA to Moonlight Beach and to inform strategies or management actions related to indicator
bacteria. Each agency participating in the program will sample within its jurisdiction at selected sites and
samples will be analyzed for a human-associated fecal marker (HF183) to gauge the presence of human
fecal material in each sample (Griffith, 2010). Overall, twenty-six sites will be sampled during dry
weather and twenty-four during wet weather or storm conditions. Both frequency and magnitude of
San Marcos HA (904.5)
Page 131
human signal will be considered for assessing the extent of human fecal contamination using the
percentage of samples positive for human fecal material at each site and across the region.
Assessment
The San Marcos HA Responsible Agencies will perform assessments ofthe following elements:
• Progress Toward Interim and Final Goals
• Bacteria TMDL Monitoring at Moonlight Beach
• Dry Weather Special Study
• Bacteria Special Study (Bight 13)
As new data and information becomes available, the Responsible Agencies will perform an integrated
assessment of the findings from the identified focused areas. The integrated assessment will evaluate
the JRMP program implementation in relationship to the findings of the assessment for progress toward
interim and final goals. This integrated assessment would be performed at this scale to identify
relationships between the strategies implemented in the focus areas and outcomes related to the
interim and final goals. The outcomes of this assessment could be used to help determine the
effectiveness and efficiency of selected the strategies implemented.
Longer-term assessments will be performed at the WMA scale as appropriate data and information is
collected and assessed.
/J\/ San Marcos HA (904.5)
\ ^ Page 132
3.6 Escondido Creek HA (904.6)
The Escondido Creek Hydrologic Area is the largest and most complex system within the WMA. The HA
extends approximately 24.6 miles inland from the coast and totals 54,100 acres in the area, comprising
40% of the WMA. Escondido Creek watershed originates in Bear Valley in north central San Diego
County and discharges into the Pacific Ocean via San Elijo Lagoon. Elevations within the HA range from
sea level to 2,420 feet on the ridges above Bear Valley in the vicinity of Daley Ranch, a 3,000 acre
conservation area managed by the City of Escondido. There are two reservoirs within the watershed:
Lake Wohlford and Dixon Lake. Over half ofthe HA is in unincorporated areas ofthe County (55%). The
remaining is in the cities of Escondido and Encinitas, with a small portion in San Marcos and Solana
Beach. The primary receiving waters are Escondido Creek, Lake Wohlford, Lake Dixon, Reidy Creek, San
Elijo Lagoon, and the Pacific Ocean.
During the initial phase of the Water Quality Improvement Plan process, assessment of existing data
determined that the PWQCs within the Escondido Creek HA include: indicator bacteria in Escondido
Creek and San Elijo Lagoon; toxicity in Escondido Creek; nutrients in Escondido Creek; sediment/siltation
in San Elijo Lagoon; and eutrophic condition in San Elijo Lagoon. Of these PWQC, the HPWQC in the
Escondido Creek HA was determined to be indicator bacteria in Escondido Creek (wet weather
conditions) and San Elijo Lagoon (dry weather conditions) (June 2014 Carlsbad WMA WQIP submittal to
RWQCB).
Figure 34 below, shows the Escondido Creek HA, HPWQC and focus areas. The focus areas and their
associated strategies and goals are explained in more detail below.
yi'^-cn <.f.. -tJfcity-jjj .•.*)^.fj. 'loit^uti, ;wtii.-jr'ii>u>-!i;.ite- ii-l.'J-I/'MI
Figure 34: Escondido Creek HA Highest Priority Water Quality Conditions and Focus Areas
Escondido Creek HA (904.6)
Page 133
3.6.1 Escondido Creek HA Sources
The following Table 42 presents a listing of inventoried sources in the Escondido Creek HA and their
association with HPWQCs and PWQCs based on source loading potential (2011 LTEA). The PWQC,
eutrophic condition, is included in the "nutrients" category in the table below.
Table 42: Pollutant Generating Sources - 904.6 Escondido Creek Hydrologic Area
Pollutant Source Loading Potential^
Inventory Sites/Facilities^ Quantities^ 01 athogens i/linerals Metals ro
OJ
oa
o Sediment Pesticides Nutrients Bacteria/P; Dissolved f Organics Toxicity Animal Facilities 25 N UL L UK L L N L UK
Auto Repair, Fueling, or Cleaning 306 L L UL UL UK UL L L UK
Auto Parking Lots or Storage 97 L L L UK UK UK UL L UK
Auto Body Repair or Painting 38 L L UL UL UL UL L L UK
Nurseries/Greenhouses 29 L UL L L L L UL UL UK
Building Materials Retail 24 L L L UL UL UL UL L UK
Concrete Manufacturing 5 L L L UL UL UL UL L UK
Eating or Drinking Establishments 410 L UL UK UK L UL L UK
Equipment Repair or Fueling 40 L L UL UL UK UL UL L UK
Fabricated Metal 53 L L UK UK UK UL UL L UK
Food Manufacturing 11 UL UL UL UL UL UL UL UL UK
General Contractors 155 UL UL L UL UL UL UL UL UK
General Industrial 53 L L UK UK UK UK UK UK
General Retail 156 UL UL L UL UL UL UL UL UK
Health Services 8 N UL L UK L UL UK L UK
Motor Freight 17 L L UK UK UK UK UL L UK
Offices 8 UK UK UK UK UK UK UK UK UK
Parks and Rec 7 UK UK UK UK L UK UL UK UK
Pest Control Services 15 N UK N L N UK N UK UK
Publicly Owned Treatment Works 1 UK UK UK N UK L UL UK UK
Primary Metal 4 L UK UK UK UK UL N UK UK
Recycling & Junk Yards 10 L L L UL UL UL L L UK
Roads, streets & Parking 1 L L L UL L L L L UK
Stone/Glass Manufacturing 21 L L L UL UL UL UL L UK
storage/Warehousing 30 L L L UL UL UL UL L UK
Municipal 100 N N L N N UK UL N UK
Construction Varies UL UL L UL UL UL L UL UK
Residential 18,910 acres L L L L L L L L UK
The highest TTWQ rated sources within each HA based on the HPWQC are identified in the table (yellow highlight signifies HPWQC). The
HPWQC is associated with the sources that are likely to generate those pollutants (blue highlight). The PWQP is highlighted in green and the
associated sources that are likely to generate those pollutants are depicted with an "L".
1: Other sources are not reported in this table including: Land Development and Non-inventoried Businesses
2: Quantities based on the Responsible Agencies FY 2012 JURMP Annual Reports
3: Pollutant Source Loading Potential taken from LTEA 2011; N = None, UK = Unknown, UL = Unlikely, L = Likely
4: The quantity of construction sites is dynamic due to projects starting and completing at any given time.
Escondido Creek HA (904.6)
Page 134
3.6.2 Escondido Creek HA Goals and Strategies
3.6.2.1 Escondido Creek HA Goals
Goals have not been established that apply to the entire Escondido Creek Hydrologic Area. Separate
goals have been established for each focus area and are presented in the sub-sections below.
3.6.2.2 Escondido Creek HA Strategies
The following Table 43 identifies the Water Quality Improvement Strategies to be implemented
throughout the entire Escondido Creek HA and in some specific focus areas of the HA. In addition to the
planned strategies, optional strategies are identified that may be implemented based on circumstances
related to the progress Responsible Agencies make towards numeric goals and funding. The strategies
associated with the focus areas are described further in the sub-sections below.
As the Responsible Agencies implement strategies and analyze data, it is expected that these strategies
and schedules may change through the iterative and adaptive management process. The adaptive
management process is presented in Section 2.4.
Escondido Creek HA (904.6)
Page 135
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Escondido Creek HA (904.6)
Page 136
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3.6.3 Escondido Creek HA Focus Areas
Concentrating program efforts in specific geographic areas to address known or suspected sources of
discharges and pollutants is expected to improve the effectiveness ofthe strategies and activities.
Based on the Responsible Agencies review of the characteristics of the Escondido Creek HA, several
areas of focus were selected for concentrated program efforts. These focus areas include the City of
Solana Beach within the Escondido Creek HA, two drainage basins in the City of Encinitas (Cardiff
Channel Drainage Area and San Elijo JPA Outfall at Cardiff) and three basins in the City of Escondido (ESC
113, ESC 128, and ESC 134). The goals and strategies for these focus areas are summarized below.
3.6.3.1 Solana Beach Drainage Area
The San Elijo Lagoon is on the northern border of the City of Solana Beach. The City of Solana Beach has
identified the entire portion of the City that discharges towards the lagoon as its focus area, shown in
Figure 35 below. The area is primarily single-family residential land use with some commercial areas,
multi-family residential, an elementary school, a portion of a golf course, common areas and
recreational park areas that include landscaping and turf. The majority of this basin was developed prior
to implementation of the City of Solana Beach SUSMP, therefore relatively few treatment control BMPs
have been established.
Figure 35: Solana Beach Drainage Area/Focus Area
Escondido Creek HA (904.6)
Page 140
Solana Beach Drainage Area Interim and Final Numeric Goals
Goals associated with this focus areas are summarized in Table 44 below. These goals have been
established as a part of this initial WQIP development process. As the City of Solana Beach progresses
through the first several years of implementation and learns through data collection and analysis, it is
expected that these goals and schedules will likely change. As goals and schedules are adapted, they will
be presented in future WQIP annual reports or updates to the WQIP document.
Table 44: Solana Beach Drainage Area, Interim and Final Numeric Goals
Interim Goal
(2013-2018)
2018^
Interim Goal
(2018-2023)
2023'
Interim Goal
(2023-2028)
2028'
Interim Goal
(2028-2033)
2033'
Final Goal
(2033-2038)
2038'
10% reduction in
anthropogenic
surface water
runoff at selected
outfalls
20% reduction in
anthropogenic
surface water
runoff at selected
outfalls
40% reduction in
anthropogenic
surface water
runoff at selected
outfalls
60% reduction in
anthropogenic
surface water
runoff at selected
outfalls
80% reduction in
anthropogenic
surface water
runoff at selected
outfalls
• . .-^. -.^ . , r - J - ' -
adapted as monitoring data/information is gathered, analyzed and baselines are established.
The means for achieving these goals are identified in the strategies discussion below. Mechanisms for
measuring progress towards and ultimately achieving these goals are included in the monitoring,
assessment and iterative process sections.
City of Solana Beach Drainage Area Strategies
The City of Solana Beach will implement their program core strategies within the focus area. In addition
to the core jurisdictional strategies, the following summarizes supplemental or modified core strategies
planned for implementation in the focus area to address the sources of pollutants and discharges.
The selected strategies are expected to have multi-pollutant benefits and intended to address non-
stormwater flows and reducing the source loading of bacteria. Reducing non-stormwater flows: (1)
reduces the loading of pollutant constituent discharged through MS4 system; (2) reduces the amount of
indicator bacteria regrowth and contributions that occurs with accumulated biofilm in MS4 systems that
requires water; and (3) reduces the wet-weather contribution of indicator bacteria from scoured biofilm
under higher velocity flows from storm discharges.
To accomplish the multi-benefit objectives, the City of Solana Beach will supplement its core
jurisdictional program by implementing the following strategies in this focus area:
1) Irrigation Runoff Reduction Program
The objective of the IRRP is to eliminate or reduce dry weather flow contributions coming from
irrigation runoff, regardless of the time of day the discharges occur. Core elements include:
Developing municipal codes that prohibit irrigation runoff
Developing educational materials and outreach program specific towards irrigation runoff
Assessing dry weather flows at outfall(s)
Identifying key times to perform site observations
Perform site observations to identify sources of irrigation runoff
Collaboration with the City of Solana Beach Public Works Department to address municipal
property irrigation systems
Initiating contact and correspondence with property managers/owners
Escondido Creek HA (904.6)
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V
• Periodically assessing flows
• Optionally developing and implementing an incentive program
2) Property-Based/Patrol Inspections
The objective of this program is to reduce discharges to the MS4 and provide inspection of existing
development in a more cost efficient and effective manner. Features include:
• Developing patrol and inspection protocols
• Developing and conducting staff training
• Conducting property-based/patrol inspections
The City of Solana Beach will perform these property-based/patrol inspections multiple times per
year at various times of the day to capture irrigation runoff and other non-authorized discharges as
well as identify BMP issues.
3) Plastic Bag Ban
The City of Solana Beach passed an ordinance banning distribution of single use plastic bags. The
ban became effective for all grocery stores and pharmacies on August 9, 2012 and for all other retail
stores on November 9, 2012.
4) Santa Rosita and Santa Florencia Slope Drainage Collection
In January 2014, the City of Solana Beach approved plans for a slope drain diversion structure that
diverts water collected in subdrains along the slopes of Santa Rosita and diverts it in the sewer
manhole located at the intersection of Santa Rosita and Santa Florencia. This project was
constructed in August 2014 and helps prevent dry weather flows caused from over irrigation from
entering the MS4.
5) Stormwater Treatment Continuous Deflection System (CDS) Unit
In 2002, the City of Solana Beach approved plans for improvements along North Cedros Avenue,
north of Cliff Street. These improvements included installation of a stormwater treatment CDS unit.
This unit was installed in 2004 and has been in operation ever since. The CDS unit screens,
separates, and traps debris in runoff from a 42" pipe.
6) Optional Strategies
• Implement structural (engineered) BMPs or retrofitting existing structural BMPs to address
flow and/or pollutant issues
• Implement offsite alternative compliance program to place water quality improvement
projects in the portion of the City of Solana Beach that discharges to San Elijo Lagoon
• Support partnership effort by social service providers to provide sanitation and trash
management for persons experiencing homelessness
3.6.3.2 City of Encinitas - Cardiff Channel and San Elijo JPA Outfall
The San Elijo Lagoon is on the southern border of the Encinitas. Encinitas has identified two basins that
discharge to the lagoon to focus their program strategies. The basins have a variety of land uses with a
mixture of single-family residential, commercial and multi-family land uses and includes homes,
commercial buildings, apartment complexes, nurseries, common areas and recreational park areas that
include landscaping and turf. The majority of these basins were developed prior to implementation of
the Encinitas's SUSMP and therefore relatively few treatment control BMPs are in place.
Escondido Creek HA (904.6)
Ml^ Page 142
Encinitas will concentrate strategy implementation in two focus areas, identified as Cardiff Channel
Drainage Area and San Elijo joint powers authority (JPA) outfall at - see Figures Figure 36 and Figure 37
below.
Cardiff Channel Focus Area
1 |] Escondido Creek HA
Cardiff Channel Drainage Area
f. 1 HPWQC
1 San Elijo Lagoon
HPWOG: Indicator Bacteria | j/J Pacific Ocean
E« Digit
AEX Gel-napiirii) ana Ihe GIS 'J«i Coimniinil',
Figure 36: Cardiff Channel Drainage Area, City of Encinitas Focus Area
Escondido Creek HA (904.6)
Page 143
San Elijo JPA Outfall
at Cardiff Drainage Area
J Escondido Creek HA
San Elijo JPA Outfall @ Cardiff
HPWQC
Pacific Ocean
Figure 37: San Elijo JPA Outfall at Cardiff Drainage Area, City of Encinitas Focus Area
Cardiff Channel and San Eljio JPA Outfall Drainage Areas Interim and Final Numeric Goals
Goals associated with these focus areas are summarized in Table 45 below. These goals have been
established as a part of this initial WQIP development process. As Encinitas progresses through the first
several years of implementation and learns through data collection and analysis, it is expected that
these goals and schedules will likely change. As goals and schedules are adapted, they will be presented
in future WQIP annual reports or updates to the WQIP document.
The means for achieving these goals are identified in the strategies discussion below. Mechanisms for
measuring progress towards and ultimately achieving these goals are included in the monitoring,
assessment and iterative process sections.
Escondido Creek HA (904.6)
Page 144
Table 45: Cardiff Channe and San Elijo JPA Outfall Drainage Areas, Interim and Final Numeric Goals
Interim Goal Interim Goal Interim Goal Final Goal
(2013-2018) (2018-2023) (2023-2028) (2028-2033)
2018 2023 2028 2033
• 100% of dry weather
flow to San Elijo JPA
outfall at Cardiff
diverted to the sanitary
sewer system
• 10% reduction in
anthropogenic dry
weather flows within the
Cardiff Channel drainage
area'
• San Elijo Lagoon
Restoration
Completed^
OR
• 50% reduction in
anthropogenic dry
weather flows
within the Cardiff
Channel drainage
area'
• San Elijo Lagoon
Restoration
Completed^
OR
• 65% reduction in
anthropogenic dry
weather flows
within the Cardiff
Channel drainage
area'
• San Elijo Lagoon
Restoration
Completed^
OR
• 80% reduction in
anthropogenic dry
weather flows
within the Cardiff
Channel drainage
area'
adapted as monitoring data/information is gathered, analyzed and baselines are established.
^ The San Elijo Lagoon Conservancy is leading the lagoon restoration effort. The City of Encinitas anticipates providing public
support for the restoration work and making some infrastructure improvements close to the lagoon that are necessary to
complement the restoration work.
Son Elijo JPA Outfall and Cardiff Channel Drainage Area Strategies
Encinitas will implement their program core strategies within the focus area. In addition to the core
jurisdictional strategies, the following summarizes supplemental or modified core strategies planned for
implementation in the focus area to address the sources of pollutants and discharges.
The selected strategies are expected to have multi-pollutant benefits and intended to address non-
stormwater flows and reducing the source loading of bacteria. Reducing non-stormwater flows: (1)
reduces the loading of pollutant constituent discharged through MS4 system; (2) reduces the amount of
indicator bacteria regrowth and contributions that occurs with accumulated biofilm in MS4 systems that
requires water; and (3) reduces the wet-weather contribution of indicator bacteria from scoured biofilm
under higher velocity flows from storm discharges.
To accomplish the multi-benefit objectives in the two drainage areas, the Encinitas will supplement its
core jurisdictional program by implementing the following strategies in these focus areas:
1) San Elijo Lagoon Restoration
The planned restoration project will directly improve beneficial uses in the impacted receiving
waters. Encinitas identifies this as one of the most effective strategies to meet identified goals.
Encinitas will support the multi-agency efforts to restore San Elijo Lagoon in coming years. Part of
the participation will come through supporting public infrastructure improvements.
2) Plastic Bag Ban
Encinitas passed an ordinance banning distribution of single use plastic bags. The ban applies to
large retailers, grocery stores, drug stores, convenience stores, and mini-markets in spring 2015 and
to farmers markets and all other retailers in fall 2015.
Escondido Creek HA (904.6)
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3) San Elijo JPA Dry Weather Diversion
In FY 2012-2013, a dry weather diversion was installed at the San Elijo JPA outfall in Cardiff. The
diversion redirects dry weather flows to the sanitary sewer system for treatment prior to
discharging to an ocean outfall. Encinitas continues to operate and maintain this diversion.
4) Dry Weather Flow Abatement Program
Upon completion of the Dry Weather Flow Source Investigation Study, Encinitas will focus on
eliminating identified anthropogenic sources of non-stormwater dry weather flows.
5) Optional Strategies
Sewer Infrastructure Improvement Project
The Olivenhain Trunk Sewer line runs adjacent to the lagoon and is planned to be rehabilitated upon
approval of funding. Rehabilitation would address the sewer line which is reaching the end of its
service life and reduce the risk of sewer overflows potentially discharging into the San Elijo Lagoon.
3.6.3.3 County of San Diego - Escondido Creek HA Focus Areas
Three of the County's major storm drain outfalls in the Escondido Creek HA have persistent flows. The
unincorporated area that makes up the three drainage areas have a range of land use types (residential,
residential with some agriculture, commercial businesses, schools, roads, etc.) which includes activities
with likely potential for pollutant source loading. The focus areas are shown below in Figures Figure 38,
Figure 39 and Figure 40.
Figure 38: County of San Diego CAR 007 Focus Areas
Escondido Creek HA (904.6)
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Figure 39: County of San Diego CAR 015 Focus Areas
Escondido Creok HPWQC Indicalot Baden
EL CAMINO DE
I Miles
0 O OS 0.1 0.2
CAR 059 Focus Area
Carlsbad WMA
\ \ CAR_059
• HPWQC
Figure 40: County of San Diego CAR 059 Focus Areas
Escondido Creek HA (904.6)
Page 147
County of San Diego CAR 007, CAR 015 and CAR 059 Interim and Final Numeric Goals
Goals associated with these focus areas are in conjunction with the targeted outcomes identified in the
County's San Marcos HA focus areas. These goals have been established as a part of this initial WQIP
development process. As the County progresses through the first several years of implementation and
learns through data collection and analysis, it is expected that these goals and schedules will likely
change. As goals and schedules are adapted, they will be presented in future WQIP annual reports or
updates to the WQIP document.
The dry weather goals were established to reduce dry weather flow in storm drains, in order to reduce
pollutant loading to water bodies during dry weather. This will be accomplished through the
implementation of JRMP strategies to reduce dry weather runoff, as described in the County JRMP.
For the grouping of seven identified persistently flowing major MS4 outfalls in the County's jurisdiction
within the entire Carlsbad WMA, the County has set targeted outcomes (in San Marcos HA) and goals of
eliminating anthropogenic flows from one major storm drain outfall that discharges to receiving waters,
during each Permit term, until all anthropogenic flows have been effectively eliminated. Goals are
expressed in Table 46 below.
Table 46: County of San Diego Escondido Creek HA Focus Areas, Interim and Final Goals
Interim Goal
(2013-2018)
2018'
Effectively eliminate
anthropogenic dry weather
flows''^ from one persistently
flowing outfalP
Interim Goals
(2018-2043)
2023'and each subsequent five
year period
Final Goal
(2043-2048)
2048'
Effectively eliminate anthropogenic
dry weather flows''^ from one
additional persistently flowing
outfall^
Effectively eliminate anthropogenic
1 2
dry weather flows ' from one
additional persistently flowing
outfall^ each subsequent permit
term, until ali flows have been
effectively eliminated
The goals may be adapted as monitoring data is collected and analyzed.
^ Here and throughout this table, the term "dry weather flows" excludes groundwater, other exempt or permitted non-
stormwater flows, and sanitary sewer overflows.
^ The County of San Diego is concerned that a long-term funding source is not identified for constructing and maintaining
structural BMPs, if structural BMPs are needed to meet compliance. The implementation of strategies to achieve goals will
depend upon approval of funding in future annual budgets.
County of San Diego CAR 007, CAR 015 and CAR 059 Drainage Basin Strategies
The County WPP will shift to a more active field program to better locate and abate dry weather flow.
WPP Stormwater Staff will increase the amount of time spent in unincorporated communities,
identifying nuisance anthropogenic flows and addressing them through appropriate education and
enforcement strategies. County staff will continue to be trained to identify and report illicit discharges
and illicit connections during required annual stormwater training. This training has been updated to
reflect recent Permit changes.
In addition to the increase in County staff field surveillance, WPP will also implement a focused program
to reduce flows at targeted MS4 outfalls that have demonstrated persistent dry weather flow
conditions. Using collected dry weather monitoring data collected, the County has identified priority
Escondido Creek HA (904.6)
Page 148
outfalls in the Carlsbad Watershed that will be monitored regularly for dry weather flow. If dry weather
flows are detected, staff will initiate a field investigation to seek out and abate the source of flow.
The County will implement their core jurisdictional program strategies within the focus area. In addition
to the core jurisdictional strategies, the following summarizes supplemental or modified core strategies
planned for implementation in the focus area to address the sources of pollutants and discharges.
The selected strategies are expected to have multi-pollutant benefits and intended to address non-
stormwater flows and reducing the source loading of bacteria. Addressing non-stormwater flows: (1)
reduces the loading of pollutant constituent discharged through MS4 system; (2) reduces the amount of
indicator bacteria regrowth and contributions that occurs with accumulated biofilm in MS4 systems that
requires water; and (3) reduces the wet-weather contribution of indicator bacteria from scoured biofilm
under higher velocity flows from storm discharges.
To accomplish the multi-benefit objectives, the County will supplement its core jurisdictional program
by implementing the following strategies in these focus areas:
1) Active Field Program to Identify and Address Dry Weather Flows - The focused area was
selected based on strategic assessments, including review of 303(d) listings, monitoring data,
and persistent flows. Field staff will conduct surveillance and may employ various tools to
reduce pollutant loads and non-stormwater flows, including outreach efforts including over-
irrigation focus, pet waste, HOA, and landscaper outreach. New outreach materials will be
developed for use in focused inspections.
2) Updated Focused Training for County Field Staff - Field Staff training to be updated with
information on HPWQCs identified in WQIP and the pollutant sources and pollutant generating
activities that may be associated with the HPWQCs.
3) BMP Manual Training - External - The BMP Manual for new and redevelopment will be updated
and training/outreach will be provided to the development industry.
4) Promote Rain Barrel Incentive Programs - Promoting partners programs for rainwater
harvesting rebates. Partner agencies including the MWD, local water districts, and the SDCWA.
Example: MWD - www.socalwatersmart.com
5) Collaborate with Partner Agencies to Promote Incentive Programs for BMP Retrofits -
Promoting incentives for water conservation and landscape retrofits through partner agencies
(same as above) such as turf replacement, sprinkler head nozzle replacements, smart irrigation
controllers, etc. Incentive programs may be developed for this program if funding is available.
6) Promote Live Turf Replacement Incentive Program - Promote turf replacement programs for
replacement with California Friendly plants.
7) Promote Water-Smart Incentive for Outdoor Water Efficiency as part of the public-private
partnership - Development of Sustainable Landscape Program is underway with partners
including: SDCWA, City of San Diego, Surfrider Foundation, the Association of Compost
Producers, and the County. Developing guidelines will promote water conservation, building
healthy soils, and sustainable practices.
Escondido Creek HA (904.6)
Page 149
8) Develop, Improve, Distribute Outreach Materials for Existing Development - Develop outreach
materials to raise awareness of stormwater and urban runoff concerns and encourage behaviors
that will improve water quality downstream.
9) Educational Workshops- Continue to sponsor workshops for specific target audiences and
pollutants of concern, including: manure management and composting workshops for horse
owners; Integrated pest management and gardening workshops for residents interested in
gardening and more sustainable landscape practices; and rain water harvesting classes to
encourage capturing rain from roofs for landscape use.
10) Education & Outreach Effectiveness Survey - The completed County baseline survey of
registered voters in the unincorporated area established a reference point for the knowledge
and awareness of residents. During educational workshops, pre and post surveying will be
conducted to assess the effectiveness of programs reaching attendees. These will measure
improvement in knowledge, awareness, and likely-hood of changing behaviors to be less
polluting.
11) Optional Strategies
• Consider feasibility of developing an alternative compliance program, and if developed
consider constructing structural controls to reduce priority water pollutants.
• Investigate feasibility of developing a Green Streets Program
• Consider improvements to tracking watershed-based inventories via consolidated database
• Develop an Equestrian BMP Handbook
• Investigate the feasibility of an inspections tracking program via mobile platform - miles,
violations, etc.
• Investigate the feasibility of improvements to inspections data tracking through mobile
phone
• Investigate the feasibility of developing and implementing an incentive program for BMP
Retrofits in areas of existing development
• Develop Sustainable Landscapes Outreach Program based on available grant funding
• Investigate feasibility of stream, channel, and/or habitat rehabilitation projects and identify
project partners
• Consider development of incentive programs for water conservation (turf replacement,
smart irrigation controllers, irrigation modifications, sustainable landscapes, rain barrels), in
collaboration with water agencies and others, to reduce priority pollutants
• Consider development of incentive programs, in collaboration with the Department of
Environmental Health, for pumping septic systems in high risk areas adjacent to waterways
(within 600 ft.) or stormwater system; subject to grant funding availability
• Consider partnerships with Master Gardeners to provide education opportunities on water
use and practices for gardening
• Consider collaboration with community groups to provide "boots on the ground" local
information to focus implementation efforts on reducing bacteria and other pollutants,
close to the source
• Consider collaboration with County internal departments to leverage mutually beneficial
projects to promote retrofits to include installation of controls to address priority pollutants,
or land acquisition efforts to preserve open space, if feasible
• Consider collaboration with the AWM to evaluate and reprioritize the AWM's stormwater
program to determine inspection priorities.
Escondido Creek HA (904.6)
Page 150
• Consider collaboration with watershed partners to encourage consistent messaging to
specific targeted audiences (commercial, residents, and others) to conserve water and
mitigate dry weather flows
• Consider collaboration with watershed partners on Round 4 of Proposition 84 IRWM grant
opportunities to fund targeted educational programs, building of structural controls (brick
and mortar projects), or incentive programs to reduce runoff from the stormwater
conveyance system
• Consider collaboration with watershed partners and RWQCB on effective measures to
reduce potential impact of pollutant loads to waterways from unauthorized encampments
• Consider collaboration with wastewater agencies to identify where sewer and stormwater
infrastructure are in close proximity and confirm the absence of flow at nearby stormwater
conveyance outfalls during dry weather, conduct additional investigations to identify and
mitigate flow if present
• Consider collaboration with watershed partners to remove invasive non-native plants
(Arundo) upstream areas of rivers or tributaries to increase flood and fire protection and
reduce the number of unauthorized encampments on the river bottom
• In collaboration with the Department of Environmental Health, consider developing
program for on-site wastewater treatment (septic) systems. May include mapping and risk
assessment, inspection, or maintenance practices.
• Consider the implementation of focused pet waste projects to reduce bacteria pollution
• Consider investigating diverting persistent dry weather flows from storm drains to sanitary
sewer, where feasible
• Consider the design of structural controls for persistent unpermitted dry weather flows
where outreach has been unsuccessful and groundwater or other non-MS4 sources has
been ruled out
• Consider developing a strategy to evaluate opportunities to naturalize concrete stormwater
conveyances, and identify potential funding sources (such as grants) for design and
implementation
3.6.3.4 ESC 113, ESC 128, and ESC 134
The Escondido Creek HA extends through a significant portion of the City of Escondido (Escondido) near
the upper portion of the HA. Escondido has identified three focus areas in the HA to focus their program
strategies. The basins have a mixture of single-family residential, commercial, industrial and multi-family
land uses and includes homes, commercial buildings, mobile home parks, nurseries, and common areas
that include landscaping and turf.
The rationale for selecting these three focus areas is based on several key factors distinguishing them
from other drainage basins. All three focus areas have:
1) Persistently flowing major MS4 outfalls directly into Escondido Creek
2) Jurisdictional basis in Escondido, with minimal surface water influence from adjacent
jurisdictions
3) Sizeable tributary areas
4) Recorded historical exceedances in indicator bacteria, the HPWQC
5) Residential Areas which will be addressed by the City of Escondido's residential JRMP
component
Escondido will implement special strategies in three focus areas, identified as ESC 113, ESC 128, and ESC
134 - shown in Figures 41 through 43.
Escondido Creek HA (904.6)
Page 151
ESC_113 Focus Area
Carlsbad WMA
ESC_113
HPWQC
Figure 41: Escondido ESC 113 Focus Area
Figure 42: Escondido ESC 128 Focus Area
V Escondido Creek HA (904.6)
Page 152
ESC-134 Focus Area
I I Cartsbad WMA
Escondido Creek HA
ESC_134 Focus Area
HPWQC
Waterbodies
0 0.07S q4i 0.)
Figure 43: Escondido ESC 134 Focus Area
fSC 113, ESC 128, ESC 134 Focus Area Goals
Goals associated with this focus area are summarized in Table 47 below. These goals have been
established as a part of this initial WQIP development process. As the Responsible Agencies progress
through the first several years of implementation and learn through data collection and analysis, it is
expected that these goals and schedules will change. As goals and schedules are adapted, they will be
presented in future WQIP annual reports or updates to the WQIP document.
Interim Goal
(2013-2018)
2018'
Interim Goal
(2018-2023)
2023'
Interim Goal
(2023-2028)
2028'
Interim Goal
(2028-2033)
2033'
Final Goal
(2033-2038)
2038'
10% reduction in
anthropogenic dry-
weather surface
water runoff at
selected outfalls
20% reduction in
anthropogenic dry-
weather surface
water runoff at
selected outfalls
40% reduction in
anthropogenic dry-
weather surface
water runoff at
selected outfalls
60% reduction in
anthropogenic dry-
weather surface
water runoff at
selected outfalls
80% reduction in
anthropogenic dry-
weather surface
water runoff at
selected outfalls
adapted as monitoring data/information is gathered, analyzed and baselines are established.
The means for achieving these goals are identified in the strategies discussion below. Mechanisms for
measuring progress towards and ultimately achieving these goals are included in the monitoring,
assessment and iterative process sections.
Escondido Creek HA (904.6)
Page 153
A
fSC 113, ESC 128, ESC 134 Focus Area Strategies
Escondido will implement their program core strategies throughout the City of Escondido and within the
three focus areas. The following summarizes supplemental or modified strategies planned for
implementation in the focus areas to address the sources of pollutants, discharges, and dry weather
anthropogenic flows.
The selected strategies are expected to have multi-pollutant benefits and intended to address non-
stormwater flows and reducing the source loading of bacteria. Reducing non-stormwater flows: (1)
reduces the loading of pollutant constituent discharged through MS4 system; (2) reduces the amount of
indicator bacteria regrowth and contributions that occurs with accumulated biofilm in MS4 systems that
requires water; and (3) reduces the wet-weather contribution of indicator bacteria from scoured biofilm
under higher velocity flows from storm discharges.
To accomplish the multi-benefit objectives in the three focus areas, the City of Escondido will
supplement its core jurisdictional program by implementing the following strategies in these focus
areas:
1) Property-Based/Patrol Inspections
The objective of this program is to reduce discharges to the MS4 and provide inspection of existing
development in a more cost efficient and effective manner. Inspections will address properties
which have not previously been inspected by Environmental Programs staff, including residential
properties, office parks, retail centers, and more. Features of this strategy include:
• Developing patrol and inspection protocols
• Developing and conducting staff training
• Conducting property-based/patrol inspections of 100% of commercial, municipal and
residential properties in focus areas at least once per year
• Recording observed violations and performing follow-up inspections as appropriate, through
outreach/education or enforcement as determined to be appropriate by Escondido staff.
2) Storm Drain Videos
On an as-needed basis, Escondido will use downhole video technology to assess where dry weather
flows enter the storm drain system. The objective of the use of video is to identify groundwater
intrusion and to facilitate a better understanding of the City of Escondido's MS4 network through
collaboration with the sewer and water utilities field staff.
3) Irrigation Runoff Reduction
The City of Escondido's water supply/conservation and storm water programs are housed in the
same department and will continue to work together to perform outreach to businesses and
residents on irrigation reduction programs. The City of Escondido hosts landscaping workshops and
regularly promotes water conservation to residents as described in the JRMP. Escondido has a goal
to increase the number of residents in Escondido who take advantage of rebates, incentives, and
water audit programs by 10% by the next permit cycle. It is anticipated that interactions during the
property-based patrol inspections will increase participation in such programs in the three focus
areas.
4) Enhanced FOG Inspection Program
Escondido's FOG inspection program addresses businesses with grease traps or separators, including
restaurants, automotive repair facilities, and others. As operator of a Publicly Owned Treatment
Escondido Creek HA (904.6)
Page 154
Works (POTW), Escondido implements an enhanced inspection schedule city-wide, inspecting said
businesses twice each year as opposed to the required once/year inspection schedule for FOG and
stormwater compliance. This enhanced inspection program mitigates the potential causes for sewer
overflows, and also address stormwater BMPs.
5) Promote Incentive Programs - Escondido will promote available programs such as rain barrel
implementation; live turf replacement; and water-smart incentives.
6) Optional Strategies
• Spruce Street Channel-Phase I: The major channel in Focus Area ESC 134 has been identified
as a high priority for rehabilitation and engineering improvements. Escondido has secured a
County of San Diego Vector Control grant for planning improvements to the channel and
expects resource agency permit applications will be submitted within the municipal permit
cycle. Spruce Street project implementation is contingent on funding and permits.
• Upon Escondido City Council approval, implement an offsite alternative compliance program
to place water quality improvement projects throughout Escondido, including Focus Areas.
3.6.3.5 City of San Marcos - Escondido Creek HA SM-EC Focus Area
The City of Escondido Creek HA extends into the western portion of the City of San Marcos. The City of
San Marcos identified SM-EC focus area to concentrate strategy implementation. The SM-EC focus area
is predominantly single-family residential with small pockets of commercial and multi-family land uses
and includes homes, commercial buildings, common areas that include landscaping and turf - see Figure
44 below.
Figure 44: San Marcos SM-EC Focus Area
Escondido Creek HA (904.6)
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SM-EC Focus Area Interim and Final Numeric Goals
Goals associated with this focus area are summarized in Table 48 below. These goals have been
established as a part of this initial WQIP development process. As the Responsible Agencies progress
through the first several years of implementation and learn through data collection and analysis, it is
expected that these goals and schedules will likely change. As goals and schedules are adapted, they will
be presented in future WQIP annual reports or updates to the WQIP document.
Interim Goal Interim Goal Interim Goal Interim Goal Final Goal
(2013-2018)
2018'
(2018-2023) (2023-2028)
2028'
(2028-2033)
2033'
(2033-2038) (2013-2018)
2018' 2023'
(2023-2028)
2028'
(2028-2033)
2033' 2038'
10% reduction in 20% reduction in 40% reduction in 60% reduction in 80% reduction in
anthropogenic dry-anthropogenic dry-anthropogenic dry-anthropogenic dry-anthropogenic dry-
weather surface weather surface weather surface weather surface weather surface
water runoff at water runoff at water runoff at water runoff at water runoff at
selected outfalls
1— ...
selected outfalls selected outfalls selected outfalls selected outfalls
adapted as monitoring data/information is gathered, analyzed and baselines are established.
The means for achieving these goals are identified in the strategies discussion below. Mechanisms for
measuring progress towards and ultimately achieving these goals are included in the monitoring,
assessment and iterative process sections.
SM-EC Focus Area Strategies
The City of San Marcos will implement their program core strategies within the focus area. In addition to
the core jurisdictional strategies, the following summarizes supplemental or modified core strategies
planned for implementation in the focus area to address the sources of pollutants and discharges.
The selected strategies are expected to have multi-pollutant benefits and intended to address non-
stormwater flows and reducing the source loading of bacteria. Reducing non-stormwater flows: (1)
reduces the loading of pollutant constituent discharged through MS4 system; (2) reduces the amount of
indicator bacteria regrowth and contributions that occurs with accumulated biofilm in MS4 systems that
requires water; and (3) reduces the wet-weather contribution of indicator bacteria from scoured biofilm
under higher velocity flows from storm discharges.
To accomplish the multi-benefit objectives in the SM-AH focus area, the City of San Marcos will
supplement its core jurisdictional program by implementing the following strategies:
1) Irrigation Runoff Reduction Program
The objective of the IRRP is to eliminate or reduce dry weather flow contributions coming from
irrigation runoff, regardless of the time of day the discharges occur. Core elements include:
• Developing municipal codes that prohibit irrigation runoff
• Developing educational materials and outreach program specific towards irrigation runoff
• Assessing dry weather flows at outfall(s)
• Identifying key times to perform site observations
• Perform site observations to identify sources of irrigation runoff
• Collaboration with the City of San Marcos Public Works Department to address municipal
property irrigation systems
• Initiating contact and correspondence with property managers/owners
Escondido Creek HA (904.6)
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• Periodically assessing flows
• Optionally developing and implementing an incentive program
2) Property-Based/Patrol Inspections
The objective of this program is to reduce discharges to the MS4 and provide inspection of existing
development in a more cost efficient and effective manner. Features include:
• Developing patrol and inspection protocols
• Developing and conducting staff training
• Conducting property-based/patrol inspections
The City of San Marcos will perform these property-based/patrol inspections multiple times per year
at various times of the day to capture irrigation runoff and other non-authorized discharges as well
as identify BMP issues.
3) City of San Marcos & VWD Irrigation Runoff/Water Waster Program
• The City of San Marcos and VWD staff collaborate and communicate regularly to share
information regarding reports and complaints
• Public water waster reporting is available on both the City of San Marcos and VWD websites
• The City of San Marcos utilizes VWD developed door hangers for City field staff to distribute
if water wasting is reported or observed at a property
• The City of San Marcos developed template response letters identifying both the City of San
Marcos and VWD requirements
4) City of San Marcos & VWD FOG Program Collaboration
• Continue coordination between the City of San Marcos and VWD programs. The City of San
Marcos anticipates a collaborative work effort between the City of San Marcos' inspection
program and VWD's FOG program in order to reduce sewer backups and overflows that
result from accumulation of FOG in the sewer system
• VWD established an Ordinance to regulate FOG
• VWD visited all of the FSEs within the City of San Marcos to provide an overview of the
program and expectations
• VWD created a guidance manual provided to each FSE that includes BMP information,
maintenance requirements, and record keeping documents. The City of San Marcos is
prepared to utilize these documents during independent inspections or investigations
• VWD will inspect all FSEs at least once a year and collaborate with the City of San Marcos to
perform dual inspections when needed
• Inspection results for both parties will be shared regularly to better identify problem areas
more efficiently
5) HOA and Property Manger Outreach Program
• The City of San Marcos will implement an education and outreach program that encourages
and/or incentivizes HOAs and business property managers to implement measures to
reduce dry weather and/or wet weather flows leaving their properties. Practices could
include proper installation and maintenance of irrigation systems, conversion to drought
tolerant landscaping, downspout disconnection, etc.
6) Enhancements to Education Program
Escondido Creek HA (904.6)
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• Bacteria and other priority pollutant specific education and outreach program to be
conducted in the SM-AH focus area for residents and commercial facilities related to
bacteria and other priority pollutants. The materials will have an emphasis on discharges to
the City of San Marcos' MS4 and the receiving waters impacts.
• Developing and implementing a training/seminar for property managers and others that
have direct responsibility for common areas within HOAs and commercial properties.
Educational materials and information will be developed and provided to the managers for
them to distribute to their residents and tenants.
• As part of the residential outreach program, the City of San Marcos will work with residents
and property owners to educate through various means, which may include school
programs, block parties or one-on-one meetings.
7) Filter Retrofit Program
• The City of San Marcos will continue to implement the filter upgrade program provided
through an existing grant program.
• Aging filters located within public facilities in need repair are retrofitted with new
proprietary filter systems that contain media filters to treat dissolvable pollutants including
nutrients and bacteria.
8) Optional Strategies
• Implement structural (engineered) BMPs or retrofitting existing structural BMPs to address
flow and/or pollutant issues
• Implement offsite alternative compliance program to place water quality improvement
projects in the SM-EC Basins
3.6.4 Escondido Creek HA Monitoring and Assessment
The Responsible Agencies will conduct the following monitoring in the Escondido Creek HA including the
collective watershed-wide monitoring activities described in Section 2.5:
• Progress Toward Interim and Final Goals
• Long-Term Receiving Water Monitoring (as described in Section 2.5)
• Dry Weather Special Study
• MS4 Outfall Monitoring (as described in Section 2.5)
• JRMP Implementation (as described in Section 2.5)
• Regulations and Policy (as described in Section 2.5)
Progress Toward Interim and Final Goals
To assess progress toward achieving the interim and final goals, the Escondido Creek HA Responsible
Agencies will monitor selected outfalls periodically specifically for flow conditions, e.g., rates and
volumes. At select outfalls, in addition to flow conditions, the Responsible Agencies will collect the
following data as part of the MS4 Outfall Monitoring Program, at minimum, during dry weather
conditions:
Total Dissolved Solids • Nitrate • Zinc
Total Suspended Solids • Total Kjeldhal Nitrogen • Total Coliform
Total Hardness • Ammonia • Fecal Coliform (or E. Coli)
Total Phosphorus • Cadmium • Enterococcus
Orthophosphate • Copper
Nitrite • Lead
Escondido Creek HA (904.6)
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In addition, the selected outfalls will collect data to evaluate applicable NALs and 303d listed
constituents as proposed in the MS4 Outfall Monitoring Plan that provides a tailored analyte list per HA.
In order to assess program impacts, the Responsible Agencies will establish baseline flow conditions. It is
anticipated that this will occur during the dry weather season of 2015. Future monitoring will provide
flow conditions periodically to calculate percent change from baseline conditions. These calculated
percent changes in flow conditions will be the assessment used to determine the progress towards
achieving interim goals in the Escondido Creek HA.
Responsible Agencies will also conduct a special study that will inform the data collection and
assessment for determining progress towards achieving the final goals for the Escondido Creek HA.
Details ofthe special study are below.
Escondido Creek HA Special Study
A Dry Weather Special Study will be developed to characterize temporal flow and fecal indicator
bacteria patterns at selected persistently flowing major MS4 outfalls during summer dry weather
conditions. The special study is related to indicator bacteria, which has been identified as a Highest
Priority Water Quality Condition for the City of Carlsbad, City of Escondido, City of San Marcos, City of
Solana Beach, and City of Vista and will be implemented in priority areas within their respective
jurisdictions.
The Dry Weather Special Study will address the following questions:
• What is the baseline flow at the specified major MS4 outfalls during summer dry weather
conditions?
• What are the temporal flow patterns at specified major MS4 outfalls during summer dry
weather conditions?
• Are summer dry weather flows at the specified major MS4 outfalls contributing fecal indicator
bacteria to the receiving water(s)?
• What are the temporal patterns of indicator bacteria concentrations at specified major MS4
outfalls?
The study will:
• Address data gaps related to temporal flow and fecal indicator bacteria patterns at selected
persistently flowing major MS4 outfalls during summer dry weather conditions.
• Allow the Responsible Agencies to understand potential sources of flow and therefore more
effectively target and control sources contributing to the Highest Priority Water Quality
Condition.
• Establish a baseline for flow during summer dry weather conditions with which to measure
subsequent flow reductions.
The Responsible Agencies will conduct the special study within the Escondido Creek HA to assess at an
outfall level as well as collectively with other outfall data collected under the same special study
throughout the WMA. The following components ofthe special study will be conducted:
• Collect continuous flow monitoring data at specified major outfalls using automated flow meter
and data logger.
• Conduct monitoring events at selected major outfalls specified in Table 49
Escondido Creek HA (904.6)
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Collect grab samples and analyze for fecal indicator bacteria (total coliform, fecal coliform, and
Enterococcus) to identify critical conditions for bacteria
Record visual observations consistent with the transitional outfall monitoring program.
Collect in-situ physical parameters for pH, temperature, and specific conductivity.
Perform site observations at key times within the catchment areas and record all observed areas
and/or sources with non-storm water flow.
Track flow patterns to sources for abatement or further investigation.
Table 49: Dry Weather Data Collection by Jurisdiction for the Escondido Creek HA
Item City of
Solana Beach
City of
San Marcos
City of
Escondido
Number of Focus Areas in Escondido Creek HA 1 1 3
Number of Outfalls for Continuous Flow Monitoring 2 1 3
Minimum Time for Continuous Flow Monitoring 2 weeks 2 weeks 2 weeks
Minimum Number of Fecal Indicator Bacteria Samples at
Each Outfall Where Flow is Measured 4 4 4
Total Number of Bacteria Samples 8 4 12
Assessment
The Escondido Creek HA Responsible Agencies will perform assessments ofthe following elements:
• Progress Toward Interim and Final Goals
• Dry Weather Special Study
As new data and information becomes available, the Responsible Agencies will perform an integrated
assessment of the findings from the identified focused areas. The integrated assessment will evaluate
the JRMP program implementation in relationship to the findings of the assessment for progress toward
interim and final goals. This integrated assessment would be performed at this scale to identify
relationships between the strategies implemented in the focus areas and outcomes related to the
interim and final goals. The outcomes of this assessment could be used to help determine the
effectiveness and efficiency of selected the strategies implemented.
Longer-term assessments will be performed at the WMA scale as appropriate data and information is
collected and assessed.
Escondido Creek HA (904.6)
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4 References
1. 2010 Integrated Report (Clean Water Act Section 303(d) List / 305(b) Report),California State Water
Resources Control Board (SWRCB), 2010
2. Agua Hedionda Watershed Management Plan - Final, Tetra Tech, 2008
3. Baseline Long-Term Effectiveness Assessment. San Diego Stormwater Copermittees, San Diego CA,
Mikhail Ogawa Engineering (MOE), Weston Solutions, Larry Walker Associates, 2005
4. Buena Vista Creek Watershed Data Compilation & Management Information System Development
Project, D-Max Engineering, Inc., 2011
5. Carlsbad Hydrologic Unit Data, San Diego Coastkeeper, 2014
6. Carlsbad Seawater Desalination Project, Watershed Sanitary Survey Report, Poseidon Resources
Corporation, 2005
7. Carlsbad Watershed Management Plan, Carlsbad Watershed Network, 2002
8. Carlsbad Watershed Urban Runoff Management Program (WURMP), Carlsbad Watershed
Management Area Copermittees, 2008
9. Carlsbad Watershed Urban Runoff Management Program FY 2008-2009 Annual Report, Carlsbad
Watershed Management Area Copermittees, 2010
10. Carlsbad Watershed Urban Runoff Management Program FY 2009-2010 Annual Report, Carlsbad
Watershed Management Area Copermittees, 2011
11. Carlsbad Watershed Urban Runoff Management Program FY 2010-2011 Annual Report, Carlsbad
Watershed Management Area Copermittees, 2012
12. Carlsbad Watershed Urban Runoff Management Program FY 2011-2012 Annual Report, Carlsbad
Watershed Management Area Copermittees, 2013
13. City of Carlsbad Jurisdictional Urban Runoff Management Plan (JURMP) (Including Annual Reports),
City of Carlsbad, 2008, Annual Reports, 2009-2013
14. City of Encinitas Jurisdictional Urban Runoff Management Plan (JURMP) (Including Annual Reports),
City of Encinitas, 2008, Annual Reports, 2009-2013
15. City of Escondido Jurisdictional Urban Runoff Management Plan (JURMP) (Including Annual Reports),
City of Escondido, 2008, Annual Reports, 2009-2013
16. City of Oceanside Jurisdictional Urban Runoff Management Plan (JURMP) (Including Annual
Reports), City of Oceanside, 2008, Annual Reports, 2009-2013
17. City of San Marcos Jurisdictional Urban Runoff Management Plan (JURMP) (Including Annual
Reports), City of San Marcos, 2008, Annual Reports, 2009-2013
18. City of Vista 2008 Jurisdictional Urban Runoff Management Plan (JURMP) (Including Annual
Reports), City of Vista, 2008, Annual Reports, 2009-2013
19. City of Solana Beach Jurisdictional Urban Runoff Management Plan (JURMP) (Including Annual
Reports), City of Solana Beach, 2008, Annual Reports, 2009-2013
20. CRAM Assessment Data and Worksheets, Preserve Calavera, 2013
21. Cottonwood Creek Urban Runoff Assessment and Action Plan, City of Encinitas, 2002
22. County of San Diego Jurisdictional Urban Runoff Management Plan (JURMP) (Including Annual
Reports), County of San Diego, 2008, Annual Reports, 2009-2013
23. Index of Biotic Integrity Scores for SCC Monitoring Sites, Preserve Calavera, 2008
References
Page 161
24. Long-Term Effectiveness Assessment. San Diego Stormwater Copermittees Urban Runoff
Management Programs, Final Report, Mikhail Ogawa Engineering (MOE), Weston Solutions, Larry
Walker Associates, 2011
25. National Pollutant Discharge Elimination System Permit and Waste Discharge Requirements for
Discharges from the Municipal Separate Storm Sewer Systems draining the watersheds ofthe San
Diego Region. Order No. R9-2013-0001, RWQCB, 2013
26. Revealing Escondido Creek, A Vision Plan for the City of Escondido, California State Polytechnic
University, Pomona, Department of Landscape Architecture, 2010
27. San Diego County Municipal Copermittees, Receiving Waters and Urban Runoff Monitoring Reports,
Weston Solutions, 2001 - 2012
28. San Elijo Lagoon Conservancy and the Escondido Creek Conservancy, 2014. Consultation Panel for
the Carlsbad Watershed Management Area Water Quality Improvement Plan, Priority Water Quality
Conditions, MS4 Sources, and Potential Strategies
29. Surface Water Ambient Monitoring Program Report on the Carlsbad Hydrologic Unit, SCCWRP, 2007.
30. Water Quality Control Plan for the San Diego Basin (Basin Plan). San Diego Regional Water Quality
Control Board, SDRWQCB, 2011..
31. Upper San Marcos Creek Watershed Nutrient Investigation and Additional Monitoring Study, D-Max
Engineering, Inc., 2013
References
Page 162
EXHIBIT 3
City of Carlsbad
Jurisdictional Runoff Management Plan
San Diego Regional Water Quality Control Board
Order R9-2013-0001
June 2015
Prepared and Submitted by the
City of Carlsbad
Table of Contents
Executive Summary iv
1 Introduction 1
1.1 Purpose and Objectives 1
1.2 Overview of City of Carlsbad 1
1.3 Water Quality Improvement Plans 2
2 City Roles and Legal Authority 5
2.1 Legal Authority 5
2.2 Enforcement Procedures 5
2.3 City Department Program Responsibilities 5
3 Non-Storm Water Discharges 7
3.1 Introduction 7
3.2 Conditional Non-Storm water Discharges 7
3.2.1 Discharges Associated with Separate NPDES Permit 7
3.2.2 Controlled Non-Storm water Discharges 8
3.2.3 Discretionary Discharge 8
3.3 Program for Non-Emergency Fire Fighting Flows 8
4 Illicit Discharge Detection and Elimination 11
4.1 Introduction 11
4.2 Program Elements 11
4.2.1 MS4Map 11
4.2.2 Dry Weather MS4 Outfall Monitoring Programs 11
4.2.3 Source Specific Observations 12
4.2.4 Observation Reporting by City Staff 12
4.2.5 Reporting and Notification 12
4.2.6 City Staff Investigation 13
4.2.7 Spill Reporting, Response, and Prevention 13
4.3 Enforcement 14
5 Development Planning 15
5.1 Introduction 15
5.2 Best Management Practice Requirements 15
5.2.1 BMPs for Standard Projects 16
5.2.2 BMPs for Priority Development Projects 16
5.3 Land Development Process 17
5.3.1 Environmental Review Process 17
5.3.2 Planning 18
5.3.3 Plan Review 19
5.3.4 Construction Verification Process 24
ll
Construction 27
6.1 Introduction 27
6.2 Project Approval Process 27
6.3 Construction Site Inventory 27
6.4 Best Management Practice Requirements 29
6.5 Construction Site Inspections 31
6.6 Corrective Actions and Enforcement 32
Existing Development 33
7.1 Introduction 33
7.2 Inventory and Tracking 33
7.3 Best Management Practices Requirements 34
7.4 Program Implementation 35
7.4.1 Inspections 35
7.4.2 Inspection Frequency 36
7.4.3 Inspection Tracking and Records 37
7.4.4 Municipal Separate Storm Sewer System Program 37
7.4.5 Existing Flood Control Devices 38
7.4.6 Street Sweeping Program 38
7.4.7 Litter Removal 38
7.4.8 Pressure Washing 38
7.4.9 Application of Pesticides, Herbicides, and Fertilizers 38
7.4.10 Sanitary Sewer Systems 39
7.4.11 Special Events 39
7.4.12 Household Hazardous Waste Collection Services 41
7.5 Enforcement 42
Retrofitting and Rehabilitation in Areas of Existing Development 43
8.1 Introduction 43
8.2 Identifying Candidate Retrofits and Rehabilitation Projects 43
8.2.1 Retrofit Types 43
8.2.2 Rehabilitation Types 44
8.3 Implementing Candidate Retrofits and Rehabilitation Projects 44
Enforcement Response Plan 45
9.1 Introduction 45
9.2 Enforcement Mechanisms 45
9.2.1 Administrative Enforcement Mechanisms 45
9.2.2 Judicial Enforcement Mechanisms 46
9.2.3 Escalated Enforcement 46
9.3 Enforcement Response Plan Components 47
9.3.1 Illicit Discharge Detection Elimination 47
9.3.2 Development Planning 48
9.3.3 Construction 48
9.3.4 Existing Development 48
9.3.5 Correction of Violations 49
9.4 Reporting of Non-Compliant Sites 49
10 Education 51
10.1 Introduction 51
10.2 Municipal Staff Training 51
10.3 Construction Site Owners and Operators 51
10.4 Commercial/Industrial Facilities Owners and Operators Training 52
10.5 Residential Community and General Public 53
11 Public Participation 55
11.1 Introduction 55
11.2 Water Quality Improvement Plans 55
11.3 Local Public Participation 55
12 Monitoring and Assessment 57
12.1 MS4 Outfall Discharge Monitoring Station Inventory 57
12.2 Dry Weather Major MS4 Outfall Discharge Field Screening Monitoring 57
12.3 Non-Storm Water Persistent Flow MS4 Discharge Monitoring 57
12.4 Wet Weather MS4 Outfall Discharge Monitoring 58
12.5 Data Assessment, Reporting, and Quality Control 59
12.6 WQIP WMA Monitoring Requirements 60
13 Fiscal Analysis 61
13.1 Expenditure Categories 61
13.2 Staff Resources 61
13.3 Expenditures and Sources of Funds 62
List of Figures
Figure 1: City of Carlsbad Watershed Drainage Areas 3
Figure 2: City of Carlsbad Organizational Chart 6
List of Tables
Table 1: Department Roles 5
Table 2: Hydrology and Water Quality Analysis Checklist 18
Table 3: BMP Table 20
Table 4: Development Process and Standards Manual Activities 21
Table 5: Highest Priority Major Outfalls and Location Description 58
Table 6: Field Measurements 58
List of Appendices
Appendix A: City of Carlsbad MS4 Map
Appendix B: City of Carlsbad Existing Development Map
iii
Executive Summary
The City of Carlsbad has developed this Jurisdictional Runoff Management Program (JRMP) to comply with
Order R9-2013-0001 - National Pollutant Discharge Elimination System Permit and Waste Discharge
Requirements for Discharges from the Municipal Separate Storm Sewer Systems (MS4) (hereinafter
referred to as the "Permit"), issued by the California Regional Water Quality Control Board (RWQCB), San
Diego Region. The Permit was adopted in May 2013 and is valid for five years. The Permit requires
Responsible Agencies in each of the region's watersheds to develop Water Quality Improvement Plans
(WQIP)s and JRMPs for each Responsible Agency's jurisdiction. The Carlsbad Watershed Management
Area (WMA) Water Quality Improvement Plan and the City of Carlsbad's JRMP were developed in
response to the requirements of the 2013 Permit.
The purpose of this JRMP is to implement programs to reduce pollution in urban runoff, including
programs to regulate new public and private land development during each ofthe three major phases of
urban development, i.e., the planning, construction, and existing development (or use) phases.
The purpose of the Carlsbad WMA WQIP is to guide the Responsible Agencies' Jurisdictional Runoff
Management Programs toward achieving improved water quality in MS4 discharges and receiving waters.
Through the WQIP, priorities and goals are established and strategies selected for implementation
through the Responsible Agencies' JRMPs to progress toward improvements in water quality. This
approach establishes the WQIP as the overarching plan that each Responsible Agency uses to develop and
implement their jurisdictional programs. Responsible Agencies' JRMPs contain the strategies, standards
and protocols by which each Responsible Agency will implement their individual program in response to
the priorities and goals established in the WQIP. The updated JRMP has been streamlined and provides
the City of Carlsbad with the implementation procedures for development planning, construction, existing
development, education, enforcement, public participation, municipal, and illicit discharge and detection
components. Based on experience gained through the implementation of programs required by previous
Permits, the City of Carlsbad maintained procedures that proved to be successful and included new
programs to effectively reduce or eliminate discharges of pollutants to the MS4.
This JRMP will be revised as needed to reflect changes in the City's urban runoff management programs
such as revised or new best management practices or new educational or training programs. The annual
updates will also reflect changes in the City's commercial, industrial, and municipal databases, including
revisions to facility/activity prioritizations that will be refined as additional monitoring and inspection data
becomes available.
The City will submit a JRMP Annual Report that identifies the level of effort conducted by the City to
implement its program. JRMP Annual Reports include a summary of all illicit discharge complaints and
resolutions, and summaries of inspections, enforcement actions, and educational programs. This data and
information will also be assessed and included in the WQIP Annual Reports.
IV
1^1
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1 Introduction
The San Diego Regional Water Quality Control Board (RWQCB) adopted the Municipal Storm water Permit
Order No. R9-2013-0001, NPDES No. CA50109266 (Permit), on May 8, 2013 to control waste discharges
in urban runoff from the Municipal Separate Storm Sewer Systems (MS4s), also known as storm drain
system, draining the watersheds in the County of San Diego, the incorporated cities of San Diego County
and the San Diego Unified Port District, collectively known as Copermittees.
The Permit's intent is to enable jurisdictions to focus their resources and efforts to "effectively prohibit
non-storm water discharges to its MS4, reduce pollutants in storm water discharges from its MS4 to the
Maximum Extent Practicable (MEP), and achieve the interim and final numeric goals..." (Permit).
Furthermore, the Permit states that "Where appropriate. Watershed Management Areas (WMAs) may be
separated into subwatersheds to focus water quality prioritization and jurisdictional runoff management
program implementation efforts by receiving water." This approach represents a paradigm shift from
previous Permits where jurisdictions essentially implemented the same activities throughout their
jurisdictions with little or no regard for prioritizing water quality conditions, sources and pollutant
generating activities that occurred within geographically based areas. Although topographic features
define watershed areas, characteristics ofthe watershed areas have direct influence on non-storm water
discharges and pollutants in storm water discharges, and ultimately the water quality conditions in
receiving waters.
The Permit requires Responsible Agencies or Copermittees, in each of the region's Watershed
Management Areas (WMAs) to develop Water Quality Improvement Plans (WQIPs). Through the WQIP,
highest priority water quality conditions within the WMA are identified and strategies are implemented
through the Copermittees' Jurisdictional Runoff Management Programs (JRMPs) to progress toward
improvements in water quality. The WQIPs contain an adaptive planning and management process and a
public participation component. The Permit and the WQIP process allow Copermittees to focus JRMPs on
particular areas or water quality issues of concern.
1.1 Purpose and Objectives
The purpose ofthe City of Carlsbad JRMP is to implement strategies that effectively prohibit non-storm
water discharges to the MS4 and reduce the discharge of pollutants in storm water to the maximum
extent practicable (MEP). This involves improving existing programs and developing new programs
intended to minimize or eliminate the effects of jurisdictional runoff from the City on receiving water
bodies. Improving the quality of the discharge from the MS4 may have beneficial effects on the local
receiving water bodies.
This document is based on the most updated information available at the time this document was
prepared. Each year the City will submit a JRMP Annual Report to the RWQCB, and changes to the City's
JRMP will be described in the annual report. Program modifications will be for the advancement ofthe
City's program and will comply with all regulations as presented in the Permit.
1.2 Overview of City of Carlsbad
The City of Carlsbad is a unique coastal community located 35 miles north of the City of San Diego
surrounded by mountains, lagoons and the Pacific Ocean. Although the "village" dates back more than
100 years, the City was incorporated July 16, 1952. At that time, Carlsbad covered 7.5 square miles and
had a population of approximately 7,000 people. The City now encompasses approximately 39 square
miles of land area and has a population of approximately 105,000 (2010 Census).
The physical geography and topography ofthe City of Carlsbad is very diverse with steep hills and coastal
areas. As a result, there are a wide range of drainage conditions throughout the City including many
waterways and tributary canyons. Although the City of Carlsbad is wholly within the Carlsbad Watershed
Management Area (WMA) the City is tributary to four distinct Hydrologic Areas or sub-watersheds:
• Buena Vista Creek and Lagoon
• Agua Hedionda Creek and Lagoon
• Encinas Creek
• San Marcos Creek and Batiquitos Lagoon
All drainage basins with the exception of Encinas terminate in lagoons. As a result, the City's receiving
water bodies are the three lagoons and the Pacific Ocean.
1.3 Water Quality Improvement Plans
Along with the other Copermittees within the Carlsbad WMA, the City of Carlsbad participated in the
development of the Carlsbad WMA WQIP to establish the priorities and goals for the watersheds in order
to focus jurisdictional strategies for implementation.
By identifying the Highest Priority Water Quality Conditions (HPWQC)s and Priority Water Quality
Conditions (PWQCs) the City established the focus of the program's planning and implementation efforts.
The HPWQCs selected for the Buena Vista Creek, Agua Hedionda and San Marcos Hydrologic Areas are
indicator bacteria, e.g., total coliform, fecal coliform and enterococcus.
The City identified areas within the hydrologic areas where specific WQIP strategies will be implemented.
These strategies may differ from the City's core program in order to focus on the specific HPWQCs, sources
and activities that may be contributing to the HPWQCs. These strategies are identified in call out boxes
throughout the JRMP.
The City developed goals and schedules for achieving those goals in order to have measureable targets
and metrics to measure progress towards improving water quality. Once the goals were established, the
City then identified the strategies that would be implemented to address the City's discharges and make
water quality improvements. Strategies typically address multiple conditions; therefore, it is anticipated
that all priority conditions will be improved through implementation of the selected water quality
improvement strategies.
For more information regarding the WQIPs, the reader is directed to the Project Clean Water website for
the current Carlsbad WMA WQIP documents and Annual Updates.
\(\0
Figure 1: City of Carlsbad Watershed Drainage Areas
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2 City Roles and Legal Authority
This section describes the City's legal authority and Department Program responsibilities and roles,
regarding storm water management. The City maintains adequate legal authority within its jurisdiction to
control pollutant discharge into and from its MS4 through the City's Municipal Code and ordinances.
2.1 Legal Authority
The City has established and maintains its legal authority to control pollutant discharges into and from its
MS4. The City will continue to ensure that it has the legal authority to require BMP implementation, to
prohibit all identified illicit discharges, to prohibit and eliminate illicit connections to the MS4, and to
control the discharge of spills, dumping, and disposal of materials other than storm water to its MS4.
Municipal Code Chapter 15.12 is the primary section related to the program and can be found at the City's
website.
2.2 Enforcement Procedures
The City employs a tiered, escalating enforcement system for violations of the City's Municipal Code
throughout the City. The escalating administrative and judicial enforcement measures are described in
Section 9 Enforcement Response Plan of this JRMP.
2.3 City Department Program Responsibilities
The following table identifies the departments and staff that conduct urban runoff management activities
and their roles under the City's JRMP. For broader descriptions ofthe departments and their overall roles
in the City operations, please see the City's website at www.carlsbadca.gov.
Department Roles
City Manager's Office Overall oversight for JRMP implementation;
City Attorney Certification of adequate legal authority; Enforcement assistance when
necessary
City Clerk Maintains records of programs and implementation; provides public
records request support when applicable
Public Works Director Designee for JRMP oversight with authority to certify related documents.
Community and Economic
Development - Planning Division
and Land Development Division
General Plan update; Environmental Review process update and
implementation; review of projects for compliance with all City
development codes; conditions of approval for project permitting process;
provide data and information for annual reports; provide education to
development community; Represent the City at regional meetings related
to Development Planning
Community and Economic
Development - Land Development
Division
Modifications to development requirements; ensure that new
development and significant redevelopment requirements (e.g., SUSMP)
are included in all development projects; maintain inventory of permits;
assist in development of and implementation of Hydromodification
Management Plan; provide data and information for annual reports;
provide education to development community
Public Works - Capital Projects
Division, Public Works - Property
Division, Public Works - Utilities
Divisions, Parks Planning Division
Ensure that capital improvement projects meet the new development or
significant redevelopment requirements; ensure that the capital
improvement projects construction activities have adequate BMPs
required for implementation by the City's contractor; provide data and
information for annual reports
Community and Economic
Development - Building Division,
Public Works - Construction
Management and Inspections
Division, Public Works - Property
Division, Public Works - Utilities
Division, Parks Planning Division
Maintain construction site inventory; Conduct inspections and regulate
construction sites regarding erosion, sediment control and other site
management activities; including post-construction BMPs; Contribute to
education and outreach for construction audience; Conduct post-
construction BMP construction verification; Maintain the treatment
control BMP inventory and oversee maintenance tracking activities;
Special event inspections; Provide data and information for annual
reporting
Community and Economic
Development - Building Division
and Code Enforcement
Plan review, permit issuance, building inspection and code enforcement
for building permit projects; provide data and information for annual
reports; provide education to development community, Provide
enforcement support for construction activities
Public Works - Environmental
Management
Coordinate and implement the IDDE program; Conduct/manage water
quality monitoring programs; Conduct education and outreach for
businesses and residents; Maintain business and residential inventory;
Conduct inspections and assessments of industrial and commercial sites,
commercial areas, residential areas, and municipal sites, including
minimum BMPs; Provide data and coordinate data collection for annual
reporting; Develop and conduct effectiveness assessments for existing
development programs; Perform Principle Copermittee duties for the
CWMA and participate in meetings and collaboration; Represent the City
at regional meetings; Act as a liaison with the RWQCB
The organizational chart, shown below in Figure 2, identifies these departments in relation to the City
management.
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Traffic Safety
Commission
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Board
Carlsbad Golf
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Advisory Board
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City Manager City Attorney
Assistant City Manager
(ProJecUl t r Assistant City Manager
(Openllons)
Alts
Commission
Historic
Preservation
Commission
Ubrary Board
of
Trustees
Parks & Rec
Commission
Senior
Commission
Beach
Preservation
Committee
Packs & Recreation Fire Department Community & Economic
Development
..L ZZL
Ubrary a Cultural Arts Administrative Services
J Housing ft
Nnghbothood Scrvktt
Property ft Envfronm«nTal
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CourKil Appointed
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Figure 2: City of Carlsbad Organizational Chart
3 Non-Storm Water Discharges
3.1 Introduction
This section describes the City's approach to controlling the non-storm water discharges to the MS4. The
City addresses non-storm water discharges as illicit discharges unless a non-storm water discharge
qualifies as a conditional discharge.
Non-storm water discharges are runoff flows from any type of activity other than weather caused
precipitation or naturally occurring groundwater. Typical non-storm water discharges include, but are not
limited to:
• Residential vehicle washing
• Residential and commercial street, sidewalk and parking lot washing (e.g., hosing down and high
pressure washing)
• Air conditioning condensation
• Swimming pool discharges
• Sanitary sewer overflows
• Septic system overflows
• Over-Irrigation discharger (e.g., overspray and over irrigation runoff)
Identifying and eliminating non-storm water discharges
from entering the City's MS4 is a cost-effective best
management practice (BMP) for improving water quality.
Through the illicit discharge detection and elimination
program (IDDE), the City investigates and eliminates any
known or observed non-storm water discharge. The IDDE
program is explained in more detail in Section 4.
Prohibited Non-Storm Water Discharges
The City prohibits all non-storm water
discharges unless a discharge is authorized
by a separate NPDES permit or qualifies as a
conditional discharge.
3.2 Conditional Non-Storm water Discharges
The following categories of non-storm water discharges are conditionally allowed by the City if the
discharge meets the criteria described below. If a discharge does not meet the criteria, then it is prohibited
by the City.
3.2.1 Discharges Associated with Separate NPDES Perinit
The RWQCB may permit a discharger to discharge water to the City's MS4, as long as the City does not
determine that the discharge is a source of pollutants.
Pumping and Groundwater
The following non-storm water discharges are allowed if the discharge has coverage under NPDES Permit
No. CAG919002 (Order No. R9-2008-0002):
• Uncontaminated pumped ground water
• Discharges from foundation drains (i.e.. If the system is located ator below the groundwater table
to extract groundwater)
• Water from crawl space pumps
• Water from footing drains
Water Line Flushing and Breaks
The City considers non-storm water discharges associated with water line flushing or breaks as an illicit
discharge, unless the discharge has coverage under NPDES Permit No. CAG 679001 (Order No. R9-2010-
0003 or subsequent order). In addition, discharges from recycled or reclaimed water lines are illicit, unless
covered under a separate NPDES Permit.
3.2.2 Controlled Non-Storm water Discharges
The City of Carlsbad allows the following non-storm water discharges to enter the MS4 if the following
controls and criteria are implemented:
Air Conditioning Condensation
The discharge should be directed to landscaped areas or other pervious surfaces.
Dechlorinated Swimming Pool Discharges
Prior to discharging to the MS4, residual chlorine, algaecide, filter backwash, or other pollutants from the
swimming pools, must be eliminated. The discharge of saline swimming pools must be directed to the
sanitary sewer, landscaped areas, or other pervious surfaces that can accommodate the volume of water.
Individual Residential Vehicle Washing
The use of water and washing detergent should be minimized and the discharge of wash water should be
directed to landscaped areas or other pervious surfaces.
3.2.3 Discretionary Discharge
The following discharges are not prohibited unless they are identified by the City or the RWQCB as
pollutant sources to receiving waters:
• Diverted stream flows
• Rising ground waters
• Uncontaminated ground water infiltration to MS4s
• Springs
• Flows form riparian habitats and wetlands
• Direct discharges from potable water sources
• Direct discharges from foundation drains
• Direct discharges from footing drains
3.3 Program for Non-Emergency Fire Fighting Flows
The Carlsbad Fire Department (CFD) has developed the Non-Emergency Fire Fighting Program to meet the
requirements of Order R9-2013-0001. This section describes the City's program to reduce pollutants from
non-emergency firefighting flows (i.e., flows from controlled or practice blazes and maintenance
activities). By default, the non-emergency firefighting flows are flows generated by the Fire Department
other than emergency situations.
The CFD will maintain a storm water pollution prevention manual (SWPPP) specific to each fire station to
serve as a central location for all storm water documents, training, and BMP descriptions, as well as
departmental policies related to storm water. The BMPs incorporated at Fire Stations are listed below:
• The SWPPPs include facility specific site maps, storm water inspection reports, facility specific spill
response procedures, training records, department policies, and other related storm water
compliance information.
• A written department policy on outside water use is followed and covers vehicle, hose, and
equipment washing.
• Spill response equipment and materials are clearly identified and staged in accessible locations.
• Sweeping and removal of organic material from parking lots and walkways is completed on a
weekly or as needed basis at all fire stations.
• The City's Safety Training Center is used for various methods of training and testing for
firefighting. Water used for this non-emergency training is retained on-site through the use of
flow retention devices and other BMPs.
• The Fire Department will continue to provide acceptable wet training opportunities for personnel,
while ensuring that appropriate BMPs are in place to protect storm drains and eliminate
discharges to the MS4.
• Awareness is heightened at fire scenes to minimize the potential for excessive water flow.
• Awareness is heightened at incident scenes to contain potential discharges (once the scene had
been stabilized) to prevent pollutants from entering the storm drain system.
• The Fire Department will continue to implement the City's spill response procedure for incidents
that occur on City streets.
The CFD will continue to communicate with other City departments to improve coordination and
education with regards to storm water. The Fire Department conducts annual training levels to ensure
that all fire department personnel are versed in storm water as it relates to fire station and firefighting
activities.
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4 Illicit Discharge Detection and Elimination
4.1 Introduction
This section describes the responsibilities of staff with respect to implementation of the Illicit Discharge
Detection and Elimination (IDDE) component ofthe JRMP. This program section is intended to provide
direction to actively seek and eliminate illicit discharges and connections.
In general, illicit discharges to the MS4 are any discharges not composed entirely of storm water unless
they are authorized under a separate NPDES permit or are considered conditional discharges, described
further in Section 3, Non-Storm Water Discharges.
The City's program to actively seek and eliminate illicit discharges to the MS4 is comprised ofthe following
elements:
• Visual outfall monitoring
• Source specific observations
• Use of City staff for reporting observations
• Use of public hotline and reporting methods
• Investigations and enforcement
• Spill response reporting, and prevention
In almost all cases of illicit discharges, elimination ofthe discharge requires some level of enforcement
and/or abatement action. Specifications in the Carlsbad Municipal Code grant the City the powers to
enforce its regulations pertaining to illicit discharges. The Municipal Code requires the violator to conduct
abatement activities required to eliminate an illicit discharge or for the City to conduct the abatement
activities itself.
4.2 Program Elements
4.2.1 MS4Map
The City maintains an updated map of its MS4 and the corresponding drainage areas. A detailed map is
included as Appendix A, identifies the following:
• Segments of the MS4 owned, operated, and maintained by the City
• Locations of inlets
• Known locations of connections with other MS4s, not owned by the City
• Known locations of MS4 outfalls and private outfalls that discharge runoff collected from areas
within the City
• Segments of receiving waters within the City that receive and convey runoff discharge from the
MS4 outfalls
• Locations of MS4 outfall discharge monitoring stations
• Locations of non-storm water persistent flow MS4 outfall discharge monitoring stations
4.2.2 Dry Weather MS4 Outfall Monitoring Programs
The City conducts field screenings of MS4 outfalls and portions ofthe MS4 infrastructure, to detect illicit
discharges. The following sections briefly describe the monitoring programs performed by the City that
are specific to IDDE. Monitoring programs are explained in more detail in Section 12, Monitoring
Programs.
11
The intent ofthe Dry Weather MS4 Outfall Discharge Monitoring Program is to investigate any observed
discharge from the MS4 and determine if the discharge is an illicit connection or discharge. The City will
use dry weather field and analytical monitoring information to characterize dry weather discharges in the
MS4 and identify conveyances that are discharging elevated levels of pollutants. Follow-up studies and
source investigations will be conducted as required, to detect and eliminate the sources of these
pollutants.
There are three components to the dry weather-monitoring program:
1. Field observations
2. Field screening
3. Laboratory analyses
Field observations include various site descriptions and a series of qualitative (primarily visual)
observations of physical and biological conditions at the site. Field screening includes determinations of
several water quality parameters and flow in the field. The laboratory analysis component involves the
collection of samples for a more extensive laboratory analysis of pollutants that can cause water quality
degradation. The presence of abnormal conditions in any of the three dry weather-monitoring
components is justification for initiating a pollutant source identification investigation.
The Non-Storm Water Persistent Flow MS4 Outfall Discharge Monitoring Program focuses analytical
monitoring at locations known to have persistent flow. The City monitors five highest priority major
outfalls.
Monitoring is required to continue unless one of the following events occurs:
• The flow is eliminated
• The flow is identified as an allowable non-storm water discharge
• The non-storm water discharge does not exceed numerical action levels (NALs) and the flow can
be re-prioritized to a lower priority
• The flow is identified as a conditional non-storm water discharge
4.2.3 Source Specific Observations
The City implements investigational source identification procedures in order to identify and eliminate
discharge sources. The City inspects municipal, industrial, commercial, residential, and construction
activities to identify sources of illicit discharge. Often, when an illicit discharge is detected during an
inspection, it can be eliminated before it affects receiving waters.
Non-storm water flows from over-irrigation or irrigation system overspray observed from field staff or
reported through the storm water hotline or email, will be forwarded to Public Works - Utilities (Carlsbad
Municipal Water District) for response and enforcement, if necessary.
4.2.4 Observation Reporting by City Staff
The City trains full-time maintenance and operations staff to immediately refer all storm water violations
observed while working in the field to the Storm Water Protection Program.
4.2.5 Reporting and Notification
The City of Carlsbad operates a Hotline used by the public to report potential illicit discharges and
connections. The Hotline number is posted on the city's website and is provided in informational mailers
12
to residents and businesses, advertisements, and social media. The Hotline is capable of receiving reports
in English and Spanish 24 hours per day, seven days per week. Relevant issues received through the County
of San Diego hotline will be forwarded to the City of Carlsbad Storm Water Protection Program.
Reports and notifications can be filed by phone or e-mail using the two public hotlines and e-mail address
listed below, which are currently operated by the City of Carlsbad and the County of San Diego
Department of Environmental Health:
• City of Carlsbad Storm Water Hotline, (760) 602-2799
• City of Carlsbad Storm Water Protection Program e-mail: stormwater@carlsbadca.gov
• County Storm Water Hotline (888) 846-0800
When reports or notifications are made, the City will implement the following receipt procedures:
1. Collection of Information, including:
a. Complainant information,
b. Potential Responsible party information,
c. Location and description of the discharge or issue, and
d. Materials and waste involved, etc.
2. Information/Investigation Tracking
a. All provided information is entered into city database.
3. Prioritization
a. Reports and notifications are prioritized using the following criteria:
i. Is the discharge currently occurring?
ii. Is there an immediate threat to human health or the environment?
iii. Is a hazardous or unknown material involved?
4. Routing/Referral
a. Based on the prioritization, complaints are routed to the appropriate City staff or
department, or other appropriate agency for further investigation and the City will
confirm receipt.
4.2.6 City staff Investigation
Once a report or notification is received, staff visit the location ofthe issue, investigate, and determine
the appropriate course of action. If the potential responsible party is found, and depending on the severity
ofthe violation. City staff may provide educational information or materials to the potential responsible
party or follow the appropriate enforcement action(s) as described in Section 9, Enforcement Response
Plan. If deemed necessary, staff would conduct a follow-up investigation to ensure the correction has
been made. This process encourages pollution prevention methods and verifies the implementation of
required BMPs.
4.2.7 Spill Reporting, Response, and Prevention
The City of Carlsbad's Spill Response Plan covers spills to the storm water conveyance system. The intent
of the Spill Response Plan is to prevent or minimize the impact of spills by implementing appropriate
actions, by various city departments, to prevent spills from entering the MS4 and/or using appropriate
cleanup and mitigation methods. Additionally, the City has a Sanitary Sewer Overflow Response Plan
(SSORP) as described in Section 7.4.10.2 of this JRMP.
13
Spills that require an emergency response by the Fire Department and the San Diego County Department
of Environmental Health Hazardous Incident Response Team (HIRT) for management or mitigation will be
reported to the Governor's Office of Emergency Services and any other appropriate agencies, including
the San Diego Regional Water Quality Control Board, by the HIRT in accordance with State requirements
and within the required timeframes.
4.3 Enforcement
The City investigates illicit discharges or connections upon receipt or following an in-field observation. City
staff document issues, observations and responses through internal memorandums, emails, and work
orders.
For any enforcement actions, the City follows the established protocols described in Section 9,
Enforcement Response Plan.
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5 Development Planning
5.1 Introduction
The development planning process is a comprehensive process that includes planning, engineering,
construction and post-construction phases. Each phase includes review, conditional requirements and
verification that the requirements have been satisfied. The construction portion of the development
process is described in Section 6 of the JRMP. Because the process weaves through various phases, there
are several City Departments/Divisions involved in the development process, including. Community and
Economic Development - Building Division and Land Development Division, Public Works - Construction
Management and Inspections Division, Public Works - Property Division and Utilities Division, Parks
Planning Division.
This section describes the requirements of the City's Development Planning Component and staff
responsibilities. As development or redevelopment occurs, the City requires projects to plan for, design
and construct post-construction BMPs to mitigate the water quality impacts of the planned land use.
Development Planning is intended to:
• reduce discharges of pollutants from developed properties;
• prevent discharges from the MS4 from causing or contributing to a violation of water quality
standards, and;
• manage increases in runoff discharge rates and durations from developed properties that are likely
to cause increased erosion of stream beds and banks, silt pollutant generation, or other impacts
to beneficial uses and stream habitat due to increased erosive force.
The City's Standards Manual includes guidelines and procedures on how stormwater requirements are
applied to development and redevelopment projects. The Standards Manual requirements apply to both
private and public development projects. The Standards Manual is located in Volume 4 of the City's
Engineering Standards Manual. Please follow the following link for the City's Standards Manual:
httD://www.carlsbadca.gov/tcivicax/filebank/blobdload.asDx?BloblD=25522.
5.2 Best Management Practice Requirements
Carlsbad's Standards Manual explains how Best Management Practices (BMPs) are applied to
development and redevelopment projects. One of the first steps is to determine the type (or level) of
storm water standards that apply to a project. The Standards Manual explains how development projects
are either subject to Standard Storm Water Requirements or Priority Development Project (PDP)
Requirements. Depending on how substantial the project is will result in either ofthe two water quality
requirements. This determination is found by completing a form called the 'Storm Water Standards
Questionnaire', which is explained further in Section 5.3.2.
The Standards Manual includes guidance to understand how a project may affect runoff in the watershed
and to consider downstream impaired water bodies or sensitive habitat. The Standards Manual provides
information on the anticipated pollutants generated by a project category. This knowledge helps to assess
the effectiveness of BMPs that are being considered for a project. Selecting the appropriate BMPs helps
treat the runoff prior to discharge from the project. In addition, the Standards Manual has design
procedures to ensure BMPs are incorporated into the project features.
15
In general, simpler projects disturbing small areas or resulting in small amounts of new impervious areas.
Standard Storm Water requirements are likely to apply. When projects disturb larger areas or are more
complex, they will usually trigger the need for PDP (or enhanced water quality treatment) requirements.
However, the thresholds are sensitive so that certain smaller projects along sensitive habitat or waterways
might also trigger PDP requirements. For more information on how storm water standards are triggered
or applied, refer to section 5.3.2.
Selecting the appropriate BMPs will vary from project to project depending on the physical site
constraints, downstream impairments, development category, types of soil, and target pollutant(s)
generated by their specific project.
5.2.1 BMPs for Standard Projects
BMPs for Standard Storm Water Requirements must use Low Impact Development (LID) techniques and
site design features using Appendix 1 in the Standards Manual. Although BMPs do not need to be sized
by a technical report (engineered), using Appendix 1 provides a menu of different BMPs with narrative to
explain when they are used and where to deploy them on their project.
The following are examples of BMPs for projects subject to Standard Stormwater Requirements:
• Having impervious areas drain to pervious surfaces (roof downspouts to vegetation).
• Store liquids or materials in covered areas to avoid contact with storm runoff.
• Minimizing impervious surfaces or using pervious paving where appropriate
• Having covers on bins for refuse storage area
• Having extended canopy covers for fuel dispensing areas
• Minimizing run-on to loading docks
• Adding stencils to inlets for no dumping of waste
The City ensures BMPs for Standard Stormwater projects are incorporated during planning and/or plan
review process through the normal project development process using Appendix 1 of the Standards
Manual.
5.2.2 BMPs for Priority Development Projects
The Carlsbad Standards Manual includes sizing methods (volume or flow-based) to select and size
treatment control BMPs (TCBMPs) for projects. BMPs for PDP projects are sized (engineered) to treat
those areas draining to them. The Carlsbad Standards Manual also provides several treatment control
BMP options that applicants may choose for their projects including raised planters, bio-retention
facilities, pervious pavements, infiltration trenches, cisterns, and more. To help make the appropriate
BMP selections, the Standards Manual includes the BMP types and their relative efficiency at removing
certain categories of pollutants. Projects are required to select BMPs that have a high or medium
efficiency at removing target pollutants. Those that choose low efficiency BMPs are required to include
extensive narrative to explain the other high efficiency BMPs and why they were not selected for their
project. If sufficient justification cannot be provided, then through the planning and/or plan review
process, other BMPs are required that are more effective at removing the anticipated pollutants.
In addition to sizing treatment control BMPs the City also has hydromodification management
requirements for priority development projects. This ensures post-development runoff does not exceed
pre-development runoff for a select range of storm flow conditions. Hydromodification requirements are
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included within the final hydromodification management plan (HMP). Please refer to the following link
for HMP technical guidelines:
http://www.proiectcleanwater.org/index.phD?oDtion=com content&view=article&id=182<emid=188.
The City has Storm Water Management Plan (SWMP) guidelines for PDP projects and includes an HMP
applicability checklist. This checklist is completed to determine whether the project is required to comply
with HMP or if exemption criteria can be met. The applicability checklist is reviewed for concurrence on
the determination. If HMP requirements apply to a project, the BMPs forthe project are designed to meet
both treatment and HMP requirements. The Carlsbad Standards Manual includes an integrated low
impact design (integrated LID) approach for applicants to select and size to satisfy both these
requirements.
This integrated process results in projects that satisfy Carlsbad's Standards Manual requirements. This
process also results in the appropriate selection of BMPs for a project that address the needs of the
downstream areas.
The City uses the County of San Diego Low Impact Development (LID) handbook as a guidance document
for applicants. The handbook is a tool to educate developers, contractors. City staff and homeowners
regarding different types of LID features on a typical project. The handbook includes different LID features,
what their purpose is, and how they are deployed on a project site. Go to the following link for this
handbook:
http://www.proiectcleanwater.org/images/stories/Docs/LID/countvofsd LID handbook.pdf.
The BMP selection and implementation steps are reviewed by staff during the environmental review
(Section 5.3.1), planning/discretionary process (Section 5.3.2) and plan review process (Section 5.3.3).
Once plan review is complete, the process of BMP installation is carried through via the construction
verification process (Section 5.3.4).
5.3 Land Development Process
5.3.1 Environmental Review Process
In accordance with California Environmental Quality Act (CEQA) guidelines, the City's environmental
review process begins with the submittal of an Initial Study Checklist for private projects or the Early
Assessment Form for City projects. The City's Planning staff is responsible to assess and promulgate
environmental determinations for development projects. Using CEQA guidelines, projects may either be
issued an exemption, mitigated negative declaration or an Environment Impact Report (EIR). Based on the
results ofthe checklist, the City requires additional studies to elaborate on the environmental impacts of
the project.
The Initial Checklist provides an expanded section on potential water quality impacts for each project.
Table 2 shows an excerpt ofthe updated Initial Study Checklist that includes specific hydrology and water
quality analysis the City uses during the environmental review process.
17
isfy
Table 2: Hydrology and Water Quality Analysis Checklist
HYDROLOGY AND WATER QUALITY. Could the project:
a. Violate any water quality standards or waste discharge requirements?
b. Substantially deplete groundwater supplies or interfere substantially with ground water
recharge such that there would be a net deficit in aquifer volume or a lowering ofthe local
ground water table level (i.e., the production rate of pre-existing nearby wells would drop
to a level which would not support existing land uses or planned uses for which permits
have been granted)?
Substantially alter the existing drainage pattern ofthe site or area, including through the
alteration ofthe course of a stream or river, in a manner, which would result in substantial
erosion or siltation on- or off-site?
Substantially alter the existing drainage pattern of the site or area, including through the
alteration of the course of a stream or river, or substantially increase the flow rate or
amount (volume) of surface runoff in a manner, which would result in flooding on- or off-
site?
Create or contribute runoff water, which would exceed the capacity of existing or planned
storm water drainage systems or provide substantial additional sources of polluted runoff?
Otherwise substantially degrade water quality?
Place housing within a 100-year flood hazard area as mapped on a Federal Flood Hazard
Boundary or Flood Insurance Rate Map or other flood delineation map?
Place within 100-year flood hazard area structures, which would impede or redirect flood
flows?
i. Expose people or structures to a significant risk of loss, injury or death involving flooding,
including flooding as a result of the failure of a levee or dam?
j. Inundation by seiche, tsunami, or mudflow?
k. Increase erosion (sediment) into receiving surface waters?
I. Impact aquatic, wetland, or riparian habitat?
m. Change receiving water quality (marine, fresh or wetland waters) during or following
construction?
Increase any pollutant to an already impaired water body as listed on the Clean Water Act
Section 303(d) list?
Increase impervious surfaces and associated runoff?
Result in the exceedance of applicable surface or groundwater receiving water quality
objectives or degradation of beneficial uses?
c.
d.
e.
f.
h.
If the project has potential impacts to water quality, technical reports (i.e.: preliminary Storm Water
Management Plan) are prepared for review. These reports are prepared to address the anticipated
pollutants and measures considered to avoid or address the development impacts to runoff to
downstream tributaries. The format for preliminary SWMPs includes the same basic content of a final
SWMP in final design, as it is used to demonstrate project feasibility similar to how a preliminary soils
investigation or a preliminary hydrology study is used to address project impacts and mitigation measures.
For City SWMP requirements, please refer to
http://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BloblD=22712.
5.3.2 Planning
Certain projects require entitlements (discretionary process) before plan development begins. City
Planning staff evaluate projects against the Municipal code and planning oveHays to determine whether
discretionary action is first required before design begins. If the entitlement process is required, submittal
18
packages using submittal checklists are prepared. Please refer to the following link for City's discretionary
project submittal checklists: http://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BloblD=24116.
During the development review process, the City requires that new development and redevelopment
projects evaluate their project against the required project Standards Manual thresholds to determine
the level of storm water requirements that apply to their project. To evaluate projects, applicants are
required to fill out and submit a Storm Water Standards Questionnaire (SWSQ) to the City. The SWSQ was
developed using criteria from the 2013 Municipal Permit. Upon submittal. City staff reviews each SWSQ
to evaluate the accuracy ofthe thresholds that may apply to the project and to ensure the proper outcome
of the SWSQ and compliance with the Carlsbad Standards Manual. Please refer to the following link for
the City's SWSQ: http://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BloblD=22711.
If the project thresholds trigger Priority Development
Requirements, a preliminary SWMP is prepared for City
review (mimics the environmental review process). Staff
reviews the preliminary SWMPs to seek concurrence with
the project description, anticipated pollutants, impaired
water bodies, BMP selection, and BMP sizing methods. Staff also reviews the BMPs in the preliminary
SWMP to ensure they are included in the project design.
Private Development
If a preliminary SWMP is not submitted,
the application is deemed incomplete
and the applicant is notified.
For development projects subject to Standard Stormwater Requirements, staff use the checklist
(Appendix 1 of the Standards Manual) to ensure typical BMPs are deployed in appropriate locations.
This process results in projects that meet Carlsbad's
Standards Manual requirements and requirements of the
Municipal Permit. Projects subject to PDP requirements
that receive discretionary approval include conditions-of-
approval requiring the:
• Submittal of final SWMPs as part of final design,
subject to City review and approval.
• Inclusion of BMPs on final grading or improvement
plans in accordance with the final SWMP.
• Inclusion of an executed/notarized permanent
BMP maintenance agreements (for private
development)
5.3.3 Plan Review
Projects are reviewed to ensure that the City's Standards Manual requirements are included and met. The
submittal requirements for plan review require the submittal of a completed SWSQ. If a project is subject
PDP requirements, a SWMP must also be included.
Private Development
During submittal review, if discrepancies
are identified on storm water related
items, they are included in the review
comments. The Applicant is responsible
for addressing the discrepancies,
updating exhibits and/or technical
reports (e.g.: preliminary SWMP) and
resubmitting until the comments are
addressed.
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During plan review, if discrepancies are identified on storm
water related items, they are included in the review
comments to the Engineer-of-Work. The plans and/or
SWMP are updated and resubmitted until the comments
are addressed.
Grading and Improvement plans for projects subject to PDP
requirements will include BMP table on the title sheet that
summarizes the permanent treatment control BMPs
(TCBMPs) being installed and which sheet includes their
construction. This process helps notify the reviewer,
developer and inspector of this permanent water quality
facility and also is used by our City Asset Management staff
as they add these TCBMPs to our GIS inventory for tracking,
on TCBMPs in the City. Below is a sample of the TCBMP table
Private Development
The City requires a SWSQ and SWMP to
be included for a complete project
application. The City's engineering
improvement plan submittal checklist
can be found at:
http://www.carlsbadca.gov/civicax/file
bank/blobdload.aspx?BloblD=22692
The City's grading plan submittal
checklist, can be found at:
http://www.carlsbadca.gov/civicax/file
bank/blobdload.aspx?BloblD=22691.
Our GIS system is used to generate reports
included on these plans:
Table 3: BMP Table
POST-CONSTRUCTION BMP TABLE
STOR^mTER REQUIREMENTS THAT APPLY: EXEMPT FROM HYDROMODinCAVON?
1 STANDARD STORMWATER REQUIREMENTS ] YES (SEE SWMP FOR DOCUMENTATION)
1 1 PRIORITY PROJECT REQUIREMENTS J NO
TYPE DESCRIPTION OWNERSHIP MAINTENANCE
AGREEMENT SHEET NO. MAINTENANCE
FREQUENCY
A single-sheet post construction BMP (SSPCBMP) plan that includes a project site plan and shows the
comprehensive locations of each BMP such as site design, source control, low impact development
technique, treatment controls, and hydromodification features is prepared. The SSPCBMP plan contains
a table that contains cross-references summarizing the selected BMPs together with the appropriate
construction document (e.g.: grading, improvement, building or landscape) that is responsible to build
each particular post-construction BMP. Upon permit issuance, a copy ofthe SSPCBMP plan is signed and
distributed with the construction drawings for reference by the contractor and inspector. At the
conclusion of the project and prior to issuance of an occupancy permit or acceptance of the
improvements, the inspector uses the SSPCBMP plan to help ensure all required post-construction BMPs
are installed as required. After verification, the inspector initials the plan and places a copy in the project
inspection file.
The SSPCBMP is required content for a SWMP. The SSPCBMP includes project information and other
tables to help organize and present the different types of post construction BMPs for a project. The
SSPCBMP serves as a comprehensive document displaying the project and the location of different post
construction BMPs that are be installed along with calling out which construction document (grading,
improvement, building, landscape plan, etc.) that is responsible to install each listed BMP. The template
is found on the City's website for use by applicants when preparing SWMPs. For a copy of the template
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SSPCBMP plan, refer to http://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BloblD=22678.
Once final plans and reports are approved, they are prepared for scanning into the City's Digital
Management System. This process ensures both plans and final SWMPs are available for reference similar
to any other project-related technical study (geotechnical report, drainage study, structural calculations,
etc.).
Grading and Improvement plans for projects subject to PDP requirements also require the owner, if other
than the City, to execute a City standard permanent BMP maintenance agreement. Prior to plan approval,
this must be executed by the property owner and submitted to the City for recordation against the
property. This document provides a notice to current and prospective property owners of their obligation
to monitor and maintain permanent BMPs on their property. It also links BMP maintenance information
to the SWMP on file with the City.
For plan reviews subject to Standard Stormwater Requirements, staff use the checklist (Appendix 1 ofthe
Standards Manual) to ensure typical BMPs are deployed in appropriate locations.
5.3.3 Summary of process steps
Table 4 is a comprehensive summary of the various steps where Standards Manual requirements are
integrated with City processes.
Table 4: Development Process and Standards Manual Activities
Development
Process Stage Standards Manual Activity Description Documents/References
Conceptual Project
Design
Developer uses the Carlsbad STANDARDS MANUAL and
Storm Water Standards Questionnaire to determine
project priority and begins project layout and design. For
priority projects the City recommends to developers that a
preliminary SWMP should be prepared.
• Storm Water Standards
Questionnaire
• Storm Water Standards Manual
which includes the Carlsbad Standards
Manual
• 303(d) List
Pre-application
Review
Developer submits the preliminary project proposal to
staff to obtain input on conceptual project layout including
storm water compliance issues.
• Preliminary site plan checklist
• SWMP Fact Sheet
For projects that
require
Discretionary
Action(s):
Application for
Discretionary
Review
City staff review application package at front Counter for
completeness of submittal including storm water
compliance documents. Project is logged into the City
database for tracking. A completed Environmental Initial
Assessment (EIA) form is submitted with the application
package.
• Project Application Submittal
Checklist
• City review letter
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Development
Process Stage Standards Manual Activity Description Documents/References
Application Review
City staff reviews application, site plans and accompanying
reports and documents including any SWMP, geotechnical
and hydrology/hydraulic reports. Project is reviewed for
consistency with General Plan, Local Coastal Plan (LCP),
Habitat Management Plan, Carlsbad Standards Manual
and City Codes and other Standards including all storm
water protection policies and requirements including new
LID and interim hydromodification requirements. Project
location is reviewed for proximity to environmentally
sensitive areas and to determine if project drains to a
water body on the 303(d) list. Project EIA is reviewed and
appropriate environmental review documents are
requested and reviewed in compliance with California
Environmental Quality Act (CEQA) requirements.
• Site plan review checklist
• SWMP checklist
• 303(d) List
• General Plan
• Local Coastal Plan
• Habitat Management Plan
• City Codes
• Environmental Assessment Form
• CEQA Guidelines
• City review letter (if any)
Discretionary
Approval
City denies project or approves with conditions including
storm water compliance conditions. Applicable standard
conditions of approval are applied to the project together
with any special conditions of approval as City staff
determines necessary to reduce or eliminate the projects
storm water pollution impacts to the MEP. Approving
authority makes required findings that project complies
with the General Plan, LCP, Habitat Management Plan,
Standards Manual, City Codes and any other appropriate
land use planning documents. Environmental documents
are certified and any mitigation monitoring requirements
are noted in the project approval.
• City's standard conditions of
approval
• Project Conditions of Approval
• Environmental mitigation and
monitoring plan (if any)
Final Project Design
Developer prepares project construction plans including
grading, improvement, landscape and building detailing
required BMPs. Construction SWPPP is prepared and
SWMP is finalized. A single sheet post construction BMP
site plan is prepared.
• Storm Water Standards Manual
• Project Conditions of Approval
• Environmental mitigation and
monitoring plan (if any)
For Private
Development:
Construction Plan
Review Application
Submittal
City staff review application package for completeness of
submittal including storm water compliance documents.
Applicant completes and submits Project Storm Water
Threat Assessment Worksheet included as part of the
Storm Water Requirements Applicability Checklist.
• Plan review Application Submittal
Checklist
• Project Threat Assessment
Worksheet
• Project Conditions of Approval
Construction Plan
Review
City staff reviews construction plans and accompanying
reports and documents including any SWMP, single sheet
post construction BMP site plan. Construction SWPPP,
geotechnical and hydrology/hydraulic reports. All storm
water pollution prevention requirements are checked
against construction plan checklist, SWMP checklist,
Construction SWPPP checklist and project conditions of
approval. Construction cost estimates are approved for
bonding costs including costs for structural BMPs. For
priority projects a BMP Maintenance Agreement is
prepared.
• Construction Plan checklist
• SWMP Checklist
• Construction SWPPP Checklist
• Project conditions of approval
• Project Threat Assessment
• City Engineering plan review
procedures
• Environmental mitigation and
monitoring plan (if any)
• Cost estimates
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0
svelopment
Process Stage Standards Manual Activity Description Process Review
Documents/References
Construction Plan
Approval
City approves construction plans and accompanying
Construction SWPPP and SWMP including single sheet
post construction BMP site plan. The executed BMP
Maintenance Agreement is recorded and entered into the
City's document management system database. All
treatment control BMPs are noted on the construction
plans and forwarded to the GIS group for entry into the
BMP inventory. Any project design changes that differ
from the approved site plan or project conditions of
approval are reviewed in compliance with the City's
Substantial Conformance Procedures to ensure that the
project remains in compliance with all land use planning
findings. If other than the City, secured agreements to
construct project improvements are obtained backed up
with cash and/or other securities. Developer is required to
note the WDID number on the project plans
• Plan review completion letter
• BMP Maintenance Agreement
• BMP Inventory update procedures
• Substantial Conformance Procedures
• Environmental mitigation and
monitoring plan (if any)
• Cost estimates
• Secured Agreements
• Single sheet post construction BMP
site plan
Ministerial
(Construction)
Permit Issuance
City issues permit(s) for construction activities including
grading, improvement, building, demolition and blasting.
Any special storm water compliance requirements are
noted on permit. City staff review plan review completion
letter for any special storm water compliance
requirements. Copies ofthe permit, construction plans.
Construction SWPPP, single sheet post construction BMP
site plan and SWMP are forwarded to the Construction
Management and Inspection Division. A construction
inspection level (low, medium or high) is assigned in
accordance with the project's threat assessment form. The
project tracking database is updated with the project
threat assessment construction level and permit issuance
status.
• Plan review completion letter
• Project SWMP
• Project Construction SWPPP
• Construction Threat Assessment
Worksheet
• Pollution Prevention Guide for the
Construction Industry
• Construction SWPPP Fact Sheet
• Single sheet post construction BMP
site plan
Preconstruction
Meeting
City staff meets with contractor and other parties to
review project construction issues, schedule, and storm
water BMP implementation, monitoring and testing
requirements. Contractor is informed of storm water
inspection and enforcement procedures and reminded to
maintain compliance with the City's storm water pollution
prevention requirements. City inspector verifies the NOI
has been filed with the Regional Board and a WDID
number has been assigned to the project.
• Preconstruction checklist
• Construction SWPPP
• SWMP
• Construction plans
• Pollution Prevention Guide for the
Construction Industry
• Single sheet post construction BMP
site plan
Construction and
Inspection
Developer constructs project including temporary and
permanent BMPs. City inspectors enforce compliance with
SWPPP, SWMP and Municipal Permit. During construction
City project inspector reviews construction for compliance
with all plans, the Construction SWPPP, SWMP and City
Standards. Regular storm water compliance inspections
are scheduled and tracked per City procedures and the
requirements of the JRMP. Enforcement actions are taken
as necessary in accordance with City inspection and
enforcement procedures. City inspector reviews and
approves any minor construction revisions. Major
construction revisions are referred to the Engineering
Development Services Division for review and approval.
• Construction SWPPP
• SWMP
• Construction plans
• City inspection and enforcement
procedures
• Pollution Prevention Guide for the
Construction Industry
• Inspection reports
• Enforcement action reports
• Secured Agreements
• Single sheet post construction BMP
site plan
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Development
Process Stage Standards Manual Activity Description Process Review
Documents/References
Project Completion
Construction plans are "as-built", securities released, and
BMP construction verified. As-Built plans prepared and
forwarded to the GIS Group to update the BMP inventory.
City inspector reviews project site to verify installation of
permanent BMPs prior to occupancy permit and/or project
acceptance using the single sheet post construction BMP
site plan. Public Improvements are accepted for
maintenance including any public structural control BMPs.
• Construction SWPPP
• SWMP
• Construction plans
• Pollution Prevention Guide for the
Construction Industry
• Punch list
• Secured Agreements
• Project Acceptance Forms
• Single sheet post construction BMP
site plan
Post Construction
Annual Treatment
Control BMP
Inspections
BMP owners maintain BMPs in accordance with
recommended and regulatory maintenance schedules.
Treatment Control BMP owners submit annual verification
of effective operation and maintenance of installed
treatment control BMPs. City staff inspects project sites
with installed treatment control BMPs to verify
compliance with storm water requirements. (New
requirement was implemented in FY 2008-09).
• SWMP
• BMP Inventory List
• Site BMP Inspection Report
• BMP Maintenance Agreement
5.3.4 Construction Verification Process
5.3.4.1 Structural BMP Verification of Installation Prior to Occupancy
The installation of all structural BMPs required for Priority Development projects will continue to be
verified prior to occupancy. The process is initiated when the contractor/developer requests a pre-
construction meeting with City inspectors. During the pre-construction meetings, the
contractor/developer is notified of the BMP installation requirements and issued a copy of the City's
memo outlining the requirements for occupancy.
In addition, the City's inspection process requires documentation on BMP installations priorto occupancy.
This process requires written verification from the developer, engineer of work, or other responsible party
that BMPs were installed in accordance with the SWMP. This verification must be submitted before a
request for occupancy is made. For all Priority Development Projects, the Certificate of Occupancy will not
be issued unless the BMPs have been inspected and signed off as being constructed properly.
The City inspects the construction and installation of BMPs associated with engineering permits, grading
permits, public improvement permits, and Capital Improvement Program (CIP) projects. The Construction
Inspectors review the projects for compliance with the water quality requirements for the project and the
storm water ordinances. Building Inspectors inspect the construction and installation of BMPs that are
associated with private development that requires a demolition or building permit.
The City will continue to scan Storm Water Management Plans (SWMPs) into the digital management
system (DMS). This allows these water quality reports to be accessed by CM&l inspectors, reviewers, and
researchers. Having access to SWMPs helps verify the types and locations of approved post construction
treatment control BMPs.
5.3.4.2 Priority Development Project Inventory and Prioritization
The City has developed and maintains a GIS watershed-based inventory of publicly and privately owned
treatment control BM Ps. The inventory will continue to be used to track and document information about
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structural BMPs including BMP type, inspection dates and findings, maintenance frequencies and
requirements, verifications, and other required information. Updating the inventory is an ongoing
process, as new structures are researched, verified, and added on a continual basis. The following
information about structural BMPs will continue to be tracked and updated:
1. Unit ID#
2. Status
3. Priority
4. PDP# and Drawings
5. Location (mailing and physical address)
6. Responsible Party (name, address and phone)
7. BMP Type (CASQA identifier)
8. BMP Description (general type description)
9. BMP Detail (specific type description)
10. BMP Manufacturer and Model No., if applicable
11. Inspection and maintenance frequency
12. Inspection Dates and Findings
13. Verification of Maintenance Dates and Findings
14. Watershed and Proximity to ESA
The database is used to verify that structural BMPs are regularly maintained by the responsible parties.
Post-construction inspection priority for each PDP will be based on the types of BMPs installed. The
inspection priority is assigned during preparation of the SWMP in accordance with the BMP Design
Manual. The prioritization of inspection of PDPs with structural BMPs will consider the following:
1. The highest water quality priorities identified in the Water Quality Improvement Plan;
2. Receiving water quality;
3. Number and sizes of structural BMPs;
4. Recommended maintenance frequency of structural BMPs;
5. Likelihood of operation and maintenance issues of structural BMPs;
6. Land use and expected pollutants generated; and
7. Compliance history.
5.3.4.3 Structural BMP Maintenance Verifications and Inspections
The City has developed an inspection and annual verification of effective operation and maintenance
program for structural BMPs. Annually, the City will review PDP sites with structural BMPs in accordance
with the inspection requirements noted above. At a minimum, the City will inspect 100% of the high
priority structural BMPs prior to October 1st of each year.
The City's structural BMP inspection and verification of maintenance program will utilize the following
steps to verify the effective operation and maintenance of each structural BMP, regardless of priority,
associated with a PDP:
1. The structural BMP inventory will be used to create a list of sites, responsible parties, addresses
and the associated BMPs required for inspection and annual verification of maintenance.
2. A verification of maintenance form is mailed out on May 1 of each year to help responsible parties
more accurately provide information about the structural BMP maintenance. The form also
includes the following information:
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a. BMPs to be verified;
b. Description of maintenance taken during previous year;
c. Requirement to supply information to demonstrate maintenance and/or operating status
(vendor invoices, photos etc.);
d. Certification from the responsible party or third party that the BMP(s) were maintained
and are operating;
3. The City will continue to use the TCBMP email address for the BMP verification program. Owners
and responsible parties can send questions, verification forms, and other requests to the
tcbmp(a)carlsbadca.gov email address, which is monitored by Public Works - Construction
Maintenance & Inspection Division. The City also uses and updates the structural BMP email list
of responsible parties. The email list has been useful in providing information about treatment
control BMP compliance program and notices about upcoming deadlines for maintenance
verification submittals.
4. The inspection process will include records review priorto a site inspection. The inspector will use
the structural BMP inspection form ) and the following criteria to review and determine the
condition ofthe treatment control BMP. The condition of each structure is rated using:
a. Good: Currently no maintenance or corrective action is required forthe treatment control
BMP. No trees, large plants, excessive trash, stagnant water, blockages, or other major
sources of pollutants were observed. The treatment control BMP appears to be
functioning as designed. Re-inspect in one year.
b. Fair: Light to minor maintenance required within the next year. Small amounts of trash,
weeds, plants, debris, and/or silt has accumulated, but the treatment control BMP is
functioning as designed. The structure should be re-inspected within one year by the
responsible party and/or the City.
c. Poor: Maintenance, installation, replacement and/or repairs are required on the
structure. Excessive trash, weeds, vegetation, stagnant water, trees, silt, and/or other
pollutants were observed during the inspection. In addition, a BMP could be rated as
"Poor" if the structure was blocked, needed repair, or is not functioning as required.
5. In the event that a responsible party does not adequately respond and/or has not maintained the
structural BMPs as required, the City will use its escalated enforcement authority (Warning
Notice, NOV, Fines, etc.) to achieve compliance.
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OA
6 Construction
6.1 Introduction
This section describes the requirements ofthe City's Construction Component and staff responsibilities.
As construction activities occur, the City requires projects to plan for and implement temporary
construction BMPs to mitigate the water quality impacts of land disturbance and non-storm water
discharges related to construction activities. All requirements of the Construction Component are
applicable to both private and public development projects.
The Construction Component is intended to:
• eliminate or reduce discharges of pollutants from construction activities; and
• prevent discharges from the MS4 from causing or contributing to a violation of water quality
standards.
6.2 Project Approval Process
The City's project approval process requires project proponents to incorporate storm water pollution
prevention and urban runoff management into their projects during construction activities. The City
requires the development of appropriate pollution control plans, including SWPPPs, and construction
BMP plans, to comply with the requirements of the Municipal Permit, local ordinances, and other
applicable regulations.
All new construction projects are required to prepare and submit an appropriate Construction SWPPP in
accordance with the Storm Water Standards Manual. For private development projects, the Construction
SWPPP is reviewed and approved by Engineering Development Services Division prior to issuance of
construction permits. For Capital Improvement Program (CIP) projects. Construction SWPPPs are
prepared prior to the notice to proceed. The approved Construction SWPPP must comply with all
applicable requirements ofthe State's Construction General Permit.
Pollution prevention practices are required at all project sites. In accordance with the City's Storm Water
and Grading Ordinances (CMC 15.12 and 15.16), project proponents are required to implement the
minimum BMPs year-round. BMPs and other erosion control practices must be implemented as the most
important "first line of defense". The project approval process also allows the City to confirm compliance
with storm water regulations by requiring the following documentation and verification of appropriate
pollution prevention efforts:
• Develop and implement a plan to manage storm water and non-stormwater discharges;
• Emphasize erosion and sediment controls as the most important measure for keeping sediment
onsite;
• Select seasonally appropriate and effective BMPs;
• Temporarily stabilize and/or re-seed disturbed soil areas as soon as possible;
• Permanently re-vegetate or landscape as soon as feasible; and
• When applicable, provide evidence of coverage under the Construction General Permit.
6.3 Construction Site Inventory
The management ofthe construction site inventories is divided as follows:
Private Development
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The Land Development Engineering and Construction Management and Inspection (CM&I) Division are
responsible for updating the watershed based inventory of new grading, building and right-of-way permits
in a database at permit issuance including the appropriate construction inspection frequency/priority. The
permit tracking database is used to generate inspection requests, update inspection records, record
enforcement actions, and follow-up inspection work. The permit tracking database is used in conjunction
with Excel spreadsheets to track the following project information:
1. Project status (active, inactive, completed, finaled);
2. Project threat prioritization;
3. Project and grading number;
4. The project start and completion dates;
5. The frequency and number of required and completed inspections by month;
6. The number of weeks active during the rainy and dry season;
7. Waste Discharge Identification (WDID) number (if applicable), size ofthe site; and approximate
area of disturbance;
8. The basic site information including project description and location (address, APN, and
hydrologic subarea);
9. Relevant contact information for each site (e.g., name, address, phone, and email for the owner
and contractor);
10. The date the City accepted or approved the pollution control plan; construction BMP plan, and/or
erosion and sediment control plan; and
11. Ongoing enforcement actions administered to the site.
The construction permit application for private development (grading, building or right-of-way) includes
submittal of a completed Construction Threat Assessment Worksheet for Determination of Threat to
Storm Water Quality. For public development projects, the project manager completes the construction
threat form to help determine the priority and threat to water quality the project may pose. When
determining threat prioritization and associated frequency of inspection, one of three threat priorities is
assigned: high; medium, or; low. At a minimum, the following project types will be considered high threat
to water quality criteria:
1. Sites located within a hydrologic subarea where sediment is known or suspected to contribute to
the highest priority water quality conditions identified in the WQIP;
2. Sites located within the same hydrologic subarea and tributary to a water body segment listed as
impaired for sediment on the CWA section 303(d) List;
3. Sites located within, directly adjacent to, or discharging directly to a receiving water within an
ESA;
4. Sites greater than an acre that have coverage under the Construction General Permit;
5. All sites located within the City's Priority Focus Areas as identified in the WQIP; and
6. Other sites determined by the City or the San Diego Water Board as a high threat to water quality.
Grading Permits and Capital Improvement Program (CIP) Projects
CM&I is responsible for updating and maintaining the inventory of all active grading permits and CIP
projects from approval to completion. CM&I verifies and updates the inventories on a monthly basis. The
database is used to update inspection records, record enforcement actions, and follow-up inspection
work. The inventories contain the most current information including when a site was last inspected, the
current construction status, changes in priority and rationale, inspection frequency priorities, and other
relevant site information.
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Building Permits
The Building Division maintains an inventory of all building permits. The building inspector is responsible
for maintaining and documenting of all storm water inspections related to building permits. The inventory
and tracking of permitted building sites is maintained in the permit tracking database where inspectors
are able to schedule inspections, track information about compliance, issue enforcement actions, and
document other relevant information.
6.4 Best Management Practice Requirements
The City has established a set of minimum BMPs for all projects. Because all sites, regardless of priority,
must be protected to prevent discharges, the minimum BMP requirements are the same for each priority.
Each site must be protected by an effective combination of site and seasonally specific erosion and
sediment controls, materials and waste management controls, and site management controls. These
minimum requirements are included in the Storm Water Standards Manual.
In addition, inactive sites must also be fully protected from erosion and discharges of sediment. A site is
considered inactive if construction activities cease for a period often or more consecutive days. It is also
the project proponent's responsibility at both active and inactive sites to implement a plan to address all
potential discharges.
SWPPPs and Water Pollution Control Plans are reviewed priorto commencement of construction activities
to ensure that the required minimum BMPs will be implemented. The City continues to utilize the
pollution prevention measures contained in the Storm Water Best Management Practice Handbooks
published by the California Storm Water Quality Association (CASQA), Caltrans Storm Water Quality
Handbooks, and Standards for Design & Construction of Public Works Improvements in the City of
Carlsbad. All inspectors are trained on construction site BMPs and the appropriate application. The City
requires the following minimum BMPs components for all construction sites:
1. Project Planning;
2. Good site management "Housekeeping", including waste management;
3. Non-storm water management;
4. Erosion control;
5. Sediment control;
6. Run-on and Run-off control; and
7. Active/Passive Sediment Treatment Systems, where applicable.
Year Round Requirements
The following are the minimum BMPs required at all sites throughout the year:
• All graded areas must have erosion protection BMPs properly installed;
• Adequate perimeter protection BMPs must be installed and maintained;
• Adequate sediment control BMPs must be installed and maintained;
• Adequate BMPs to control offsite sediment tracking must be installed and maintained;
• A minimum of 125% of the material needed to install standby BMPs to protect the exposed areas
from erosion and prevent sediment discharges, must be stored onsite. Areas already protected
from erosion using physical stabilization or established vegetation stabilization BMPs are not
considered to be "exposed" for purposes of this requirement;
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The project proponent must have an approved "weather triggered" action plan and be able to
deploy standby BMPs to completely protect the exposed portions of the site within 48 hours of a
predicted storm event (a predicted storm event is defined as a forecasted, 40% chance of rain by
5-day National Weather Service). On request, the project proponent or the City's contractor must
provide proof of this capability that is acceptable to the City;
Deployment of physical or vegetation erosion control BMPs must commence as soon as slopes
are completed. The project proponent may not continue to rely on the ability to deploy standby
BMP materials to prevent erosion of slopes that have been completed;
The area that can be cleared, graded, and left exposed at one time is limited to the amount of
acreage that the contractor can adequately protect prior to a predicted rain event. For larger sites
grading should be phased. It may be necessary to deploy erosion and sediment control BMPs in
areas that are not completed, but are not actively being worked before additional grading is
completed.
All exposed disturbed areas must have erosion protection BMPs properly installed. This includes
all building pads, unfinished roads, and slopes;
Perimeter protection and sediment control BMPs will be upgraded, if necessary, to provide
sufficient protection from runoff during the rainy season;
Deployment of erosion control BMPs will commence as soon as slopes are completed for any
portion ofthe site. Erosion control BMPs will be installed and maintained for all completed slopes
priorto October 1;
All disturbed areas that are not completed and/or not being actively graded must be fully
protected from erosion if left for 10 or more days. The ability to install BMP materials in a prompt
manner is NOT sufficient; BMPs need to be installed for these areas;
BMPs must be stockpiled at various locations throughout the project site forthe duration ofthe
rainy season. Whenever there is a 40% chance or greater of a rain within a five (5) day forecast,
the inspectorwill verify that BMPs are adequately stockpiled. BMPs must be ready for deployment
when there is 50% chance of a rain event within a 72 hour forecast. Failure to comply with this
requirement could result in the issuance of a Stop Work Notice or other enforcement action;
When a Rain Event Action Plan is required it must be prepared and completed in accordance with
the Construction General Permit. The plan shall include, in detail, any and all actions to be taken
in advance (50% chance or greater) of a rain event in the five (5) day forecast by the National
Weather Service. A copy of each updated action plan shall be placed in the project SWPPP and be
available for review by the city inspector;
All treatment and erosion control BMPs must be inspected weekly and prior to a forecasted rain
event of greater than 50%. In addition, treatment control BMPs must be inspected and/or
serviced priorto October 1;
Inspections at sites covered under the CGP shall be conducted by the QSD/QSP or designee prior
to a forecasted event, during and after a rain event, at least bi-weekly during the rainy season,
and as necessary to ensure site compliance;
All construction employees must be trained on the importance of storm water pollution
prevention and BMP maintenance prior to the rainy season;
All construction and grading projects are required to emphasize erosion prevention as the most
important measure for keeping sediment on-site during construction. Sediment controls are to
be used as a supplement to erosion prevention never as the single or primary method.
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6.5 Construction Site Inspections
The City inspects all active construction projects including private development and CIP projects. CM&I
inspectors are responsible for grading, infrastructure, CIP, right-of-way, and engineering projects, while
Building Inspectors are responsible for all building projects. All inspectors are responsible for ensuring
construction activities are performed in accordance with the City Standards, building and grading permits,
and all applicable codes, regulations and ordinances. Inspections are electronically documented and
placed in the project files. In addition, the City regularly verifies the projects threat priority and status
throughout the active construction phase.
Inspection Frequency
The inspection frequencies for determining compliance with
the City's requirements are based upon the threat to water
quality prioritization (Table 6-1). Inspection frequencies will
be periodically reevaluated, particularly when grading
activities occur during the rainy season. The need for
additional inspections may vary depending upon several
factors including: site conditions; previous violations; history
of developer or contractor past performance; grading during
rainy season; and weather patterns.
WQIP Focus Areas
Based on the City's identification of WQIP
Focus Areas, the inspection frequency will be
different in these areas vs. non Focus Areas.
The table below reflects the inspection
frequencies for the various project
categories.
Table 6-1: Inspection Frequency Based on Threat Prioritization
Threat
Priority
Minimum Inspe ctions Required Minimum Minimum Minimum Threat
Priority
a
M
3 <^
a.
9 Nov Dec c
(0 01
u-
a
s
h.
Q. «^
> a c
3
Wet Season
Inspections
Dry Season
Inspections
Required
Inspections
High** 2 2 2 4 4 4 4 4 4 4 2 2 28 10 38
High 1 1 1 2 2 2 2 2 2 2 1 1 14 5 19
Medium** 1 1 1 2 1 2 1 2 1 2 1 1 11 5 16
Medium 1 0 1 1 1 1 1 1 1 1 0 1 6 3 9
Low 0 0 1 0 0 1 0 0 1 0 0 1 2 2 4
**Projects located within a WQIP Focus Area
If inspected sites do not comply with the City's requirements, inspectors immediately direct compliance
and conduct follow-up inspections to assure compliance. Enforcement procedures are used when
necessary and may include verbal or written warnings, stop work orders, revocation of permits, and/or
legal action. Please see the City's Enforcement Response Plan for more information about escalated
enforcement actions.
Inspection Content
The City's inspection content and procedures include the following:
• Assessment of BMP adequacy and effectiveness including implementation of an effective
combination of erosion, sediment, and non-stormwater BMPs to meet the minimum water quality
protection requirements and prevent the discharge of pollutants into storm water and receiving
waters;
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• Checking for coverage under the Construction General Permit (WDID No.) during initial inspection.
The City will continue to work with RWQCB staff to ensure compliance at these sites;
• Assurance of compliance with applicable ordinances, permits and other site-specific
requirements;
• Visual observations of actual or potential non-stormwater discharges, potential illicit connections,
and/or potential discharge of sediment, pollutants or other construction related materials in
storm water runoff;
• Documentation of violations and escalation of appropriate enforcement actions, when required;
• Review of proper implementation of plans and specifications; and
• Education and outreach on storm water pollution prevention as needed.
Inspection Tracking and Records
The City tracks inspections and re-inspections of all inventoried construction sites, including those covered
by building permits. City inspectors will continue to use the NPDES Inspection Report to verify BMP
compliance and effectiveness. The results of each inspection are entered in the construction site inventory
database. The inspection form/record documents BMP compliance, clarifies required corrective actions,
tracks the numbers and types of violations, and identifies any necessary escalated enforcement actions.
The NPDES Inspection Report covers all administrative requirements including inspection and evaluation
of SWPPPs, wall maps, basins, materials and waste management, temporary BMPs, slope protection, and
site conditions and interactions. A copy of the inspection report can be provided directly to the site
representative upon completion of an inspection. Inspection reports and data tracking includes the
following:
1. Site name, location (address and hydrologic subarea), and WDID number (if applicable);
2. Inspection date and time;
3. Project No. and Permit No.;
4. Type of Inspection (follow-up, compliance, pre-event, complaint, etc.);
5. Approximate amount of rainfall since last inspection and percentage of rain expected;
6. BMP implementation and compliance activity which includes descriptions of problems observed
with BMPs, CMC violations, indication of need for addition/repair/replacement of BMPs, any
scheduled re-inspection, and date of re-inspection;
7. Descriptions of any other specific inspection comments, including rationales for longer
compliance time, changes in status or priority, and other notable information;
8. Description of enforcement actions issued in accordance with the Enforcement Response Plan;
and
9. Resolution of problems noted and date problems fixed.
6.6 Corrective Actions and Enforcement
The enforcement measures and remedies are available to the City for grading and construction related
activities are described in the City's Enforcement Response Plan - see Section 9.
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7 Existing Development
7.1 Introduction
This section describes the responsibilities of the City with respect to implementation of the Existing
Development Component of the JRMP including commercial, industrial, municipal, and residential
facilities and areas. This program section is intended to reduce existing development discharges of non-
storm water and pollutants from the MS4 to the MEP.
7.2 Inventory and Tracking
City Storm Water Staff maintain a watershed-based inventory of all industrial facilities and commercial
sites/sources within the City's jurisdiction. A copy ofthe current commercial and industrial inventory is
available upon request. Basic inventory information includes:
Facility name
Contact information
Location information (address and watershed)
Identification of business type (stationary or mobile)
Industrial General Permit NOI and/or WDID number, if applicable
Identification of pollutants generated and potentially generated by the facility or area
Whether facility is adjacent to an ESA
Whether the facility or area is tributary to and within the same hydrologic subarea as a water
body segment listed as impaired on the CWA section 303(d) list and if the facility or area
generates pollutants for which the water body segment is impaired for.
The City's commercial and industrial inventory includes commercial areas, commercial facilities, and
industrial facilities. Commercial areas include areas where commercial activities occur. Commercial
facilities include for example, repair shops, restaurants, and various types of wholesalers. Industrial
facilities include facilities such as manufacturing and hazardous waste treatment. Mobile businesses
include businesses such as power washers, auto detailers, landscapers, and contractors.
At a minimum, the commercial and industrial inventory is updated annually through reviewing business
license records for new businesses, performing routine inspections, and responding to reported incidents.
The following are the categories within the existing development inventory:
1. Commercial facilities or areas
All commercial use areas, properties, parcels and facilities will be represented in the existing
development inventory. They may be grouped together as commercial management areas or
inventoried as individual businesses or parcels. The inventory consists of:
a. Commercial Areas, Shopping Center or. Commercial Zone or
b. Commercial Facility (Individual Business or Parcel)
2. Industrial facilities
Industrial facilities will be inventoried and inspected as individual industrial entities. Inventoried
Industrial facilities will include all facilities enrolled in the Industrial General Permit and those
facilities that report to the City and are confirmed to conduct activities onsite consistent with the
industrial SIC and/or NAICS codes (listed in Attachment A ofthe Industrial General Permit).
3. Municipal Facilities
4. Residential Management Areas
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Residential Management Areas (RMAs), are geographic designations that constitute the
residential inventory and delineate the inspection areas. The RMAs within the City of Carlsbad
were created using GIS information such as General Plan land use. Home Owner Association,
drainage basin and neighborhood delineations. Geographic size, private gated communities and
other information were also taken into consideration.
The City maintains an existing development map (Appendix B) that identifies locations of:
• commercial and industrial facilities;
• commercial areas;
• residential management areas;
• municipal facilities;
• watershed boundaries; and
• water bodies.
The City's inventory of existing development will include the following information, as applicable, and any
additional information necessary to effectively implement this existing development program:
1. Name;
2. Location;
3. Classification as commercial, industrial, municipal, or residential;
4. Status of facility or area as active or inactive;
5. Identification if a business is a mobile business;
6. SIC Code or NAICS Code, if applicable;
7. Industrial General Permit NOI and/or WDID number, if applicable;
8. Identification if a residential area is or includes a Common Interest Area / Home Owner
Association, or mobile home park;
9. Identification of pollutants generated and potentially generated by the facility or area;
10. Whether the facility or area is adjacent to an ESA;
11. Whether the facility or area is tributary to and within the same hydrologic subarea as a water
body segment listed as impaired on the CWA section 303(d) List and generates pollutants for
which the water body segment is impaired
12. Presence of Common Interest Area or Home Owner Association; and
Potential/actual pollutants generated.
7.3 Best Management Practices Requirements
Existing development facilities and areas produce a range of pollutants that can threaten human and
environmental health if washed into the storm drain system by storm water runoff. The City of Carlsbad
requires all existing development facilities and areas to ensure proper implementation, operation and
maintenance of required BMPs. The City also requires the use of pollution prevention methods to address
the HPWQC (indicator bacteria) and strategies in the WQIP(s).
Facilities that utilize pesticides, herbicides, and/or fertilizers are required to implement BMPs to address
application, storage, and disposal. Improper use, handling, or storage of pesticides, herbicides, and
fertilizers may allow these chemicals to come into contact with receiving waters via storm water or urban
runoff.
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Described below is a summary of minimum BMPs required to be implemented for commercial, industrial,
municipal and residential facilities and areas throughout the City:
Commercial and Industrial Facilities/Areas
Good housekeeping
Preventative maintenance
Material storage, handling and application
Employee training
Solid waste (non-hazardous) handling and recycling
Spill response
Record keeping
Self-inspection/quality assurance
Municipal Facilities/Areas
• Employee training
• Pollution prevention
• Good housekeeping
• Spill response and prevention
Residential Areas
Move or cover potential pollution sources from storm water contact
Use dry cleanup methods
Residential car washing
Pet waste cleanup methods
Trash management
Recycle, reduce and reuse
Reduce the use of landscape chemicals
7.4 Program Implementation
7.4.1 Inspections
The City of Carlsbad implements a hybrid inspection program that includes patrolling and complete
inspections throughout its jurisdiction. The City's Storm Water Staff utilize patrols to monitor and inspect
commercial areas and residential areas for storm water violations per the City's ordinances. Patrolling
inspections are an effective and efficient method to enforce compliance with the storm water ordinances,
discover and abate hotspots and trouble areas, and educate business owners, property managers, and
residents regarding the City's storm water requirements. In addition, the patrol methodology allows for a
more efficient visual observation of the City and incorporates multiple components of the JRMP, e.g.,
IDDE, existing development, construction and TCBMP inspections as applicable.
Inspections of residential areas constitute a new element to the management and enforcement of
residential pollutant sources. Visual inspections of RMAs identify the presence of actual and potential
illegal discharges, and actual or potential illicit connections. Assessment of compliance and BMP
implementation will also occur. If any problems or violations are noted or observed, the inspector would
follow the Enforcement Response Plan.
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1. Inspection Types:
a. Patrol Inspection - Patrol inspections may be either onsite or drive-by. They focus on
publicly accessible, high-risk outdoor areas and activities of commercial areas and
facilities including: Trash dumpsters, grease bins and general housekeeping BMPs,
Irrigation systems and irrigations runoff; outdoor work areas; washing activities; sediment
and erosion control; and non-storm water discharges to the MS4. During Patrol
Inspections, only observed issues and/or violations are documented.
b. Facility Inspection - An on-site inspection in which a City employee or contractor conducts
a complete site assessment of a commercial or industrial facility and records all required
information regardless of whether issues are observed.
c. Follow-up Inspection- City staff verifies that required corrective actions are completed
and/or violation is no longer occurring. An entire site evaluation may not be completed
during follow-up inspections. Follow-up inspections may be conducted as a drive-by or
onsite.
Periodically, inventoried Commercial and industrial facilities are selected for an inspection and/or review.
Throughout the year, the City conducts scheduled, unscheduled and follow-up site inspections.
During site inspections City staff:
• Assess BMP implementation, maintenance and effectiveness.
• Review BMP implementation plans, if applicable.
• Check for coverage under the IGP (Notice of Intent, No Exposure Certification, and/or Waste
Discharge Identification Number), if applicable.
• Assess compliance with Copermittee ordinances and permits related to storm water runoff.
• Conduct visual observations for non-storm water discharges, potential illicit connections, and
potential discharge of pollutants in storm water runoff.
• Review facility monitoring data, if applicable.
7.4.2 Inspection Frequency
At a minimum. City staff conduct patrol inspections or facility inspections at each existing development
facility or area once in five years. More frequent inspections are based on the potential for a facility or
area to discharge non-storm water and pollutants. Additionally, inspection frequency is based on the
facility's potential to discharge pollutants associated with the highest priority water quality condition as
defined by the WQIPs.
Annually, the City will inspect at least 20% ofthe existing development inventory.
Follow-up Inspections
City staff conducts follow-up inspections to determine if corrective actions have occurred in accordance
with City ordinances and minimum BMP requirements. Escalating enforcement steps, providing flexibility
for the City staff to establish appropriate compliance periods on a case-by-case basis, will be used to
ensure compliance. Follow-up and enforcement actions are documented in the inspection tracking
system.
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7.4.3 Inspection Tracking and Records
City staff track and record all inspections and follow-up inspections at all locations in the existing
development inventory. This information is retained in a database. The information and data gathered as
part ofthe inspections includes, but is not limited to:
• Name and location of the facility (address and hydrologic subarea) consistent with inventory
name and location
• Inspection and re-inspection date(s)
• Inspection method(s) (drive-by or onsite)
• Observations and findings from the inspection(s)
• Descriptions of any problems or violations found during the inspection
• Description of enforcement actions issued in accordance with the City's Enforcement Response
Plan
• The date that problems or violations were resolved
7.4.4 Municipal Separate Storm Sewer System Program
The City's Public Works Department is responsible for the routine and emergency maintenance of the
City's MS4. The Storm Drain Maintenance Division (SDMD) and or their contractors will inspect and clean
the following types of facilities: catch basins, curb inlets, under sidewalk drains, channels, and
detention/desalination basins.
The City will implement the following schedule for inspection and cleaning of MS4:
• Once a year the City will inspect all MS4 facilities that receive or collect high volumes and trash
between May 1st and September 30th of each year. All remaining MS4 facilities will be inspected
at any time during the calendar year. Inspections are conducted to ensure that:
o BMPs are properly implemented and functioning effectively.
o Identify necessary maintenance (material removal is needed) and repair needs.
o Ensure proper implementation of JRMP requirements.
• Any catch basin or storm inlet that has accumulated trash and debris greater than 33% of the
design capacity (holding area) will be cleaned in a timely manner. Any MS4 facility/structure that
is designed to be self-cleaning will be cleaned of any accumulated trash and debris immediately
upon inspection. Open channels shall be cleaned of all observed anthropogenic trash and litter in
a timely manner.
When practical, work is to be done when conditions are dry. The SDMD will vacuum water runoff to
remove any silt buildup from MS4 activity maintenance. Acceptable vacuums, wet and dry shop vacuum,
or large Hydro flusher vacuum machines are used for the operations. Sediment control BMPs will be
implemented to prevent materials from discharging downstream ofthe sites cleaning activities.
During rain events Public Works staff from Public Works - Streets Division will be out from beginning of
rainfall to clear debris from inlets, grates, pipe openings, and road shoulders also to remove debris from
roadways prior to entering the conveyance system. Also to provide emergency erosion/sediment control
as needed. And to provide other City Departments with needed assistance with their multiple requests.
Survey City streets for damage due to rain and or flooding, and monitor drainage throughout the City.
37
h
7.4.5 Existing Flood Control Devices
The City's inventory of existing flood control devices will be reviewed updated and Incorporated into the
City's GIS system annually. If additional pollutant removal and urban runoff is possible and feasible,
permanent pollution removal measures would be incorporated in future retrofit projects.
7.4.6 street Sweeping Program
Street sweeping is widely recognized as an effective BMP for reducing the amount of pollutants, litter,
green waste, grease and sediments, on streets and parking lots that would impact stormwater quality.
The City contracts out street sweeping service and currently sweeps approximately 1,700 miles monthly.
The City has developed a frequency for street sweeping based on historic sweeping volumes collected and
traffic loadings. The street network is stratified into high, moderate and low volume generating areas
which is used to classify the streets with relation to each other, not to qualify the streets as generating
significant or non-significant amounts of trash and debris. The following is a breakdown of the street
sweeping categories:
1. High volume (arterials, majors and primes) 4 times per month.
2. Moderate volume (residential and local streets) 2 times per month.
3. Low volume (parking lots and seawall) 2 times per month.
7.4.7 Litter Removal
The City removes anthropogenic trash from arterial, major and prime streets on a daily basis. The City also
removes bulky items and other anthropogenic trash as needed in other locations. This facilitates removing
all litter and debris prior to reaching the MS4 conveyance system and getting into receiving waters.
7.4.8 Pressure Washing
The City cleans all high-volume foot traffic areas of dirt, sediments, gum and other food related substances
on a daily basis. As a part of this process, the City captures all the water and places it into the sanitary
sewer system. Other as-needed locations are cleaned throughout the year to prevent the pollutants from
reaching the receiving waters.
7.4.9 Application of Pesticides, Herbicides, and Fertilizers
The Federal Pesticide, Fungicide, and Rodenticide Act and California Title 3, Division 6, Pesticides and Pest
Control Operations place strict controls over pesticide application and handling and specify training,
annual refresher, and testing requirements. The regulations cover a list of approved pesticides and
selected uses, updated regularly; general application information; equipment use and maintenance
procedures; and record keeping. The California Department of Pesticide Regulations and the County
Agricultural Commission coordinate and maintain the licensing and certification programs. These
certifications require the implementation of Integrated Pest Management (IPM) practices during
maintenance activities. All City staff who apply pesticides and herbicides in "agricultural use" areas such
as parks, golf courses, rights-of-way and recreation areas are certified in accordance with state
regulations. All certifications are kept on file at the City's Parks Department. Contracts for landscape
maintenance include similar requirements.
All employees that handle or apply pesticides are trained on and responsible for understanding and
implementing safety precautions in current Materials Safety Data Sheet (MSDS). City staff implements
BMPs for: IPM practices including; minimizing use; caution when handling any hazardous product; reading
and following use instructions, completely using the product prior to marking as waste, and hazardous
waste storage and proper disposal.
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BMPs for pesticide, herbicide and fertilizer management are implemented at all municipal facilities, public
rights-of-ways, parks, recreational facilities, and other landscaped areas.
7.4.10 Sanitary Sewer Systems
The City provides wastewater collection, transmission and some treatment for its residential, commercial,
and industrial users. The average daily wastewater flow for the City is approximately 7.3 million gallons
per day (mgd).
7.4.10.1 Source Characterization
In general, the wastewater system is an underground utility system that is a conveyance system for
polluted waters. The system includes a network of approximately 265 miles of pipeline which range in size
from 6-inch to 42-inch in diameter and approximately 6,300 manholes. The system also includes 14 pump
stations, a water reclamation facility (operated under a separate permit by Encina Wastewater Authority),
and several metering stations that conveys wastewater (along with other jurisdictions' wastewater) to the
35 mgd Encina Wastewater Treatment Plant located in Carlsbad.
7.4.10.2 Best Management Practice Requirements
Prevention or response based BMPs will be implemented to reduce or eliminate the potential for
wastewater system failures, infiltration, or emergencies. The following is a summary ofthe prevention
and response efforts that will be implemented for the wastewater operations.
Sewer System Overflow Response
The Maintenance and Operations (M&O) Division conducts Sewer System Overflow Response under
varying emergency conditions. The primary function of the responses is to prevent human and
environmental impacts from sanitary sewer spills. The Sewer System Overflow Response Plan (SSORP)
details all ofthe procedures that are implemented during any type of sanitary sewer overflow and includes
procedures for response, clean-up and reporting.
System Cleaning
A primary function of the Wastewater Division is to perform sanitary sewer collection system cleaning. As
a part of the cleaning efforts, the division uses jet-rodding equipment and vactor trucks to collect the
cleanings.
Video Inspection
Another primary function ofthe Wastewater Division is to perform video inspections ofthe sanitary sewer
collection systems to identify potential problems and to prioritize the City's maintenance and
rehabilitation program. These video inspections are currently performed on an as-needed basis. The City
began a comprehensive system-wide video inspection program in Fiscal Year 2008-09.
Utility Crew Work
Another primary function of the Wastewater Division is to perform general utility work, including
maintenance and modifications to sanitary sewer manholes, and point repairs in the sanitary sewer
collection system.
7.4.11 Special Events
Periodically the City is host to special events, both directly as City functions, and indirectly, permitted to
special event organizers. Examples of these special events are:
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• Street Festivals
• Marathons
• Taste of Carlsbad
• Art Splash
7.4.11.1 Source Characterization
Typically, special events have a high density use of people per square foot raising the potential for
pollutant generation. The pollutant generating activities and their potential pollutant types at special
events typically include:
• Setup and teardown of equipment booths- illicit discharges and trash generation
• Booth operation - trash generation
• Food/drink preparation and consumption - illicit discharges, trash generation, and organic
materials
• Hydraulic rides-oil and grease
• Temporary Portable Restrooms - chemicals and bacteria
• Hydration stations - water cups and other trash items
7.4.11.2 Best Management Practices
The following standard Best Management Practices represent the minimum requirements for a variety of
special events that could take place in the City. The City may improve or modify these BMPs at any time
if it is determined to provide equal or greater protection.
It is imperative that Event Organizers train event staff in storm water pollution prevention activities at the
event venue and to notify all vendors of their storm water pollution prevention responsibilities.
All Event Organizers shall select an effective combination of Storm Water Best Management Practices
(BMPs) to prevent trash or other pollutants from entering the storm drain system - BMPs to select from
include:
Food and beverage, and all chemical and liquid activities or products:
Event Hosts/Organizers and vendors must have spill kits in or adjacent to their work area. Spill kits include:
paper towels, cloth towels, kitty litter and/or sand. All spill materials must be picked up out of the public
right of way once the spilled material is absorbed off the ground. Spills leaving the event venue area into
the surrounding streets must be captured and prevented from enteringthe surrounding non-event area(s)
and storm drains.
Storm Drain Protection:
• Event Hosts/Organizers must protect all storm drains identified on their site plans. If no rain is
projected, consider placing fabric filters or approved inlet protection device over the drain
opening. The use of fabrics and other types of inlet protection devices will require gravel bags or
other form of anchor to keep them in place during the event. The gravel bags must be clean and
free of sediment.
• If a 40% (5-day National Weather Service) chance or greater of rain is forecasted, gravel bags
protecting the storm drain perimeter or other approved inlet protection devices are sufficient,
however must be removed in the event of rain to prevent flooding.
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• All impacted catch basins identified on the special events storm water pollution prevention plan
must be visually inspected and cleaned, if necessary, following the special event and prior to an
anticipated rain event (40% from 5-day National Weather Service).
Craft/Art Creative Areas and Post Event Public Art Removal:
• All craft/art creative areas must have spill kits on hand (see above).
• Post event clean-up of these areas includes removal of temporary public art (chalk, paint,
charcoal, clay, etc.). Event/vendor staff must use wet-mops. Any water in a bucket must be either
poured into the sanitary sewer via for example a sink, or released over a landscaped area that has
adequate capacity to contain the liquids and the pollutant without allowing discharge onto
sidewalks, curbs, gutters streets and storm drains.
Trash and Debris:
• Adequate trash and recycling containers must be provided throughout the event venue, including
at the exit and entry points. All trash containers must be covered. Regular collection of loose trash
and debris is required.
• All trash and /or recycling collection areas should have spill kits and wet mop(s) and brooms
available and staff trained in spill clean-up methods.
• Temporary Fencing will be required to be put into place if the event, or any portion thereof, is
determined to pose a threat of wind-blown debris into any water bodies.
• Post event sweeping of the entire venue area and related staging areas may be required, where
necessary.
Temporary portable restrooms:
• All temporary portable restrooms will be placed away from all storm drain inlets, drainage swales,
water bodies, and any other locations that have the potential to impact the storm drain system.
• All temporary portable restrooms are required to have a secondary containment pan or additional
BMPs in place around the stations for possible overflows.
• The contact information for the company responsible for the restrooms clearly marked on or
around the restrooms.
7.4.11.3 Program Implementation
Event Organizers must complete a permit application which includes developing a site plan that shows
the limits ofthe special event and identifies all ofthe drain inlets (and other entry ways to the storm drain
system). This application will be reviewed and approved by the City priorto permit issuance.
Site conditions and post-event conditions will be inspected by City staff. In the event that the Special Event
organizer fails to adequately clean the venue, the City will clean the site and seek retribution for costs
through enforcement actions.
7.4.12 Household Hazardous Waste Collection Services
The City has successfully implemented a Household Hazardous Waste (HHW) program and continues to
promote used oil recycling for all residents. The City will continue to implement the HHW Door-to-Door
pick up program approved and adopted by the Carlsbad City Council in FY 05-06. The Door-to-Door
collection program is contracted and offers residents a toll-free phone number to call for a disposal
appointment. The program provides a means for Carlsbad residents to have HHW picked up from their
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homes and hauled away for a nominal fee. The maximum weight allowable is 15 gallons or 125 pounds.
Appointments are typically made a week from the collection date. In addition, residents can also dispose
of HHW for free at two permanent facilities in Vista and Oceanside.
In addition, the City of Carlsbad will continue to sponsor a free annual HHW disposal day where Carlsbad
residents can dispose of up to 15 gallons or 125 pounds of HHW materials. During the event, residents
will be able to dispose of HHW and receive information about other, available environmental programs,
including storm water, bulky item pick up, used oil recycling, water conservation, and trash collection.
The City will continue to endorse a used oil-recycling program to ensure residents have access to facilities
to recycle used oil in their community.
The City will continue to promote the used oil collection program through various outreach and education
efforts and the web site.
7.5 Enforcement
If the City determines that an existing development facility or area is out of compliance with requirements,
the violation and the corrective actions necessary to bring the site into compliance are documented.
Corrective actions include a compliance date at which the City inspector or investigator determines that
the site needs to be in compliance. A follow-up inspection is performed to determine compliance. If
compliance has not been achieved by the follow-up inspection, increased enforcement actions may be
implemented.
For further details regarding the City's enforcement procedures see Section 9, Enforcement Response
Plan.
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8 Retrofitting and Rehabilitation in Areas of Existing
Development
8.1 Introduction
The City will be developing a retrofit and rehabilitation program that identifies opportunities to implement
retrofits and stream, channel and/or habitat rehabilitation within areas of existing development. The
intent ofthe City's program is to encourage the construction of retrofit or rehabilitation projects in areas
of existing development where controls do not exist or are ineffective. Construction of retrofit and
rehabilitation projects in areas of existing development are expected to improve the discharges from the
City's MS4.
8.2 Identifying Candidate Retrofits and Rehabilitation Projects
The City will develop and maintain a list of candidate retrofits and rehabilitation projects using a system
of identification and field verification. Identification will be conducted using desktop analyses to identify
key areas in the City where it is expected that retrofits and rehabilitation projects will have effective and
efficient benefits. Field confirmations will be used for final verification that the identified retrofits and
rehabilitation projects are appropriate applications of BMPs and controls both in type and location.
The process for identifying projects will evaluate the following considerations:
• Water Quality Improvement Plan (WQIP) Priority and Highest Priority Water Quality Conditions
• Likely sources of pollutants generating pollutants related to WQIP conditions
• Focus areas identified in WQIP
• Vintage of geographic areas of the City - time period when existing development was
constructed
• Areas of persistent discharges
• Inspection/Illicit Discharge Detection and Elimination program findings
• Identified areas of hydromodification or other stream impacts
Using the considerations above, the City will identify areas where opportunities could provide water
quality improvement benefits. Evaluation will include layering of the findings to determine where
compounding factors overlap. The City will consider the locations where overlapping occurs and
significance ofthe factors to prioritize areas suited for retrofits and rehabilitation projects.
Once specific areas within the City have been identified and prioritized for retrofits and/or rehabilitation
projects, the City will perform field verifications on an as-needed basis to substantiate the:
• locations of potential retrofits or rehabilitation projects
• appropriate type(s) of retrofit or rehabilitation project
• appropriate responsible party to implement the retrofits or rehabilitation projects
8.2.1 Retrofit Types
The type of retrofit recommended for a specific area will depend on the site conditions and consider the
desktop analyses conducted during the initial candidate evaluations. Types of retrofits range from large
storage systems to on-site applications of source control and treatment. The types of retrofits the City will
consider when evaluating applicability may include:
• Modifications to existing basins (flood control or treatment basins)
• Installing inline filtration (e.g., inlet, vaults)
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Disconnecting impervious surfaces (e.g., roof drainage from conveyance system)
Creating buffer areas around irrigated systems
Creating storage in areas adjacent to conveyance systems (e.g., culverts, outfalls)
Installing source control systems, e.g., covering pollutant generating activity areas (e.g., trash
enclosures, material storage)
Creating storage within the conveyance system
Installing bioretention systems
Converting impervious surfaces to pervious
Upgrading irrigation systems to low-flow or direct systems
Installing green roofs
Installation of green streets
Installation of additional covered trash receptacles in key areas
Stabilization of erodible areas
Geographic areas identified and prioritized for retrofits as well as site specific retrofit candidates will be
maintained by the City and available to the various departments that may require or use the list for
implementation of retrofits.
8.2.2 Rehabilitation Types
The type of rehabilitation recommended for a specific area will depend on the site conditions and consider
the desktop analyses conducted during the initial candidate evaluations. Types of rehabilitation projects
range from in-channel improvements to habitat improvements. The types of rehabilitation projects the
City will consider when evaluating applicability may include:
• Stream/channel modifications
o Hard bank stabilization
o Soft bank stabilization
o Grade controls
o Flow deflection/diversion
o Habitat enhancement
• Habitat restoration
• Wetland restoration
Geographic areas identified and prioritized for rehabilitation projects as well as site specific rehabilitation
project candidates will be maintained by the City and available to the various departments that may
require or use the list for implementation.
8.3 Implementing Candidate Retrofits and Rehabilitation Projects
Facilitating the construction of retrofits and rehabilitation projects is a multi-pronged long-term process.
The City will continue to develop this aspect of the program and provide appropriate updates.
Mechanisms to fund retrofits and rehabilitation projects may include:
Grants from other public agencies and/or private organizations
Development impact fees
Developer implementing offsite alternative compliance (if applicable)
City funding
Private property owners
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9 Enforcement Response Plan
9.1 Introduction
The City implements an Enforcement Response Plan as part of its jurisdictional runoff management
program. The Enforcement Response Plan describes the applicable approaches and options to enforce
the City's legal authority to achieve compliance with the requirements ofthe Permit.
The City enforces its Municipal Code throughout its jurisdiction and implements escalating enforcement
responses to compel compliance with statutes, ordinances, permits, contracts, orders, and other
requirements forthe IDDE, development planning, construction management, and existing development
components of the JRMP. A storm water enforcement action will typically occur as a result of an inspection
or in response to a reported incident by the public or City staff.
9.2 Enforcement Mechanisms
The City typically employs a tiered, increasing enforcement system. However, the City reserves the right
to apply stricter initial enforcement measures where significant non-compliance is noted or when a
potential rain event increases the potential for the violation to have a negative impact on water quality.
The various increasing administrative and judicial enforcement measures, as prescribed by the City's
Municipal Code, are discussed below.
9.2.1 Administrative Enforcement Mechanisms
Verbal and Written Warnings
Warnings are used as an initial method of requesting corrective action and enforcing compliance. City
staff notifies the violator, verbally or in writing, and may establish a specific time frame for correcting the
problem.
Notice of Violation
If the violation noted in a warning is not corrected by the scheduled follow-up date, or the severity of the
violation is such that a warning is not strong enough, a notice of violation (NOV) would be issued. The
NOV describes the infraction that is to be corrected, and provides a time frame and date for corrective
actions. Associated follow-up inspections are conducted to ensure compliance. A copy ofthe notice will
be provided in person or via certified mail, to the violator. The City inspector or investigator will document
the violation and date of resolution.
Enforcement of Contracts (For Municipal Projects Only)
Construction contracts include the City's authority to refuse payment, stop work (without time penalties)
or revoke contracts, if contractors performing the construction activities do not comply with appropriate
permits, laws, regulations and ordinances.
Stop Work Orders (Construction Activities)
If an NOV has not been addressed by the follow-up inspection, the contractor has not complied with
permit requirements, or a significant threat to water quality is observed (such as a failure of BMPs
resulting in a significant release of sediment or other pollutants), a stop work order may be issued by the
appropriate City official. Stop work orders prohibit further construction activity until the violation is
resolved and provide a time frame for correcting the problem. The stop work order describes the
infraction and specifies what corrective action must be taken. To restart work once a stop work order has
been issued, the contractor's project supervisor must request that the City re-inspect the project and
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verify that the deficiencies have been satisfactorily corrected. If the City is satisfied with the corrections,
work may proceed. The stop work order and other related information is documented in the inspection
inventory.
Denial or Revocation of Permits
In severe cases of non-compliance or significant discharges related to development or construction
projects, the City may decide to revoke the building or grading permits or deny future permits. The project
proponents would have to re-apply for permits and meet any requirements that the City may place on
the project.
Denial or Revocation of Business License
In severe cases of non-compliance or significant discharges related to businesses, it may be appropriate
to revoke a business' license. If revocation occurs, the facility owner would need to re-apply for a business
license and meet all applicable City requirements.
9.2.2 Judicial Enforcement Mechanisms
Civil and Criminal Court Actions and Penalties
The City may use Civil and or Criminal court actions under the State Porter Cologne Water Quality Act, the
Federal Clean Water Act, and/or the City's municipal code to enforce requirements. The approach may
result in significant fines for the violator. Any violation of the Carlsbad Municipal Code Section 15.12
(Storm Water Management and Discharge Control) can result in monetary fines.
The following factors are considered when the City determines the amount of civil and criminal penalties:
• Seriousness of the violation
• Duration of the violation
• Frequency or recurrence of the violation
• History of the violation
• Violator's conduct after issuance of the Notice and Order
• Violator's good faith efforts to comply
• Impact of the violation upon the community
9.2.3 Escalated Enforcement
Escalated Enforcement is considered to be major enforcement actions taken by the City to correct a
significant threat to water quality or discharge that has occurred. Threats are generally corrected through
the tiered increasing enforcement actions applied by the City. However, if the threat to water quality is
not addressed in a timely manner - Escalated Enforcement would be implemented by the City. If a
significant discharge has occurred and penalties need to be considered and assessed, the City considers
these penalties to be Escalated Enforcement.
Escalated Enforcement actions for construction sites include:
• Notice of Violation
• Administrative Citations
• Civil and Criminal Court Actions and Penalties
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Escalated Enforcement actions for existing development include any enforcement that is Notice of
Violation or higher and is at least the second enforcement action for the same violation and responsible
party. Enforcement typically progresses in the following order:
1. Education and Outreach
2. Warning (Oral or Written)
3. Notice of Violation
4. Administrative Citation Warning
5. Administrative Citation
Education and Outreach and Warnings can be omitted or bypassed if the enforcement official deems it
necessary to initiate enforcement at a higher level. The enforcement official may use additional
mechanisms to eliminate the violation and/or threat to water quality, if necessary. These actions are not
required to progress in any order, are also considered escalated enforcement actions, and include the
following:
1. Other Administrative code enforcement powers and procedures
a. Cease and Desist Orders
b. Notice to Clean, Test and/or abate
c. Stop Work Order
d. Permit or License Suspension, Denial or Revocation
e. Civil Penalties
2. Judicial Enforcement
a. Criminal Penalties
b. Injunction/Abatement of Public Nuisance
c. Other Civil Action
Escalated Enforcement is implemented through each of the individual Enforcement Response Plan
components. Should the City determine that Escalated Enforcement is not required for any violation; the
rationale would be properly documented in the City's tracking system. Violations are documented in the
Enforcement Response Plan excel database. Documentation includes the violation type, when it was
identified and compliance achievement date.
In general, the City's approach to enforcement is to use an iterative process. Upon issuing any level of
enforcement, if the violator does not take appropriate corrective actions in a timely manner, the City
would increase enforcement actions. The City, on a case by case basis, may forgo lower tier enforcement
and increase to higher level of enforcement. Generally, this is based on severity of the issue, past
violations by violator/responsible party or other factors.
9.3 Enforcement Response Plan Components
9.3.1 Illicit Discharge Detection Elimination
The City enforces its ordinances and orders to prevent illegal connections and illicit discharges to its MS4.
Enforcement mechanisms are implemented on an increasing scale to ensure compliance is achieved.
The typical process for implementing necessary actions involves an administrative abatement procedure
in the form of a notice of violation with corrective actions. The City requires the violator to conduct
activities necessary to eliminate the illicit discharge at his or her own expense. The activities necessary
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are directed by City staff and are described on the notice. A deadline for correcting the infraction with the
required activities is provided by City staff. If the violator does not meet compliance by the deadline, the
City may conduct the necessary corrective actions and charge the resulting costs to the violator.
9.3.2 Development Planning
The City will use a variety of enforcement methods to ensure storm water requirements are implemented
for all development projects within the City's jurisdiction. Enforcement methods include verbal and
written warnings, monetary penalties, stop work orders, and denial of permits or occupancy. Construction
inspectors review the projects for compliance with the water quality requirements for the project and the
storm water ordinances. For CIPs that are Priority Development Projects, enforcement may include
withholding operational acceptance or notification of completion until post-construction BMPs are
properly installed.
Building inspectors inspect the installation of BMPs that are associated with private development and that
require a demolition or building permit. For Priority Development Projects that are private developments,
the Certificate of Occupancy will not be issued unless the BMPs have been inspected and signed off as
being constructed properly by the City.
Prior to certifying a project ready for occupancy (one of the final project releases) or releasing the
applicant's bonds, the City will verify that each post-construction BMP has been installed per City
requirements.
9.3.3 Construction
The City is responsible for enforcement of applicable local ordinances and permits at all construction sites
in its jurisdiction. City inspection staff have the authority to take immediate enforcement actions when
necessary. This facilitates rapid correction of inadequate BMP implementation, reducing the risk of
pollutant discharges from a construction site.
If an inspector determines that a construction site is out of compliance with the City's requirements, the
inspector would document the corrective actions necessary to bring the site into compliance.
Documentation of the corrective actions includes a compliance date at which the inspector has
determined that the site needs to be in compliance. This compliance date is based on the best professional
judgment of the inspector. The inspector will perform a follow-up inspection to determine compliance.
If compliance has not been achieved, the City would implement appropriate enforcement measures based
on the severity of the violation. Enforcement can range from verbal warnings to more severe enforcement
such as stop work orders. Increasing enforcement measures would be used when necessary if proper
corrective actions are not implemented during the allotted time frame.
9.3.4 Existing Development
Municipal
If the City determines that a municipal facility or activity is out of compliance with requirements, the
corrective actions are documented and implemented in order to bring the site into compliance as
practicable.
Industrial and Commercial
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If City staff determines that a site is out of compliance with City requirements, the violation and corrective
actions necessary to bring the site into compliance are documented and include a compliance date by
which the site needs to be in compliance. If compliance has not been achieved by the follow-up inspection.
City Staff would implement increasing enforcement actions.
Residential
The City uses the following mechanisms to determine areas where residential enforcement actions may
be necessary:
• Public reporting hotline
• Analysis of monitoring data ( field screening and analytical monitoring results)
• Observations from City field personnel
• Residential Management Area inspection program
If City Staff observe a significant and/or immediate threat to water quality, enforcement actions are taken
to require the residential property owner to immediately eliminate the discharge. City Staff would conduct
follow-up inspections to determine if corrective actions have been taken in accordance with City
ordinances and minimum BMP requirements. Escalating enforcement steps may be utilized at the
discretion of City staff in order to establish appropriate compliance time frames on a case-by-case basis.
9.3.5 Correction of Violations
The City requires any violation to be corrected in a timely manner with the goal of correcting the violations
within 30 calendar days after the violations are discovered, or prior to the next predicted rain event,
whichever is sooner. If more than 30 calendar days are required to achieve compliance, then the City
documents the rationale.
9.4 Reporting of Non-Compliant Sites
The City will notify the RWQCB in writing within five (5) business days of issuing Escalated Enforcement to
a construction site that poses a significant threat to water quality as a result of violations or other non-
compliance with its permits and applicable location ordinances, and the requirements of the Permit.
The City will notify the RWQCB of any persons required to obtain coverage under the statewide IGP and
CGP and failing to do so, within five (5) calendar days from the time the City becomes aware of the
circumstances.
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10 Education
10.1 Introduction
The City implements a public education program to promote and encourage pollution prevention best
management practices that reduce the discharge of pollutants to receiving waters.
10.2 Municipal Staff Training
Storm water training for municipal departments and personnel will include general training and job
specific training using appropriate topics. The objectives ofthe employee training programs are as follows:
• Promote a clear understanding of the urban runoff and water quality issues, including activities
that can potentially pollute receiving water bodies.
• Identify and implement strategies for BMPs.
• Promote employee ownership of the problems and their ability to apply solutions.
• Integrate employee feedback into training and BMP implementation.
The City provides training to staff involved with the implementation of the JRMP. Staff training may take
the form of class room style presentations, attending conferences, field trainings, tailgate meetings,
videos, reading written SOPs, emails, and/or other appropriate methods.
In addition to the specific training topics listed above. City staff will continuously receive information and
general storm water training through various communication methods including:
1. City website: Employees are able to access BMP information
2. Internal Newsletters: Internal newsletters feature updates on the Storm Water Protection
Program and Environmental Programs. Employees are notified by e-mail when these newsletters
are published and posted on the City's intranet, and hard copies were given to personnel without
computer access.
3. Workshops: All new employees are invited to attend a three-day orientation workshop entitled
First Mondays. At this workshop, employees are given a Power Point presentation introducing
them to the Storm Water Protection Program.
4. Promotional Items: Items such as water bottles, notepads, mouse pads, cups, and pens with the
hotline numbers and other pollution prevention messages continue to be distributed to
employees.
5. Hotline Decals and Notepads: Car window decals and notepads with the storm water hotline are
distributed for employee use in the field.
10.3 Construction Site Owners and Operators
The greatest strength of Carlsbad's efforts to educate construction site owners and developers is our
motivated and well-informed project review and inspection staff. The City is committed to working with
and educating project proponents on storm water compliance during all phases of construction. During
the application process, one-on-one or small group meetings, pre-construction meetings, inspections, and
complaint investigations the City provides outreach and education that promotes and encourages the
development of programs, management practices, and behaviors that potentially lead to the prevention
of illegal discharges.
The City also provides sample SWPPPs and SWMPs for engineers, developers, and applicants to use as
guides when preparing documents for proposed development projects. Construction and Building
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Inspectors work with contractors, homeowners, developers, and others in the construction industry to
identify storm water compliance issues, detail corrective actions, assess the appropriateness of BMPs, and
provide educational information and resources. CM&I requires pre-construction meetings with
contractors and developers prior to the issuance of grading permits. During the pre-construction meeting,
the contractor/developer is educated on the City's storm water requirements and compliance efforts.
Each contractor/developer is also provided with a copy ofthe City's minimum BMP requirements and any
applicable compliance update memos.
In addition, the City has set up public email addresses to request information from Utilities Construction
Maintenance and Inspection Division, Community and Economic Development - Land Development
Division and Building Division. Contractors, developers, the public, structural BMP responsible parties can
send questions, verification forms, and other requests to the various departmental email addresses, which
are monitored during business hours. The City has also developed an email address list for structural BMP
responsible parties. The email mailing list has been useful in providing information about BMP compliance
and other educational information.
The City will continue to provide regular storm water training to engineers, plan checkers, and inspectors
covering topics such as regulatory requirements, new and evolving BMP standards, inspections and
compliance, inventory management and reporting, and new development design and BMP effectiveness.
The City also encourages attendance at storm water conferences and workshops, supports applications
for storm water compliance certifications, and distributes BMP and pollution prevention information to
contractors, developers, and the general public.
10.4 Commercial/Industrial Facilities Owners and Operators Training
The City of Carlsbad conducts education of storm water regulations during inspections and through
trainings/workshops. As part of the inspection program, site-specific BMPs, employee training and
pollution prevention information is shared with the facility and/or business manager. These strategies are
in accordance with those identified in Permit No. R9-2013-0001 and the Carlsbad WMA Water Quality
Improvement Plan.
Forms of outreach education:
• Brochures
• Direct mailings
• City website
• Onsite presentations
• Inspection reports
• Workshops
• Informational booths
• Other activities as needed
Areas/Issues addressed:
Pollution prevention
BMP Implementation and Maintenance
Pesticides, Herbicides and Fertilizers BMPs
Other BMPs as identified and required
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10.5 Residential Community and General Public
The City of Carlsbad continues its outreach and education to the residential community and general public
in accordance with Permit No. R9-2013-0001 and the Carlsbad WMA WQIP.
Outreach and education to these target audiences occurs during complaint investigations, storm water
patrols, public events, workshops and presentations, among other opportunities. The City may also
contract with third party vendors, non-profit organizations and other groups to implement the outreach
and education program.
In accordance with Permit No. R9-2013-0001, Provision E.7.a, the City of Carlsbad will focus on the
reduction of pollutants associated with the application of pesticides, herbicides and fertilizers; proper
management and disposal of used oil and toxic materials; and other pollutants of concern associated with
specific target audiences.
Pollutants/sources of concern associated with residential communities and the general public:
• Pesticides, herbicides and fertilizers
• Used oil and toxic materials
• Trash
• Pet waste
• Sediment
• Over-irrigation
• Prohibited discharges
• Other pollutants
Forms of outreach education:
• Direct mailings
• Correspondence from inspections and investigations
• Public events
• Outreach materials
• Neighborhood events
• Classroom presentations
• Workshops
• Media
• Other strategies as identified and needed
Printed materials can be provided in Spanish and Spanish speaking employees are available during regular
business hours city-wide for verbal interpretation, if needed. In addition the City promotes proficiency in
Spanish by offering bilingual pay.
The City of Carlsbad continues to provide storm water education to school-aged children within the
Carlsbad Unified School District. Presentations and outreach can be available to all levels from
kindergarten to high school.
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11 Public Participation
11.1 Introduction
The goals of the public participation program are to develop mechanisms for public participation
throughout the development and implementation of the JRMP. The City encourages public participation
through the programs discussed below.
11.2 Water Quality Improvement Plans
The process of developing and implementing the WQIPs incorporates a significant public participation
process, through engaging stakeholders at public workshops, coordinating with formal Consultation
Panels including businesses, developers and Environmental stakeholder members, as well as providing
significant public review and comment periods for all WQIP documents. The public participation process
not only influences the development ofthe WQIP, but also the implementation mechanisms included in
the City's JRMP.
The public participation process ofthe WQIP was and continues to be rigorous and transparent. All public
meetings are communicated through all city media outlets, including social media.
11.3 Local Public Participation
Public participation is fundamental in the implementation of storm water permit regulations. The City of
Carlsbad will deploy strategies to engage the public, and to allow for a public forum to provide input and
feedback to improve programs. Public participation implements a process for the public to participate in
the WQIP process; opportunities for the public to provide feedback on improving the program; and
opportunities for the public to participate in programs and/or activities.
In addition, the City of Carlsbad provides numerous other opportunities to engage the public and allow
for input:
City of Carlsbad Council meetings
City boards, commissions, and committees
WQIP meetings
Public events
Social media
Neighborhood events
Storm Water Hotline
Storm Water email
Public events, such as California Coastal Cleanup Day, Kids Day at the Flower Fields, Citizens'
Academy
Workshops
Inspections and investigations
Social media
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12 Monitoring and Assessment
The City conducts wet and dry weather monitoring of MS4 outfalls and receiving waters to assess water
quality improvement efforts with respect to 303(d) listed constituents and the Highest Priority Water
Quality Conditions (HPWQCs) as identified in the Carlsbad Watershed Management Area (WMA) Water
Quality Improvement Plan (WQIP). This section describes the City's monitoring and assessment efforts
performed on a jurisdictional level and as part ofthe Carlsbad WMA.
12.1 MS4 Outfall Discharge Monitoring Station Inventory
The City has identified 141 major MS4 outfalls that discharge directly to receiving waters within its
jurisdiction and maintains information about the outfalls it the inventory. The MS4 network is regularly
evaluated to ensure that applicable discharge points are included in the inventory. Additionally,
monitored outfalls are evaluated onsite to ensure they meet the MS4 outfall discharge monitoring station
inventory.
12.2 Dry Weather Major MS4 Outfall Discharge Field Screening Monitoring
As a component of its Dry Weather Monitoring (DWM) efforts, field screening is conducted at outfalls
identified the MS4 outfall discharge monitoring station inventory to:
• identify and investigate observed discharges;
• prioritize dry weather MS4 discharges to eliminate;
• assess effectiveness of source elimination; and
• to differentiate monitoring conducted for the highest priority MS4 outfalls with persistent and
transient non-storm water discharge.
The minimum number of field screenings conducted annually will be the same as the quantity of major
MS4 outfalls identified per in the MS4 outfall discharge monitoring station inventory (currently 141).
However, specific outfall locations and frequencies of visual monitoring may change according to non-
storm water discharges observed, source elimination, and the HPWQCs of the WMA.
Major MS4 outfalls are assessed through field observations and data measurements. Field observations
collected are unique to specific major MS4 outfalls and describe:
• Site conditions (i.e. vegetation, structural condition, trash, etc..)
• Evidence of illicit Evidence of illicit connections or illegal dumping
• Presence and characteristics of flow, pooled or ponded water found
When field observations or field screening monitoring identifies an obvious illicit discharge, immediate
action is taken to identify the source - see Section 4 Illicit Discharge Detection and Elimination.
12.3 Non-Storm Water Persistent Flow MS4 Discharge Monitoring
The City conducts non-storm water persistent flow MS4 outfall discharge monitoring at specific major
MS4 outfalls identified during an assessment ofthe City's MS4. Monitoring of persistent flow is performed
to identify which persistent non-storm water discharges contain concentrations of pollutants below NALs
and which have the potential to impact receiving water quality during dry weather. The City prioritizes all
persistently flowing major MS4 outfalls based on:
• Transitional monitoring results
• HPWQCs
• Historical data (DWM/CSDM)
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• 3rd party data
• Historical Temporary Watershed Assessment Station (TWAS) monitoring
• Historical Mass Loading Station (MLS) monitoring
The City identified five major MS4 outfalls and classified them as the highest priority outfalls for additional
monitoring. These highest priority major outfalls and their locations within the Carlsbad WMA are listed
in Table 5. The City monitors these high priority outfalls semi-annually during dry weather conditions until
results from non-storm water discharges no longer qualify as a highest priority outfall. This occurs when:
• Discharge has been eliminated for three consecutive dry-weather monitoring events
• Data evaluation illustrates that constituents fall below an NAL
• The outfall is found to be an authorized discharge or covered by a separate NPDES permit
Table 5: Highest Priority Major Ouffalls and Location Description
MS4 0utfalllD Location
19C-1 North of Sunny Creek Rd.
lD-21 West of Haymar Dr. and El Camino Real
16C-61 South of Chinquapin. Near YMCA camp.
9B-S216 State St. north of Laguna Dr.
9B-38 State St. north of Laguna Dr.
The City will periodically reevaluate and prioritize (as needed) its non-storm water persistent flow MS4
outfalls. This process ensures that the highest priority major MS4 outfalls are focused on for their
contributions. In general, the City will continue to focus on addressing the highest priority MS4 outfalls
until one of the conditions above are met and lower priority outfalls will be integrated into the highest
priority MS4 outfall listing.
Discharge monitoring includes DWM field observations identified above (Section 12.1) with the addition
of field parameter measurements and collection of grab samples when discharge is either ponded/pooled
or flowing. Field parameters measured are shown below in Table 6.
Table 6: Field Measurements
Parameter Units
Temperature °C
Specific Conductivity pmhos/cm
pH pH Units
Dissolved Oxygen mg/L
Turbidity NTU
When active flow is present, the non-storm water discharge is sampled and is analyzed for the
constituents identified in the Carlsbad WMA MS4 Outfall Monitoring Plan: Attachment D - Table D-3. The
current monitoring plan can be found at the Project Clean Water website under the Carlsbad WMA page.
Collection methods of samples and field parameters follow SWRCB approved SWAMP guidelines and/or
EPA methods described, unless a site-specific method must be used enable to collect representative data.
12.4 Wet Weather MS4 Outfall Discharge Monitoring
The City performs wet weather MS4 outfall monitoring to identify pollutants in storm water discharges
from the MS4s and to guide pollutant source identification and mitigation efforts. MS4 wet weather
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monitoring stations within the Carlsbad WMA were selected to best represent land use types (i.e.
residential, commercial, industrial and mixed) within its limits. The City performs monitoring at one MS4
outfall monitoring station. The City's wet weather monitoring station is currently outfall lD-21. Each year
the city will reevaluate the site selection and make changes as needed in order to provide accurate data
or facilitate better assessments.
During the wet season (October 1- April 30), the City monitors at least one wet weather event at lD-21
using the procedures identified in the Carlsbad WMA MS4 Outfall Monitoring Plan. If pollutants are
identified that cause or contribute to a HPWQC at the wet weather monitoring station, additional wet
weather monitoring and source investigation will be scheduled to guide pollutant source identification
efforts until eliminated. For each wet weather monitoring event, the City records the following
information:
1. A narrative description of the location and condition of the monitoring station.
2. A narrative description and quantification of the storm event conditions.
3. Results of field measurements listed in Table 14-2. Collected grab samples may be used to collect
field measurements with the addition of hardness and indicator bacteria.
4. Results of time-weighted, flow-weighted, manual compositing or a blend composite sample for a
duration of a storm event to represent the changes in pollutant concentration and runoff flows.
Samples are collected using methods and protocols approved by the SWRCB and described in the MS4
Outfall Monitoring Plan. Composite samples are analyzed for constituents that have been identified in the
Carlsbad WMA MS4 Outfall Monitoring Plan: Attachment D - Table D-4.
The City analyzes the wet weather monitoring results to support and assess the effectiveness ofthe water
quality improvement efforts. Based on the results, the City may implement additional efforts to achieve
water quality benchmarks set for the WMA.
12.5 Data Assessment, Reporting, and Quality Control
The City assesses collected dry and wet weather monitoring data for assessing the effectiveness of the
current water quality improvements implemented. Results from dry weather MS4 outfall discharge
monitoring is used as part of a prioritization procedure for non-storm water discharges to be addressed
by the IDDE program. It is a key component in the iterative approach to water quality improvements and
provides the City with adaptive management options to best address water quality concerns.
Monitoring efforts that occur at a greater frequency than expressed in this Monitoring and Assessment
section are reported to the RWQCB at prescribed intervals. Annually, collected monitoring data are
uploaded using specified templates to the California Environmental Data Exchange Network (CEDEN)
Southern California Regional Data Center. The uploaded regional water quality information is ultimately
available to the general public through the CEDEN website.
As a quality control component, the City maintains monitoring and calibration data fora minimum of five
years from date sampled, measured, reported or applied. Sample collection methods involve the inclusion
of a quality assurance/quality control (QAQC) program. The sampling, analysis, and, QAQC were
conducted in accordance with the Quality Assurance Management Plan (QAMP) for SWAMP.
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12.6 WQIP WMA Monitoring Requirements
As part ofthe Carlsbad WMA, the City works in collaboration with the other stakeholders within the WMA
boundary. The goal is to create a bridge between the overall health of the receiving waters within the
WMA and water quality from MS4 systems. These requirements include:
• Sediment Quality Monitoring;
• Long-term Receiving Water Monitoring Requirements; and
• Special Studies.
• Storm Water Monitoring Coalition Regional Monitoring
• Southern California Bight Regional Monitoring
These monitoring programs are described in the following documents:
• Carlsbad WMA Water Quality Improvement Plan;
• Carlsbad WMA Sediment Monitoring Plan; and
• CaHsbad Receiving Water Monitoring Plan.
The current versions of these documents are located at the Project Clean Water website under the
Carlsbad WMA page-www.projectcleanwater.org.
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13 Fiscal Analysis
Effective programs require adequate funding to implement planned strategies. The first step in securing
adequate program funding is to provide a strategy for effectively conducting a fiscal analysis of the
Program in its entirety. The fiscal analysis evaluates the expenditures (such as capital, operation and
maintenance, outreach and education, and administrative expenditures) necessary to accomplish the
activities of the Program. The fiscal analyses will be completed annually and included in the Carlsbad
Water Quality Improvement Plan Annual Reports.
13.1 Expenditure Categories
The City has identified categories of expenditures related to storm water management and
implementation. The following are category descriptions of specific implementation, capital, operation
and maintenance activities. Five expenditure categories were identified for fiscal analysis to effectively
communicate the types of program costs. Descriptions for these categories of expenditures are provided
below:
Administrative Tasks
Administrative activities include a range of tasks across multiple Divisions. Such tasks include general
government services related to storm water management programs and miscellaneous administrative
tasks such as contract management, invoice processing, and accounting.
Development Planning and Construction Management
Development planning and construction management relate to both public and private projects. City
capital projects are primarily the responsibility ofthe Public Works Department and private discretionary
projects are primarily the responsibility of the Community Development Department. Tasks include
development planning review, project management, and construction site inspections.
Existing Development Management and O&M
This category covers existing development and includes program implementation and management of
storm water best management practices (BMPs) forthe municipal, commercial, residential, and treatment
control inventories. It also includes operation and maintenance activities that relate to storm water
management such as street and MS4 cleaning. The Public Works Department is primarily responsible for
the management and O&M of existing development.
Capital Projects
The Public Works Department is responsible for implementing the Capital Improvement Program (CIP) for
the City. Water quality capital projects are included in this category and may be considered as individual
projects or as features within other CIP projects implemented by the City.
Watershed and Regional Costs
Regional and watershed costs are allocated from the Public Works Department and are tracked according
by program type.
13.2 staff Resources
To meet the storm water management requirements in the Municipal Permit, implementation efforts and
costs are shared across the entire City. For the fiscal analysis the City staff will identify the staff resources
and needed to implement the City's overall program. City staff resources will be analyzed according to
their functions related to the City using the Expenditure Categories identified above.
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13.3 Expenditures and Sources of Funds
Annually, the City will present its expenditures forthe fiscal year as well as a proposed budget forthe next
fiscal year. The fiscal year expenditures are presented in tabular format with separate rows for different
divisions and subdivisions. The budget for the next fiscal year is presented in similar format and includes
the anticipated total expenditures.
The sources of the funds needed to fund the current and next fiscal year will be included in the analysis
and include any identified restrictions on the use of those funds.
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